ML103430567

License Requirement for Facilities Repairing Contaminated Equipment

ML103430567
Person / Time
Issue date:	12/13/1977
From:	Fisher W NRC/RGN-III
To:
References
05484-309
Download: ML103430567 (9)

Text

132 RECORD #132 TITLE:

License Requirement for Facilities Repairing Contaminated Equipment FICHE:

05484-309 3,

132

r UNtTED STATES NUCLEAR REGULAIORY COMMISSION REGION III 799 ROOSEVELT ROAD GLCN. ELLYN, ILLINOIS 60137 December 13,' 1977 NEMORANDUM FOR:

FROM:

SUBJECT:

Inspection Staff W. L. Fisher, Acting Chief, Fuel Facility and Materials Safety Branch OFFSITE REPAIR OF CONTAMINATED ITEMS EMVIORA NDUM NO.

M 14 The attached letter contains guidance for a rather common problem.

Please bring this to the attention of all reactor, fuel cycle, and other licensees who might find themselves in need of sending a contaminated item to an unlicensed facility.

W. L. Fisher, Acting Chief Fuel Facility and Materials Safety Branch

Attachment:

Ltr dtd 11-1-77

W W.ill NUCLEAR R13(;U1 WAStimci IPSIATES LAI OR Y COMM~ISSION I ON. D. C. 20555 V

Novem~ber 1, 197 A

V.

V TO ALL PO*ER R EACTOR FIX I I, ITY, LCF1:$ErS Gentlemen:

V It has come to our attention tlat tC reactor Jacility licensees

ýJl occasionally find it necessay to s nd a comporent contaminated with "1 radioactivity to rmanufacturers or se 'vice companies for repair or calibration.

1t is not alhays pract cal or feasible, however, for the facility licenseetob 'reduce the r dioactivity associated with thQ component to le%,;el.s acceptable fo unrestricted use.

The manufacturers or service colapanies do not, in many cases, have appro._i*atC

'IC or Agreei:ient State.licenses authorizing-receipt, po,->ession, use and transfer of byproduct material nor do they have

-the qualified personnel necessary to obtain such licenses.

The ship-ment of these components by or to unlicensed persons has resulted in enforcement action being taken, against-the'persons shipping or receiving

.the conta:minated ccwponents.

Urgently needed repairs and service have been delayed while the concerned regulatory agencies attempted to resolve the problem.

It is essential that appropriate licenses be held by the repair shop or the facility licensee in accordance with the guidance of this letter, prior to shipment of the contaminated component.

Some.RC facility licensees have obtained I.RC or Agreement State licenses,.as appropriate, authorizing possession and use of components containing byproduct material at uý,' pecified, off site locations throughout the state in which the facility is located.

We suggest that you consider obtaining such a license to avoid such problems.

Applications to the MRC or to an Agreement State by NRC facility.

licensees for such byproduct materials licenses must be completely supported by necessary information, including contract provisions to be

,eimplo.l'ed to deoonstrete fuill licensee control of all related matters, Ssuch. as shipping procedures, health physics-support personnel, health

.physics procedures-traiuing and experience, cleanup op.erations, and,-'

-fi-nal survey..reports.Y-In instances where full.licensee contrpl-o.f all matters relating to t he contar'iinated. item, while in the'repaiir shop is rot intended or is.-not feasible, the repair shop must obtain the appropriate license to per;,it the repair.

If the licensee is able to satisfy the requirefments for a byproduct materials license authorizing possession and.use of his conta:;ir*ated rr.aterials at unspecified sites, he may, in accordancc with reciprocal

.RC or Agreement State regulations receive, possess, use and trarnsfer such contaiiinated components at unspecified off-site locations-in other states.

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If the facility is located in a non-Agreement State, the NRC byproduct material license (issued pursuant to 10 CFR Part 30) would authorize the possession and use of the contaminated component in other non-Agreement States.

ly notifying the appropriate Agreement State authority by letter, or if necessary by telephone, at least five days prior to shipment of a contaminated cc:,pLnent, an I4RC licensee authorized to possess end use components containing byproduct material at unspecified off site locations throughout a non-Agreement State can (pursuant to Agreement State regulations similar to 10 CFR 150.20) obtain authorization

-to conduct the same activities within an Agreeý,ient State.

If the licensed facility is located in an Agreement State, the facility licensee must obtain from the Anreement State a license authorizinci.

possession and use of components containing byproduct naterial at unspecified locations throunlhout that State.

Under the reciprocity provisions. Of 10 CFP 150.20 and similar provisions in other Agreement State regUlations, the licensee is permitted (for up to 180 days in any calendar year) to c-onduct the same activities in othcr Acreement and non-Aareement-StAtes.

If the shipment is to be made to a location in a non-agrecment State, NRC Form 241 must be submitted at least three days prior to shipment.

A copy of Form 241 is enclosed with this letter (enclosurel).

For shipments to locations in other Agreenient States, appropriate notification toust be marie.

If the licensee-conducts the same activity for more than lIN days in any calendar year in any othler state 1.h.-.n the one for which the license was issued, he mnust o'.tain another byproduct material license from the NRC or the Agreement State, as appropriate, authorizing him to conduct such activities in that State.

For facilities locat.ed in a non-Agreement State, an' application forn and guidance for these 1,-.prodtjct materials licenses are included as Enclosurcs 2 and 3.

[or facilities located-in Aoreemient States,- you should contact the appropriate A.1reement State licensing official (see- ).

Sincerely, (7,

Karl R. Goller, Assistant Director for:Opc-rating Reactcors Division of Operating Reactors

Enclosures:

1.

NPRC Form 241

2.

Application form

3.

Guidatice

4.

Agrc.!nent States cc w/o enclosures:

See next page

June 1974 U.S. ATOMIC ENERGY COMMISSION 1 1)0 REGULATORY DIRECTORATE OF REGULATORY STANDARDS GUIDE REGULATORY GUIDE 1.86

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V TERMINATION OF OPERATING LICENSES FOR NUCLEAR REACTORS I

A. INTRODUCTION Section 50.51, "Duration of license, renewal," of 10 CFR Part 50, "Licensing of Production and Utilization Facilities,"

requires that each license to operate a production and utilization facility be issued for a specified duration. Upon expiration of the specified.

period, the license may be. either renewed or terminated by the Commission. Section 50.82, "Applications for termination of licenses," specifies the requirements that must be satisfied to terminate an operating license, including the requirement that the dismantlement of the facility and 'disposal of the component parts not be inimical to the common~defense and security or to the health and safety of the public. This guide describes methods and pcedures considered acceptable by the Regulatory staff for the termination of operating licenses for nuclear reactors. The Advisory Committee on Reactor Safeguards has been consulted concerning this guide and has concurred In the regulatory position.

A licensee having a possession-only license must retain, with the Part 50 license, authorization for special nuclear material (10 CFR Part 70, "Special Nuclear Material"), byproduct material (10 CFR Part 30, "Rules of General Applicability to Licensing of Byproduct Material"), and source material (10 CFR Part 40, "Licensing of Source Material"), until the fuel, radio-achive components, and sources are removed from the facility. Appropriate administrative controls and facility requirements are imposed by the Part 50 license and the technical specifications to assure that proper surveillance is performed and that the reactor facility is maintained in a safe condition and not operated.

A possession-only license permits various options and procedures for decommissioning, such as mothballing, entombment, or dismantling. The requirements imposed depend on the option selected.

B. DISCUSSION When a licensee decides to terminate his.nuclear reactor operating license, he may, as a first step in the process, request that his operating license be amended to restrict him to possess but not operate the facility. The advantage to the licensee of converting to such a possession-only license is reduced surveillance require-ments in that periodic surveillance of equipment im-portant to the safety of reactor operation is no longer required. Once this possession-only license is issued, reactor operation is not-permitted. Other activities related to cessation of operations such as unloading fuel from the reactor and placing it in storage (either onsite of offsite) may be continued.

Section 50.82 provides that the licensee may dis-mantle and dispose of the component parts of a nuclear reactor in accordance with existing regulations. For research reactors and critical facilities, this has usually meant the disassembly of a reactor and its shipment offsite, sometimes to another, appropriately licensed organization for further use. The site from which a reactor has been removed must be decontaminated, as necessary, and inspected by the Commission to deter-mine whether unrestricted access can be approved. In the case of nuclear power reactors, dismantling has usually been accomplished by shipping fuel offsite, making the reactor inoperable, and disposing of some of the radioactive components.

Radioactive components may be either shipped off-site for burial at an authorized burial ground or secured G__

USAEC REGULATORY GUIDES Cop;.

of published uides may be obteirnd by request ind;ot, the diisiOno desired to the US. Atomic Energy Commrnion. Washington. D.C. 20645, Regulatory Guideo ama issued to describe end make wvailable to the public Attention: Oirector of Regulatory Sionderds. Commtents and ouvgstions for trathods ac*epuable to the AEC Regulatory satff of implementing sapcific patt of irrprowarments in these ides we encouraged and should be sent t the Secretary the Comcnaeiov's regutatiori, to delineate techniques.,a" db, the staff in of the Commnssion. Ul. Atomic Energy Commission. Wahington. O.C. 20545, evluating apspfic problems or postulated eisgocdnts, or to provide guidance to Attention: Chief, Public Procedings Staff.

epplicnts. Regulatory Guido ar not substitutes for reguilaicons and compliana with themi not reQuired. Metthods and solutions different fromn thaw set out in The guides ae issued in the following ten broad divisions:

the quiclo will be acceptable if they pro-ide a basis for the findings requisite to the vioan or ontimaene of a permit or ficere by the Commission.

1. Power ReactNors

6. Product

2. Research and Test Reactors

7. Trarsportation

3. Fuels end Materia*l Fcilmiis

9. Occuaioaltl Health Publshes guides will, be revised periodimlly; as appropriate. to accommodste

4. Environmental and Siting

9. Antitrust Review comrnism and to reflect rew infornltion or experience.

5. Materials and Plant ProtectiO*n

10. Gerafl

I on the site. Those radioactive materials remaining on the site must be isolated from the public by physical barriers or other means to prevent public access to hazardous levels of radiation. Surveillance is necessary to assure the long teim integrity of the barriers. The amount of surveillance required depends upon (1) the potential Laz3:.d to the health and safety of the public from i.Ji.-.tive material remaining on the site and (2) the integrity of the physical barriers. Before areas may be released for unrestricted use, they must, have been decontaminated or the radioactivity must have decayed to less than presgribed limits (Table I).

The hazard associated with the retired facility is evaluated -by considering the amount and type of remaining contamination, the degree of confinement of the remaining radioactive materials, the physical security provided by the confinement, the susceptibility to release of radiation as a result of natural phenomena, and the duration of required surveillance.

C. REGULATORY POSITION I. APPLICATION FOR A LICENSE TO POSSESS BUT NOT OPERATE (POSSESSION-ONLY LICENSE)

A request to amend an operating license to a possession-only license should be made to the Director of Licensing, U.S. Atomic Energy Commission, Washing-ton, D.C. 2-457. The request should include the following information:

a. A description of the current status of tlw facility.

b. A description of measures that wfll be taken to prevent criticality or reactivity changes and to minimize releases of radioactivity fiom the facility.

c. Any proposed changes to the technical specifica-tions that reflect the possession-only facility status and the necessary disassembly/retirement activities to be performed.

d. A safety analysis of both the activities to be accomplished and the proposed changes to the technical specifications.

e. An inventory of activated materials and their location in the facility.

2. ALTERNATIVES FOR REACTOR RETIREMENT Four alternatives for retirement of nuclear reactor facilities are considered acceptable by the Regulatory staff. These are:

a. Mothballing. Mothballing of a nuclear reactor facility consists of putting the facility in a state of protective storage. In general, the facility may be left intact except that all fuel assemblies and the radioactive fluids and waste should be removed from the site.

Adequate radiation monitoring, environmental surveil-lance, and appropriate security procedures should be" established under a possession-only license to ensure that the health and safety of the public is not endangered.

b. In-Place Entombment. In-place entombment con-sists of sealing all the remaining highly radioactive or contaminated components (e.g.,.the pressure vessel and reactor 'internals) within a structure integral with the biological shield after having all fuel assemblies, radio-active fluids and wastes, and certain 'selected com-portents shipped offsite. The structure should provide integrity over the period of time in which significant quantities (greater than Table I levels) of radioactivity remain with the material in the entombment. An appropriate and continuing surveillance program should be established under a possession-only'license.-

c. Removal of Radioactive Componeints and Dis-mantling. All fuel assemblies, radioactive fluids. and waste, and other materials having activities above ac-cepted unrestricted activity levels (Table 1) should be removed from the site. The facility owner may then have unrestricted use of the site with no requirement for a license: If the facility owner so desires, the remainder of the reactor facility may be dismantled and all vestiges removed and disposed of.

d. Conversion to a New Nuclear System or a Fossil Fuel System. This alternative, which applies only to nuclear power plants, utilizes the-existing turbine system with a new steam supply system. The original nuclear steam supply system should be separated from the.

electric generating system and disposed ofin accordance with one of the previous three retirement alternatives.

3. SURVEILLANCE, AND SECURITY FOR THE RE-TIREMENT ALTERNATIVES WHOSE FINAL STATUS REQUIRES A POSSESSION-ONLY LICENSE A facility which has been licensed under a posses-sion-only license may contain a significant amount of radioactivity in the form of activated and contaminated hardware and structural materials. Surveillance and commensurate security should be provided to assure that the public health and safety are not endangered.,,

a. Physical security to prevent inadvertent exposure of personnel should be provided by multiple locked barriers. The presence of these barriers should make it extremely' difficult for an unauthorized person to gain access to areas where radiation or contamination levels exceed those specified in Regulatory Position C.4. To prevent inadvertent exposure, radiation areas above 5 mR/hi, such as near the act'ivated primary system of a power plant, should be appropriately marked and should not be accessible except by cutting of welded closures or the disassembly and -removal of substantial structures 1.86-2

and/or shielding material. Means such as a remote-i' readout intrusion alarm system should be provided to w

indicate to designated personnel when a physical barrier is penetrated. Security personnel that provide access control to the facility may be used instead of the physical barriers and the intrusion alarm systems..

b. The physical barriers to unauthorized entrance into the facility,' e.g.; fences, buildings, welded doors, and access openings, should be inspected at least quarterly to assure that these barriers, have not deterior-ated and that locks and locking apparatus are intact.

c. A facility radiation survey should be performed at least quarterly to verify that no radioactive material is escaping or being transported through the containment barriers in the facility. Sampling should be done along the most probable path by which radioactive material such as that stored in the inner containment regions could be transported to the outer regions of the facility and ultimately to the environs.

d. An environmental radiation survey should be performed at least semiannually to verify that no signficant amounts of radiation have been released to the environment from the facility. Samples such as soil, vegetation, and water should be taken at locations for which statistical data has been established during reactor operations.

e. A site representative should be designated to be responsible for controlling authorized access into and movement within the facility.

f. Administrative procedures should be established for the notification and reporting of abnormal occur-rences such as (1) the entrance of an unauthorized.

person or persons into the facility and (2) a significant change in the radiation or contamination levels in the facility or the offsite environment.

g. The following reports should be made:

(1) An annual report to the Director of Licensing, U.S. Atomic Energy Commission, Washington, D.C.

20545, describing the results of the environmental and facility radiation surveys, the status of the facility, and an evaluation of the performance of security and surveillance measures.

(2) An abnormal occurrence report to the Regula-tory Operations Regional Office by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery of an abnormal occurrence. The abnormal occurrence will also be reported in the annual report described in the preceding item.

h. Records or logs relative to the following items should be kept and retained until the license is termi-nated, after which they may be stored with other plant records:

(1) Environmental surveys, (2) Facility radiation surveys, (3) Inspections of the physical barriers, and

,(4) Abnormal occurrences.

4. DECONTAMINATION FOR RELEASE FOR UN-RESTRICTED USE If it is desired to terminate a license and to eliminate any further surveillance requirements, the facility should be sufficiently decontaminated to prevent risk to the public health and safety. After the decontamination is satisfactorily accomplished and the. site inspected by the Commission, the Commission may authorize the license to be terminated and the facility, abandoned or released for unrestricted use. The licensee should per-form the decontamination using the following guide-lines:

a. The licensee should make a. reasonable, effort to eliminate residual contamination.

b. No covering should be applied to radioactive surfaces of equipment or structures by paint, plating, or other covering material until it is known that contamina-tion levels (determined by a survey and documented) are below the limits specified in Table I. In addition, a reasonable effort should be made (and documented) to further minimize contamination prior to any such covering.

c. The radioactivity of the interior surfaces of pipes, drain lines, or ductwork should be determined by making measurements at all traps and other appropriate access points, provided contamination at these locations is likely to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or location as to make the surface inaccessible for purposes of measurement should be assumed to be contaminated in excess of the permissable radiation limits.

d. Upon request, the Commission may authorize a licensee to relinquish possession or control of premises, equipment, or scrap having surfaces contaminated in excess of the limits specified. This may include, but is not limited.to, special circumstances such as the transfer of premises to another licensed organization that will continue to work with radioactive -materials. Requests for such authorization should provide:

(1) Detailed, specific information describing the premises, equipment, scrap, and radioactive contami-nants and the nature, extent, and degree of residual surface contamination.

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(2) A detailed health and safety analysis indi-cating that the residual amounts of materials on surface areas, together with other considerations such as the prospective use of the premises, equipment, or scrap, are unlikely to result in an -unreasonable risk to the health and safety of the public.

e. Prior to release of the premises for unrestricted use, the lice nsef sho.uld make a comprehensive radiation survey establishing that contamination is within the limits specified in Table I. A survey report should be filed with the Director of Licensing, U.S. Atomic Energy Commission, Washington, D.C. 20545, with a copy to the Director of the Regulatory Operations Regional Office having jurisdiction. The report should be filed at least 30 days prior to the planned date of abandonment.

The survey report should:

(1) Identify the premises; (2) Show that reasonable effort has been made to reduce residual contamination to as low as practicable levels; (3) Describe the scope of the survey and the general procedures followed; and (4) State the finding of the survey'in units specified in Table 1.

After review of the report, the Commission may inspect the facilities to confirm the survey prior to granting approval for abandonment.

S. REACTOR RETIREMENT PROCEDURES As indicated in Regulatory Position C.2, several alternatives are acceptable for reactor facility retirement.

If minor disassembly or "mothballing" is planned, this could be done by the existing operating and mainte-nance procedures under the license in effect. Any planned actions involving an unreviewed safety question or a change in the technical specifications should be reviewed and approved in accordance with the require-ments of 10 CFR §50.59.

If major structural changes to radioactive components of the facility are planned, such as removal of the pressure vessel or major components of the primary system, a dismantlement plan including the information required by §50.82 should be submitted to the Commis sion. A dismantlement plan should be submitted for all the alternatives of Regulatory Position C.2 except mothballing. However, minor disassembly activities may still be performed in the absence of such a plan, provided they are permitted by existing operating and maintenance procedures. A dismantlement plan should include the following:

a. A description of the ultimate status of the facility

b. A description of the dismantling activities and the precautions to be taken.

c. A safety analysis of the dismantling activities including any effluents which may be released.

d. A safety analysis of the facility in its ultimate status.

Upon satisfactory review and approval of the dis-mantling plan, a dismantling order is issued by the A Commission in accordance with §50.82. When dis-mantling is completed -and the Commission has been notified by letter, the appropriate Regulatory Opera-tions Regional Office inspects the facility and verifies completion in accordance with the dismantlement plan.

If residual radiation levels do not exceed the values in Table I, the Commission may terminate the license. If these levels are exceeded, the licensee retains the possession-only license under which the dismantling activities have been conducted or, as an alternative, may make application to the State (if an Agreement State) for a byproduct materials license.

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a TABLE I ACCEPTABLE SURFACE CONTAMINATION LEVELS NUCLIDEa AVERAGEb c MAXIMUMb d REMOVABLEb e U-nat, U-235, U-238, and associated decayqroducts Transuranics, Ra-226, Ra-228, Th-230, Th-228, Pa-231, Ac-227, 1.125,1-129 Th-nat, Th-232, Sr-90, Ra-223, Ra-224, U-232, 1-126,1-131,1-133 Beta-gamm emitters (nuclides with decay modes other than alpha emission or spontaneous fission) except St-90 and others noted above.

5,000 dpm a/100 cm2 100 dpm/lO0 cm2 1000 dpm/l O0 cm2 5000 dpm 0-y/100 cm 2 15,000 dpm a/ 100 cm 2 300 dpm/1O0 cm2 3000 dpm/100 cm 2 15,000 dpm 0-,/100 cm 2 1,000 dpm a/100 cm 2 20 dpm/100 cm2.

200 dpm/ l00 cm 2 1000 dpmr'7/100 cm 2 aWhere surface contamination. by both alpha-and beta-gamma-emitting nuclides exists, the limits beta-gamma-emitting nuclides should apply independently.

established for alpha-and bA, used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appioprlate detector for background, efficiency, and geometric factors associated with the instrumentation-qteasurements of iverwe contaminant should not be averaged over more than 1 square mete.. For objects of less surface area, the average should be derived for each such object.

dThe maximum contamination level applies to an area of not more than 100 cm 2.

The amount of removable radioactive material per 100 cm 2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of lesF surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.

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