ML11158A015
| ML11158A015 | |
| Person / Time | |
|---|---|
| Site: | General Atomics |
| Issue date: | 06/02/2011 |
| From: | Asmussen K General Atomics |
| To: | James Shepherd Document Control Desk, NRC/FSME/DWMEP |
| References | |
| 38/67-4477 | |
| Download: ML11158A015 (3) | |
Text
+ GENERAL ATOMICS June 2, 2011 38/67-4477 VIA OVERNIGHT DELIVERY Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Mr. James Shepherd Docket Nos.: 50-89 and 50-163; License Nos. R-38 and R-67, Respectively
Subject:
Submittal of General Atomics' Interim Revised TRIGA Reactors Facility Decommissioning Schedule.
Dear Mr. Mr. Shepherd:
As you are aware, General Atomics' (GA's) TRIGA Reactors Facility (TRF) is where GA's two TRIGA research reactors are located and where their associated fuel had been located. The two reactors are possessed under Nuclear Regulatory Commission (NRC) License Nos. R-38 and R-67; designated as the Mark I and Mark F reactors respectively. The Mark F was permanently shut down on April 11, 1995 and the Mark I was permanently shut down on August 4, 1997. GA initiated the decontamination and decommissioning of its TRF shortly after the Mark I reactor was shut down.
GA commenced TFR decommissioning by physically transferring all of the fuel from the Mark I reactor into the fuel storage canals of the Mark F reactor. GA then proceeded to dismantle the Mark I reactor, empty its pool, remove the aluminum liner, and decontaminate the Mark I reactor room as well as certain adjoining rooms. GA pursued its TRF decommissioning activities to the extent it was feasible to do so without compromising the structural integrity of the facility related to the physical protection requirements associated with storing the Mark I and Mark F fuel in the Mark F reactor's fuel storage canals. Further decommissioning was put on hold pending removal of all of the fuel from GA's site.
After an unanticipated lengthy delay, the TRIGA fuel associated with GA's reactors was shipped off of GA's site in September 2010. Accordingly, GA has re-commenced activities associated with the decommissioning of its TRF pursuant to its NRC-approved decommissioning plan (Plan) dated July 1999 (Reference).
A schedule for TRF decommissioning was provided in the Plan as Figure 2-6 "Decommissioning Schedule." However, because of the unanticipated and prolonged delay between the time the Plan was written and when GA was authorized to ship its TRIGA fuel off site, there have been numerous changes in circumstances which necessitate revisions to the previously prepared schedule. Accordingly, enclosed is a revised schedule to replace Figure 2-6.
Please note the enclosed schedule is an "interim" and "living" schedule in that there are some items outside of GA's control that cannot be scheduled accurately at this time. For example, there are, at the moment, some unknowns regarding the options for disposing of certain activated items currently in the Mark F reactor pool (e.g., two 3550 GENERAL ATOMICS COURT, SAN DIEGO, CA 92121-1122 PO BOX 85608, SAN DIEGO, CA 92186-5608 (858) 455-3000
Document Control Desk June 2, 2011 GA Letter 38/67-4477 Page 2 neutron sources) and of the scope of work for certain key activities, e.g., the extent of soil contamination beyond the concrete biological shields and the resulting extent of building demolition necessary to excavate contaminated soil. Thus, the enclosed schedule is subject to further revision as new information becomes known.
! You will note that the enclosed schedule identifies significant action items (in their approximate sequence) to be accomplished between now and the completion of decommissioning activities, but no associated milestone dates are given beyond December 2012. This is because the schedule beyond December 2012 is strongly dependent on the results of the radiological (and hazardous material) characterization of the facility and soil (e.g. extent of soil contamination) which won't be available until about the third quarter of 2012. These results will be the most significant factor impacting the recommendations of the demolition engineering consultant regarding how best to de-construct the building, remove the concrete biological shields, and gain access to the soil that must be excavated.
The recommendations of the demolition engineering consultant will be factored into a revised TRF decommissioning schedule with milestones and dates which will be submitted to the NRC in a timely manner. It is currently estimated that during 2012 and 2013, GA would complete major decommissioning activities, followed by final radiological surveys, submittal of final release request, confirmatory surveys, and release to unrestricted use in 2014.
If you should have any questions regarding this submittal, please do not hesitate to contact me at (858) 455-2823 or at keith.asmussen@.qat.com.
Very truly yours, Keith E. Asmussen, Ph.D., Director Licensing, Safety and Nuclear Compliance
Enclosure:
Figure 2-6 Decommissioning Schedule, Revised 06/02/2011
Reference:
General Atomics' NRC-approved decommissioning plan. GA document no. PC-000482, Revision 3, titled: "General Atomics TRIGA Reactor Facility Decommissioning Plan," dated July 1999.
ID 1 AiN.rwDrao .. .. . Start Finish redecesmors lo. De19 '10 IFnb61IWT
'11 1Mar27,
'I.. F'1 M 51 MIISSMIT ul T5.12 ST MJan S FIS A1TT T TOct9 T I 10t I '11 INo2 STIW 1 a1 M I27Y 'F11 I ITIW 2Mr 1 SlM 2I T2J,1 S 4.10,W F MarF12 2Jr2 IJW IT 12 I F 112 i IuF29 ISeM I S IM16.'12 N IT IF IT1 INov4'12 IW Dec23 De2 S IM 12TFeb1S IS'2Fb1 IS I
I I D&D TRIGA Reactor Facility 501 days? Mon 113111 Mon 1213112 I -
2 D&D TRIGA MkF 260 days Mon 1/3/11 Fri 12/30/11 3
Disposition of Remaining Items in MkF Pool 260 days Mon 113111 Fri 12/30/11 4 Disposition of Neutron Sources 260 days Mon 1/3/11 Fri 12/30/11 5 MRC-AmBe-2290 260 days Mon 1/3/11 Fri 12/30/11 MRC-AmBe-2289 260 days Mon 1/3/11 Fri 12/30/11 7 ii SbBe Sources 260 days Mon 1/3/11 Fri 12/30/11 Thermionic Spacers 260 days Mon 1/3/11 Fri 12/30/11 Remaining SST Items 260 days Mon 1/3/11 Fri 12/30/11 10 Drain MkF Pool 45 days Mon 1/2/12 Fri 3/2/12 3 Establish Contract with NNSS for Waste Disposal 20 days Fri 5/13/11 Thu 6/9/11 t Procure Waste Containers 1 day? Fri 5/13/11 Fri 5/13/11 t 13 Re-Establish Gamma Spectrometer System 1 day? Fri 5/13/11 Fri 5/13/11 14 Radiological Characterization of Mkl and MkF 87 days Fri 3/2/12 Mon 7/2/12 15 Prepare RFP for Core Drilling Contractor 87 days Fri 3/2/12 Mon 7/2/12 16 Review Bids and Award Core Drilling Contract 87 days Fri 3/2/12 Mon 7/2/12 17 Core Drill MkF Biological Shield 87 days Fri 3/2/12 Mon 7/2112 15 HPs Sample Roof/Walls/Deck/MkF Biological Shield 87 days Fri 3/2/12 Mon 7/2/12 is HP Lab Analysis of Samples 87 days Fri 3/2/12 Mon 7/2/12 20 Hazardous Material Assessment of TRF 22 days Fri 3/2/12 Mon 4/2/12 21 Asbestos characterization 10 days Fri 5/13/11 Thu 5/26/11 22 Summarize facility Rad/Hazardous/Asbestos sample results for use in 44 days Tue 7/3/12 Fri 8/31/12 defining extent of structural demolition required 23 Contract with Structural/Demolition Engineer to assess entire 65 days Mon 9/3/12 Fri 11/30/12 22 demolition/excavation job.
24 Determine extent of building demolition required to access MkF and Mkl I 64 days Mon 9/3/12 Thu 11/29/12 25 Determine extent of Roof demolition required 65 days Mon 9/3/12 Fri 11/30/12 26 Determine extent of masonry Wall demolition required 65 days Mon 9/3/12 Fri 11130/12 27 Determine types of WVll buttressing required to proceed with partial build 65 days Mon 9/3/12 Fri 11/30/12 28 Determine types/extent of shoring required to safely remove Biological St 65 days Mon 9/3/12 Fri 11/30/12 29 Structural Engineer to prepare demolition plan 65 days Mon 9/3/12 Fri11/30/12 30 Prepare facility for partial demolition I day? Mon 12/3/12 Mon 12/3/12 31 Remove/disposition MkF Control Console, MkF Bridge, and all other fumi 1 day Mon 12/3/12 Mon 12/3/12 32 Remove/disposition overhead Cranes 1 day? Mon 12/3/12 Mon 12/3/12 33 Remove TRF HEPA Ventilation System, as appropriate 1 day? Mon 12/3112 Mon 12/3/12 34 Prior to installed HEPA system removal, HPs declare areas are free 1 day? Mon 12/3/12 Mon 12/3/12 35 Set up portable HEPA ventilation systems, as required by HP for built 1 day? Mon 12/3/12 Mon 12/3/12 38 Procure radioactive waste containers/fixtures for building demo debris 1 day? Mon 12/3/12 Mon 12/3/12 37 Top-Loading Sea-Land Containers for major building and roof debris 1day? Mon 12/3/12 Mon 12/3/12 3,8 Y-4 Boxes/Liners/banding for smaller items 1day? Mon 12/3/12 Mon 12/3/12 39 Pallets/shrinkwrap/banding for masonry Wall sections 1day? Mon 12/3/12 Mon 2/3/12 40 Building Demo Sequence I day? Mon 12/3/12 Mon 12/3/12 U 41 Shore-up all exterior and interior walls 1day? Mon 12/3/12 Mon 12/3/12 42 Remove roof; package/disposition debris I day? Mon 12/3/12 Mon 12/3/12 43
-- 9-- Asbestos Abatement service vendor required for roof removal 1day? Mon 12/3/12 Mon 12/3/12 44 Section/cut masonry Walls to be removed into 4' x 4' squares; package/dispo 1day? Mon 12/3/12 Mon 12/3/12 45 Section/cut concrete decks to be removed into 4' x 4' squares; package/dispc 1day? Mon 12/3/12 Mon 12/3/12 46 Remove all Gunnite from MkF Pool Liner; package/disposition 1day? Mon 12/3/12 Mon 12/3/12 58g-f 47 Torch cut/section MkF Pool steel Liner; package/disposition 1day? Mon 12/3/12 Mon 12/3/12 48 Excavate/remove MkF Fuel Storage Walls; package/disposition 1day? Mon 12/3/12 Mon 12/3/12 49 Remove contaminated soil from behind the MkF Biological Shield (to assure I 1day? Mon 12/3/12 Mon 12/3/12 50 Cut/section MkF concrete Biological Shield/package/disposition debris 1day? Mon 12/3/12 Mon 12/3/12 51 Section/remove Sump system from around the MkF Pool; package/disposito 1 day? Mon 12/3/12 Mon 12/3/12 52 Excavate contaminated backing soil from around/under MkF Pool; package/r 1 day? Mon 12/3/12 Mon 12/3/12 53 Section/cut Mkl concrete Biological Shield (to assure the soil does not collapt 1 day? Mon 12/3/12 Mon 12/3/12 Excavate contaminated backing soil from around Mkl Pool; package/dispositi 1 day? Mon 12/3/12 Mon 12/3/12 GA HP Survey building/soil for residual contamination 60 days? Mon 12/3/12 Fri 2/22/13 s55 Submit final radiological survey plan/design to NRC for concurrence 60 days Mon 12/3/12 Fri 2/22/13 HP conducts final survey report / Project remediates, as needed 1 day? Mon 12/3/12 Mon 12/3/12 57 Prepare GA final survey results report and submit release request to NRC 1 day? Mon 12/3/12 Mon 12/3/12 s8 m
NRC/ORISE perform confirmatory surveys in Mkl and MkF facilities 1 day? Mon 12/3112 Mon 12/3/12 Project: TRF DThu 682011Schedule Dr Task Progress Surnurry V- External Tasks Q Deadline Date: Thu 6/2/11 Spli ......... ......... Milestone
- Project Surrerary .... External Milestone 4 Page 1 F-igure 2-6 uecommissioning S cedule, Revised June 2, 2U11