ML19310A626
| ML19310A626 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 04/07/1980 |
| From: | Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Evans L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 16049, NUDOCS 8006200565 | |
| Download: ML19310A626 (4) | |
Text
w iv - nr
- [ 8hh sxe Hf 9
.9 DOCKETED USNRC f,.,
j sea bd5ls.
)Dht 70 ~ II'f m--
e, gw: s
,e friERAL mom: e"**~
~
'i CENERAL AToutC CoMPA 4/
b
\\,M
- Ifil?;eply P.O. DOX 81608
'\\ \\"Ref se.$pp496-1169 CCFORNIA 92138
[;"j,?,E n7 MSO Np llEWWD $
APR 151980 >
Mr. L. J. Evans, Jr.
Regulatory Improvement Branch
- ** hdO/,f7"'
/)
Division of Safeguards suiiL Office of Nuclear Material Safety & Safeguards
'b
/f U.S. Nuclear Regulatory Cocmiscion Qj g
Washington, D.C. 20555
(
Subject:
Meeting to Discuss Upgrading Physical Protection of HEU; Request for.
Dear Mr. Evans:
General Atomic Company (CAC) requests a meeting with your staff at GAC to discuss our plans for upgrading the physical protection of High Enriched Uranium. GAC has verbally explained to certain NRC staff members its ten-tative proposals for the protection of Sm! under the 10 CFR 73.67 and up-grade rules. These proposals include cessation of HEU fuel fabrication in the TRIGA fuel fabrication facility, certain TRIGA reactor building nodifi-cations to bring the TRIGA Mark F reactor's physical protection into compli-ance with 10 CFR 73.60 and 73.67, and a rajor S7A facility modification as required by the " Upgrade Rule" in order to allow the site dependent physical protection of SMI.
We have tentatively arranged, through prior conversations with your staff, a visit to our facility *.he week of April 15.
The site visit is believed nost beneficial because of the complexity of options in the najor modifications in the Sorrento Valley Facility. The major modifications comprise:
1.
The partitioning of a large building into tun sections, excluding one part from the protected area.
2.
Relocation of HEU Storage areas frnn the main site to rev storage at the Sorrento Valley site.
3.
Redrawing protected area fencing and barriers to eliminate unessen-tial activities and traffic from the regions between such barriers and the material access or controlled access areas.
4.
Relocation of certain process equipment.
. j*
3
.E, E k,
E.:,
- Ik e hiI u
3 0 4.9 G
80062en 566 C-
L. J. Evans, Jr. 696-1169 To responsibly plan for and implement the " Upgrade Rule," it is imperative that we promptly receive certain guidance from NRC about the acceptability of alternatives available to us.
Accordingly, we request that your guidance Eroup complete its plans to visit cur site during the week of April 14-18.
We believe that a two day site visit would suffice.
We have already begun preparation of our new physical protection plans under the presumption that our two remote but contiguous sites with addresses 10955 John Jay Hopkins Drive (Main Site) and 11388 Flintkote Ave. (Sorrento Valley site) will be afforded physical protection under two separate plans.
The " Main Site" will basically consist of two to four Moderate Strategic Significant facilities and five to eight low strategic significant facili-
.j; ties. The "Sorrento Valley Site" will consist of the HTGR fuel fab facility 7
and an associated R&D laboratory building (SVB). Under these plans CAC will i
on its main site (1) forego unirradiated HEU fuel production or storage; (2) use at enly one location (TRIGA Mark 7) reactor fuel elements containing HEU in a quantity greater than 1 kg U-235, and (3) limit other discrete labora-j tory buildings to less than the Category III limits with each individual laboratory having its lesser limit as dictated by nuclear safety consider-ations. Typically such limits are either 350 gn or 500 gm, dependent on the material's physical form.
Also under these plans GAC will (1) relocate current main site HEU storage MAAs to the Sorrento Valley site (2) significantly modify-its protected area boundaries, barriers, etc., and (3) exclude from the Sorrento Valley site pro-tected area an R&D laboratory building (SVB) under the presumption that its limited SNM can be afforded adequate physical protection by treating it as a controlled access area located in close proximity to a guard station and with-in a hundred feet of a Category I protected facility.
The general adequacy of GAC's long standing plans fo'r complying with improved SNM physical protection requirements turn on several key points presented here.
i
[
1.
What penetration resistance is required when the PCAS, SAS and response force are all within a building of 50,000 to 60,000 i
k square feet, and the encompassing protected area is only slightly 2
larger, and local law enforcenent is only a few minutes away; fur-ther, nearly all SNM is stored in vaults within the MAA when not r
being processed.
2.
Do finished HTCR fuel elements require storage in a hardened MAA storage? Each HTCR fuel element packaged in its nominal 55 gallon sized container weighs the order of 450 pounds.
3.
What are the hardening requirements for a roof of a multi-story building when penetration of the roof will not allow individuals to have direct access to a formula quantity of directly usable SNM.
l l
l l
l.
L. J. Evans, Jr. 696-1169 4.
During the upgrade rule modifications and construction, deviations from existing Security Plans will be required. Does the NRC en-vision a sub-plan approval?
5.
73.45(c) & (.d)(9) suggests that only activities involving the pro-cessing of HEU be conducted within material access areas. As part of General Atomic's fuel manufacturing, certain thorium production activities are accomplished within the existing facility. Must they be removed?
6.
Strict compliance with 73.46 is practically impossible without ex-tensive equipment relocation. General compliance can be accom-
.q plished with limited equipment relocation.
The adequacy of this
.I partial compliance cust be determined at a conceptual proposal stage prior to the establishment of internal barriers.
The details of our facilities and plans can best be portrayed to individuals being on site and capable of observing the intricacies of these as well as other options that may be available.
The above are only a few of the questions the staff may be able to answer after having seen the facility.
~
We look forward to your visit.
Should you have any questions, please direct them to me promptly by telephone, (714) 4552823 Very truly yours, vvg
}{t, William R. Howry Licensing Adminis ration Nuclear Ibterials Control Division WRM:hes
Attachment:
Assistance Request Sheet.
cc:
C. W. McCorkle, Chief Physical Security Licensing Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555
. ~
p;f
-?
_ M EGUARDS GUIDANCE GROUP (j,
ASSISTANCE RE0 VEST SHEET 4/7/80 DATE:
ORGANIZATION:
General Atomic Company ADDRESS:
P.O. Box 81608 San Diego, CA 92138 LICENSEECONTACT(S): 111111am R. Mowry/ Steve Akin TELEPHONE NUMBER: (714p55-2823 455-4371 GENERAL AREAS IN WHICH SAFEGUARDS GUIDANCE GROUP ASSISTANCE IS RE See General Atomic Company letter 696-1169 dated 4/7/80.
k PLEASE STATE IF A SGG/ LICENSEE MEETING IS DESIRED:
Peculiarsiteandfacilityproblemsdictatethenecess@ityofasitevisitbySGGStaff.
S]N0 S
\\
3
=
C DITION"L REF.A:.KS:
d
.y
.y
_ ~.. -
Y; t
. isms -
~
4