ML20028H408

Forwards Request for Addl Info Re Decommissioning Plan

ML20028H408
Person / Time
Site:	05000054
Issue date:	12/21/1990
From:	Michaels T Office of Nuclear Reactor Regulation
To:	Mcgovern J CINTICHEM, INC.
References
NUDOCS 9101020367
Download: ML20028H408 (7)

Text

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O December 21, 1990 Docket No. 50 54 Mr. James J. McGovern, President Cintichem, Inc.

P. O. Box 816 Tuxedo, flew York 10987

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING DECOMMISSION!NG PLAN. CINTICHEM, INC.

In order for us to complete our review of your decommissioning plan, submitted by letter dated October 19, 1990, we need additional information as indicated in the enclosure.

Please feel free to call me on 301 492 1102 or, if I am not available, Jack Hayes on 301 492 3167 if you have any questions regarding this request.

Sincerely, Original signed by:

Theodore S. Michaels, Senior Project Manager Non. Power Reactors, Decommissioning ano Environmental Projects Directorate Division of Advanced Reactors and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

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,J wAsmNotoN. o c. na December 21, 1990 Docket No. 50-54 Mr. James J. McGovern, President Cintichem, Inc.

P. O. Box 816 Tuxedo, New York 10987

SUBJECT:

RE0 VEST FOR ADDITIONAL INFORMAL!ON REGARDING DECOMMISSIONING PLAN - CINTICHEM, INC.

In order for us to complete our review of your decommissioning plan, submitted by letter dated October 19, 1990, we need additional information as indicated in the enclosure.

Please feel free to call me on 301-492-1102 or, if 1 am not evailable, Jack Heyes on 301-492-3167 if you have any questions regarding this request.

Sincerely, u $.l Theodore S. Michaels, Senior Project Manager Non Power Reactors, Decommissioning and Environmental Projects Directorate Division of Advanced Reactors and Special Projects Office of Nuclear Reactor Regulation i

Enclosure:

As stated cc w/ enclosure:

See next page l

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Cintichem, Inc.

Docket No. 50-54 r

cc:

Dr. Paul J. Merges, Director Bureau of Radiation, DHSR NYS Department of Environmental Conservation 50 Wolf Road Albany, New York 12233-7255 New York State Department of Labor ATTN: Dr. Francis J. Bradley, Principal Radiophysicist, Radiological Health Unit One Main Street, Room 813 Brooklyn, New York 11201 Director, Technical Development Programs State of New York Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 Supervisor Annette Dorozynski Town of Tuxedo P. O. Box 725 Tuxedo, New York 10987 Berle, Koss and Case 145 Rockerfeller Plaza New York, New York 10111 A11N: Ava Gartner V

ENCt.0$l!RE 1

Recuest for Additional Information, Cintichem 1.

Provide, for each structure noted in items 23-1 through 33-4 of Table 1.2a, the volume of structural contamination and the curie content by isotope.

Provide similar information for contaminated systems and components such as the primary reactor cooling system, the primary reactor cooling purifi-cation system, the reactor builoing air exhaust system, the exterior air discharge duct and the stack, and the weste water evaporator system.

Provide the volume of waste associated with each component and structural element in Table 1.4 such as the reactor core support tower, the reactor grid plate and locator pins, the plenum, the core outlet assembly, the pneumatic rabbit essembly, the beam tubes, and the thermal column and the thermal column lead shield assembly.

2.

It is unclear f rom Section 1.3.5 where contemination was f ound and where it was not found.

Provide such information.

In addition, provide a layout indicating where subsurface contamination was found, include with the layout an estimate of the volume of contaminated soil and the curie content of these volumes by isotopt.

3.

The decommissioning plan does not indicate whether the quality assurance guicelines of Pegulatory Alde 1.33, with respect to decommissioning, will be met. Will these guidelines be met?

4 The Cintichem facility presently has a radiological environmental program.

Will the some procram continue during the decommissioning ond dismantling operations or will the progrem be modified to address these operdtions?

5.

Explein why the totel curies for each component in Table 1.4 15 not in agreement with the total curiet presented in Table 1.3.

6.

Clarification should be provided in Sectiun 3.3 as to the use of HEPA ventilation contamination control. When it is indicated that such control is being utilized, does thi.t mean all the actions associated with a given task utilize HEPA ventilotion contamination.ontrol or do only some of the actions utilize such control?

7.

Why aren't the activities associated with the removal of the thermal column liner incorporating the HEPA ventilation contamination control system, when such an activity incorporates the cutting of the steel panels and the cutting of the liner, which would presumably generate airborne radioacti-vity? A similar question is raised on the use of such a ventilation system for the tasks associated with the decontamination of the reactor pump room and the pool / stall and the removal of the storage tank, the reactor building exhaust ventilation system, and the canal / gamma pit.

8.

What is the volume of liquid redweste which will be generated during the decontemination and dismantling process, the isotopic concentration levels prior to and following processing and the total curies released offsite?

What will the resultant doses be to the maximum exposed individual?

9.

What type of process equipment will be utilized in the mobile radwaste system and describe its intended mode of operation?

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10.

Provide the quantity, in curies, and the concentration, for each radio.

nuclide, of gaseous releases.

11.

Provide the manner in which the various forms of solid wastes will be treated and prepared for shipment offsite.

Present sections in the decommissioning plan do not discuss treatment of all wastes.

For example, will evaporator sludges be solidified?

If so, how will they be?

12.

Section 7.3.1 states that the stack monitor will be used to measure the total radioactive airborne concentration leaving the reactor building and the hot laboratory until the ventilation system is disabled. The section then states that airborne radioactive effluent will be monitored as per Table 7.1, yet it is unclear from the Table how such monitoring will be implemented.

Provide information on the replacement monitoring and include it in Table 7.1.

13.

Since a great deal of dust and particul6tes will be generated during the decommissioning operations, why doesn't the HEPA filter include a differen-tiel pressure gauge with an alarm instead of a weekly check to ensure that the filter is not clogged?

14 Has it been confirmed from the latest land use census that the garden pathway or other ingestion pathways such as the milk ingestion pathway are nonexistent?

15. Does the determination of total surf ace contamination levels of systems and equipment, as noted in Section 8.2.2.3, include both fixed and loose contamination?

16. Why were the accioent doses calculated at the nearest residential develop-ment instead of at the nearest site boundary?

Provide these same analyses for the nearest site boundary.

17. Why did one accident analysis involving airborne releases have the dose calculated to a teenager while the other analysis calculate the dose to a child? Provide the dose to the maximum exposed individual.

18.

It was indicated in Section 5 that an accident analysis was conducted of flooding af ter the reactor building and the hot laboratory were breached.

However, the analysis presented in Appendix G only evaluated flooding of the hot laboratory and then only the contamination associated with the sediment was considered thereby, giving the impression that the accident considered is actually following the razing of the building. Was an analysis performed of the impact of flooding of the above two buildings immediateiy after they had been breached?

In other words, the buildings are still intact except for the breach point. Was contamination associated with the structures, equipment, components, and systems remaining in the buildings following the breaching of the buildings included in the evalua-tion and found not to be the worst case? Provide the results of such analyses. Why was the evaluation to demonstrate compliance with Appendix B of Part 20, calculated with the concentration of the release based upon dilution of the Indian Kill Reservoir and not calculated based upon the concentration of the water at the restricted area boundary in accordance with 10 CFR 20.106(d).

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15. The information presented in the decommissioning plan on the dose to the maximum exposed individual should not have been based upon the performance of a single task but rather on the performance of all tasks.

A calculation should have been performed of the effluents associated with all of the decommissioning and dismantling tasks involving the potential discharge of radioactive materials. This information should have been provided in the licensee's decommissioning plan along with the related doses.

Therefore, provide the total estimated effluents fro'n decommissioning and their related doses. The doses should be calculated at the site boundary with the highest X/Q value and at the actual receptor location which combines the most sensitive ingestion pathway and highest deposition rate, if applicable.

20. On page 2.12 it states that "All significant dismantling operations will be controlled by written procedures." What defines an operation as significant?

21.

In numerous places there are statements saying that a certein material (e.g. " inner building well" on p. 3.20 and " oil between windows" on

p. 3.21) will be disposed as clean material. Will these materials (and others already ideritified as clean material) be verified as being " clean" before release?

22. Has soil where water was collected during accidental release in 1989 and 1990 been surveyed?

If not, should this be added as an area for a biased environmental survey?

23. Section 1.0 and 1.4 says the New York state license will be terminated, which is inconsistent with Section 1.1.1 which says that operations will be discontinued only in Buildings 1, 2 and 6.

Building 4 is under the N.Y. state license.

Please clarify.

24. Discuss the target fretting and leaking problem identified in the 1983 - 1984 time period.

25.

In Section 1.3.1 shouldn't the outside Primary Water Holdup tank be listedascontamInatedanddiscussedinSection1.3.2?

26. Shouldn't Section 1.3.2 also address Building 6?

27.

Section 1.6 should also include NUREG CR-5512, " Residual Radioactive Contamination from Decommissioning" in the informal guidance.

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I Cintichem, Inc.

Docket No. 50-54 CCI Dr. Paul J. Merges, Director Bureau of Radiation DHSR NYSDep6ftmentofEnvIronmental Conservation 50 Wolf Road Albany, New York 12233-7255 New York State Department of Labor ATTN: Dr. Francis J. Bradley, Principal Radiophysicist, Radiologicel Health Unit One Main Street, Room B13 Brooklyn, New York 11201 Director, Technical Development Programs State of New York Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 Supervisor Annette Dorozynski Town of Tuxedo P. O. Box 725 Tuxedo, New York 109B7 Berle, Koss and Case 145 f<ockerfeller Plaza New York, New York 10111 ATTN:

Ava Gartner t

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