ML20034G502
| ML20034G502 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 03/01/1993 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Adensam E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20034G503 | List: |
| References | |
| 696-2036, NUDOCS 9303090615 | |
| Download: ML20034G502 (4) | |
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f CEMERAI, ATUREM3 March 1,1993 696-2036 Ms. Elinor G. Adensam, Chief (Acting)
Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS L
U.S. Nuclear Regulatory Commission
{
Washington, DC 20555 l
Subject:
Docket No.70-734; License No. SNM-696; Request for Confirmatory Survey and Authorization to Dismantle GA's IITGR Fuel Fabrication Facility
Dear Ms. Adensam:
General Atomics (GA) is in the process of decommissioning its HTGR Fuel Fabrication Facility located in the northern half of its Building 37 (also known as GA's Sorrento Valley "A" (SVA) facility). This work is being conducted in accordance with a plan titled, "SVA Decom-missioning Plan," which was submitted by letter dated March 30,1990 (Ref.1), revised in response to NRC comments and resubmitted by letter dated August 24,1990 (Ref. 2), and approved in November 1990 (Ref. 3).
Originally, the approach, as described in the plan, was to decontaminate the entire SVA -
fuel fabrication facility, obtain its release to unrestricted use and then dismantle it. However, because of contamination on inaccessible surfaces such as the roof's trusses and because it is impractical to remove the contamination with the trusses in place, it was necessary to develop an alternate approach. After careful consideration as to how best to proceed, a two phase approach was formulated that is both practical and safe for the workers, the public, and the environment.
Briefly, the first phase of this approach consisted of decontaminating accessible contaminated surfaces to levels which meet the guidelines for release to unrestricted use, the application of fixative on those surfaces that cannot be decontaminated, conducting a pre-dismantlement raasological survey, documenting the survey results in a pre-dismantlement report, and obtaining NRC concurrence that the facility is safe to open to the environment and dismantle under carefully controlled conditions.
The second phase consists of dismantling the facility, packaging and disposal of waste, conducting any needed site (i.ci., soil) remediation, conducting a final radiological survey to demonstrate compliance with approved criteria for relcase to unrestricted use, documenting these data in a ~ final report submitted to the NRC and State of California, and requesting a confirmatory survey as the basis for release of the site to unrestricted use.
j9303090615 93o3o2
-gDR-ADOCK 07000734 PDR iG 3560 GENERAL ATOMICS COURT, $A N DIEGO CA 921211194 PO ROX $5608, SAN DIEGO. CA 92186 9784 (619)455-3000
E. G< Adensam, U.S. NRC March 1,1993
' 696-2036 Page 2 During dismantlement (Phase II), those portions of the facility meeting the criteria for release to unrestricted use will be disposed of at a sanitary landfill and those portions with fixed contamination will either be decontaminated or packaged for disposal at a U.S. Department of Energy low-level radioactive waste disposal site.
The above described two-phase approach was discussed with the NRC on May 2,1991 and submitted for their concurrence on May 30,1991 (Ref. 4). NRC approval was obtained by letter dated August 12,1991 (Ref. 5).
Another change to the SVA Decommissioning Plan was necessitated when NRC staff confirmed that there are significant unresolved concerns regarding the technical content of NUREGICR-5512; which was to provide the technical basis for release criteria derived from a pathway analysis. Consequently, GA requested (Ref. 6) and received (Ref. 7) NRC concurrence that: 1) the NRC approved criteria for release of facilities and equipment to unrestricted use are not those stated in GA's SVA Decommissioning Plan, but rather, are those found in " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
. Termination of L.icenses for Byproduct, Source, or Special Nuclear Material," and 2) the applicable NRC approved release criteria for soil are those of Option 1 of the NRC Policy Issue i
Phase I of the SVA Deccmmissioning project has now been completed. The only radio-active contaminants found were thorium and highly enriched uranium. The results of GA's pre-dismantlement radiological survey of the SVA Fuel Fabrication Facility demonstrate that the facility meets the prerequisite criteria for dismantlement (Refs. 4 & 5). Specifically, those l
criteria are that the facilig surfaces (except those that require dismantlement in order to gain access) meet the approved guidelines for release to unrestricted use or have readily identifiable fixed contamination, and that, therefore, h is safe to open the building to the environment and commence dismantling it in a carefully conmled manner. These results are documented in the l
enclosed report titled, "SVA Decommissioning Project Phase I (Pre-Dismantlement) Survey
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Report," dated February 1993.
Accordingly, GA hereby requests that its SVA Fuel Fabrication facility, with exceptions as described in the enclosed report, be released to unrestricted use for purposes of dismantlement. The enclosed report is being provided to assist in planning for a confirmatory survey and in support of this request to dismantle the subject facility.
GA is submitting a copy of the enclosed report to the State of California Department of Health Services and suggesting that they coordinate any pre-dismantlement surveys they may wish to conduct with Messrs. Pate or Cillis of NRC's Region V office.
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E. G. Adensam, U.S. NRC March 1,1993 696-2036 Page 3 1
If you should have any questions regarding our request or the enclosed report, please unact me at (619) 455-2823. Inasmuch as the SVA Decommissioning Project is at a hold point
,..as it receives NRC approval to dismantle, your assistance in expeditiously responding to e,or request is very much appreciated.
Very truly yours, Keith E. Asmussen, Director Licensing, Safety and Nuclear Compliance KEA:shs
Enclosures:
i Report titled, "SVA Decommissioning Project Phase I (Pre-Dismantlement) Survey Report" dated February 1993 (6 copies) cc:
Mr. Robert J. Pate, NRC Region V (w/1 copy of above report)
Mr. Michael Cillis, NRC Region V (w/1 copy of above report)
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P 1
b E. G, Adensam. U.S. NRC Ma.ch 1.1993
- 696-2036 Page 4 i
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References:
1.
Asmussen, K. E., Letter No. 696-1534 to Charles J. Haughney, " Submittal of SVA Decommissioning Plan," dated March 30,1990 i
2.
Asmussen, K. E., Ixtter No. 696-1612 to George H. Bidinger, " Submittal of Additional Information in Support of Request for SVA Decommissioning Plan Approval," dated August 24,1990 3.
Haughney, Charles J., Letter to General Atomics, ATTN: Dr. Keith-E. Asmussen, License No. SNM-696 Amendment No.16, dated November 13, 1990 l
4.
Asmussen, Keith E., Letter No. 696-1743 to George Bidinger, "SVA Decommissioning and Building Dismantlement," dated May 30,1991 5.
Haughney, Charles J., Letter to General Atomics, ATrN: Dr. Keith E. Asmussen, i
License No. SNM-696, dated August 12, 1991 j
6.
Asmussen, K. E., Letter No. 696-1896 to John W. N. Hickey, " Decontamination I
Guidelines for GA's SVA Decommissioning Project," dated April 14, 1992 7.
Hickey, John W. N., Letter to General Atomics, ATTN: Dr. Keith E. Asmussen, License No. SNM-696, dated May 1,1992 i
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