ML20045C113
| ML20045C113 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 06/03/1993 |
| From: | Cillis M, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20045C105 | List: |
| References | |
| 70-0734-93-02, 70-734-93-2, NUDOCS 9306220090 | |
| Download: ML20045C113 (55) | |
Text
.
U. S. NUCLEAR REGULATORY COMMISSION REGION V Docket No.:
70-734/93-02 License No.:
SNM-696 General Atomics (GA)
Licensee:
P. O. Box 85608 San Diego, California 92138 Torrey Pines Mesa and Sorrento Valley Sites Facility Name:
Inspection at:
San Diego, California Inspection Conducted: April 29-30, 1993, and May 12, 1993 d'
77
/
/
Micha illis,~Sen' Radiation Specialist Date S'igned Inspectors:
d3k3 Approved by:
/f)h Dat'e Signed J aes
. K5ese, Chief /
Fa it' s Radiologica1 Protection Branch Summary:
This was a special announced inspection to witness a Areas Inspected:
confirmatory measurement survey conducted by Oak Ridge Institute for Science and Education (0 RISE) upon completion of decontamination and decommissioning This facility was located of the licensee's HTGR Fuel Fabrication Facility.
in the northern half of Building 37, also known as General Atomic's Sorrento Inspection procedures 30703 and 83890 were addressed.
Valley " A" (SVA).
I In the areas inspected, the licensee's programs were adequate to the Results:
It was concluded that accomplishment of their safety objectives.
decontamination and decommissioning activities had been accomplished in No accordance with the licensee's NRC approved decommissioning plan.
violations or deviations were identified.
9306220090 930603
{DR ADOCK 07000734 PDR
DETAILS 1.
Persons Contacted:
a.
Licensee
+*K. E. Asmussen, Manager, Licensing, Safety and Nuclear Compliance
+*L. R. Quitana, Manager, Health Physics
+*P. L. Warner, Manager, Operations
- A. Lewis, Safety Engineer
+*R. C. Noren, Director, Nuclear Fuel Fabrication Division
+*P. R. Maschka, Health Physics Supervisor, SVA Project
+S. P. Massey, Quality Assurance b.
Decontamination and Decommissionina (D&D) Contract Personnel (Bechtel National. Inc)
+*P. K. Jackson, Project Manager, D&D Project c.
State of California
+*B. Kapel, Senior Health Physicist, Department of Health Services (DHS)
K. S. Wong, Senior Health Physicist, DHS d.
ORISE
+*M. R. Landis, Project Manager
- G. Foltz, Senior Health Physics Technician
+*M. Henke, Health Physics Technician Vallev Pines Associates (VPA) e.
- A. R. Fritsch, Consultant, VPA
+*B. Robertson, Project Engineer
+*D. Kowal, Site Representative f.
Allied Staffina Associates
+*M. St. Lawrence, g.
Cleveland Wreckinc Compan_y
+J. Droubay h.
NRC
+J. H. Reese, Chief, Facilities Radiological Protection Branch, RV
+R. E. Wilson, Project Manager, NMSS/IMSB
- Denotes those individuals attending the exit interview on April 30, 1993.
.x,--
2
+ Denotes those individuals attending the exit interview on May 12, 1993.
In addition to the individuals noted above, the inspectors met and held discussions with other members of the licensee's and contractor's staff's.
2.
Decontamination and Decommissioning of Building 37 a.
Historical Information Gene.al Atomics has been in the process of_ decommissioning its HTGR Fuel Fabrication Facility located in the northern half of Building 37. Decontamination and decommissioning activities have been in progress since November 1990. The work was conducted in accordance with an NRC approved decommissioning plan, titled, "SVA Decommissioning Plan," dated August 24, 1990.
Originally, the licensee planned to decontaminate the entire fuel fabrication facility, obtain its release for unrestricted use and The plan was subsequently changed because of then dismantle it.
contamination found in many inaccessible areas such as, the roof trusses. -The licensee concluded that it was impractical to continue with its original plan. After careful consideration, a two phase approach was developed.
Phase I was to decontaminate all accessible contaminated surfaces to levels which met the guidelines for unrestricted use.
Phase I also included the application of fixative on surfaces which could not be decontaminated, conducting and documenting a pre-dismantlement survey, and obtaining NRC concurrence that the facility is safe to open to the environment and dismantle.
1 The second phase (e.g., Phase II) involves the dismantlement of the facility, packaging and disposal of waste, and performing a final radiological survey to demonstrate compliance with the The approved guideline criteria for release to unrestricted use.
activities conducted under phase II will be documented in a final report, submitted to the NRC and State of California for review and approval.
During the phase II, portions of the facility with contamination that cannot be decontaminated to the criteria to unrestricted use will be packaged for disposal at a Department of Energy (00E) low-level radioactive waste disposal site. Portions. meeting the criteria for release to unrestricted use will be disposed of at a clean sanitary land fill site.
Phase I was, completed on May 12, 1993. The only radioactive contaminates found during Phase 1 Decontamination and Decommissioning (D&D) activities were thorium an highly enriched i
1 3
[
uranium. The licensee's survey report (see below) indicated that the facility meets the prerequisite criteria for proceeding to Phase II.
The licensee requested approval from the NRC and State of California to start the Phase II disma'ntlement operations.
The licensee stated that a final survey would be submitted upon completion of the dismantlement of Building 37. The survey will include the results of surveys taken during dismantlement and of the soil after Building 37 has been completely dismantled. The licensee said that dismantlement would take approximately six months to complete.
The inspector and State of California representative informed the licensee that additional confirmatory surveys would be scheduled during and after phase II.
b.
Wastes 7
Discussions with the licensee's staff disclosed that the Department of Energy (DOE) has agreed to accept all of the radioactive wastes containing SNM which will result from the dismantlement of Building 37. The licensee's staff stated that DOE will perform periodic inspections of the wastes transfers made to an approved DOE facility.
c.
Confirmatory Measurement Survey This special inspection was accomplished for'the purpose of observing the condition of Building 37 and to verify the results of final surveys that were taken by the licensee in the facility upon completion Phase 1 of the D&D project. The survey which was documented in the licensee's Phase 1 (Pre-dismantlement) survey report dated February 1993 was reviewed by both the Region V and ORISE staff prior to scheduling an independent survey of the facility. The independent confirmatory survey was scheduled by the Region V staff and State of California, Department-of Health Services were notified of the plans for performing a confirmatory survey. The survey was performed by ORISE during the week of April 26-30, 1993, in accordance with an ORISE survey plan which is included as Attachment A.
The ORISE confirmatory survey was witnessed by the inspector, the licensee's staff, and by representatives from the State of California.
i The results of the ORISE confirmatory survey are discussed in Attachment B and the results of an independent survey taken by the State of California representatives is discussed in Attachment C.
The NRC review of the February 1993 final survey report disclosed that D&D activities had been consistent with the Decommissioning Plan and that the release criteria to unrestricted use prescribed in Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors," had been achieved.
4 d.
Conclusions Based on the results of the licensee's surveys documented in the February 1993 report referenced in Section 2.a, above, and the l
ORISE and State of California confirmatory surveys, the licensee requested approval from the NRC and State of California to start dismantlement of its fuel Fabrication Facility, Building 37. The licensee stated that several operations would have to be completed i
before dismantlement could actually begin and asked for permission to start the dismantlement preparations by being allowed to:
(1)
Initiate asbestos removal activities.
(2)
Initiate structural support work adjacent to the center wall (e.g., between SVA north and south) or what is commonly referred to as the ' China Wall."
(3)
Disconnect the HEPA filtered ventilation system that is-currently installed on the Building 37 roof top provided that the system will not be needed for work associated with l
items (1) and (2) above.
The licensee plans to use portable HEPA ventilation units and reconnect part of the existing roof top ventilation j
system during dismantlement. The existing roof top ventilation unit will be removed and portions of it needed for the dismantlement phase will be reconnected after it is moved to a more convenient location.
Both the NRC and State of California informed the licensee that they were authorized to proceed with the above work activities.
The inspector and State of California asked the licensee how they planned to segregate the clean waste planned for disposal at a local land fill site from contaminated waste which will be i
J transferred to an DOE approved burial site. The licensee's staff stated that a Dismantlement Plan had been developed to address the segregation of wastes during the dismantlement of Building 37.
The licensee added that station health physics procedures and the health physics staff will exercise strict quality control measures to prevent any cross contamination or mixing of clean / contaminated material during the dismantlement problem. The licensee stated that a careful review of the dismantlement plan was in progress and that the purpose for the review was to include critical health physics " Hold Points" to ensure the wastes are properly surveyed for segregation.
The licensee agreed to provide the NRC, State of California, and ORISE with copies of the Dismantlement Plan, dismantlement work schedule, applicable procedures, and an ' Exceptions List.'. The Exceptions List provides a description and location of all
i 5
surfaces that were inaccessible for monitoring during the performance of Phase 1.
It also provides the location of all equipment that was found.to be contaminated which will require further decontamination.
Equipment which can not be decontaminated will be controlled and disposed of during the dismantlement phase.
The licensee held a meeting on May 12, 1993, with the NRC Region V and NMSS staff, State of California, ORISE, and the other individuals denoted in Section 1.
The purpose for the meeting was to discuss, the Dismantlement Plan (DP), DP organization, DP " Hold Points," applicable procedures, dismantlement sequence, dismantlement work schedule, quality assurance and quality control functions, and the Exceptions List. The purpose for the meeting was to clarify the method and controls which will be implemented during the dismantlement of Building 37. The licensee addressed each of these areas in great detail. A tour of Building 37 was conducted at the conclusion of the meeting. The Agenda for the meeting is include as Attachment D.
Questions resulting from the meeting were immediately resolved by the licensee with.the commitment to:
(1)
Revise the release procedure to include a requirement for performing both beta-gamma and alpha surveys on the underside of the concrete.
(2)
To submit a soil sampling and remediation plan for NRC approval.
(3)
Develop and implement a formal procedure documenting the quality controls that will be used in the segregation of clean and contaminated wastes.
(4)
Submit a official copy of the dismantlement schedule to both the State of California and NRC.
(5)
To keep the State of California and NRC informed of the dismantlement progress and of any abnormal contamination levels that are identified during dismantlement.
Both the State of California (See Attachment E) and NRC representatives attending the meeting agreed that the licensee had demonstrated that they were prepared to proceed with the dismantlement of Building 37. A letter authorizing the dismantlement to start was issued by NMSS and the State of California on May 13, 1993.
The inspector concluded that the licensee's performance in this area were consistent with the Decommissioning Plan and were adequate in the accomplishment of their safety objectives. No violations or deviations were identified.
l
6 3.
Exit Interview (30703) g The inspectors met with the' licensee representatives, denoted in Section 1, at the conclusion of the inspection on April 30, 1993 and May 12, The 1993.
The scope and findings of the inspection were summarized.
i licensee was informed that no apparent violations or deviations were identified.
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- 9 g April 22,1993 Mr. Mike Cillis U.S. Nuclear Regulatory Commission Region V Nuclear Materials and Fuel Fabrication Branch 1450 Maria Lane Suite 210 Walnut Creek, CA 94596-5368 RADIOLOGICAL SURVEY PLAN FOR TIIE GENERAL ATOMICS SVA-FACILITY,
SUBJECT:
SAN DIEGO, CALIFORNIA
Dear Mr. Cillis:
Enclosed is a copy of the survey plan for the radiological survey of the General Atomics SVA Facility in San Diego, California.
This survey plan was developed based on the information provided in the SVA Decommissioning Project, Phase I (Pre-Dismantlemeni) Survey Report February 1993. ESSAP provided comments on the GA Survey Report; a response to these comments would have facilitated development of a more site-specific survey plan. A more general approach was used to develop the enclosed survey plan..
If you have any questions or comments regarding this information, please contact me at (615) 576-2908.
Sincerely, l
Ib $ c.s Michele R. Landis Project Manager Environmental Survey and Site Assessment Program MRL:tte Enclosure cc:
T. Mo, NRC/NMSS, 6H3 R. Wilson, NRC/NMSS,6H3 D. Tiktinsky, NRC/NMSS,6E6 C. Emeigh, NRC/NMSS,4E4 J. Reese, NRC/ Region V J. Berger, ORISE PMDA,6E6 g
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File /213 R O BOX i17.OM RIDGL ~ENNELL[f 37E310117 uw,y 3 cad c,p+<u'ad by Od 9.dge AnconiW Un.<e-*cs be 'Le U s Der,ce -' 'J f ev.o
RADIOLOGICAL SURVEY PLAN Impullt FOR THE GENERAL ATOMICS SVA FACILITY j
SAN DIEGO, CALIFORh7A INTRODUCTION AND SITE HISTORY General Atomics (GA) operated the Sorrento Valley "A" (SVA) fuel fabrication facility under U.S. Nuclear Regulatory Commission (NRC) License SNM-696 and State of California Source and Byproduct license 0145-80 beginning in 1959. Activities conducted included:
Development of fuel fabrication processes, Fabrication of new fuel for several reactors and other fuel utilization programs, Design of coated particle fuel, and Design, construction and qualification of manufacturing equipment.
Radioactive materials used in these manufacturing operations included highly enriched uranium and thorium. Operations resulted in the contamination of process equipment and some internal surfaces of the facility.
Large production processes were shutdown in April of 1985; small fuel fabrication operations and demonstrations continued until 1990. The SVA Decommissioning Plan was submitted to the NRC in April 1990 and revised August 1990. Final NRC approval was given in October 1990. Additionally, changes to the release criteria specified in the Plan were requested per GA letter dated April 14,1992 and approved by NRC letter dated May 1,1992.
Decommissioning activities are being conducted in two phases. Phase I was the deconta'mination and radiological survey of the facility. Phase II is facility dismantlement with areas not decontaminated to be disposed of as low-level radioactive waste.
Prepared by the Environmental Survey and Site Assessment Program of Oak Ridge Institute for Science and Education, Oak Ridge, TN, under interagency agreement (NRC Fin. No. A-9076) between the U.S. Nuclear Regulatory Commission and the U.S. Department of Energy.
H:ESSAP PLANS'.SVA\\SVA.001 SVA Facilty - April 15.1993
Phase 1 activities began around October 1990 and continued to February 1993 and included the following activities:
Approval of the Plan by the NRC.
Removal of all equipment and internal structures.
Packaging of radioactive waste.
Pre-survey of the facility after removal of flooring, equipment and internal structures (i.e., mezzanines, wallboard, tile).
Decontamination of accessible surfaces.
Conducting detailed surveys of the facility surfaces.
Decontamination of " hot spots" identified during the survey.
Re-survey of the " hot spots" and identification of all exceptions (locations which could not be decontaminated and/or surveyed and will be disposed of as radiological waste or decontaminated to meet the release guidelines during the dismantlement of the building).
Application of fixative to selected surfaces to contain/ control surface contamination during dismantlement.
Shipment of radioactive waste to DOE disposal sites.
Submittal of Phase I report to NRC.2 1
Phase II activities, to be completed upon authorization from the NRC and State of California allowing GA to commence controlled dismantlement of the north end of the building, will include the following activities:
Dismantlement of the building; " exceptions" will be disposed of in a controlled manner as contaminated low-level radioactive waste or decontaminated to meet release' criteria, clean portions of the building will be disposed of at a nearby landfill.
Removal of all underground drain lines.
Soil remediation (as needed).
Soil sampling, analysis and documentation.
Submittal of a Phase II (post-dismantlement) report to the NRC summarizing the activities completed in Phase II.
2 n.scssri a taxs.svassv4.coi SVA l'uiirty - Aprit 15,1993
NRC concurrence that the open land site meets the criteria.
Removal of the site from GA's NRC and State licenses.
GA has completed the Phase I activities. The U.S. Nuclear Regulatory Commission, Region V Office, has requested that the Environmental Survey and Site Assessment Program (ESSAP) of Oak Ridge Institute for Science and Education (ORISE) perform a radiological survey of portions of this facility.
SITE AND FACILITY DESCRIFFIONS The SVA facility is located in the north half of Building 37 (SVA facility) located in Sorrento Valley at 11222 Flintkote Avenue, San Diego, California.
Approximately 41,000 square feet housed fuel fabrication processing equipment, offices, change rooms, laboratories, storerooms, a machine shop and stockroom.
Figure 1 illustrates the location of the GA Sorrento Valley Complex in relation to other GA facilities. Figure 2 illustrates the location of Building 37 (and the north end of Building 3{) in relation to other structures at the GA Sorrento Valley complex.
For project control and tracking, the facility was divided into 14 zones which are described below and shown in Figure 3.
Zone 1 North Tunnel Annex Zone 2 China Wall Zone 3 CAS (Central Alarm Station)
Zone 4 West Vault Zone 5 Hot Machine Shop (North End) and Stockroom (South End)
Zone 6 Vault Office and Assay Room Zone 7 Soot Filter Pads Located Outside North of Building 37 Zone 8 Production Floor (Section 1-4)
Syr recary. April 15. 1993 3
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Zone 9 North and South Ends of the North Tunnel Zone 10 East Mezzanine Zone 11 North Annex Zone 12 West HEPA Room I
Zone 13 SAS (Secondary Alarm Station)
Zone 14 Outside Walls of Building 4
BUILDING CONSTRUCTION The 3700 m (41,000 ft ) fccility being decommissioned consist of the following:
2 2
Main Building (zones 1, 2, 6, 8, 9 and 10) - Concrete tilt-up panel construction. The panels are attached to a structural steel framework and rest against the edge and footings of the concrete floor with a composition roof. A storage tunnelis located under the east edge of the main floor.
West Vault (Zone 4) - A heavily reinforced concrete storage structure with numerous shield walls forming storage aisles.
1 Hot Machine Shop and West HEPA Room Buildings (Zones 5 and 12, respectively) -
Consist of metal siding and. roofs attached to structural steel framework with concrete floors. These structures abut the main building, west vault and north annex.
CAS (Zone 3) - A concrete block structure with a cast-in-place roof located within the west HEPA room building (Zone 12).
Notth Annex (Zone 11)- A metal structure similar to those previously described, south.
wall of which is the north wall of the main building.
Security Annex (SAS) (Zone 13) - A reinforced concrete structure consisting of four rooms and two hallways. One of the hallways extends south along side the north annex.
SVA Facilty Aprit 15.1973 4
H:TruAP.PIANESVA\\SVA.001
b The Doors consist of about eight (8) inches of reinforced concrete. Concrete walls are about 7-12 inches thick. Metal walls and roofing am of standard cornigated metal stock.
Composite roofs are metal decking with insulation and tac coverings. The roof of the SVA main building consists of ribbed steel decking topped with a layer of rigid insulation, multiple layers or roofing and a bituminous top dressing. The sheets of metal span supporting roof trusses and purlins to which they are welded. The roof is considered to be contaminated. Fixative has been applied to the inside ceiling and trusses to fix the contamination in place and facilitate the safe removal of these portions of the building during dismantlement. The roof will be disposed of as radioactive waste; or, if feasible, portions may be decontaminated.
OBJECTIVE The objectives of the confirmatory process are to provide independent document reviews and radiological data, for use by the NRC in evaluating the adequacy of the licensee's radiological status report, relative to established guidelines.
In addition, ESSAP will perform measurements for total alpha and beta surface actisity. This data will not be sufficient to meet the recommendations of NUREG/CR-5849 for final-status f
surveys, but may be used by the NRC to supplement the licensee's data and assist the NRC in evaluating the radiological status of the facility.
RESPONSIBILITY Work described in this suncy plan will be performed under the direction of Michele Landis Project Manager with ESSAP. The cognizant site supervisor has the authority to make appropriate changes to the survey procedures as deemed necessary. After consultation with the NRC site representative, the scope of the survey may be altered as the survey progresses.
Deviations to the survey plan or procedures will be documented in the site log book.
5 n ussar.rwmsvatsv4.mi SVA facGry. April 15. sm
PROCEDURES Survey activities will be conducted in accordance with the ORISE ESSAP Survey Procedures and Quality Assurance Manuals. Specific procedures applicable to this survey are listed on Page 9 of this survey plan. Identification oflow and high potential areas, used in this survey plan, is the same as that designated by GA.
DOCUMENT REVIEW ESSAP has reviewed the licensee's radiological survey data. Procedures and methods utilized by the licensee were reviewed for adequacy and appropriateness. The data were reviewed for accuracy, completeness, and compliance with guidelines.
CONFIRMATORY SURVEY Reference Grid The reference grid systems established by the licensee will be utilized where possjble.
Measurement locations on ungridded surfaces will be referenced to prominent building features or the existing grid.
Surface Scans Surface scans for alpha, beta, and gamma activity will be performed using large-area gas proportional and NaI scintillation detectors, coupled to countrate meters with audible indicators.
Iocations of elevated direct radiation detected by scans will be marked for funher investigation.
In low potential areas,100% of the floor surfaces will be scanned for alpha, beta, and gamma activity. In high potential areas, 50 to 100% of the floor surfaces will be scanned for alpha, f
beta and gamma activity and 25% of the wall and ceiling surfaces will be scanned for alpha and l
beta activity.
SVA FacZey. April 15. Im 6
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RADIOLOGICAL SURVEY Surface Activity Measurements Measurements of total and removable alpha and beta activity will be performed at randomly selected locations. These measurements will be performed using thin-window GM and ZnS
+
scintillation detectors, coupled to countrate meters.
In low potential areas, approximately 30 measurements will be performed. In high potential areas approximately 200 measurements will be performed on floor surfaces and 30 on wall and ceiling surfaces.
Direct measurements and smears will also be obtained from locations of elevated activity identified by surface scans. Areas of residual activity, in excess of the guidelines, will be brought to the immediate attention of the licensee and the NRC. If additional remediation is performed during the ESSAP survey, follow-up measurements will be performed.
SAMPLE ANALYSIS AND DATA INTERPRETATION Samples and data will be returned to ORISE's ESSAP laboratory in Oak Ridge, TN for analysis and interpretation. Smears will be analyzed for gross alpha and gross beta activity using a low background gas proportional counter, and the results will be converted to units of disintegrations per minute per 100 cm (dpm/100 cm). Direct measurements for surface activity will be 2
2 converted to units of dpm/100 cm. The data generated will be compared with the licensee's 2
documentation and NRC guidelines established for release to unrestricted use.22 Results willbe presented in a report and provided to the NRC for review and comment.
P 7
EEMAPMNT.SVAtSVA.Mi SVA racmty. Apra 15, im
GUIDELINES 2
The surface contamination guidelines for beta-gamma emitters are:
Total Activity 2
2 5,000 dpm #7/100 cm, averaged over a 1 m area 2
2 15,000 dpm #q/100 cm, maximum in a 100 cm area Removable Activity 2
1000 dpm #9/100 cm The surface contamination guidelines for uranium are:
Total Activity 2
2 5,000 dpm a/100 cm, total, averaged over a 1 m area 2
2 15,000 dpm a/100 cm, total, maximum in a 100 cm area Removable Activity 1
2 1000 dpm a/100 cm TENTATIVE SCHEDULE Measurement and Sampling April 26-30,1993 Sample Analysis May 3-14,1993 Draft Report June 1993 J
4 SVA Facrey. Arra !$.1993 8
H:TSSAPPLANS'3VA'3VA.001 I
LIST OF CURRENT PROCEDURES Applicable procedures from ORISE ESSAP Survey Procedures Manual (Revision 7; May 31, 1992) include:
Section 5.0 Instrument Calibration and Operational Check-Out 5.1 General Information 5.2 Electronic Calibration of Ratemeters 5.3 Gamma Scintillation Detector Check-Out and Cross Calibration 5.4 Alpha Scintillation Detector Calibration and Check-Out 5.5 GM Detector Calibration and Check-Out 1
5.6 Proportional Detector Calibration and Check-Out 5.9 Floor Monitor Check-Out 5.13 Field Measuring Tape Calibration Se: tion 7.0 Scanning and Measurement Techniques 7.1 Surface Scanning 7.3 Alpha Radiation Measurement 7.4 Beta Radiation Measurement Section 8.0 Sampling Procedure 8.8 Miscellaneous Sampling 8.9 Sample Identification and Labeling Section 9.0 Integrated Survey Procedures t
9.2 General Survey Approaches and Strategies Section 10.0 Health and Safety Control of Cross Contamination e
Section 11.0 Quality Assurance and Quality Control t
I svA r.ccry. Apra ss. Im 9
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ua REFERENCES 1.
"SVA Decommissioning Plan," General Atomics, April 1990, revised August 1990.
2.
'SVA Decommissioning Project Phase I (Pre-Dismantlement) Survey Report," General Atomics, February 1993.
3.
" Guidelines for Decontamination of Facilities and Equipment Prior to Release for-Unrestricted Use or Termination of Licenses for Byproduct, source, or Special Nuclear Material," U.S. Nuclear Regulatory Commission, August 1987.
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i May 4,1993 Mr. Michael Cillis
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U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 t
Subject:
PRELIMINARY CONFIRMATORY SURVEY RESULTS OF THE GENERAL ATOMICS SVA FACILITY, LA JOLLA, CA
.i
Dear Mr. Cillis,
During the week of April 26-30,1993, ESSAP performed a confirmatory survey of the General Atomics SVA Facility in La Jolla, CA. Survey activities included surface scans for alpha, beta, and gamma activity and direct measurements and smears for total and removable alpha and beta 3
surface activity. Surface scans identified seven areas of elevated direct radiation which are identified in Table 1. Those areas which have been labeled as an exception will be handled as.
radioactive waste during the dismantlement process.
It is ESSAP's opinion that the areas of elevated gamma activity in Zone 8 may be indicative of subsurface contamination and warrant close investigation during the dismantlement phase.
I Please direct any questions you may have regarding this information to me at FTS (615) 576-2908.
Sincerely,
/
Michele R. Landis Project Manager Environmental Survey and Site Assessment Program j
MRL:kew cc:
T. Mo, NRC/NMSS, 6H3 ggggg[
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R. Wilson, NRC/NMSS, 6H3 D. Tiktinsky, NRC/NMSS, 6B6 C. Emeigh, NRC/NMSS, 4E4 J. Reese, NRC/ Region V J. Ber$ct, ORISFJESSAP PMDA, 6E6 File /213 r.o.soxii7,oxx,oot, reuse 3er27,.3i.oiir Monopri ond operoied by Dok Mao Assoc oied Ve.1ro< sit.os for 6e US. Dopon+on' r>8 tao'gr
TABLE 1 AREAS OF ELEVATED DIRECT RADIATION GENERAL ATOMICS SVA FACILITY LA JOLLA, CA Tott,1 Activity (dpm/100 cm')
Comment location Zone 5100 13,000 Remediated Outdoor Pad 7
2300 12,000 Exception 7
Foundation 3500 17,000 Exception 8
Interior Roof Above Zone 6
< 73 2900 Elevated Gamma 8
Floor Exception
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' DEPARTMENT OF HEALTH SERVICES 714/144 P 5ttlit P.o 60K 942732 5 A CR AMIN 10, C A 94 34 7370
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USNRC, Region V May 4,.1993
- 1450 Maria Lane, Suite 210 Walnut Creek,.CA 94596 Attention: Michael Cillis f
Senior Radiation Specialist j
RE: General Atomics Decon Plan for SVA Facility, Confirmatory Survey Results and Discussion
Dear Mr. Cillis:
As per.our close-out meeting with GA and ORISE on April 30, 1993, I
the Department-has the following comment.s:
1.
The State. confirmatory survey indicated no levels approaching the limits for beta-gamma or alpha radionuclides in.the. areas specified by GA's survey report.
l
- 2. The State concurs with the NRC that GA be permitted to proceed with the asbestos removal, China Wall work, and the removal of
^!
the'HEPA ventillation system..The removal of the HEPA system should be carried out after consideration of the need to have Y
the system functioning.,
- 3. GA needs to submit copies of the Dismantlement Plan and relevant portions of the Dismantlement Procedures for our concurrent 3
review and approval prior to continuing with the removal of -the roof, walls, etc.
- 4. The State may wish to' visit'the SVA facility during the
-Dismantlement Phase, particularly during the removal of the slab.
flooring and drain lines, j
If you have any questions, please call me at (916) 323-4456.
Sincerely, j
l 1
Ben sapel Chief, Industrial Licensing Unit Radiologic ~ Health Branch pm %.
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9 SVA DECOMMISSIONING PROJECT NRC/ STATE OF CALIFORNIA REVIEW May 12,1993 GENERAL ATOMICS A7%$G//(f)/f
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SVA DECOMMISSIONING PROJECT NRC/ STATE OF CALIFORNIA REVIEW May 12,1993 AGENDA INTRODUCTION (30 Min /K.Asmussen) e Personnel Introduction e
Organiz.ation e
History e
Objective e
RADIOLOGICAUENVIRONMENTAL (30 Min /L. Quintana) e CONTROL PROGRAM
SUMMARY
DISMANTLEMENT SEQUENCE (15 Min /ICJackson) e FACILITY WALK-TIIRU (1 Hour) e Operations Review (K. Jackson)
Radiological / Environmental (L. Quintana) e Program QUESTIONS / ANSWERS DISCUSSION (1 Hr.45 Min) o l
i l
a May 12,1993 NRC Agenda
. =.
Y' SVA DECOMMISSIONING PROJECT NRC/ STATE OF CALIFORNIA REVIEW May 12,1993 PRIMARY PARTIES GENERAL ATOMICS (GA) - GA was the operator of the facility and is the current holder of the NRC and State Licenses. During the SVA e
Decommissioning Project, GA was responsible for providing primary health physics services and for the disposal of radioactive waste to authorized disposal sites.
i VALLEY PINES ASSOCIATES (VPA) - VPA is a general partnership between Chevron U.S.A., Inc. and Shell Oil Company and has financial e
responsibility for the SVA Decommissioning Project.
BECHTEL NATIONAL INC. (BNI) - BNI was retained by VPA, with GA's consent, to provide an operational organization for the SVA Decommissioning Project and as such, was responsible for the performance of decommissioning activities.
U.S. DEPARTMENT OF ENERGY (DOEl-A majority of the uranium processed at SVA was a result of Atomic Energy Commission (A e
contracts. DOE has accepted responsibility for the radioactive waste and agreed to accept the waste at two of its sites (Nevada and Hanford)
I e
-FIGURE 1 DUSINESS RELATIONSIIIPS Lice nse GA Management Overview Review, Approve, Fund,
-VPA Manage and Administer PEPRXU1 DDC0t711SSIOt11tG VDRK Communication
?
BNI GA Cooperation Subcontractors Subcontr actors 44 e
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SVA DECOMMISSIONING PROJECT NRC/ STATE OF CALIFORNIA REVIEW May 12,1993 HISTORY PLAN PREPARED BY GA, BNI AND VPA Plan submitted to NRC/ State April 1990 August 1990 Plan revised October 1990 Plan approved Phased approach proposed May 1991 Phased approach approved August 1991 Revised release criteria approved May 1992 October 1990 - February 1993 Phase I March 1993 Phase I (Pre-dismantlement) suivey submitted ORISE Confirmatory Survey completed April 30,1993 4
9 r
SVA DECOMMISSIONING PROJECT NRC/ STATE OF CALIFORNIA REVIEW May 12,1993 OBJECTIVE Obtain NRC and State Authorization to commence dismantlement of SVA (i.e. start PHASE II) v e
e i.4
NRC/ STATE OF CALIFORNIA PHASE 11 (DISMANTLEMENT) PRESENTATION MAY 12,1993 1.
Health Physics Organization a.
SVA Project staffing e
Manager e
Supervisor Senior Lead Technician e
Lead Technician e
9 Technicians for dismantlement support 1 Technician for waste packaging and shipping e
e 1 Technician for instrumentation e
1 Administrative Secretary b.
Main site support - Health Physics Lab, Records Maintenance, Technical Services 2.
Job Coverage BNI Project Staff - 5 people to oversee 15-20 contractors a.
b.
Cleveland Wrecking crew size e
2 crews for dismantling 1 waste packaging crew HP Technicians will provide full-time job coverage for each crew e
3.
Project Meetings (GA, BNI, Cleveland Wrecking Co.)
a.
0700 daily pre-work meeting Job assignments Dissemination of information e
Problem resolutions b.
1600 daily HP/ contractors / supervision plan of the day meeting Job status e
Plan next dny Resolve problems i
1 NRC/ State of California Phase 11 (Dismantlement) Presentation Page 2 1400 Thursday weekly project management meeting c.
e Job status Policy and programmatic decisions e
Resolve major problems e
4.
Work Authorization #2977 will authorize Phase 11 (dismantlement) activities.
Includes:
a.
Dismantlement Plan b.
Exceptions List (4/30/93 issue) c.
Authorized individuals d.
Index of the approximately 39 Health Physics procedures covering the work:
Receipt, packaging and shipments of radioactive material and low-level radioactive waste e
Use and calibration of instruments Evacuation procedures Radiological Work Permits Respiratory protection program e
Training and bioassay e
e Air sampling Sample analysis and quality control for the HP Lab Health Physics duties and responsibilities e
e inspections e.
BNI health and safety procedures (15) f.
BNI operating procedures (34) g.
Joint GA/BNIinterface procedures (5) h.
Facility emergency procedure 1.
Evacuation route drawings
l NRC/ State of California Phase 11 (Dismantlement) Presentation Page 3 5.
Radiological Control of Area One central site access control point (security station) a.
RC A boundaries (boundaries may change during dismantlement process) b.
c.
RWP sign-in sheets d.
Personnel frisk prior to exit e.
Equipment release logs 6.
Condition of Building Smearable contamination on ceiling trusses and purlins < 2000 dpm/100 a.
cm*
Fixed contamination marked as exceptions and painted with a red b.
fixative / orange paint c.
Radiologically controlled area 7.
Stack Sampling and Building Ventilation System Stack Sampling - Evaluation conducted / stack sampling terminated a.
Evaluated air sample data e
Evaluated stack results No further aggressive decon required e
Building Ventilation System - To be dismantled upon approval of b.
procedure 8.
Health Physics Monitoring Portable ventilation units and HEPA filtered vacuums a.
b.
Tents / enclosures - as needed c.
Air sampling (as needed)
Continuous air monitors
NRC/ State of California Phase 11 (Dismantlement) Presentation Page 4 e
Portable air samplers d.
Instrumentation e
Floor monitors Alpha hand-helds e
Beta / gamma hand-helds e
Wipe counters (alpha and beta) e Low-level alpha beta counting systems e
e Gamma spectroscopy e.
Internal monitoring (as needed) e U-235 lung counts e
Thorium lung counts e
Bioassay f.
Health Physics inspections (HP-406)
Daily - Senior Lead Tech Weekly - supervision e
e Quarterly - HP management 9.
HP Hold Points (Dismantlement Plan specifies " hold points" to allow for HP surveys). For example, Smear survey of exposed roof surfaces (minor decon/ red fixative), as a.
needed i
b.
Spot-check surveys of exposed concrete Spot-check after removal of metal framework c.
d.
Spot check of metal overlap joints during disassembly e.
Spot checks during concrete removal 10.
Clean Waste Packaging Area Separate location from contaminated waste a.
b.
No red fixative / orange paint on debris to be transferred to clean waste
NRC/ State of California Phase II (Dismantlement) Presentation Page5 processing area Spot-check surveys by job-coverage HP Technician prior to transferring c.
to the area d.
Documentation and review of survey data Daily visual inspections of structural debris in the area by Lead HP e.
Technician 11.
Low-Level Radioactive Waste Staging and Packaging Areas a.
Separate location from clean waste b.
Material with red fixative or " exception" markings Packaging - LSA boxes or " Bulk Disposal" c.
d.
Prepare for shipment Estimate uranium and thorium in waste (per HP-217) e.
12.
Slab Removal Remove exceptions from floor slabs and transfer to radioactive material a.
staging / packaging area b.
Cut into manageable sections Flip slab sections onto plastic covering for survey / check-c.
d.
HP survey for beta / gamma contamination e.
Chip off (or paint) contaminated area f.
Spot-check survey of newly exposed surface g.
Transfer clean slabs to clean processing area h.
Send contaminated concrete to radioactive material processing area
NRC/ State of California Phase 11 (Dismantlement) Presentation Page6
^
13.
Drain Removal / Soil Sampling Do a spot check of soil with microR meters before and during drain a.
removal b.
Soil remediation (as needed) c.
Proceed with soil sampling d.
Additional soil remediation and follow-up soil sampling (as needed) e.
Final soil sampling 14.
Final Report a.
Summarize dismaria. '.it work b.
Provide soil sample results sufficient to demonstrate compliance with the Option 1 criteria (U.S. Nuclear Regulatory Commission Policy issue SECY-81-576, Disposal or Onsite Storage of Residual Thorium or Uranium (either as Natural Ores or Without Daughters Present) From Past Operations, dated October 5,1981)
J t
i I
e
SVA DECOhlhllSSIONING PROJECT
~
DISH 1ANTLEhlENT WORK SEQUENCE OUTLINE 1.
West Vault e
Not contaminated Renegotiate RCA boundary inward (up to East Wall) e Dismantle down to slab - use general demolition techniques e
Send debris to clean disposal-landfill Survey between West Vault and Assay Room (an exception) e 2.
North Annex Mostly non-contaminated area with some exceptions marked e
Dismantle upper level of elevator shaft - concrete cutting & breaking e
Dismantle liquid rad waste station - concrete cutting & breaking Remove 2 drainpipes listed as exceptions Spot check (smearable and fixed) newly exposed surfaces around exceptions Package drainpipes and material from exception areas as radwaste Send clean debris to clean packaging are.a for clean landfill disposal e
Dismantle roof decking - flame cut or mechanical e
Spot check listed exceptions for loose and fixed contamination e
Send clean roof decking to clean waste e
Dismantle wall panels by unbolting - vacuum overlap Spot check of concrete /metalintersection e
Send metal sheets to clean waste packaging area after survey of overlaps Dismantle purlins with remaining decking intact - flame or mechanical cut Spot check while " exceptions" are separated from clean material Transfer contaminated sections to RM packaging area e
Send clean debris to clean disposal e
DISM.WK.5U).
hge 1 of 5 May 12 WB
3.
Security Alarm Station (SAS) llistorically non-contaminated e
Dismantic using standard demolition techniques Spot check material during disassembly Dispose material at clean landfill e
4.
Smice Buildine (Hot Machine Shop / Stock-room) e Metal structure contaminated (exception) e Concrete contains some exceptions Unbolt and dismantle roof and wall decking e
Spot check concretc/metaljoints e
Dismantle structural steel Smear and paint exposed edges (as required by results) e Transfer contaminated metal to RM packaging area e
Transfer clean concrete to clean packaging area e
5.
West HEPA Roota/CAS CAS non contaminated, West HEPA room metal and some floor areas are e
contaminated (exceptions)
Provide contamination control to prevent cross-contamination e
Dismantle CAS concrete Spot check newly exposed floor surfaces e
Send to clean packaging area e
Dismantle roof and wall decking e
Dismantle structural steel Smear exposed edges of metal (paint if required) e Spot check survey concrete /metaljoints and areas around removed exceptions e
Send ' contaminated metal to RM packaging area e
6.
Assav Room (Concurrent with Service Buildinn and West Shed)
Mostly non-contaminated with some exceptions identified Dl5M.WK.5fD.
Page 2 of 5 May 12. IV>3
Establish contamination control e
Remove all exceptions from Door and walls e
Spot check newly exposed surfaces Dismantle concrete walls and ceiling Spot check newly exposed surfaces Send exceptions to RM packaging area Send clean debris to clean disposal - landfill e
7.
South Vault Walls (Concurrent with Service Building and West Shed)
Non contaminated with some exceptions identified e
Establish contamination control Remove exceptions from walls e
Spot check newly exposed surfaces e
Dismantle walls down to 4-inch level Cut out remaining stub of walls e
Spot check newly exposed surfaces e
Send contaminated concrete to RM packaging area e
Send clean debris to clean disposal e
8.
East Mezzanine (Prior to Production Floor)
Non contaminated with minor exceptions identified Asbestos panels already removed e
Dismantle concrete slab and transfer to clean processing area e
Spot check newly exposed surfaces e
Dismantle structural steel Transfer East I-Beam (exception) to RM packaging area e
e Spot survey of remaining steel Send non-contaminated material to clean disposal e
9.
Production Floor e
Both contaminated and non-contaminated areas exist DisM.WK.sl4 J' age 3 nf 5 May 11 IW3
Torch cut roof decking sections in large pieces (contaminated)
Smear / paint with fixative (as needed)
Transfer directly to RM packaging area Remove west tilt-up panels - one at a time e
Spot check newly exposed surfaces Lay panel down in enclosed decon area Blastrac top (painted) portions of selected panels e
Survey (with floor monitors and/or hand held probes) for release to unrestricted use Transfer clean material to clean packaging area Remove remaining tilt-up panels and walls e
Spot check newly exposed surfaces Spot check back sides of columns Spot check newly exposed structural steel Dismantle structural steel using flame cut & mechanical techniques Transfer clean material to clean processing area Transfer contaminated material to RM processing area 10.
North Tunnel Mostly non-contaminated, exception areas identified Remove all known exception areas Spot check newly exposed surfaces Send exceptions to RM packaging area Dismantle concrete ceiling and walls Send clean debris to clean disposal 11.
Slab Removal Non-contaminated with some exceptions Remove exceptions from floor slabs Cut floor in manageable sections ntsu wnsin r,e o,1 s un a wn
e Go south to north / cast to west Flip slab sections onto plastic covering Spot check newly exposed slab surfaces e
Chip off (or paint) contaminated areas Resurvey (spot check) newly exposed surface for loose and fixed contamination Send clean slabs to clean packaging area e
Send contaminated pieces to RM packaging area e
12.
Drain Removal / Soil Sampline Do a spot check of soil with microR meters before and during drain removal e
Soil remediation (as needed) e Proceed with soil sampling e
Additional soil remediation and follow-up soil sampling (as needed) e Final soil sampling e
L p
Dl5M WK.5Eo.
l' age 5 of 5 May 12. IVB i
SVA DECOhthilSSIONING PROJECT DISH 1ANTLEh1ENT WASTE MATERIAL CONTROL 1.0 Initial Component Condition
- Non-contaminated (clean) e Contaminated - entire piece fixative or exception location e Partially contaminated - exception shown on part of item 2.0 Separation
- Three flow paths e Radiological or spot checks e Partially contaminated - further separation e Resurvey as necessary, separate contaminated (red / orange) from non-contaminated e Reduced to two waste paths (contaminated /non-contaminated) 3.0 Contamim;ted Path e Material with fixative or exception marking
- Material directed to path from separation phase e Packaging - LSA boxes or wrapped for " Bulk Disposal"
- Prepare and ship for radwaste disposal f
4.0 Non-contaminated Path e Known clean structure e.g.: West Vault, Security Annex
- Clean material isolated from contaminated material e Contamination control to avoid cross-contamination
- Load and dispose as clean waste at local landfill e Document disposal t
May 12, l'h3 Dam.wnte MarlCtrl
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$ACR AMIN 10. C A 94M4 7370 ll; USNRC, Region V May 14, 1993 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Attention: Michael Cillis Senior Radiation Specialist RE: General Atomics SVA Facility, Dismantlement Phase Meeting of May 12, 1993
Dear Mr. Cillis:
This letter confirms our discussions with GA,
- BNI, and ORISE regarding the dismantlement procedures for the SVA facility.
The Department had several questions regarding the procedures and most of them were addressed during the presentation session.
These remaining issues were raised at the conclusion of the lecture portion:
- 1. Will there be saw or flame cutting of contaminated waste? It was prohibited in Section 1.7 but permitted in Section 16. BNI had indicated that this would be only when absolutely necessary, such the roof panels to enable them to be lowered, and other rare as situations only with approval frcm GA.
2.
Will wrecking balls be used as this conflicts with the definition of " dismantlement"? BNI stated that wrecking balls would only be used for the West Vault, due to the fact that it has no contaminated zones and it is made of heavily reinforced concrete.
- 3. Will decontamination procedures be used during dismantlement?
BNI indicated that they may need to perform "non-agressive"decon for the tops of the tilt-up walls, since they are so large, and the majority is clean.
These responses were acceptable to the Department. It is understood that additional information will be forthcoming recarding issues raised by the NRC and/or ORISE including:
A. Release QC for clean waste (paper trail)
B. Alpha survey under floor slabs.
C.
Soil sampling plan.
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March 14, 1993 GA/SVA The Department expects to be satisfied by this information as such issues were adequately discussed at the meeting. In conclusion, the Department has no objection to the commencement of dismantlement operations at the SVA facility.
If you have any questions, please call me at (916) 323-4456.
sincerely, Ben
' pe Chief, Industrial Licensing Unit Radiologic Health Branch r
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