ML20055E044
| ML20055E044 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 07/03/1990 |
| From: | Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rutherford P ROCKWELL INTERNATIONAL CORP. |
| References | |
| NUDOCS 9007100316 | |
| Download: ML20055E044 (4) | |
Text
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i JUL 3 1990 i
Docket No. 70 25 License No. SNM.21 Rocketdyne Division
~Rockwell International Corporation ATTN:, Mr. P. D. Rutherford, Manager Nuclear Safety' and Reliability Engineering
. Mail Code HB07 6633 Canoga Avenue Canoga Park, California 91303 Gentlemen:
This refers to your decommissioning plan submitted by letter dated April 12, I,
1990.
1 Our review of your plan has identified several areas where additional information is needed before final approval can be given. The revised plan should be provided within 30 days of the date of this letter.
If you have any questions regarding this matter, please contact Ms. Merri Horn ofntystaffat(301)492-0606, 7
Sincerely, l.
Onint Sised k l
George H. Bidinger, Section Leader l
Uranium Fuel Section L.
Fuel Cycle Safety Branch Division of Industrial and l
Medical Nuclear Safety, NMSS L
Enclosure:
As stated L
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0-Comments / Request for Additional Information Decommissioning plan Dated April 15, 1990 Rocketdyne Divis'lon Docket No. 70-25 Please provide the following:
1.
The Annex B limits are no longer being used as the release criteria for buildings; however, this criteria can still be used for the release of equipment that is removed from the facility. The NRC is currently developing new criteria for residual levels of radioactivity for decommissioning of nuclear facilities. The interim criteria require that a pathway analysis be conducted to ensure that the annual total effective dose equivalent (TEDE) not exceed 10 mrem /yr. The interim release criteria provide the allowable levels of residual contamination following decomissioning of buildings and soil.
When mixtures of radionuclides are encountered, the allowable levels of contamination can be determined using the sum of fractions rule. This rule states that the sum of the ratios of the concentration of individual radionuclides in the mixture to their allowable level must be less than or equal to 1.0, Rockwell will need to determine the mix of radionuclides present as contamination or assume that all contamination is from the most restrictive radionuclide.
NUREG/CR-5512 (copy enclosed) contains the technical basis for the new criteria.
2.
provide a more detailed description of the proposed decomissioning activities that will be performed in the various areas.
Include all
]
areas.
3.
Commit to performing a hazards analysis for any new decommissioning l
l activities that may be conducted.
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l 4.
if pipes, drains, stacks, etc., are to be left in place, Rockwell must be L
able to demonstrate that the release criteria are met and the NRC must be able to confirm the measurements.
Additionally, Rockwell must determine l
if the pipes have leaked in the past and contaminated the area o
surrounding the pipe, j
5.
What are the plans for disposing of the mixed waste present on the site?
6.
We note that the sodium burn pit, which is not mentioned in the plan, is an 0
area suspected to be contaminated. This area and any other area or building on the non-DOE controlled land must be addressed either in the plan or in a supplement to the plan.
Rockwell should carefully review its records to assure that all areas where radioactive material was used is included in the decommissioning efforts and final survey.
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7.
The final survey as described in your plan is not adequate to show that the site meets release criteria.
The effected. areas (areas expected to be contaminated) must be 100 percent surveyed using a 1m x Im grid system. A 10m x 10m grid system may be used outside. Clean areas may be sampled on a statistical basis.
RefertoNUREG/CR-2082(copyenclosed)for more information on confirmatory sampling. Additional guidance is 1
currently being prepared on conducting the confirmatory s9rvey.
It will be necessary for Rockwell to conduct a pathway analysis in accordance with J
8.
The schedule on pagt 2-10 lists demolition as a planned activity, however, dens 11 tion is not discussed in the plan. The demolition activities should be discussed in the text.
Demolition of the building I
could effect the dose calculations for final release of the facility.
9.
On page 3-4 you indicate that each time a respirator is returned it is servicedbeforebeingreissued.
Indicate the frequency of return, i.e.,
after each use, daily.
- 10. The decommissioning plan should describe the fire protection measures including the fixed and portable fire extinguishment systems.
Portable extinguishers of suitable types should be deployed throughout the facility, in accordance with NFPA 10-1988, portable Fire Extinguishers.
These should be in addition to any fixed fire suppression system.
Additionally, there are other fire protection concerns listed below, in each case, we have provided suggested precautionary measures. These concerns should be addressed in the plan.
Concern Precautionary Measure A.
Welding, torch-cutting, and The requirements of such other hot working may NFPA 518-1984 Fire Prevention ignite ordinary combustibles.
in Use of Cutting and Welding Process, should be followed.
B.
Sand or grit blasting of Such cleaning work should be contaminated metal parts performed in an enclosed space, could produce sparks, and a portable extinguisher should be on hand.
C.
Use of fla mable liquids Such cleaning should be in decommissioning performed in an enclosed (Example:
aceton, carbon area, the flammable tetrachloride,etc.)
vapor (ifsubstantial l
amountsaregenerated) should be exhausted out L
of the space, and ignition l
sources should be prohibited l
in the area.
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p' e
4 pi D.
Reactive chemicals, such as Areas using such chemicals.
. nitric acid, could spill and
,. should be diked to prevent react with ordinary combustiblesL spills from spreading..
. causing fires.
Acid-soaked rags, etc.,
should be handled in fire-proof containers-and-disposed of separately from other combustible materials.
E.
Storages of combustible Remove such storages.from liquids, such as hydraulic the' operating area. Also, oil, may be. ignited.
arain manipulator hydraulic-systems and remove the fluid beforehand.
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F.
Ordinary combustibles, Administrative controls should such as pallets, cardboard be exercised to maintain good.
boxes, and plastic sheets, housekeeping.
often are allowed to pile up and may ignite.
- 11. -Provide a section on criticality safety.-
- 12. ' Provide more detail to the cost estimates; and provide the plan for assuring.the availability of adequate funds for completion of deconiissioning, other than, Building 20.
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