ML20055J311
| ML20055J311 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 07/24/1990 |
| From: | Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| References | |
| NUDOCS 9008020080 | |
| Download: ML20055J311 (3) | |
Text
_
All 2 41990 Docket No.70-734 I
License No. SNM-696 General Atomics ATTN:
Dr. Keith E. Asmussen, Manager Licensing Saf(ty, and Nuclear Compliance P.O. Box 85608 San Diego, California 92138-5608 Gentlemen:
This refers to your decommissioning plan submitted by letter dated March 30, 1990.
Our review of your plan has identified several areas where additional information is needed before final approval can be given.
The additional information, in the form of revised pages, 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 of my staff at (301) 492-0606.
Sincerely, MM%
George H. Bidinger, Section Leader Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS Distribution w/encls.
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NFIS
Comments /Recuest for Additional Information General Atomics SVA Decommissioning Plan dated April 1990 Docket No.70-734 Provide the statement that GA retains the ultimate responsibility for all aspects of the decommissioning work.
The licensee should state the field (s) of the college degrees required of the GA Project Manager.
The licensee should state the minimum years of experience required of the GA Project Manager in managing decommissioning or decontamination projects.
The Plan should provide minimum edNation and experience requirements for the Bechtel National,.inc., (BNI) management positions.
The licensee should provida e chart showing the interfaces between the GA and 5
BNI management positions (functional not business).
The licensee should provide resumes (if not previously provided) for the individuals that will fill the GA and BNI management positions discussed in Sections 2.2.2.2 and 2.2.3.1.
In Section 3.3.1.3, the licensee should specify the acceptance criteria for air sampler representativeness.
In addition, the action level for measured airborne radioactivity should be expressed in NPC-hours rather than > 1 MPC.
In addition to the contamination action levels in Table 3.3-1, the licensee should commit to the alpha contamination limits in Table 2 of Regulatory Guide 8.24 for skin, protective clothing worn in controlled areas, and personal clothing worn outside restricted areas.
In Section 3.3.2.3, define " Maximum Permissible Limit"- and " Maximum Permissible Lung Burden."
What is meant by "Non-Manual" and " Manual" in Table 3.3-3?
In Section 3.3.4.3, the licensee should ci.amit to performing monthly checks to determine if "tir flow is from zones of lesser contamination to zones of i
greater contamination potential." What is the minimum negative pressure differential allowed for glove box atmospheres?
In addition, the licensee should commit to testing final HEPA filters in portable and fixed ventilation systems, as well as vacuum cleaners, annually and after any maintenance or filter change in accordance with ANSI 510-1980 (or latest revision).
In Section 3.3.5, provide the lower sensitivity limits for the listed instruments.
i.
-r In Section 3.3.7.3, the licensee should commit to a specific frequency for BNI inspections of the health and safety program.
The licensee should also state to whom the inspection findings will be reported.
In Section 3.6.1, who is responsible for reviewing and approving hazardous work permits?
In the third paragraph on pages 2-66 and 3-12, remove the word "or" from "and/o r. "
Provide a commitment that GA will conduct a safety hazards analyses when using new equipment or conducting a new activity.
The analyses should consider, as a minimum, fire protection, radiological safety, industrial safety, containment, 3
criticality prevention, and loss of utilities.
l The Annex C limits are no longer being used as the release criteria for buildings; however, this criteria can still be used for the release of 4
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 tesidual contamination following decommissioning 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.
GA 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 contains the technical basis for the new criteria.
In conducting the confirmatory surve should be 1 square meter (building) y, the grid size for an affected area or 100 square meter (outdoors).
Surveillance should be conducted in every affected area grid.
(An affected area is an area with a high potential of having radioactive contamination.)
When the area is designated as an unaffected area, a random (statistical) survey with a large grid size is allowed.
Guidance is currently being developed on survey procedures.
Fire Safety i
The submission does not have a separate section containing a description of fire protection equipment or fire safety measures.
It is recommend that there be a separate section on fire safety under 3.0, Methods for Protection of Occupational and Public Health and Safety, which includes:
1.
Description of fire protection features.
2.
Operations that are a potential fire hazard and the method of protection (e.g., torch cutting).
3.
Commitment to follow specific NFPA codes on distribution of fire extinguishers and issuance of welding, torch cutting, and other hot' working permits.
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