ML20058H721
| ML20058H721 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 11/13/1990 |
| From: | Bidinger G, Horn M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20058H719 | List: |
| References | |
| NUDOCS 9011210286 | |
| Download: ML20058H721 (5) | |
Text
.
[.
y.
o, UNITED STATES D
NUCLEAR REGULATORY COMMISSION n
- f WASHINo ton. D. C. 20S$5 i
k...* /
November 13, 1990 DOCKET N0:
70-734
' LICENSEE:
General Atomics (GA)
San Diego,. California
SUBJECT:
SAFETY EVALUATION REPORT FOR AMENDMENT RLQUEST DATED i
MARCH 30, 1990, AND SUPPLEMENT DATED AUGUST 24, 1990, RE DECOMMISSIONING PLAN FOR THE HTGR FUEL FABRICATION
't FACILITY
Background
By letter dated March 30, 1990, GA submitted for NRC review and approval a j
decommissioning-plan for the HTGR Fuel _ Fabrication Facility.
The plan is entitled "SVA Decommissioning Plan" and is dated April 1,1990.
By letter dated-
- July 24, 1990, the staff requested additional information.
On August 24, 1990, GA submitted revised sections dated August 22, 1990, which addressed the staff's concerns.
The facility known as SVA was established in 1959 to foster research L
and development activities with ceramic-based nuclear fuel materials.and fabri-
.cate high temperature gas cooled (HTGR) fuel assemblies.-
SVA-is comprised of Building 37-North and its ancillary structures, occupying a total of approxi-mately 41,000 square feet.
It houses the fuel fabrication processes, offices, change rooms, laboratories, storerooms, eating area, and_ shop.
Nuclear fuel operations at -SVA centered on the design of coated particle fuel,. development p
of fuel processes, and fabrication of fuel.
These operations resulted in the contamination of the. process equipment and the internal-surfaces of the facility.
According -to GA, the radioactive contaminants, present are U-234, U-235, U-238, and thorium and its daughters.
The-facility was operated under both NRC and State of California-licenses;~therefore, GA has also provided a copy of the Plan v
L to:the' State'of California Department of Health Services.
Final release of the H"
facility will be coordinated with the State.
Discussion i
The objectives of the Plan are to provide information on safety considerations, available_ technology, estimated costs, availability of required funding, proj-il ected schedule, the criteria to be used for the release of-equipment and facilities to unrestricted use, and the general approach for decommissioning l
.the facility.
The scope of work will include:
dismantlement, removal, and l
~offsite-disposal of equipment and the facility's inner structures; decontami-nation of the' remaining structure, including, if necessary, removal of portions or all of the roof; and post-decontamination radiation and contamination surveys to verify release criteria have been met.
The projected schedule encompasses 9 months.
After the facility is released, GA plans to demolish the building.
9011210286 901113 POR ADOCK 07000734 C
.y General Atomics 2
When feasible, GA plans to use passive decontamination techniques.
These techniques include standard vacuuming, damp cloth wiping, and hand washing /
scrubbing operations.
If passive methods fail to reduce surface contamination to releasable levels, more aggressive methods will be applied.
These methods include dry abrasive blasting with vacuum, scabbling/ scarification, ultra-high-pressure water, and abrasive honing.
Organization and Responsibilities GA will oversee the decommissioning activities and is responsible for ensuring compliance with license requirements and regulations.
GA will be responsible for disposal of radioactive waste at authorized burial sites and providing the primary health physics service.
Bechtel National, Inc. (BNI), will perform most decommissioning at tivities and will provide the organization for the decommis-sioning effort; however, GA retains ultimate rcsponsibility for all aspects of the decommission 11g work.
Valley Pines Associates (VPA) has retained financial responsibility for the SVA decommissioning.
The GA Project Manager has the overall responsibility for the control and safety of GA's decommiss'oning activities and for protection of people and the environment against potential radiation / contamination exposures from these activities.
His specific responsibilities include approving procedures required for implementation of the Plan, coordinating the activities of the GA staff, interfacing with BNI and VPA management, approving overall project plans, and ensuring compliance with GA's license.
The qualifications for this position include an accredited 4 year college degree in science or engineering; previous project management experience; 2 years' experience in a project management position for a decommissioning or decontamination project; substantial knowledge of the SVA. facility including its history and the operations; knowledge of GA's radiation protection, nuclear safety, and industrial safety programs; and past experience in interfacing with the GA compliance organization.
The BNI Project Manager has the overall responsibility for the management and execution of the project.
The qualifications for this position include an accredited 4 year college degree, prior project management experience, 2 years' experience on previous decommissioning or decontamination projects, and prior involvement-in the detailed preparation of a decommissioning program.
During inspection 70-734/90-03, the Region V Inspector examined some of the activities associated with preparations for decommissioning the SVA.
The inspector noted that to augment the current staff, GA had hired an additional
.five health physics (HP) technicians and a degreed HP supervisor.
The inspector reviewed the resumes of the new HP staff and noted that each individual appeared to be well qualified for their assigned position.
The inspector also met several of the BNI staff and noted that these individuals appeared to be well qualified.
The inspector also noted that BNI and GA appeared to have a good working relationship.
General Atomics 3
Operating Procedures Written work instructions and procedures will be used to perform and control decommissioning activities.
The procedures will establish the methodology for performing specific tasks.
BNI procedures will be reviewed and approved by BNI management.
GA approval of BNI procedures involving, or potentially involving, work with radioactive material will be in accordance with the GA Work Authori-zation approval process.
BNI will use Unit Work Instructions (UWIs) in the performance of daily activities of the decommissioning work force.
To perform specific tasks, the UWIs will invoke GA/BNI approved procedures.
These UWIs will be reviewed /apnroved by the BNI Health Physicist, BNI QA Engineer, and the BNI Project Engineer.
UWIs involving work with radioactive material will invoke the requirements of Radiological Work Permits (RWP).
The function of the RWP is to define radio-logical conditions and personnel protection measures required to perform the tasks specified in the UWI.
The RWP will be approved by the GA Health Physics Manager, who will make the determination as to whether other GA approvals such as Nuclear Safety are required.
GA's oversight will include verification that an evaluation of new equipment and new activities for potential safety hazards has been performed.
Concerns to be addressed in the evaluation include fire protection and industrial. safety, as well as provisions for containment and loss of utility services.
This evaluation will generally be part of the review and approval process for procedures and work authorizations.
Training Personnel will receive training concerning the project's radiological protection and health and safety programs.
Each decommissioning project worker will re-ceive training consisting of instruction in jobsite radiological protection, health and safety, hazard recognition and control, fire extinguisher training, and emergency and safety awareness.
The training program includes applicable decontamination procedures for work in areas of real or potential radiological significance,- radiation' effects, radiation safety, radiation dosimetry,
. contamination control, and regulatory requirements.
The training shall consist of classroom training and practical drills.
Additional radiological and general safety training that is specifically directed toward planned work activities.
will be conducted prior to the start of the activity.
Unit Work Instructions issued for each task include reference to the applicable procedure and specific concerns / precautions related to health and safety.
Retraining will be conducted at least annually.
Fire Protection The principal fire risk at this facility arises from welding, torch-cutting, and other hot working processes.
The licensee proposes to administratively I
control such operations and post fire watches equipped with fire extinguishers.
The facility is equipped with a sprinkler system and hose stations supplied by a fire main.
These systems cover all work areas.
On October 22 and 23, 1990, during telephone conversations with Dr. A. Datta, Dr. Keith Asmussen of l
t i
I
1 General Atomics 4
GA confirmed t.1at all fire protection equipment is inspected and maintained according to 'Jrevalent industry standards and that the fire alarm system is connected to a central annunciator panel that is continuously supervised.
The licensee pro 1oses to train all employees in fire protection.
Radiological Safety A radiation tafety program is provided to protect workers, as well as the public and environment, from radiation exposures.
The program is managed by qualified individuals and includes a system to control and assess workers' internal and external radiation exposures, surface contamination in the work area, performance of the ventilation systems, and eevironmental impacts.
The licensee is committed to maintaining radiation exposures and releases of radioactive materials in effluents as low as is reasonably achievable (ALARA).
In addition,.the program includes action levels and actions to be taken to initiate investigations and corrective actions to reduce or prevent recurrence of radiation exposures.
Criticality Safety.
The licensee addresses the potential for 700 grams of U-235 existing in the HEPA system ducts and in the process equipment.
Three provisions are key to reducing the risk of a criticality accident.
First, GA will conduct appropriate surveys and analysis for U-235; therefore, appropriate procedures can be developed and safely implemented.
Second, in areas where U-235 was processed during facility operations or where the presence of U-235 was established by characterization surveys, criticality-safe containers will' be used for decontamination liquids and solid residues.
Procedures for vacuum cleaners will address the risk of uranium accumulation in non-critically safe volumes.
- Third, training-in criticality safety will be provided to employees.
Waste Disposal All radioactive waste generatt.d during decommissioning is expected to be Class A waste and will be disposed of at an authorized low-level radioactive waste
_ disposal site.
To reduce the quantity of waste to be buried, GA plans to use waste volume techniques.
These include a bailer / compactor, a shredder / compactor, and nesting.
Radioacti'/e liquids that are generated will, after analysis,.be either decontaminated to unrestricted release levels or be disposed of as solidified or absorbed waste.
GA expects 32,000 cubic feet of waste to be packaged for radioactive waste burial.
l'inal Survey
. Af ter completion of the decontamination operation, a final radiation survey is planned to provide assurance that the site meets the criteria for release to unrestricted use.
The survey will be conducted by or under the guidance of the GA Health Physics organization.
The results will be used to support GA's request to release the site to unrestricted use.
GA has agreed to calculate
General Atomics 5
the total effective dose equivalent (TEDE) to ensure that 10 mrem /yr is not exceeded.
However, the final release criteria are subject to change.
The document which the criteria are based is a draft document, therefore, some changes in the criteria may occur when the document is finalized.
GA has been informed of_the potential change in release criteria.
Conclusions / Recommendations Based on the above discussion, the staff concludes that the decommissioning plan for the HTGR facility is acceptable and should be approved.
The staff concludes that the health and safety of the workers and the public is adequately protected, and the work will be' completed within a reasonable time.
Amendment of GA's license to incorporate the decommissioning plan is recommended.
The Region V Principal Inspector has no ob.iection.
OriO nal Signed By Merri Horn Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical-Nuclear Safety, NMSS Approved by:
George H. Bidinger, Section Leader HH/70734 GA SER AMD 16 i
5..........b b.bb?b$'...........................
NAME:
n:mh:
VD rpe:
GHBidinger:
~ ATE:11/
/90:
11/tiY90:
11/I3 /90:
0FFICIAL RECORD COPY t