ML20127G107

Application for Amend to License SNM-696,authorizing Changes in Radiological Safety & Environ Surveillance Requirements During Specified Limited Fort St Vrain Operation.Fee Paid

ML20127G107
Person / Time
Site:	07000734
Issue date:	04/23/1985
From:	Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
25214, 696-7045, NUDOCS 8505200658
Download: ML20127G107 (10)

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q Dr. William T. Crow U.S. Nuclear Regulatory Commission COMyddy?g '/

. Office of Nuclear Material-Safety & Safeguards 7;

gen Washington, D.C. 20555 21 40 Xi0 QS

Subject:

~ Docket 70-734: SNM-696; Request for Amendment of Certain License Specifications and Related License Conditions.

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M. BRAN 3

Dear Dr. Crow:

GA Technologies has recently received a renewal of the subject license.

This license was renewed on the basis of significant levels of fuel fab-rication activity.

Recently we've been requested to delay HTGR fuel pro-duction for a period of 2-3 years.

In addition, declines in the sales of TRIGA _research reactors and their fuels also dictates a substantial reduc-tion in the level of TRIGA fuel manufacturing activity with protracted periods of shutdown. As you are aware, the Fort St. Vrain reactor has operated for sometime at a small fraction of full power capacity and is currently shutdown most probably through 1985. This has significantly delayed the availability of irradiated fuel elements scheduled for post irradiation examination in ' GA's Hot Cell.

c Many of the license requirements were deemed necessary to_ assure compli-ance with regulatory requirements, protect facility personnel and the facility environs during periods of significant fuel processing and Hot Cell PIE operations. With the advent of a cessation of HTGR fuel produc-tion, a reduced level of TRIGA fuel production including periodic. shut-

'down and no scheduled Hot Cell PIE work for the near future, we request a license amendment authorizing certain changes in the Radiological Safety

& Environmental surveillance requirements during the above specified limited facility operations.

I This amendment request is being accompanied by other requests, submitted

, under separate cover, to the NMSS Safeguards Branch. Matters within them contain both " Safeguards and Confidential National Security" information.

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• 1 * - (D We presume.your staff will coordinate with other ' NMSS staff as our re-quests are being considered.

Enclosed is a check for $150 to cover the

'I administrative costs of filing this amendment request.

bA Attachment A-is a table identifying the items for which change is sought.

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The table contains the license specifications section reference, the cur-

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rent requirement and 'the proposed new requirement along with any accom-

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It is intended that this table'be the basis g: d.,,g 3 of the license amendment authorizing the Specification change and devia-Q

%y j-tions from the specification volume requirements which will continue in 4% 28e 8505200658 850423 PDR ADOCK 07000734 C

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W. R. Crow 696-7045 effect in areas other than the SVA. TFFF and Hot Cell facilities.

Includ-ed in the change is a clarification relating to the testing and calibra-tion requirements for the CWAS as differentiated from other survey and analytic equipment. Pages II 4-13 and II 4-16 have been altered to pro-vide the clarification.

Attachment B contains several descriptive arguments intended to justify the changes sought in Attachment A and the above amendment.

We have an urgent need to receive the requested amendment on or befo.e May 20, 1985. This will allow an orderly retreat from the existing pro-cedural requirements as the level of fuel processing activity moves to storage only mode. We request that your staff promptly contact us via phone or telecopy about any concerns they may have.

We remain hopeful that the above schedule can be met and look forward to your issuance of a license amendment covering our request.

Very truly yours, William R. Howry Licensing Administrator WRM:ho Attachments:

A.

Changed Requirements for Shutdown Facilities B.

Supporting Arguments for Shutdown Facility License Conditions C.

SNM-696 Specifications Volume Pages II 4-13 D.

SNM-696 Specifications Volume Pages II 4-16 Enclosure :

Check for $150.00 cc: NRC, Region V

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'i, ATTACHMENT A CHANGED REQUIREMENTS FOR SHUTDOWN. FACILITIES Spec.

Vol.

New Subject Item Sec.

Existing Requirement Requirement Comment or Condition

-Internal ~ Inspections Health Physics 3.6.1 Quarterly Annual HTGR & Hot Cell Particulate ex-posures essentially eliminated by.nothing in storage Nuclear: Safety Quarterly Annual Where atl is vault stored in stable forms, e.g.. oxide or encapsulated Persor nel Monitoring U-235 bioassay 4.1 3 includes guards eliminate guards during shutdown of fuel fab Surveys Wipes-4.1.4.1 Daily Monthly in shutdown' fuel fab areas Weekly in QC Lab & other Type II workplaces Air Velocity Quarterly No Survey when hoods enclosure cleaned to mini-are unused mize potential for airborne release of material Glove Box

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'4N ATTACINIENTJAL(Page 2)

Spec.

Vol.

New-Subject Item Sec.

Existing ' Requirement -.

Requirement Comment'or Condition Air Samples-Work place 4.1.4.2 Shift Monthly.

In -shutdown fuel feb areas Weekly Weekly In QC Lab' & other Type II..

a Work places 4

~ Analysis Interval Within 24 hrs 1 week Weekly

.Honthly In shutdowns processing areas -

. Stack Water Sampling Sewage 4.1.4.3 Collected d'aily Collected weekly Samples evaluated daily Samples evaluated monthly plus sample and evaluate on days of discharge Alarm checks &

Calibration Criticality 4.2.1 & ' Semiannual recalibration Eliminate CWAS from Functionally test monthly with 4.2.1.4.to NBS Traceable Sources requirement of 4.2.1' builtin check or portable sources or other system features.

. Work Place Air changes 4.1.2.1' All work places Eliminate requirement 4 air changes /hr in areas when all mater-ial-is stored.and equip-ment is cleaned out.

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j ATTAC} MENT A (Page 3)

-Spec.

Vol.

New Subject Item Sec.

Existing Requirement Requirement Comment or Condition hcl Monitoring 6.6.1 Quarterly 0

No planned hcl furnace operations Environmental Air Sampling 6.1 Weekly Monthly Suspended Particulate 6.6.1 Semiannual No change Tap Water Sampling 4.1.4 3 Daily Evaluation Weekly Evaluation Sewage Sampling 6.2 Daily Sampled daily

. Analyzed 5=ekly

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DO ATTACHMENT B SUPPORTING' ARGUMENTS FOR SHUTDOWN FACILITY LICENSE CONDITIONS

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' This'contains justifications for changing the ' inspections, monitoring, sur-veillance and certain other requirements usually required by the SNM-696 license to less. frequent periods during intervals that the HTGR and or TFF' ifuel production as well as Hot Cell PIE activities are shutdown.

L The ' justifications are as follows:

1.

- Internal Inspections.

. During routine operations large ' amounts of SNM in wide ranging forms and quantities are being handled, used, and moved about within the

.above facilities. Daily surveys and quarterly inspections are re-quired to ensure continuing safety of facility operating personnel.

The inspections-monitor ~ activities for compliance with established procedures and safe practices.

During the periods when activities are shutdown and essentially all material is in vault storage, we believe that annual inspections can assure continued safety and that storage containers are intact with no indications of failure. This conclusion is' supported by data taken during the shutdown periods occasioned-from 1981 to late 11982 during the security upgrade. It is expected thst no materials will be stored in a reactive state such as concentrated acidic solutions or in pyrophoric form.

2.-

Personnel Monitoring.

Currently members of the guard force are required to work.in or make frequent' patrols in HEU fuel processing areas where there is airborne -

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contamination. Accordingly, they have been included in a bioassay program. During the interval where HEU production materials are stored in vaults and essentially no unencapsulated material forms are being handled, we believe they should be exempted from the recurrent j

- bionssay > testing requirements.

3 Surveys The HTGR fuel processing area, normally a contamination control area, will be cleaned thoroughly. Past experience shows that contamination is' not transported when operations are shutdown or unsealed material is containerized and put.into vault storage or material will be con-tained in " cleaned out" process equipment. : Surveys will be to assure

.that contam?tation is not' migrating from unknown causes.

It should be

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further note, that the TRIGA fuel process is a metallic operation.

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, Only metal han' ling can cause contamination to spread in this facil-ity.

In additi t, during periods when the Hot Cell is shutdown and not operating, 4 3 ' operating areas are also clean and the engineered provisions of ce sealing assure that contamination does not' spread from that contai. d within the cell during periods of non-activity.

Accordingly, we t.ieve that a much less frequent wipe survey of Hot

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-ATTACHMENT E (Page 2) a.

.-Air J Sample's _

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A Lrelaxation in;the requirement for daily to monthly air. samples is Tjustified on essentially the same basis as that for -surveys mentioned above.. Anple ' evidence indicates that when rx) materials are being

. handled, the likelihood of airborne contamination is very, very small.

i 5. ' Water andisewerage' Sampling We havel collected and evaluated influent (tap) water samples for many

-years. - A large amount of data exists enabling comparison of any week-ly orfmonthly average sample data with past results.

We believe that changes in sewerage sampling and -sample evaluation is

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justified because the HTGR Fuel Fabrication Facility is the only-fa-

' cility which has rest rooms within a radiation control boundary lead-

- ing directly to the sewerage system.

These rest rooms are located within the process area change room.

During the period of shutdown.

the production area change rooms and their restrooms are not expected

'to be'used. As committed elsewhere, most of'the space within produc-

-tion contamination control area will be cleaned to levels acceptable for the elimination of shoe covers and protective clothing require-

.ments..

All other. facilities and laboratories have holdup tanks as needed to contain the radioactive liquids or contaminated wash waters generated by their operation; ' Rest rooms associated with these facilities are generally ~somewhat removed from the operating areas involving radio-active materials. Under the reduced level of fuel production opera-tions, any releases to ie sewarage system will be batch processed

. and very infrequent compared to the roughly weekly release when the facilities are in operation because of sizable amounts of wash water, fume scrubber water, mop water, etc., generated.

2 6.

Alarm Checks and Calibration The criticality alarm can be removed from any analytic instrument and o

survey meter calibration requirements of 4.2.1.

Criticality alarms are. required to respond to specified increases in radiation associa-i.

ted with a criticality event.

They are not required to provide

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analytic intelligence over a wide range of operating levels but l

merely cause a signal when a specified level is exceeded. A sub-stantial number of the ' CWAS detectors and readout systems have builtin check sources which may be operated remotely, causing an in-crease in detector output'which can be used to verify correctness of warning alarm trip levels. We believe that the use of these remotely operated check sources can verify that the system responses and alarm i

levels are' correct and that removing such system components for fre-quent periodic 'calibrationg against MBS traceable standard sources

' unnecessarily detracts from the desired system reliability. We do recognize.the need to calibrate the detectors when they are out of 4

the system for. repair and the need to perform special tests as they I

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ATTACHMENT B (Page 3).

are placed back into the. system. These,te'sts can b'e easily proced-uralized.

Criticality alarm systear "used by GA all have lock Lin fea-=

~tures when detectors output equals or exceeds the specified trip levels and they also remain locked -in nr.til.they are reset.

GA's-systems are.also designed to continte to operate at levels above 10

R/hr unless the ion-chambers or their individual power supplies fail due toLprolonged operation at high current levels. Such -falure is a highly unlikely event.

LE 7.

Wdrk Place Air Changes.

The license-requires that areas where unencapsulated or unsealed ma-9 b

terial is handled, used or stored, shall have a minimum of four air y

changes per hour. During periods of shutdown of HTGR fuel process-ing, all material will be containerized and stored in vaults. Accord-

--ingly, 'the likelihood of material becoming airborne is very, very :

small.

During these periods, we-believe it is unreasonable to main-tain the required four air changes per. hour in the very large proces-sing area. We believe-that maintaining air flow through any open enclosures and maintaining only those ventilation systems necessary

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4 to provide for a flow of air from" the less contaminated areas to the

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more contaminated areas, is ample to assure safety of indivuals who may sporadically frequent the facility on patrols, inspections, etc.

8.

hcl Monitoring The RKrGR process utilizes hydrogen chloride in a fuel rod cleaning operation.

During the period of shutdown there will be no hcl fur-nace operations.

9 Environmental Sanpling We believe that' the changes'in the environmental sampling program are

. justified because of the same direct benefits described earlier in shutdown air sampling,- tap water sampling, and sewerage senpling.

Obviously, if contamination levels within the facility are expected Lto be very;1ow, then the likelihood of any release to the environment from these areas is corresponding reduced. We expect to continue to do the suspended particulate analysis on a semiannual basis. The suspended particulate test will provide an opportunity to maintain information about long term averages throughout the shutdown period.

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Where calculations indicate SNM can be emitted to the site boundary at concentration lewls, averaged over a calendar quarter, which are equal to or greater than at least 10% of the appropriate concentration listed in 10 CFR 20, Appendix B Table II, effluents shall be continuously sampled.

Anytime the air sampling data indicates that a level of 25% of the MPC listed in 10 CFR 20, Appendix P. Table II, has been exceeded on a quarterly basis, an investigation will be conducted and corrective action will be taken as required.

4.1.7.2 Liquid Liquid efflue shall be controlled by storage until determined safe for disposal by solar

. > oration or through a licensed waste disposal agency, or safe for release to the metro sewerage system.

Radioactive discharge to the environment shall be as far below the MPC for unrestricted areas (as defined in 10 CFR Part 20) as reasonably achieve-able and shall not cause any unrestricted area effluent to exceed 100% of MPC.

Continual evaluation of water sampling results shall be used to assess the concentrations and cumulative amount dischcrged. Any time the data indicate that a level of 100% of the MPC may be exceeded on a quarterly basis, an in-vestigation shall be mate to determine the corrective action needed.

l 4.2 EQUIPMENT 4.2.1 Radiation Detection and Survey Instrumentation for detection and measurement of radiation shall be pro-vided.

Instrumentation other than 4.2.1.4 CWAS systems shall be calibrated l

after repair and routinely at least twice annually by use of a source with calibration data traceable to the National Bureau of Standards.

License No.

SNM-696 License Amendment No.

Page II 4-13 5

4/23/85 Released By Revision No.

Date

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4.2.1 3 Radioactive Material Detection and Assay Portable instrumentation shall be available and utilized for detection and assay. This instrumentation includes:

X ray and gamma - Geiger-Muller (GM) detectors, scintillation detectors, scintillation detectors coupled with a portable scaIer for assay of low levels of activity, scintillation detector coupled with a single-channel analyzer, and ion chambers.

Beta - GM detectors and ion chambers.

Alpha - Air proportional and scintillation detectors.

Neutron - mrem or Rem reading neutron monitor.

Fixed instrumentation shall be available and utilized as required for radiological safety purposes. Such instruments shall include counting equip-ment, spectrometers for analysis of samples, calibration sources (s) to cali-brate instruments, and meteorological equipment for measurement of certain meteorological ccnditions.

1 4.2.1.4 Criticality Monitoring and Alarm System The licensee shall maint7tn in each area where SNM is handled, used, or stored a monitoring system,using gamma or neutron-sensitive radiation detec-tors which will energize clearly audible alarm signals if accidental criti-cality occurs. This system shall meet the performance requirements of 10 CFR 70.24(a).

Each system shall be tested monthly using internal check sources or portable sources.

License No.

SNM-696 License Amendment No.

Page Revision No. 5 Date 4/23/85 Released By Il 4-16