ML20128G792

General Atomics Site Decommissioning Plan

ML20128G792
Person / Time
Site:	07000734
Issue date:	09/30/1996
From:	GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:
Shared Package
ML20128G784	List: ML20128G779 ML20128G792
References
NUDOCS 9610090131
Download: ML20128G792 (126)

Text

{{#Wiki_filter:_ lO GENERAL ATOMICS' SITE DECOMMISSIONING PLAN SFsPTEMBER 1996 O 1 O sea %8s!A 39888 6 B PDR

i TABLE OF CONTENTS 4 i TABLE OF CONTENTS ii LIST OF TABLES iv LIST OF FIGURES. iv j INTRODUCTION. 1

SUMMARY

S-1 1. GENERAL INFORMATION AND

SUMMARY

OF D&D EXPERIENCE 1-1 1.1 Licensee Name and Address... 1-1 1.2 Licensee Information. 1-1 2.

SUMMARY

OF D&D EXPERIENCE . 2-1 3. SITE DESCRIPTION 3-1 3.1 Location and Size 3-1 3.2 Topography. 3-1 3.3 GA Facilities.. 3-2 3.3.1 GA's Sorrento Electronics Site.... 3-2 3.3.2 Room 049 of Building 9.... 3-2 3.3.3 Building 10..... . 3-3 3.3.4 TRIGA Reactors Building (Building 21) 3-3 3.3.5 TRIGA Fuel Fabrication Facility (Building 22) 3-3 3.3.6 Hot Cell Facility (Building 23) 3-3 3.3.7 Low-Level Liquid Filtration Facility (Building 25) 3-4 3.3.8 Nuclear Waste Processing Facility (Building 41) 3-4 3.3.9 Experimental Area (Building 27). 3-4 l 3.3.10 Experimental Area Bunker (Building 27-1). 3-4 3.3.11 Linac Facility (Building 30).. . 3-4 3.3.12 NMA Storage " Vault" (Building 31) 3-5 3.3.13 Inertial Confinement Fusion (Building 33). 3-5 3.3.14 Building 33-1 (Former HP Lab). 3-5 3.3.15 Fusion Building (Building 34).... . 3-5 3.3.16 Test Tower (Building 35) 3-5 3.3.17 Sorrento Valley A (Building 37) 3-6 3.3.18 Fuel Production Process Building - Sorrento Valley B (Building 39) 3-6 3.3.19 Calibration Facility (Building 42) 3-6 3.3.20 Science Laboratories (Building 2). 3-7 3.3.21 Underground Storage Tanks -Buildings 9, 31, 21 & Lab 540 of Bldg. 2 3-8 4. DECOMMISSIONING ORGANIZATION, TRAINING AND METHODS USED FOR PROTECTION OF OCCUPATIONAL AND PUBLIC HEALTH AND SAFETY 4-1 4.1 Decommissioning Organization and Responsibilities 4-1 4.2 Description of Overall Organizational Structure. . 4-1 4.3 Decommissioning Safety Responsibilities 4-1 4.3.1 Industrial Safety / Hygiene 4-1 4.3.2 Radiological Safety.. 4-2 4.4 Training . 4-2 4.4.1 Radiological Safety / Retraining 4-2 4.4.2 Equipment Operator Training 4-3 4.4.3 Safety / Accident Prevention Training 4-3 j il

l l 4.4.4 Hazardous Material Training. 4-4 j 4.4.5 Other Training... 4-5 4.5 Procedures..... . 4-5 1 4.6 Schedule...................... 4-5 4.7 Methods Used for Protection of Occupational and Public Health and Safety... . 4-5 4.7.1 ALARA Program...... . 4-5 4.7.2 Management Positions Responsible for Radiation Protection and Maintaining l Exposures............. 4-6 4.7.3 Methods for Occupational Exposure Reduction......... 4-6 4.7.3.1 Work Authorization Approval 4-6 4.7.3.2 Radiation Work Permits............ . 4-7 j 4.7.4 Control and Storage af Radioactive Materials . 4-7 4.8 Health Physics Program................ 4-7 i 4.8.1 Project Health Physics Program - General. 4-7 4.8.2 Audits, Inspections, and Management Review.... 4-8 4.8.3 Health Physics Equipment and Instrumentation....... 4-9 4.8.3.1 Criteria for Selection and Instrumentation for Conduct of Radiation and Contamination Surveys and Personnel Monitoring 4-9 4.8.3.2 Storage, Calibration, Testing and Maintenance of Health Physics Equipment and Instrumentation 4.8.3.3 Specific Health Physics Equipment and Instrumentation, Use and.. 4 Capabilities...... . 4-10 j 4.9 Processes & Systems for Handling, Storage, & Disposing of Radioactive Waste.. 4-10 i 4.9.1 Conformance to Requirements of 10CFR61,10CFR71, & 10CFR20,2006... 4-11 4.9.2 Conformance to Disposal Site' Requirements 4-12 - O 4.9.3 Conformance to State Requirements....... 4-12 D 4.9.4 Waste Characterization Projections and Volumes 4-12 5. ANTICIPATED APPROACHES TO DECONTAMINATION AND DECOMMISSIONING. 5-1 5.1 APPROACH A....... 5-2 5.2 APPROACH B.............. . 5-4 5.3 APPROACH C................... 5-14 6. FINAL SURVEY.... 6-1 j 6.1 Release Criteria for Items, Equipment and Facility....................... 6-1 6.1.1 Release of Items and Equipment 6-1 6.1.2 Release of a Facility.. 6-2 ) 6.1.3 Description of Final Radiation Survey Plan........ 6-2 6.1.4 Classification of Areas by Contamination Potential 6-4 6.1.4.1 Scoping or Confirmatory Survey....... 6-4 6.1.4.2 Affected Area Surveys........... 6-4 6.1.4.3 Unaffected Area Surveys.. 6-6 6.2 Soil Sampling Plan 6-6 6.2.1 Release Criteria... 6-7 6.2.2 Soil Background Concentrations 6-7 6.2.3 Affected Areas - Open Land Areas 6-8 6.2.4 Unaffected Areas - Open Land Areas. 6-11 6.2.5 Sample Collection...... 6-11 6.2.6 Direct Radiation Measurements........ 6-11 iii

6.3 Methods to be Employed for Reviewing, Analyzing, and Auditing Data....... 6-11 O 6.3.1 Laboratory / Radiological Measurements Quality Assurance.... 6-11 6.3.2 Supervisory and Management Review of Results 6-11 6.4 Final Survey Report . 6-12 7. FUNDING . 7-1 8. PHYSICAL SECURITY PLAN AND SPECIAL NUCLEAR MATERIAL ACCOUNTABILITY.. 8-1 i TABLES Table S-1 GA Sites to be Decommissioned .......... S-2 Table 3-1 Status of tabs in Building 2................ .... 3-9 Table 4-1 Typical List of Instruments Used During D&D Projects..... 4-14 Table 6-1 Acceptable Surface Contamination Levels...... .. 6-3 Table 6-2 Soil and Concrete / Asphalt Rubble Release Criteria. 6-10 LIST OFFIGURES(notpaged) Figure 3-1 Main Site and Sorrento Valley Site Figure 3-2 Sorrento Electronics Site Figure 3-3 Sorrento Electronics Manufacturing and Supporting laboratories and offices Figure 3-4 Building 9 " Hot Suite" Figure 3-5 Building 10 Figure 3-6 TRIGA Reactors Building 21 Figure 3 7 TRIGA Fuel Fabrication Facility Building 22 O Figure 3-8 Hot Cell Figure 3-9 Low-Level Filtration Facility Building 25 Figure 3-10 Nuclear Waste Processing Facility Building 41 Figure 3-11 Experimental Area (EA) Building 27 Figure 3-12 Experimental Area -1 " Bunker" Building 27-1 Figure 3-13 Relationship between Building 27-1,27,21,23 and 22 Figure 3-14 Building 30/31 Complex Figure 3-15 Building 31 Room 103 NMA Storage Figure 3-16 Inertial Confinement Fusion Building 33 Figure 3-17 Building 33-1 Former HP LAB Figure 3-18 Fusion Site Building 34 Figure 3-19 Test Tower Building 35 Figure 3-20 Sorrento Valley A Building 37 Figure 3-21 Sorrento Valley B Building 39 Figure 3-22 Calibration Laboratory Building 42 Figure 3-23 Science Laboratory Building 2 Figure 3-24 Laboratory B Section Building 2 Figure 3-25 Laboratory C Section Building 2 Figure 3-26 Laboratory A Section Building 2 Figure 4-1 Decommissioning Organization iv

SUMMARY

O A summary of the GA sites to be decommissioned is provided in Table S-1, which provides a short description of each facility, the type of activity conducted, the radioactive material used, the status and current activity, the current regulatory jurisdiction (NRC and/or State of CA), whether jurisdiction could be transferred to State only, whether ground contamination is suspected, the anticipated D&D effort and approach to be used, and the final survey anticipated to be required. Additional information on each facility / site listed in Table S-1 is provided in Chapter 3. Detailed information on each approach anticipated for the facilities / sites in Table S-1 is provided in Chapter 5. Detailed information on the I %al Survey anticipated to be required is provided in Chapter 6. The information provided in this General Decommissioning Plan meets the requirements of 10CFR70.38. i O S-1

o o o TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of September 25,1996)~ Building Name/ Type of Radioactive Status and Regulatory Ground Anticipated No. Description Activity Material Current Activity Jurisdiction (50il) C'* "i"i*" Used D&D Effort Final Survey N and Approach Required Sorrento Leased Manufacture of Byproduct In operation State ?.o No D&D of facility is expected Unaffected Electronics facility in radiation Area Survey Mira Mesa monitoring Removal of Sources needed assuming no j instrumentation contaminatien Approach A is round, i t Room (ata "E" or TRIGA Fuel SNM No Rad NRC None Moderate D&D Affected 049 in experimental Fabrication Usage /Telecon expected Area Survey I Bldg 9 Building) prior to 1976 Equipment Storage Approach B Only All of Bldg 9 released except room 049 10 IIP Lab Calibration of Byproduct, In use. State No No D&D of facility expected. Affected (1/97) radiation sealed IIcalth Physics Area Survey Previously detection sources Laboratory (as of Remove sources and CalLab equipment and ~12/96) equipment including hood and IIP laboratory ducts Approach B 21 TRIGA Non-power All Mark I reactor NRC To be Major D&D Affected Reactor Reactors; license active and State Determined Area Survey Facility R&D Approach C and Soil Cleanup Mark F reactor Soil Criteria disabled /POLA S-2

O O O TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of September 25,1996) Building Name/ Type of Radioactive Status and Regulatory Ground Anticipated No. Description Activity Material Current Activity Jurisdiction (50ill C*"'* "i"* 'i*" Used D&D Elfort Final Survey and Approach "I Required 22 TRIGA Fuel TRIGA Fuel Predominantly Operations ceased. NRC Yes Major D&D Affected Fabrication Manufacturing SNM Area Survey Facility Some All equipment Approach C and Soil Cleanup Depleted removed, ready for uranium D&D Soil Criteria 23 llot Cell R&D All Currently in D&D. State & Yes in accordance with NRC and State of CA and PIE NRC approved D&D Plan (Refs. NRC SNM-696 Expected to be license amendment #35 dated 5/1/96 and State completed by of CA Radioactive Material License 0145-80 1999. amendment # 123 dakd 7/5/96) 25 Liquid Treat liquid All in Use. Yes Moderate D&D expected and Affected Waste LLW for possible Soil Remediation Area Survey Treatment Discharge to and Soil Facility sewer Approach C Criteria 41 Nuclear Nuclear Waste All In Use. State & Yes Major D&D expected and Soil Affected W aste (LLW) NRC/ Remediation Area Survey Processing Processing.

Baling, To be and Soit Facility compacting, transferred Approach C Criteria (NWPF) solidification, &

to State only drying repackaging 27 EA Radiochemistry All inactive State & Possibly Moderate D&D expected and Affected (Experimental and Chemistry NRC/ possible Soil Remediation Area Survey ^)' Labs Shut-down 9/96 To be (possibly Soil transferred Approach B Criteria) to State only S-3

/ O O O TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of September 25,1996) Building Name/ Type of Radioactive Status and Regulatory Ground Anticipated No. Description Activity Material Current Activity Jurisdiction (50il) C*"'*"i"*" Used D&D Efrort Final Survey N f and Approach Required 27-1 EA-1 R&D All inactive State & Possibly hloderate D&D expected and Affected Bunker associated with NRC/ possible Soil Remediation Area Survey Facility radiochemistry Equipment To be (possibly Soil Removed. Ready for transferred Approach C Criteria) D&D. to State only Room Linac Irradiated Fuel All In Use. NRC/ No No D&D of facility anticipated Unaffected 118 of Facility Storage in State, after Area Survey Building Casks Storage Only, the removal Confirmatory Survey Needed ifno 30 offuel contamination (SNM) Approach A is found. Bldg. Linac Activation Activation Not in Use. State No Confirmatory Survey Required Affected 30 Building Products Products Operations ceased. Area Survey (except Approach'A room i18) Room Nuc! car Radioactive All in use. State and No Minor D&D,if needed Affected 103 of material Material NRC Area Survey ^'

• Y Storage Storage, sampling, State, after Approach B Bldg. 31 and combmmg.

removal of SNM 33 ICF Fusion Radiation tritum in Use. State No Remove sources. No D&D of Unaffected Machines and facilities expected. Area Survey sealed tritium source Approach A S-4 P b

L O O O ~ TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of September 25,1996). Building Name/ Type of Radioactive Status and Regulatory Ground Anticipated No. Description Activity Material Current Activity Jurisdiction (soil) C'" "i"i"" Used D&D Effort Final Survey N and Approach Required 33-1 Fonner llP Samples All Inactive State No No D&D of facility was Unaffected Lab containing needed (survey performed after Area Survey small quantities (SNM in lab move ofIIP Lab; no ifno ofradioactive under State contamination detected). contamination material license) is found. Approach A f i 34 DIII-D Fusion Short-lived In use. State No No D&D of facility expected. UnalTected Research Activation Remove sources and activated Area Survey l Products and equipment. l Tritium Afrected l Approach A Area Survey in Dill-D pit 35 Test Tower Testing and Mixed fission Operations ceased. State No Scoping Survey needed. No Unaffected maintenance of and contamination expected. Area Survey 1 contaminated activation ifno helium products Approach A contamination circulators is found. (1) SVA-S uth Temporary All No rad material State & No Scoping survey needed. UnafTected 37 storage of usage. NRC/ Area Survey be Approach A ifno (Formerly Nonh Only non-rad transferred contamination the South D&D activities in to State only is found. l end of building. Building Scaled sources 37) for calibration of TRIGA monitoring / l control equipment l l t S-5

O O O TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of September 25,1996) Building Name/ Type of Radioactive Status and Regulatory Ground Anticipated No. Description Activity Material Current Activity Jurisdiction (50i1) C*" "i"* d "" Used D&D Effort Final survey UI and Approach Required 39 SVB/ Pilot Pilot Plant - SNM Operations ceased. State and Yes Major D&D Affected Plant Fuel Depleted U NRC Area Survey Development Thorium Equipment Approach C (possibly Soil and Soil R&D Removal and Remediation) Criteria Characterization in progress. 42 Calibration Previously the Cs-137 in operation. State No Remove all sources Afrected Facility; ladustrial Sealed Area Survey previously Radiography Source, cal Calibration of Approach A Radiography b'dg; now standards Instruments illdg. calibration facility. t 2t2) Science R&D, Testing, Variable inactive except for State and/or None Lab Specific Lab Specific Laboratory Experimental HP lab which is NRC/ expected Building being moved to Bldg.10. Lab Specific / (a.k.a. "L" or 1021 abs have been Laboratories released. 36 labs To be r Bldg.) to be released.tz) transferred to State only i s S-6

O O O TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of September 25,1996) Building Name/ Type of Radioactive Status and Regulatory Ground Anticipated No. Description Activity Material Current Activity Jurisdiction (50ill C**'*"i"**'*" Used D&D Effort Final survey and Approach (U Required Bldg 2 Service Services All Inactive State and/or To date,2 To be Determined Affected Service Core and provided to NRC/ drain lines and Area Survey Core Drain lines labs plus drain All known one area or for Selected C "C'C'C lines from radioactively To be Areas contaminated ducts transferred some of the in the labs. to State only Rest of core ther Unaffected other accessible known ducts were surveyed contamination. Area and no contamination found or removed as radioactive waste. Building 2 lab 307 Temporary Tank State and Soil was D&D effort including soil remediation Underground Storage storage of removed and NRC remediated in completed 11/94. See Report to NRC dated Tank radioactively so 1 1984. I1/30/94 (letter 696-6083). C ntaminated remediated in y",j. h. P" I984-A'.ea n t decontaminated to Option i Release 37 C Criteria Sr.90 Under. Bldg 9 Tank Temporary Various Tanks Removed in State and No GA report dated 2/11/85 shows soil ground Bldg 31 Tank storage of 1984 W NRC concentrations below the Option I release B!da 21 Tank radioactively criteria. Soil Samples Obtained by the NRC Storage Tanks ) bid 2 8 contaminated during removal of the tanks. 5 hquids. Formal Release Not Yet Obtained. S-7

O O O TABLE S-1: General Atomics' Facilities and Sites to'Be Decommissioned (Status as of September 25,1996) Building Name/ Type of Radioactive Status and Regulatory Ground Anticipated No. Description Activity Material Current Activity Jurisdiction (Sail) C*" "i" * 'i*" Used D&D EtTort Final survey UI and Approach Required W The north end of Building 37 (llTGR Fuel Fab Facility) was released in 1995 and the north end of the building dismantled (no longer exists). W Bu!Iding 2 Summary: Total of 142 labs; of these 33 labs Have Not Yet Been Released to Unrestricted Use and 109 labs have been released to unrestricted use in Groups I through 8C (Groups 8B and 8C release anticipated in 1996 and included in total number oflabs released. Labs notyet released are as follows: Laboratory B Section: Labs 202,204,206,208/210,216,218,238/240 and 242 (10 labs) Laboratory C Section: Labs 325 (mezzanine released), 401,403,405,407,409/411 and mezzanine,413 and mezzanine,415 and mezzanine),441,443/445 and mezzanine (12 labs) Laboratory A Section: Labs 511,513,517,605,607,615,617,619/ 621 and mezzanine,623 and 645 (11 labs). (3) The underground storage tanks were removed in 1984. A report dated 2/11/85 provides the results of soil samples collected in each area where tanks were removed. Official release to unrestricted use from the NRC and the State of CA has not been obtained (as of 9/25/96). ") Summary of Approaches: Approach A: Removal of radioactive material sources Only. No contamination expected or likely. Confirmatory or Scoping Survey needed. If no contamination is found, no further action is needed. Approach B: Minor facility cleanup required including scabbling a small area of concrete. Approach C: Major cleanup required including aggressive D&D oflarge areas. Facility contamination is widespread. S-8

I INTRODUCTION l O General Atomics (GA), at its San Diego sites, has been engaged for over 35 years in both government and privately-sponsored research and development operations involving the use of radioactive material. GA carried out various activities which were/are licensed by the Nuclear Regulatory Commission and/or the State of California, an agreement state. These activities can generally be described as: (1) broad nuclear research, (2) reactor fuel fabrication and (3) operation of two TRIGA research reactors. The nuclear research and fuel development and fuel fabrication activities involving SNM were licensed under SNM-696, Docket 70-734, until September 30,1995 when GA permanently ceased principal activities authorized by SNM-696 pursuant to GA's request for Possession Only License Amendment 8 (POLA). Only storage of SNM and activities incidental to D&D of facilities are currently autliorized j under this license. The activities involving the use of byproduct and source material are licensed under State of California Radioactive Materials License 0145-80. Various activities are currently being conducted under this license including GA's inertial Confinement Fusion program, Sorrento Electronic's use of sources for calibration of nuclear instrumentation, and other research and development activities. The two TRIGA research reactors, the Mark I and Mark F, are NRC licensed (R-38, Docket 50-89 and R-67, Docket 50-163, respectively). The reactors are licensed under 10CFR50. O This decommissioning plan has been developed in response to the " timeliness" rule discussed in 10CFR70.38. This plan contains the following: a description of each facility and site to be decommissioned, or transferred exclusively to GA's State license; the current status of each facility or site; a description of planned decommissioning activities; a description of methods used to ensure protection of workers and the environment against radiation hazards during decommissioning;

• a description of the planned final radiation survey;
• an updated detailed cost estimate for decommissioning; and a description of the physical security plan and material control and accounting plan provisions in place during decommissioning.

' Asmussen, Keith E. Letter No. 696-2462 to Carl J. Paperillo " Request for Possession Only License Amendment and Permanent Cessation of Principal Activities", dated Septernber 26,1995. I

____.m., 4 4

1. GENERALINFORMATION l

4 o .1 LicenseeNameandAddress 1 i Licensee Name: General Atomics { Licensee Address: Attn: Dr. Keith E. Asmussen, Director Licensing, Safety and Nuclear Compliance PO Box 85608 San Diego, California 92186-9784 l.2 Licenseinformation i NRC Snecial Nucicy Material License: SNM-696, Docket 70 734 4 State of California Radioactive Material License: 0145-80 Location: General Atomics' main site is located at 3550 General Atomics Court (formerly 10955 John Jay Hopkins Drive), San Diego, Califomia 92121-1194. General Atomics'sorrento valley site is located at 11222 Flintkote Avenue, San Diego, California 92121-1215. General Atomics' Sorrento Electronics' site is located at 10240 Flanders Court, San Diego, California 92121 I j 1 i l l-l j

- - _ - =. i

2. SUMMA R Y OF GA 'S DECONTAMINA TION / DECOMMISSIONING EXPERIENCE Since 1984, General Atomics (GA) has been involved in D&D projects at GA facilities. On 4

l October 1,19852, GA submitted to NRC a revised version ofits 1984 project-specific decommis-i sioning plan. The plan included release criteria for soil as well as items and equipment. This j plan was approved by the NRC on November 26,19853 GA also obtained approval of several l other decommissioning plans (from both the NRC and the State of California) since 1985, including a plan to release 215 acres ofland surrounding the current GA facilities, the SVA Decommissioning Plan and the GA Hot Cell Facility Decommissioning Plan (interim approval). Af ter approval of these plans, GA has completed the following projects: o Decontamination / decommissioning of a 25 year old Nuclear Waste Processing Facility. Completed in two phases; 1984-1988. Phase I included the decontamination of all Nuclear Waste Processing Areas with the exception of asphalt covered land areas used to 3 temporarily store 85,000 ft of contaminated soil until it could be shipped to an authorized disposal site. Phase II was the survey of the asphalt after all soil was shipped ofTsite. This project included the following: Decommissioning of Solar Evaporation Ponds i Survey and decontamination of a former Radioactive Waste Incinerator Site Decommissioning and decontamination of the entire Nuclear Waste Processing i Facility (to process, package and solidify wastes) l Survey of all storage yards Removal of high level chielded storage facilities and underground storage wells 12 feet deep i Survey and soil terr..ation of the hillside and canyon area below the waste l handling areas { Survey of undeveloped land } Analysis of samples (air, wipe, soil, concrete, etc.) for contaminants including l longer lived mixed fission and mixed activation products, thorium, depleted uranium and enriched uranium. i J i I 2Asmussen, K.E. to W.T. Crow, Docket 70-734: " Plan for Obtaining Release of Certain Areas to Unrestricted Use," letter dated October 1,1985,696-8023. 3Crow, W.T to K.E. Asmussen," Evaluation of GA's Proposed Decontaminstion Plan," letter dated 2 J November 26,1985, Docket No. 70-734. j 2-1 4

i Removal and disposal of approximately 85,000 ft of contaminated soil 2 O o Release of 215 acres of undeveloped land. No contamination was present. 1987-1988. ) o Release of Area B1 - 15 acres of steep, rough hillside land located generally west and . north of GA's TRIGA Reactor Facility and behind the Hot Cell and other Nuclear Facilities on GA's Main Site. ~1988 o Release of Area B2 - Small sewage pump station on GA's Main Site. Sludge was contaminated with Cs-137 and a small area of the concrete holding tank needed to be decontaminated, o Release of Area B3 - About 3 acres of an abandoned city sewage treatment facility (also known as "Calle Ponds") including the removal of digestors and approximately 10,000 2 ft of contamin* :d soil from evaporation ponds (enriched uranium contamination). 1987-1988. o Beginning around 1987, GA began to survey labs in building 2 for release to unrestricted use. A total of eight groups oflabs (each containing between 9-25 labs) have been O reieesed te enrestricted eee frem -1987 te eresent <the reieese ef Greegs 8B and 8C are anticipated by November 1996); for a total of 109 laboratories released to unrestricted use. Thirty-three (33) laboratories have not yet been released. o ECF (Experimental Critical Facility)- Building 31-2. Enriched uranium contamination j was found on the concrete surface and in the soil beneath the concrete surface. ~1991 i ) o Building 9 (Experimental Building) Process Area. 1986-1987 Thorium and depleted uranium was used in a portion of the building for HTGR fuel treatment methodology studies and demonstrations from 1971-1985, however, no enriched or irradiated nuclear fuel was used. Thorium and depleted uranium were used as well as short-lived radioactive tracers, i.e.,1-131 and Zr-95. o Building 9 (Experimental Building) Former TRIGA Fuel Fabrication Area. TRIGA Fuel Fabrication Facility activities were conducted in the southwest portion 2-2

l of the Building 9 until operations were moved to a new building (Building 22) (] around 1975. The area was decontaminated in 1975, but not officially released to unrestricted use. Stage 1 and 2 were decontaminated in 1989-1990 and have been released to unrestricted use. Stage 3, comprised of one room containing telecommunications equipment, has not been officially released; the original floor which may be potentially contaminated is located about 8" below the cur ~ ' raised wooden floor on which G A's telecommunications equipment is located. o Leased facilities in Sorrento Valley (Sorrento Valley Court and Sorrento Valley Blvd) previously used by Sorrento Electronics. Obtained State of California Release to Unrestricted Use.1987. o HTGR Fuel Manufacturing Facility (SVA Facility) 1990-1995 The facility was used for the manufacture of HTGR fuel for the Ft. St. Vrain HTGR reactor using high enriched uranium (93% U-235) and thorium. Process utilized " dry mix" kemel formation, pyrocarbon and silicon carbide coating, compact fabrication, assembly, uranium recovery using solvent extraction h, and quality control laboratory. NRC Category I security requirements. Phase I activities October 1990 - February 1993 included the removal of equipment and decontamination of the facility (~45,000 ft area). 2 Phase II activities May 1993 - August 1995 included the dismantlement of the building, removal of all underground drain lines, soil remediation and completion of the final survey conducted according to an NRC and State of California approved Soil Sampling Plan. A total of 2378 soil samples were collected during characterization and post-remediation of the site. A total of 587 final systematic samples were collected including soil samples taken on a 5 m triangular grid, every 5 feet in trenches, plus subsurface soil samples. l 2-3

3. SITE DESCRIPTION 3.1. LOCATION AND SIZE General Atomics' facilities in San Diego are located on two contiguous sites (shown in Figure 3-1);

these are the Main Site and the Sorrento Valley Site. The Main Site is located at 3350 General Atomics Court, approximately 13 miles north of downtown San Diego. This site occupies approximately 60 acres. The Sorrento Valley Site is located just north (about 0.1 mile) of the main site. The Sorrento Valley Site has two entrances, one at 11220 Flintkote Avenue and the other at 3483 Dunhill Street. This site also occupies about 60 acres. General Atomics also leases facilities located at 10240 and 10247 Flanders Court for its Sorrento Electronics operations. This facility is located about six (6) miles from GA's main site. 3.2. TOPOGRAPHY GA's Main Site is on Torrey Pines Mesa about I mile east of the ocean at an elevation o:300 h above sea level. GA's Sorrento Valley Site is in the adjacent Sorrento Valley at an elevation of between 50 and. _ it above sea level. The mesa runs in a northerly direction paralleling the coast and rising to a height of 400 ft above sea level between the site and the ocean. Sorrento Valley runs in a northwest direction from the east side of the main site to the ocean, intersecting the ocean at the northern end of the mesa. Sorrento Valley is about 5000 ft wide at its mouth and narrows to 1000 ft at its southern end. The valley intersects Los Penasquitos Canyon east of the main site. No Inappable faults exist within the property limits. The fault nearest the property is the Rose Canyon fault, which is five miles distance at its closest approach. Geological evidence indicates that there has been no suiface displacement on the fault since early Pleistocene times, before deposition of the terrace deposits which cover much of Torrey Pines Mesa; epicenters have been located along the fault trace, however The second nearest fault on land is the Elsinore fault which lies 40 miles from the site. All buildings which contain radioactive material are designed to meet the seismic criteria specified in the Uniform Building Code (UBC) in effect at the time the buildings were constructed. The seismic parameter "C" (later designated "ZKC") used by the analyst were in accordance with the UBC in effect at the time and were dependent upon the particular type of structural component being analyzed. The 4 magnitude of these parameters are still consistent with and meet the requirements of the UBC 1973 Edition. O(v 3-1

3.3 GA FACILITIES A summary of each facility on the GA site is provided below in the same order as that provided in Table S-l. Table S-1 provides a current listing of all General Atomics' facilities and sites to be decommissioned including the building number, the name/ description of the area, the type of activity conducted and radioactive material used, the current status and activity, the regulatoryjurisdiction, whether ground contamination is expected and the anticipated D&D effort and approach (including the type of fmal survey required). 3.3.1 GA's Sorrento Electronics Site GA leases a facility located at 10240 Flanders Court about six (6) miles from GA's Main Site for its afHliated company, Sorrento Electronics, as shown in Figure 3-2. The facility (Figure 3-3) is primarily for electronic manufacturing with supporting offices and laboratories. Sorrento Electronic's products and services are used primarily in utility power plant instrumentation and control systems. They also include radiation detection and monitoring systems, and data acquisition and display systems. Sealed sources are utilized in authorized areas which are identified and posted in accordance with the State of California regulations. Unsealed sources such as liquid solutions and gas are used in an enclosed g controlled access area provided with a hood, high-efficiency filter, etc., to assure the proper control of air V or surface contamination. Sealed sources are also used at this location. All radioactive material is licensed by the State of California. All activities involving the possession, use, processing or transfer of radioactive materials at Sorrento Electronics are conducted under a Work Authorization (WA) or Radiological Work Permit (RWP). 3.3.2 Room 049 of Building 9 This room was one of several rooms in the northeast portion of Building 9 (a.k.a. "E" or Experimental Building) which housed the TRIGA Fuel Fabrication Facility until 1976. At the time, this area was called the " Hot Suite" Area (see Figure 3-4). Rooms included in Stages 1 and 2 have been released to unrestricted use and only room 049 (Stage 3) remains to be surveyed and released. The location of this room in the northeast portion of Building 9 is shown in Figure 3-4. Room 049 of Building 9 currently houses GA's telecommunications equipment and has not been officially released. The original Door which may be slightly contaminated is located about 8" below the current raised wooden floor. AU 3-2

3.3.3 Buildinc 10 0 This building (Figure 3-5) formerly housed the nuclear calibration laboratory. Only sealed sources for calibration of instruments were used in this facility. The Health Physics laboratory will be moved to this building around December,1996. The building currently houses the Helgeson "Do-It-Yourself" total body counter. 2 3.3.4 TRIGA Reactors Buildine (Blde. No. 21) (6730 ft ) Located north of the Laboratory Building, the TRIGA Reactors Building (Figure 3-6) provides an area for diversified experimental and irradiation studies using the inherently-safe TRIGA Mark I and Mark F, reactor facilities. Included within the building are associated reactor control consoles, a low-level counting room, a small shop, a neutron beam tube room, x-ray room and administrative offices. Specific uses of radioactive material in this area generally are governed by the terms of Utilization Facility Licenses R-38 and R-67; however, radioactive material that is not involved with the direct operation or control of the reactors is under GA's State of California radioactive materials license. Two fenced storage areas are located outside of the building. The Mark F TRIGA reactor has been i disabled and has a possession only license amendment. l 3.3.5 TRIGA Fuel Fabrication Buildine (Blde. No. 22) (7500 ft ), 2 The TRIGA fuel fabrication building (Figure 3-7), approximately 60 ft x 125 ft, is constructed of reinforced concrete prefabricated panels of about 7-1/2 in. thick for the walls. The roof is prestressed concrete approximately 4 in. thick. The Building contains storage vaults, a drum storage area, operations associated offices, lockers and restrooms, as well as the fuel fabrication areas. The building has, on the north end, a pad providing outside space for a bottled gas farm, liquid nitrogen storage tank, air-conditioning units, high-efficiency air filter plenums and blowers, etc., which require routine servicing by persons not needed in the fuel fabrication areas. The building is divided into a northern portion and a southern portion by the vault, walls, and 3/8-inch thick steel plating. The northern portion was used for TRIGA fuel fabrication related activities until September 30,1995, when GA ceased its prncipal NRC licensed activies and requested a possession only license amendment. The southern portion of the building is used for non-TRIGA, non-radioactive material related activities, such as storage. 2 3 1.6 Hot Cell Facility: (Blde. No. 23) (6950 ft ), i The Hot Cell t'ccility (Figure 3-8) is currently being decommissioned under an NRC and State of California approve 3 Decommissioning Plan (Refs: NRC SNM-696 license amendment #35 dated 5/1/96 3-3

l and State of CA Radioactive Materials License 0145-80 amendment #123 dated 7/5/96). O 3,3.7 Low-Level Liould Filtration Facility (Bldg. No. 25)(600 ft ), 2 The low-level liquid filtration facility (Figure 3-9) is located about 300 ft southwest of the TRIGA reactors facility. It is approximately 30 ft x 20 ft. This building houses a system for filtering liquids { containing low levels of radioactive contamination. After filtering, the liquid is sampled and analyzed. If the concentrations of contaminants are below applicable fe&ral, state and local regulatory limits, the liquid is disposed of into the sanitary sewerage system. If the concentrations do not meet the criteria for disposal into the sanitary sewerage system, the liquids are solidified and packaged for shipment to an authorized offsite disposal facility, j 3.3.8 Nuclear Waste Processing Facility (NWPF)(Bldg. No. 41) (14.364 ft ), 2 The Nuclear Waste Processing Facility (NWPF) is located on the Sorrento Valley Site just south of Building SVA-South (Building 37). The facility (Figure 3-10) consists of a main processing and compacting area (Building 41) and various storage areas. East of the building, at a grade level -15 ft lower than Building 41, is a service and storage yard used for processing and packaging low-level waste. Access to the facility is limited to authorized personnel. Northwest of Building 41 is a 7,000 ft 2 fenced area containing a concrete shielded storage facility. Access to this area is also limited to authorized personnel. 3.3.9 Exoerimental Area (Bldg. No. 27) (4600 ft ) 2 The Experimental Area (EA) building (Figure 3-11) consists of radiochemistry and analytical chemistry laboratories and offices. The laboratories were used for general laboratory activities, including activities related to the TRIGA reactors and Hot Cell decommissioning operations. Operations in these labs ceased September 1996. 3.3.10 Exnerimental Area -l " Bunker (Bldg. No. 27-1) (1600 ft ) 2 Located nearby the Building 27 is a partially underground bunker (Figure 3-12) which housed a high-level chemistry lab and associated underground storage wells. The bunker facility also housed a Y-90 production facility until 1994 when the mini hot cells containing several hundred curies of Sr-90/Y-90 were removed and disposed of as radioactive waste. Figure 3-13 shows the relationship between Building 27-1,27,21,23 and 22, 3.3.11 Building 30 - Linac Facility l q l C 3-4 l

l l l l The Linac Facility (Building 30/31 complex) previously housed a 100 meV linear accelerator and most recently housed a 14 MeV linear accelerator. Only room 118 is currently being used for licensed activities. It is being used for the storage of radioactive materials; two (2) casks containing irradiated fuel are stored here. Radiation levels on the outside of the casks are < 2 mR/hr. The Building 30/31 complex (including room i18 of Building 30) is shown in Figure 3-14. 3.3.12 Building 31 - NMA Storage " Vault"- S-1 Building 31 is located in the Building 30/31 complex shown in Figure 3-14. The Nuclear Material Accountability (NMA) vault-like storage area (a.k.a. " vault") is located in room 103 of Building 31 shown in Figure 3-14. Room 103 is also shown in Figure 3-15. 3.3.13 Buildine 33-Inertial Confmement Fusion The Inertial Confmement Fusion project currently occupies Building 33 (Figure 3-16). Currently, only radiation machines and sealed tritium sources are used in this facility (under the jurisdiction at the State of California). 3.3.14 Building 33-1 Former HP Lab p Rooms 108 and 109 of Building 33-1 (Figure 3-17) was occupied by Health Physics (HP laboratory) d until 1991. A survey completed in 1991, after moving the lab from this facility, showed no contamination of the facility. 3.3.15 Fusion Building (Bldg. No. 34). The Fusion Site (Figure 3-18) is divided into a building housing an experimental fusion machine (Building 34) and a laboratories annex (Buildings 34-1, 34-2,34-3 and 34-4). The fusion building is designed for large-scale experimental apparatus used in the study of controlled thermonuclear reactions. In the fusion program, a variety of experiments are conducted that involve high-temperature plasmas. Only ion accelerators and sealed sources are used in the facility. The Dill-D machine is registered with the State of California as a radiation machine (along with each type of accelerator). Activation of the machine itself occurs during operation and tritium is also produced. THrefore, at the time of deconunissioning, it is expected that the " pit" area (which houses the DIII-D device) would be surveyed as the "affected area" of the facility with the rest of the site being an unaffected area; in some areas, no survey will be required. 3.7.16 Buildine 35 (Test Tower Buildine)(6.426 ft 3 2 i I U 3-5

Building 35, the Test Tower Building is shown in Figure 3-19. The test tower was used in the 1970's (T and early 1980's to occasionally house helium circulators returned to GA for repair from the Ft. St. Vrain Nuclear Generating Station in Colorado. These activities were conducted under GA's California radioactive materials license. There is no known contamination of the facility but a detailed " scoping" survey is needed to confirm this. 3.7.17 Sorrento Vallev A Buildine (SVAb Building Bldg. No. 37 ( ~ 50.000 ft ), 2 Building 37 is located at i1220 Flintkote Avenue at GA's Sorrento Valley Site (Figure 3-20). The fuel manufacturing area was previously located in the northern half of the building but was decommissioned and dismantled during the period 1990-1995 under an NRC and State of California approved Decommissioning Plan called the "SVA Decommissioning Plan" Both the NRC and the State of California have released the site where the north end of Building 37 had been located and the surrounding footprint area to unrestricted use (Refs. NRC SNM-696 license amendment #35 dated 5/1/96 and State of CA Radioactive Material License 0145-80 amendment # 123 dated 7/5/96). As mentioned above, the north end of the building was demolished during the decommissioning project. The remaining portion of the building (shown in Figure 3-20) is currently being used for non-(q ,/ radioactive work. It had previously been used for storage of properly packaged radioactive waste from the SVA Decommissioning Project. Sealed sources were also used by the TRIGA reactor division for calibration of nuclear instrumentation. Some surveys of the south end of the building were conducted during the SVA Decommissioning Project including the roof, exterior walls and soil surrounding the facility (contamination detected was cleaned up at that time). Additional final and confirmatory surveys will be needed to release the building and surrounding area to unrestricted use. 3.3.18 Fuel Production Process Develooment Building: SV-B (Bldg. No. 39) (15.200 ft ), 2 Building 39 is also located at GA's Sorrento Valley Site (Figure 3-20)just north of the SVA Building (Bldg. 37). Process development, pilot scale operations, and specialized fabrication work related to fuel production were conducted in the building (Figure 3-21) until September 1995. A portion of the building is devoted to offices and other activities. 3.3.19 Building 42 - Calibration Laboratory (1.791 f1), 2 v 3-6

l A small portion of this building houses the nuclear calibration facility as shown in Figure 3-22. The calibration laboratory uses a large NIST traceable Cs-37 source (the " range") and other calibration standards to calibration nuclear instrumentation for GA. 3.3.20 Building 2 - Science Laboratorvjuilding (119.370 ft ), 2 The Laboratory Building contains laboratories, offices, shops, and low-level caves for work with low-level radioactivity. Most of the research activities in metallurgy, chemistry, and experimental physics involving the use of radioactive material, were conducted in this building. The laboratory complex is shown in Figure 3-23. Building 2 Summary: Total of 142 labs; of these,33 labs have notyet been released to unrestricted use and 109 labs have been released to unrestricted use in Groups 1 th<ough 8C. (The release of Groups 8B and 8C is anticipated in 1996 and has been included in th-total number oflabs reported as released). A summary of each laboratory is provided in Table 3 1 showing the " group" in which it was released. Labs (33) notyet released are as follows: Laboratory B Section: Figure 3-24 Ten (10; Labs: 202, 204, 206, 208/210, 216, 218, 238/240 an d 242 Laboratory C Section: Figure 3-25 Twelve (12) Labs: 325 (menanine released), 401,403,405, p 407,409/411 and menanine,413 and mezzanine,415 and mezzanine),441,443/445 and mezzanine Laboratory A Section: Figure 3-26 Eleven (l1) Labs: 511,513,517,605,607,615,617,619/621 and mezzanine,623 and 645 There is no known contamination in any of the 10 labs located in the B section of Building 2. All radioactive material and contaminated equipment has been removed from all 12 labs in the C section of Building 2, including equipment from the laboratories used during the manufacture of thermionics fuel in labs 401,403,405,407,409/411 and 413. All radioactive material and contaminated equipment has also been removed from the 11 labs in the Laboratory A section of Building 2 with the exception oflabs 511/513 which currently house the Health Physics Laboratory. As mentioned above, GA plans to move the Health Physics Lab to Building 10 by December 1996. All known radioactively contaminated ducts that were in the service core area of building 2 (and in each lab) have been removed (and replaced). All other accessible ducts were surveyed and no contamination above the release criteria was found or it was removed and disposed of as radioactive waste. In the service core, to date, there are two (2) drain lines which have very low levels of contamination detected and one area of concrete with uranium contamination (depleted uranium). No l other areas in the service core are known to be contaminated. ] V 3-7

3.3.21 Underground Storage Tanks near Buildings 9. 31. 21 and lab 540 of Building 2 /~N In 1984, underground storage tanks located near Buildings 9,31,21 and near lab 540 of Building 2 were emptied and removed. These tanks had been used for the temporary storage of low level radioactive liquid wastes. During the time of removal of each tank, the NRC collected soil samples prior to GA backfilling each hole. GA also collected soil samples. No decontamination was required of the soil surrounding any of these tanks. The results of the soil sampling have been documented in a GA report dated February 11, 1985. The soil met the approved release criteria. /"'% V 3-8

TABLE 3-1 STATUS OF LABS IN BUILDING 2 r Number Lab flas the Lab GROUPNO. COMMENTS No. Been Rei 1AB WAs RELEASED IN 1 102 YES I 2 104 YES 1 3 107 YES 1 4 109 YES 1 109 & 111 are a comb i 5 111 YES 1 109 & 111 are a comb ~i 6 113 YES 1 7 115 YES 1 115 & 117 arc a combi mezzan i 8 117 YES 1 115 & 117 are a comb i mezzan i 9 119 YES I 119 & 122 are a comb ~l mezzan i 10 122 YES 1 119 & 122 are a comb'l mezzan'l 11 128 YES 1 12 130 YES 1 130,132 & 134 are a comb ~l 13 132 YES I 130,132 & 134 are a comb'l 14 134 YES 1 130,132 & 134 are a comb ^l 15 137 YES 1 16 139 YES 1 17 141 YES 1 18 143 YES 1 19 145 YES 1 20 147 YES 1 21 149 YES I j 22 151 YES 1 23 154 YES 1 Two rooms 24 202 NO Izased 3-9

TABLE 3-1 STATUS OF LABS IN BUILDING 2 O V Number Lab IIas the Lab GROUP NO. COMMENTS No. Been Rei uswAs RELEASED IN 25 204 NO Leased 26 206 No leased 27 208 NO Leased 28 210 NO Ieased 29 212 YES 5 212 & 214 are a comb'l mezzan 1 30 214 YES 5 212 & 214 are a comb i mezzan'i 31 216 NO Leased 32 218 No teased 33 228 YES 2 228,230,232 are a comb'l 34 230 YES 2 228,230,232 are a comb i l 35 232 YES 2 228,230,232 are a comb i 36 234 YES 3 37 236 YES 2 38 238 NO LABS 238,240 & 242 are a combi l and 1 l 39 240 NO LABS 238,240 & 242 are a comb'l and 1 40 242 NO LABS 238,240 & 242 are a comb I and'l 41 309-1 YES 3 309-1,309 2 & 309-3 are a comb'l 42 309-2 YES 3 309-1,309-2 & 309-3 are a comb i j l 43 309-3 YES 5 309-1,309-2 & 309-3 are a comb i 44 307 YES S 45 311A YES 5 46 311 YES 2 47 313 YES 2 48 315 YES 3 5 3-10 r

l TABLE 3-1 STATUS OF LABS IN BUILDING 2 Number Lab 11as the Lab GROUPNO. COMMENTS No. Ileen ReI LAs wAs RELEASED IN 49 317 YES 4 Inci 50 319 YES 2 51 321 YES 3 321 & 323 arc a comb i mezzan 1 52 323 YES 3 321 & 323 are a comb i mezzan i 53 325 NO Mezzan i 54 327 YES 3 Incl 55 331 YES 2 331 & 333 are a comb'l mezzani 56 333 YES 2 331 & 333 ARE A COMBINED LAB - INCLUDES MEZZANINE 57 335 YES 6 335 & 337 ARE A COMBINED LAB - MEZZANINE INCLUDED IN GROUP l 3 58 337 YES 6 335 & 337 ARE A COMBINED LAB - MEZZANINE INCLUDED IN GROUP 3 59 339 YES 5 339 & 341 ARE A COMBINED LAB - MEZZANLNE INCLUDED IN GROUP 3 60 341 YES 5 339 & 341 ARE A COMBINED LAB - MEZZANINE INCLUDED IN GROUP 3 61 343 YES 3 343 & 345 ARE A COMBINED LAB - INCLUDES MEZZANINE 62 345 YES 3 343 & 345 ARE A COMBINED LAB-INCLUDES MEZZANINE 63 347 YES 3 347 & 349 ARE A COMBINED LAB-INCLUDES MEZZANINE 64 349 YES 5 347 & 349 ARE A COMBINED LAB - INCLUDES MEZZANINE - MEZZANINE INCLUDED IN GROUP 3 3-11

... ~.. i ) TABLE 3-1 STATUS OF LABS IN BUILDING 2 Number Lab lias the Lab GROUP NO. COMMENTS No. Been Rei LAB wAs RELEASED IN 65 351 YES 5 351353 ARE A COMBINED - INCLUDED MEZZANINE 66 353 YES 5 351 & 353 ARE A COMBINED - INCLUDES MEZZANINE 67 355 YES 4 355 & 357 ARE COMBINED LAB 68 357 YES 4 355 & 357 ARE COMBINED LAB 69 359 YES 4 359 & 361 ARE A COMBINED - INCLUDES MEZZANINE 70 361 YES 4 359 & 361 ARE A COMBINED - INCLUDES MEZZANINE 71 401 NO 72 403 NO 73 405 NO 74 407 NO O 75 409 NO 409 & 411 ARE A COMBINED - INCLUDES MEZZANINE 76 411 NO 409 & 411 ARE A COMBINED LAB + f INCLUDES MEZZANINE 77 413 NO INCLUDES MEZZANINE 78 415 NO INCLUDES MEZZANINT 79 417 YES 6 MEZZANINE INCLUDED IN GROUP 2 80 419 YES 2 INCLUDES MEZZANINE 81 421 YES 2 82 425 YES 3 INCLUDES MEZZANINE 83 427 YES 3 INCLUDES MEZZANINE,427 & 429 ARE A COMBINED LAB 84 429 YES 3 INCLUDES MEZZANLNE,427 & 429 ARE A COMBINED LAB 85 431 YES 3 INCLUDES MEZZANINE,431 & 433 ARE A COMBINED LAB O 3-i2 l

i TABLE 3-1 STATUS OF LABS IN BUILDING 2 sQ C Number Lab lias the Lab GROUP No. COMMENTS No. Been ReI us wAs i RELEASED IN ) 86 433 YES 3 431 & 433 ARE A COMBINED LAB-INCLUDES MEZZANINE 1 87 435 YES 2 435 & 437 ARE A COMBINED LAB INCLUDES MEZZANINE 88 437 YES 2 435 & 437 ARE A COMBINED LAB INCLUDES MEZZANINE 89 439 YES 7 90 441 NO 91 443 NO 443 & 445 ARE A COMBINED LAB 92 445 NO 443 & 445 ARE A COMBINED LAB 93 502 YES 6 502 & 504 ARE A COMBINED - INCLUDES MEZZANINE 94 504 YES 6 502 & 504 ARE A COMBINED LAB - INCLUDES MEZZANINE 95 506 YES 8B 2 ROOMS b 96 508 YES 8B 2 ROOMS 97 511 NO 511 & 513 ARE A COMBINED LAB-IIP LAB 98 513 NO 511 & 513 ARE A COMBINED LAB-IIP LAB 99 515 YES 8B 100 517 NO 101 519 YES 8B 519 & 521 ARE A COMBINED LAB 102 521 YES 8B 519 & 521 ARE A COMBINED LAB 103 523 YES 8B 104 523A YES 7 105 525 YES 7 3 ROOMS -INCLUDES MEZZANINE 106 528 YES 7 107 530 YES 8B 530 & 532 ARE A COMBINED LAB 108 532 YES 8B 530 & 532 ARE A COMBINED LAB 3-13

TABLE 3-1 STATUS OF LABS IN BUILDING 2 Number Lab Ilas the Lab GROUP NO. COMMENTS No. Been ReI LAs wAs RELEASED IN 109 534 YES 7 110 540 YES 5 111 543 YES 5 112 545 YES 5 545 a 548 ARE A COMBINED - 2 ROOMS EACH I13 548 YES 5 545 & 548 ARE A COMBINED - 2 ROOMS EACH 114 550 YES 5 115 552 YES 5 INCLUDES MEZZANINE I16 554 YES 4 554,556 & 558 ARE A COMBINED LAB - INCLUDES MEZZANLNE 117 556 YES 4 554,556 & 558 ARE A COMBINED LAB - 1NCLUDES MEZZANINE 118 558 YES 4 554,556 & 558 ARE A COMBINED LAB -INCLUDES MEZZANINE i 120 562 YES 4 562 & 564 ARE A COMBINED LAB 121 564 YES 4 562 & 564 ARE A COMBINED LAB 122 603 YES 7 123 605 NO 124 607 NO 125 609 YES 7 609,611& 613 ARE A COMBINED LAB 126 611 YES 6 609,611& 613 ARE A COMBINED LAB 127 613 YES 6 609,611& 613 ARE A COMBINED LAB 128 615 NO MEZZANINE RELEASED IN GROUP 3 129 617 NO MEZZANINE RELEASED IN GROUP 3 3-14

TABLE 3-I STATUS OF LABS IN BUILDING 2 Number Lab Ilas the Lab GROUP NO. COMMENTS No. Been Re! LAs wAs RELEASED IN 130 629 NO 619 & 621 ARE A COMBINED LAB - INCLUDES MEZZANINE 131 621 NO 619 & 621 ARE A COMBINED LAB - INCLUDES MEZZANINE 132 623 NO 623 & 625 ARE A COMBINED LAB 133 625 YES 6 623 & 625 ARE A COMBINED LAB 134 635 YES 8B INCLUDES MEZZANINE 135 637 YES 8B 637 & 639 ARE A COMBINED LAB - INCLUDES MEZZANINE 136 639 YES 8B 637 & 639 ARE A COMBINED LAB-INCLUDES MEZZANINE 137 641 YES 1 641 & 643 ARE A COMBINED LAB - INCLUDES MEZZANINE 138 643 YES 1 641 & 643 ARE A COMBINED LAB - INCLUDES MEZZANINE O-139 645 NO MEZZANINE RELEASED IN GROUP 8B 140 647 YES 3 & 8B INCLUDES MEZZANINE - GROUP 3 & 8B 141 649 YES 3 & 8A 142 651 YES 3 & 8A O 3-is I

l BUILDING NO. NAME [ Suildmg 1 Administration l Beidmg 2 Scienc3 Laboratories A,8, C k% Building 7 Caleteria X Building 9 Emperimental Building [ ing $3 Maintoaeace Building l mg 13 Technical OfEco Suilding LDT2 ing l4 Technical 0ffice tast 4 i ading 15 Technicol offica tast j Building 19 Swimming Peel Building

1. ./ k l

Building 21 TRIGA Building 39 39 1 Building 22 TRIGA Fuel Lab Suilding Building 23 Het Cell l j l Jgggg7gy Building 25 Weste Yard Building ( Building U Experimental Ares 63 65 Building 271 Emporimental Area l 8uilding 29 Experimental Area 42 1 Suilding 25-2 Emergency Vehicle Storege Building 2 1 ' 4h]l. 1 64 l Building D Linac Complex sN_ ",ggNSN g' Building 31 TRICA Storage Building Building 311 Neutron Radiography Building \\ { s Bmiding 312 ECT Critical Building g%2 34-3 N Building 313 Storage Building 34-4 Ouilding 33 Fusion Building i 34 h Building 33-1 Fusion Lab 8miding \\ j v 34-1 Building 33-5 Fusion Building Annes 5 Building 34 Fusion Doublet HI Building i 8 Building 34-1 Fusion Doublet til Capacitor Building LOT 32 45 i g ) Building 34-2 Fusion Doublet til Lab Building 51 ',/ Suilding 34 3 Fusion Doublet HI Storage Building 6* 0 Balding D Test Tower 8miding Building D 1 Facilities (Shipping & Receiving) Building /"S 8 ilding 36 Blower Assembly Building , # QEg1 OPENSPACE i l Building 37 Sorrente Volley Building ,e Bmidmg D Serrente Valley Building / B zilding D1 Storage Building f / CONTROLLED Building 41 Rew Stock Facility / f Buildmg C NDT Facility / f 31-1 ACCESS 8:ilding Q Helivni Circulator Test facility / / Building 63 5550 Dunhill SL / 31 2 gg7g f f 8vilding U 11030 Roselle SL / f gg,3 / Building ') 11040 Roselle SL / / 4 811 ding O 3520 Dunhill St / / 31 J 22 4 [ Ting 67 3510 Dunhill SL ,/ / 30 f / e' e' q Q h 23 I / OPEN \\ / 21 ci

• SPAC Q~/

II ec 27 1 \\ N 29 my d M[b 29 2 25 2 ATOMICS 4 gg73 ( l CENERAL ( g m N o, s \\ LOTJ1 h 9. COURT )2 3 c w g y 5 5 E N E l a = a L JOHN JAY HOPKINS i I COURT ~1 g N .5 W 'tqop, P.4q g 33 A LOTS UCSD -- FENCING PROPERTY LINE O 250 500 750 1000 1:::P"'""9::3'""". ] SCALE IN FEET L-122(1) g 19-95 Figure 3-1 Main Site and Sorrento Valley Site

l 50RRENTO ELECTRONICS.INC. Romile St. LEAD (NG SYSTEMS,INC. o 11025 50RRENTO VALLEY CT. DG.SMS Dunhitt St. anders Drwes g r .k g f g p e6 g Flanders Ct. T APPLIED P- {

1. g SUPERCONETICS. INC.

8980 CRESTMAR FT. [+ GENERAL Scranton Rd. l A ICS 4,, ADVANCED MATERIAL

1. e,/c TECHNOLOGY-8tDG. 71 8963 C7VOLL WAY S.

• • r, O

-~ f avg _ o t q ses r Cl ?I l SAN DIEGO 1 SUPERCOMPUTER g,g Crerrmar Pt. i sok0 E gggA9A f '*} #"#*" #*' Distnbution Ave. Camino Santa Fe ( l ggEDBW t_ A JOL I i J-2 Sorrenio Electronics site

~) f)l O %/ u Radioactive Material Laboratory Radioactive Material Storage @l n , Y.,' S,-e- ~ Ie p-o r :r ... a r .w-n 1 t .r. i -~ -,s, y* m-- - ~ ,. [,, l v, -nst-., n n 2 .w ..r - a1 -j* __ 22@ -._i ,vi y -a t e. .fL. m m y. - ~ .a a 1 Av 'r; v 3' of s as .n

k<

• e.,

~ 5 W "..% M5 v?W M?r -k a-lik ~ ,.u. rr .m. 9:;}. r wq._ l r 7: ~ rw -.11 2 ew s. t- .,.wmm: 59 f

• . F. E p 41 t-

.m E -t ~ c.9-7Fi' es1- ,rw- .8 p -- 7-' -y .s ~% G ,4'- -. '.n.. =T .s y - ~ ~ r- ~m' 3 a,r .u. u ~u,- t-n , \\ r-- ,!k 3.st 5 '-* 2 e. n?"r, 2A

• u t ds

. u to

m

.m.. ~ .t l m an' t. = y -., i,__ 5 l.th 5 E !'u .r m 11-n, a M _f *_ 5" .n.- BLDS *t' FL004 PLaos C~' ~ w. i 10247 Flanders Court L u.e.o. - es maa. as m as G esmaa4u.a a & M wtasJ .BLOG *D' PLOOR PL AM s' m w e.a,.a mm r./.g'.ar* l 10240 Flanders Court Figure 3-3 Sorrento Electronics Manufacturing and Supporting laboratories and offices

DECONTAMINATION STAGES FOR THE " HOT SUITE" AREA BUILDING 9 ai'/ ^ /- / y ~ r. = i / /\\_ ,/ l '//#////_ /' /, t \\ / ) ['/.Q11,.

• 5

.at21 Y[ l 1 / t g ..... :.e!.*;.'. **.!:'

• • ~,l*...,

R l' 'K,;,s' s* I"j'j 'j.,1 'i 2 :.! :,*...* : *" ' :'.* : enn '/ \\ ** t

.:: :. ; : :.. v':.;

ge ' f,* *..

* ~.. '.'.'I '.. M..,* :, '.

At,,sr i r n- ,'f

• ....,, * *, i;'. j'.

.a== t*.s e, t

. s.. * ;

!! ~h ons .,*. *..~. : : O. i s = . -:. 9.: Is ., m[ r a / I gh./ ' emmasumum !~[ f / l 8P ' d k / // = = "' f/////J-///// /L. tt 4 m 048

W

/ / / 7 't / STAE 1 Relaas.d co unr.striccad I / usa. l l i 'y / Z;. .y:; / szau 2 R.t....'d co unt..crie:.d = =. l 1 l e t s STAE 3 Not released to unrestri ~ ust. Figure 3-4 Building 9 " Hot Suite"

-,n 4e a, -a-,n e. n a --,.1 m-e --b m.A __m+ 2 ->e a ,a a ,,aa o ,a -mm-m 1 O E n I h C) E 3 m i r lO .2

• 5

'h n m b a II: E h T E g O

l O

~ ai v L i ' i' us u4

,mxm N ] l-i D L-( ) ll ~ ~ s e mu N. [' ui 1 i LAJ ~ g un = "i%" P 0 V h [a---'1 M2 h 5 't , m.. k e n '0}L ( '[_ yy tee ) k d i i I ) Y f v "u LM h'- ~ j ~ -- p t ~ 01 4 to 25 50 F1IT O Figure 3-6 TRIGA Reactors Building 21

l L

l' . O a N J I k a!!j i a Mg~ M /. mm m m m m a m p. m J. mus 2 i 2 g n i d l iu } B iu y =- t j ' .J i = l i \\ c a g F

y n

2_

• g o

/. _ O i CC1 t L a c T a' b ir J n-aF l eu F g A ( G I R .e T .n ll i' ' ,l II II 3 7-y, e r u s g iF G O

l l c-BsO SQUIPMEtif STORACE STAtt Ptf + .s. ( SEALED 000R 0 gl(7(g cA$$g77g 9 CYCLONE MArHlNE FUME FUME 00CK C STACK p 'JA5HER M *0 0. 5 HOP ,7 1 M i il E i Qt P.5--- Q U'f CAL : C.r~- l l Q I ,d' ,I l MANIPut.ATOR 00M REPAIR OECO:8 g STORACE 11 d,il ll PIT 200M g e 1 SERVICE GALLERY i IO i '~ ' L i W ME i. g y[ 6REAK-4WAY t UTil.lTY ca CELL ,g l 000R EQUIPMENT p gna-- <., - (; ROOM a d 5 /; b [' kl LOVER 6 3EALED LEVEL ~ 000R CE Y"dk.* ~ .tycRAULit $4. a O] is: ,#;. j gs SYSTEM ?i: ,2.i:1 HIGH iG 'e (m.N,) j LEVEL n OhE h, 7 - (, "g I. CELL E 'I soo o '" # U S be CLOSED HOT SHR EL_h h5 Yhh X 8 AY COLD SHR d j ,,,..g.!;- j 400M, g E JAN CHANGE :.00M E gJ !. i ,i k. n i, i i i.. 9 ,e W OP!8ATING GALLERY m%_ OE + A ygn r f ~ LOBSY I OUTER OFFICE OFFICL OFFtCf V' MEN ~ Y Q \\ O q I.%., LECEHO: ..i..>> ~ .'[ ' $.ONTlHUCUS AIR n0NITOR s ec:t ::enrERS (cM) 9

• * ' ~ '.E R S (GM )

l A R Am ( R EMO TE AR EA.-ON I TO R I NG i ' T'~;.N S 415 5AMPLERS suzzza CONTROLLID ZONE (CLOTHING OMAr**El

• (d Figure 3 8 Hot Cell l

l L

4 i 3

o

= n1 H H 1 700 1900 T a g J I50 GAL O .t 4 J. O i I t! ~ I i '. -.1 i y-y. f ~ 's Figure 3-9 Low-Level Filtration Facility Building 25 O

t r, f de tc i r ts . O \\ 5 R 0 1 _ R 1 A 4 S o t t 1 T 4 4 S 1 L 4 C g n 7 [ s i 0 0 d 1 l d-; u 1 i r B 1 1 4 4 y 4 t -, uA 0 i A l 1 i c a F o 1 4 i g i n 4 i s u3 \\ e s I' H. \\ c !( o H r P e -. n t saW r l .i1 a 6 e l dr i K0 c 1 u Rp N 1 4 0 [ Wp 1 - 3 u l er Pih-3, u i I g i F l it_T g _~ ii_T g / 1 n o i i__Tg 1 1 t_T y~ 1 I 4 1 s ii_T e ii_T i j i i_ O Ti e -1 ieFM~ 6 [ A 0 1 1 / a - 1 d

(1 j

E I Ik f. j ', ?f i 4 5 6 I 1 1 1 I 1 1 1 ) I I N 2 3 1 1 1 1 I I j 0 1 7 1 2 1 1 1 g n id l iu I z B ) AE ( j a 8 9 e 0 r 0 A 1 1 l a tn e I I m irep xE j 6 7 0 0 I 1 1 1 -3 er I I u ig F pO U HANI A B I 2 5 5 I 0 Y1 0 0 1 [ I I B A 3 4 1 10 0 0 0 1 1 1 1 I I H 1 0 T 0 0 R 1 1 ON y I y I

( I esa l l ll i O -J i l l l l] O Figure 312 Experimental Area -1 " Bunker" Building 27 1 s i 9

- --,.i-... -.,a.. s..s-n --..2sa-. a+ u --.w--a. ~ * - - - , - - =. .s.,- 0 { [. i s!!il U s en h 6 N d t. 9 k Q \\ O/ 44 o 4 >jre a. i ,o 5 G N o O

l I I 5 c u 5 y m ^ k

\\ r r 1, _,,,..... A s N = 3 N ii ~ g m w q 1 [, I ~ wate c f u g ~~ ,m j v p f =wI L' 'l W._.:, a u i 1 y> E n W } / 'Ag ?, kh k l} 141. 2 5 W" vu !^ 3 IE vu

D O O S-1 STORAGE 2ND FLOOR CATWALK" souncEummart.ar.runnocr MA1 TRIAL AND E&frITES r a.,..... l'.'T' ' ^- ' Td,,,, 1 ?V// IST FLOOR STORAGE ['// / ....,,i a

• 3,

..... _-;--a...cc: r.. : e .r., :u r.. a 4 - - - /' i ig = \\ I jh. ..-s..n.t. -s.,rg.F e ,y ) I TIDREStSTORAGE O T/ .f {w,,a Adt4*A6. f h E MATL ORSOURC s e / ? I'Y x 1 I U, .. + =* t 9*e e /////// j 5j 1 /g.anunut laman// / \\'l an ,., ' ' \\ -g.ty/'

• dj j:

BUILDING 31-103 e p b- ]< h n -w- _......~....- TEMPORARYSTORAGE , oo RAploacnYE RECEFTS440PMENTS & EasrnES .

• e. *,. s.. o o o ooo <>o wennstituissMMM//MM//M/MMM/nssa't**Mt-emos%w-~... ---- - SNM LIMITS: <2se one ua r s s. g..- %?
• r s. t.

ooooou .. e t r. . s s y s

• J 8

nssns/MMMffffff/Mfff/Mff/Mffff////f/fM/MM - ft' .w... l .sieL _ *.T. _ 0& Y ,,m, -- 4r'- V.1-j oco lY ,_,_ c. u, w,4_ gum 3-15 Basilding 31 Room 103 NMA Storage f =- =

1 1 1 b i O 4 1 i IY1 ..di ..is. 'N m-um l. ( \\ 4 wanc i E k n ou i 9 m I C = i G !O v m i I mee l Y _i (' / ' + J ~ N war O Figure 3-16 Inertial Confinement Fusion Building 33

O O O N.. 8 1 33-1-102 33-1-104 33-1-106 33-1-108 3 3 110 f f f f ( { i i 33-1-112 i 7 so* < q j ) < J M ( c= w 33 101 33-1-103 33-1-105 33-1-107 33-1-109 3 3 111 g g g M Dd 7 .i NORTH Figure 3-17 Building 33-1 Former HP LAB

I I I

• I I

I .I g = ~ \\ L f i [ O f* 1 'vi !;f f.gi 3./01 "yh

S-ah*:r

.s, I g ooo D 1) 1 E i i *. g3 w a

c..

I H9^Va on trD b M $w d w. X -!, J f: r - m y lh / $ y y - g 4 1 a e ,.s

• *s YYh

= . A j : ' (> 1 s ..?; o .,s ,,x ? 0 h $f +- . :y ., g A i s / + j. t I,t "l 5 / J ~ A i:

1. 7 G

'I

O ~ = I, 3 a b =4 a g h

• I ae ens y

O ws P J g .~ mu n sm O 4 e' ( a --5 \\ o 1

1 O I g. i i = a l 3g.=h l EgE 8'- I 3 s B l.i ~ 'g 1 _g, g = O e s2 0;1 p" \\ ~ e W \\ l' s. N, O u' 1 i 3 \\ $1 m d 3a n 2 E be m o! E N E 3 e "I l l E { ay N u \\ -\\ h E t, N!llt ',i I 4 0 5

j l O = PtLOT SCALE l FUEL PARTICLE I = OEVELOPMENT AREA 142 r..: s 143

fr*;g; 120 Qi 121 l

/ nts w&LL T3 800F allCMf i l I Cl l I N 118 114 vi di seaflCLI *83 ug

• 000 3 8 ""
• *009C T l

(~ l .m0 SL(No (ValuAflon C0Aftg 400n rung ConfROL 10U18atef.ata 411(stLY N000 C510L E Ou. 108 fTT1 102 c2an0ainf 0-l C 2ri, non 4Cr rum 106 ""'S" PC A031M(f t A c R00 FlasmC narass A88

1. UAmeCt CAV1N &

Pvth0M(Ttt S E tutt 300? E'#" M II k ,,g 7, LA80aarent ? Pant FUM .aat n000 n0C0 l a00 *e s List 4 0FilC(5 l

== I 9 N N 099lCl$ a t i N Figure 3 21 Sorrento Valley B Building 39 1

n s.,;.t.,..m w:4.,e.=;4.w. :': r.mu.%,,, v 9a: 'c?*.. ,q p. ..i a G... f.i.': \\%* .m, t s.. y. W y.*. + ~ .v S. hi. f.. is t );;.- p.- , s.-

s. L t.

...c

.y 3

rd n.- 1m j..; te-2 ,.n e-s ?.%,I .... s "I T:. Nuclear Calibration Area

N

). 3.. s..: to. p*. r,: ,(.. s e t.y c 7".:.:

• f";

te-g et-t Es

9. e n.:.

t -.- .N ,,e ..s. v. ".', **,b s }, &.f

• _ C' '.5*,l d', b.

Figure 3 22 Calibration Laboratory Building 42 P

f im V ,,g e -{- ..h, s z, '?<E /*+c .~ L.],7, ,.., 3,. I ...;g;, N" ht d Y"k2 h'p,,, gf..P=T.'4,f4+R;;,,4 $l;.% s,9>c /> g ej,/ <;: i 8 .s 5 \\, -h D /4 Q /'f [ j/ / \\, $'# f,fi ? sr le U 4 \\ \\ 'L ', Y *s = s\\ @i c, s e

i

=) f ~f I Lr i t W. T 2 a rt s s.+ - g n V . 4' it

\\ ' ?, '

\\s sA \\ s 3 I .' \\ 2 M6 g p s %** g s (% s \\'h 'c, ~ N 'c n ', N .N 'c, N 't. N,g=$' ' s., t\\s, - + ,' s '"2~a. , * [;~ . '(q' T,T, ,, ~ Figure 3 23 Science Laboratory Building 2 qN/

/ u. [ s;I' l .. ~.. gy, s,' O"? I$X \\ 4 $4 ,s \\p/ \\ k t t i s s i S i t } I i 5' h 4 bY r 4 $lm.,. ' i m .s s sai 8 A \\T n D h cp 7 9 .8 m k c m,3 Tj S? Q g )l1~,~ i} ' gf,, ' h - 4 g z (. a ~ = x &G N ? z ~

• • 'a g

b ~ I !~ i [ s, s 7.. Y'

ma m_4h-eL4M-_ _ Jr x) z / J 0\\'\\k,, f -,, y,, ^ $e O

• g t

5 18s4 . t, 1 ~ 1 /;'y<< (g ,4 ' $'l'/i. ~ \\ 3 ,s h /< "j,. i, fi g z;ri i s E .n m y

f. '1 E

5 l S E ] L._ .^. A . s-e 13 4 0 5 { u .8 = n .n a n f-- j .N - e g ? n o l = ? a ~' P/k.P y a a 9 . ?$ l ptk gf_ / /

• p 46 4

p-f N

fs g

-g f.. p '.[- s .i ~ l s 'x ~ ~ S *- ~ J e /q "mv

g y ,,mm---# ,g_,"'A ms ei&" 4 '4k (. g 3., i s, s I', es c, \\ .) i 2 \\ t, v y g 3 \\ 's, Qi h e 3

,t s

b-a(. r i s a g .i + ,3 7.] .h j O

a

<:C m1 v - $tL q?)(f.1 g """""? 3 3 e q e n r r e, ," !#1 ' (s-

.v w.

.s ( g d., p[L ~ j;:41 / ?,a? i M A'

1. y

? ? ik 3 9 i .f ,a x 's

4. DECOMMISSIONING ORGANIZA TION, TRAINING AND METHODS USED y

FOR PROTECTION OF OCCUPA TIONAL AND PUBLIC HEALTHAND SAFETY A- / 4.1 Decommissioning Organization and Responsibilities GA is committed to and retains uhimate responsibility for full compliance with the existing NRC and j State licenses and the applicable regulatory requirements during decommissioning. Company policies will be followed to ensure high standards of performance in every Decommissioning Project. y 4.2 Description of Overali OrganizationalStructure 4.2.1 GA Organization The GA organization involved directly with decommissioning projects is provided at the end of this chapter as well as resumes of principal individuals who have responsibility for vn ius aspects of decommissioning. 4.2.2 Use, Control, and Management of Subcontractors Subcontractors may be used at the discretion of GA's Project Management to either fill organizational positions or perform specific decommissioning tasks. Specialist contractors will be utilized from time to time on an as-needed basis. Tasks where contractors may be used include but are not limited to: Shipment and disposal of radioactive and nonradioactive waste materials Laboratory testing and analysis Concrete cutting Specialty engineering and design services Temporary staff augmentation 4.3 Decomntissioning Safety Responsibilities 4.3.1 Industrial Safety / Hygiene Industrial Safety personnel and GA's Industrial Hygienist, shall be responsible to ensure that the Project meets occupational health and safety requirements for personnel and the general public during on-going decommissioning activities. Primary functional responsibility is to ensure compliance with the OSHA ) of 1973 as implemented by California Labor Code Section 6400 and the General Industry Safety Orders (GISO 3203). Specific responsibilities include conducting an industrial training program to instruct employees in general safe work practices; review Decommissioning procedures to verify adequate coverage of industrial safety and industrial hygiene concerns and requirements; performing periodic inspections of work areas and activities to identify and correct any unsafe conditions and work practices; providing industrial hygiene services as required; administering the Hazardous Work Authorization Program; and advising management on industrial safety matters and on results of safety inspections. 4-1

4.3.2 Radiological Safety q '~'/ Primary functional responsibility is to ensure compliance with Title 10 CFR, Pans 19 and 20 and with license-imposed radiological safety requirements. This responsibility includes review and approval of proposed activities involving radioactive material, monitoring / auditing of such activities, and providing services such as personnel and environmental monitoring, dose rate measurement, radioactive material detection and assay, and radiation safety training. Services include review and approval of WAs and the preparation of Radiological Work Permits (RWPs), and identification and quantification of radioactivity in waste materials. GA's Health Physics (HP) organization maintains a laboratory containing a gamma-ray spectrometer, alpha / beta / gamma counting systems, and a VAX Station 4000 VLC (Canberra Genie). An emergency van is equipped with self-contained breathing apparatus, portable air samplers, ponable radiation monitoring equipment, and protective clothing. An environmental monitoring program evaluates the effectiveness of the radiological effluents control program and provides information to assist in timely corrective action in the event of accidental releases. The Program includes environmental sampling of particulates in air, water sampling (including sewage), and sampling of soil and vegetation in and around the GA site. Film and thermoluminescent dosimeters (TLDs) are situated at various locations within the GA site as well as the GA site boundary and off-site locations to determine the external integrated radiation exposure. GA staff includes HP Management, professional level Health Physicists and experienced HP Technicians O which support D&D projects. Q/ 4.4 Training All personnel working on decommissioning projects receive Health and Safety training in order to recognize and understand the potential risks involving personnel health and safety. The Health and Safety training implemented at GA is to ensure compliance with the requirements of the NRC (10 CFR), the EPA (40 CFR), and both OSHA and CAL-OSHA (29 CFR and CCR Title 8). Workers and regular visitors are familiarized with plans, procedures, and operation of equipment to conduct themselves safely. In addition, each worker must be familiar with procedures that provide for good quality control. Training is conducted and controlled in accordance with GA procedures, license commitments, and in accordance with the applicable Work Authorization for the specific decommissioning project. 4.4.1 Radiological Safety Training / Retraining General Emnlovee Radiological Training (GERT 4 Hour)-Training will be provided to personnel required to enter Restricted Areas (with the exception of visitors and infrequent suppon personnel), including n (] Radiation Areas and some Radioactive Materials Areas, but not perform " hands-on work" or who may 4-2

i i perform limited work with radioactive material. If the worker requires entry into any of the above special areas or if the job requires any of the " hands-on" work mentioned, then the worker must attend Radiological Worker Training. Radiological Worker Training (RWT 16 Hour)--- Training will be provided to personnel who require unescorted access to Restricted Areas and who may perform more complex radiologicaljob functions. GERT and RWT are required initially. Both are effective for one year, not to exceed 15 months (NRC licensed activities), or two years, not to exceed 27 months (State licensed activities) except when a change of visitor status (GERT) to worker status occurs, in which case RWT is required. Health Physics Technician Training - Only HP Technicians with sufficient experience will be used. HP Technicians must successfully complete Radiological Worker Training. In addition, HP Technicians must review and understand procedures according to the HP Technician Procedure Review Sign-off Forms. HP Technicians will also review applicable procedure revisions in a timely manner. HP Technicians will also be familiarized with the specific procedures for the specific decommissioning project. l Contamination Control Training-Personnel will be trained in contamination control together with boundary control, ventilation control, etc. Cross contamination will be limited by the use of training and radiological controls. Radiological and hazardous material contamination will be strictly controlled during all decommissioning work. This control will be accomplished using qualified workers to perform work identified in approved work procedures. In some instances, special briefings and dry-mns may be used to perfect, demonstrate, and qualify the workers. i l 4.4.2 Equipment Operator Training All equipment operators will have proper training completed and documented prior to working with the equipment. 4.4.3 Safety / Accident Prevention Training GA has an Accident Prevention Program which is defined in the Accident Prevention Program Manual (APPM). All employees are required to abide by the requirements of this Manual. Additional specific Project requirements are specified in the plans and procedures for specific decommissioning projects. These additional requirements arise because of the nature of the work to be performed. Hazard Communication Training-A hazard communication training program has been developed for decommissioning projects in accordance with OSHA 1910.1200 and the GA APPM. This program promotes awareness of chemical hazards that are present at the specific facility, and provides means to communicate 4-3

those hazards to employees. A designated person will maintain the hazardous material inventory and Material Safety Data Sheets (MSDS) for on-site hazardous materials, and provide all D & D Project personnel with infonnation advising them of the potential for hazardous constituents in the work place. A list of such materials for each project is maintained at the job site, and copies of the appropriate MSDS are available to site workers upon request. The MSDS form provides more detailed information about the chemical than a label does. A hazardous chemical inventory is maintained which reflects the current supplies located in the work area. Any chemicals not previously located and identified or new chemicals received on the job site will be added to the inventory list. Similarly, chemicals removed from the job site will be deleted from the inventory list. Resoirator Training-Each individual who may be expected to need the use of a respirator will be required to receive respiratory protection training, be medically quali6ed to use respirator protection, and receive a quantitative 6t test for each specific device that they are qualified to use. Training will meet the requirements of the U.S. Department of Health, Education, and Welfare, National Institute for Occupational Safety and Health (NIOSH1 ANSI Z88.2-1980 Practicesfor Respiratory Protection and 10CFR20. Respirator fit tests will be administered before initial assignments to jobs requiring the use of a respirator, and will be conducted annually thereafter. Medical qualification will be assessed every 12 months. Confined Space En*v Training-Employees required to enter confined or enclosed spaces will be trained to r the OSHA confined space entry requirements. They will be instructed as to the nature of the hazards involved, the necessary precautions to be taken and the use of required emergency and protective equipment. A confined space permit must be issued prior to access into the confined space. 4.4.4 Hazardous Materials Training Training for hazardous materials is dependent on the job description for each individual and the types and amounts of hazardous materials or hazardous wastes being handled as specified in the position's training plan. In general, the training specified for worken and supervisors directly involved with decommissioning includes some or all of the following training requirements: HAZWOPER Training Course--OSHA 1910.120,40 hour classroom and 24 hour on-the-job training specific to hazardous materials handled during decommissioning activities will be provided to workers. An annual update is provided. Hmrdous Materials Packaging-Reviews the requirements for handling and shipping hazardous materials and wastes as required by 49 CFR, the Department of Transportation (DOT) regulations. A refresher update is required every two years. Ov 4-4

RCRA Facility Standards Overview Training-This class covers the requirements established under 40 CFR 264.16 for personnel who may handle hazardous wastes within the Facility. The class covers the Federal Standards and discusses compliance requirements for generators of hazardous and mixed wastes. An annual update is provided. 4.4.5 Other Training Waste Accentance Criteria-Training is provided to the requirements established for the disposal site (s). An annual training update is provided. GA Emercency Resnonse Training-GA has an " Emergency Plan"(a.k.a. Radiological Contingency Plan), as required by the NRC and the State of California. All facilities in which licensed material is stored or used have specific implementing procedures for this plan. Training on the Radiological Contingency Plan is provided annually to Emergency Response and Recovery Directors (specific to each facility) and their alternates. Emergency Response Team members also receive training specific to their facility's potential hazards / emergencies. 4.5 Procedures ) All decommissioning work will be performed in accordance with written, approved procedures and/or v plans. Revisions to Decommissioning Project procedures are reviewed, approved, and processed in the same manner as the initial document. Field changes to existing approved procedures are made in accordance with current procedure control requirements. HP procedures are developed by Project and GA HP personnel and approved by GA HP and Licensing, Safety, and Nuclear Compliance (LS&NC) management. Quality Assurance procedures are developed by Project and GA Quality Assurance personnel and approved by GA Quality Assurance management. 4.6 Schedule GA anticipates decommissioning, or the transfer ofjurisdiction to the State of California, of all facilities described in Table S-1 to take 5-10 years. 4.7 Methods Used For Protection of Occujiational and Public Health and Safety (3 O 4.7.1 ALARA Program 4-5

- -~ 1 1 Decommissioning activities at GA involving the handling of radioactive materials will be conducted such that- . radiation exposure will be maintained as low as is reasonably achievable, taking into account the cunent state of technology and economics ofimprovements in relation to the benefits. Current practice is as follows: l A documented ALARA evaluation will be required for specific tasks if a Health Physicist determines that 10% of the applicable dose limits for the following may be exceeded: - Total Effective Dose Equivalent (TEDE) - The sum of the Deep-Dose Equivalent (DDE) and the Committed Dose Equivalent (CDE) to any individual organ or tissue other than the lens of the eye - Eye Dose Equivalent (EDE) - Shallow-Dose Equivalent (SDE) A documented ALARA evaluation will be required if a Health Physicist determines that effluent averaged over one year is expected to exceed 25% of applicable concentration in 10 CFR 20, Appendix B, Table 2, Columns 1 and 2 at the site boundary. 4.7.2 Management Positions Responsible for Radiation Protection and Maintaining Exposures d ALARA During Decommissioning l The management positions responsible for the overall ALARA program during decommissioning include the Director, LSNC, GA HP Manager and the Decommissioning Project HP Manager (as applicable). 4.7.3 Methods for Occupational Exposure Reduction Various methods will be utilized during decommissioning to ensum that occupational exposure to radioactive materials is kept ALARA. The methods include Work Authorizations, Radiation Work Permits, special equipment, techniques, and practices as described in the following subsections. 4.7.3.1 Work Authorization (WA) Approval Authorization for work to be performed in accordance with Facility licenses and/or the Decommissioning Plan must be obtained through the LSNC Depanment by preparation and maintenance of an approved WA. The WA identifies the proposed work scope and activities, quantity, physical and chemical form of radioactive materials involved, individuals authorized to perform the work, and applicable work procedures. An estimate of the isotope (s),is included in the WA. Implementation of operating procedures is contingent I upon approval of the WA by various compliance functions, as described in GA's NRC and State Licenses, 4-6

i including GA HP Management, Nuclear Safety, Nuclear Material Accountability and Licensing and when appropriate, by Industrial Hygiene, Security and/or GA's Radiation and Criticality Safety Committee. Work is performed in strict accordance with the methods and precautions provided in the approved WA. 4.7.3.2 Radiation Work Permits (RWPs) RWPs are used when: a work task is not described in the Work Authorization, provided that the margin of safety provided - + by the RWP is comparable to, or greater than, that specified in the WA, personnel not listed as authorized users on the Work Authorization must perform work, + or outside contractors or subcontractor personnel must perform limited or routine work in a + Restricted Area. The RWP is issued in accordance with existing Health Physics procedural requirements, and is initiated by the Principal Investigator or other responsible individual who has good knowledge of the task to be performed / and other work being performed in the area. RWPs include requirements to ensure radiological safety controls are implemented. 4.7.4 Control and Storage of Radioactive Materials The GA HP Program establishes radioactive material controls that ensure: Deterrence of inadvertent release oflicensed radioactive materials to unrestricted areas. Confidence that personnel are not inadvertently exposed to licensed radioactive materials. All material leaving a Restricted Area will be surveyed to ensure that radioactive material is not inadvertently released from the Facility. The following methods will be utilized, as appropriate to the material being evaluated, to survey for licensed materials: Direct scans with a portable detector. Indirect survey by collection of representative smears for removable contamination with analysis. Collection of representative samples of bulk liquids or solids for analysis. Details of equipment and materials unrestricted release criteria are provided in Chapter 6. 4.8 Health Physics Program O 4.8.1 Project Health Physics Program-General 4-7 l

GA Health Physics procedures will continue to be implemented during decommissioning of GA facilities and sites. If new Health Physics procedures are required at some point in the work to suppon decommissioning, they will be developed and approved in accordance with GA Health Physics procedures and applicable plans. Personnel Monitoring-Internal and External-Prospective internal and external exposure evaluations will be performed, at a minimum, on an annual basis, or whenever changes in worker exposures warrant. Visitors to the Facility will be monitored in accordance with requirements specified in GA HP procedures, and according to the radiological hazards of thc areas to be entered. Resoiratory Protection-The GA respiratory protection program provides direction for use of National Institute for Occupational Safety and Health /Mine Safety and Health Administration (NIOSH/MSHA) certified equipment. This program is administered by GA Health Physics in consultation with GA Industrial Hygiene. NIOSH/MSHA approved equipment are air purifying respirators which include full face piece assemblies with air purifying elements to provide respiratory protection against hazardous vapors, gasses, and/or particulate matter to individuals in airborne radioactive materials areas. Individuals may be required to use continuous or constant ficw full-face airline respirators for work in areas with actual or potential airborne radioactivity. The Manager, HP, or designee will also ensure that the respiratory protection program meets the requirements of 10 CFR Pan 20, subpan H. p) y Access Control-The Restricted Area (RA) will be properly posted and access controlled so as to prevent unauthorized access. 4.8.2 Audits, Inspections, and Management Review During decommissic,ning, aspects of the work may be assessed by the GA Quality Assurance Department, through audits, assessments, and inspections of various aspectc of decommissioning performance, including HP. Formal audits of the GA Health Physics program are conducted annually in accordance with GA HP procedures, and the requirements of 10 CFR 20. These audits will normally include aspects of all ongoing decommissioning projects.. Inspections will be performed on procured and fabricated items to verify compliance with the controlling documents. Inspections will be conducted by qualified inspectors in accordance with inspection plans approved by a Quality Engineer. Discrepancies will be documented on a Non-conformance Repon, which will be dispositioned by a Quality Engineer. Additional assessments or management reviews may be performed when deemed appropriate by the Project 4-8

t Manager, the Principle Investigator and/or the Director, LSNC. 4.8.3 Health Physics Equipment and Instmmentation GA has selected HP equipment and instrumentation suitable to pennit ready detection and quantification of radiological hazards to workers and the public, and to ensure the validity of measurements taken during remediation and final release surveys. The selection of equipment and instrumentation to be utilized is based upon detailed knowledge of the radiological contaminants, concentrations, chemical forms, and chemical behaviors that are expected to exist at the facility / site being decommissioned as demonstrated during radiological characterization, and as known from process knowledge of the working history of the Facility. Equipment and instrumentation selection also takes into account the working conditions, contamination levels, and source terms that are reasonably expected to be encountered during the performance of decommissioning work as presented in this Plan. ) 'Ihe following sections present details of the equipment and instrumentation presently selected for use during oecommissioning. It is anticipated that through retirement of worn or damaged equipment / instrumentation or increases in quantities of available components or instruments, that new technology will permit upgrades or, at a minimum, like-for-like replacements. GA is committed to maintaining conformance to minimum O performance capabilities stated in this Plan whenever new components or instruments are selected. 4.8.3.1 Criteria for Selecting Equipment and Instrumentation for Conduct of Radiation and Contamination Surveys and Perso:mel Monitoring A sufficient inventory and variety of instrumentation will be maintained at GA to facilitate effective measurement of radiological conditions and control of worker exposure consistent with ALARA, and to evaluate suitability of materials for release to unrestricted use. Instrumentation and equipment will be capable of measuring the range of dose rates and radioactivity concentrations expected to be encountered during conduct of rer fiation and dismantlement of a facility (if applicable); as well as for final survey 1 measurements. HP staff will select instrumentation that is sensitive to the minimum detection limits for the particular task being performed, but also with sufficient range to ensure that the full spectrum of anticipated conditions for a task or survey can be met by the instrumentation in use. Consumable supplies will conform to manufacturer and/or regulatory recommendation to ensure that measurements meet desired sensitivity and are valid for the intended purpose. 4.8.3.2 Storage, Calibration, Testing, and Maintenance ofHealth Physics Equipment and Instrumentation 4-9

Survey instruments are stored in a common location under the control of HP personnel. A program to clearly qb identify and remove from service any inoperable or out-of-calibration instruments or equipment as described in HP procedures will be adhered to throughout all decommissioning activities. Survey instruments, counting j equipment, air samplers, air monitors, and personnel contamination moniton f 31 be calibrated at j license-required intervals or manufacturer-prescribed intervals (if shorter frequency) against standards that are NIST traceable in accordance with Calibration Laboratory procedures, HP procedures, or vendor technical manuals. Counting equipment operability will be verified daily when in use. 4.8.3.3 Specific Health Physics Equipment andInstrumentation, Use and Capabilities i Table 4-1 provides typical HP equipment and instrumentation available on the GA site for decommissioning i projects. Radiation Surveys-Radiation, airborne radioactivity, and contamination surveys during decommissioning activities will be conducted in accordance with approved HP procedure (s), as needed. The purposes of these surveys will be to (1) protect the health and safety of workers,(2) protect the health and safety of the general public, and (3) demonstrate compliance with applicable license, federal, and state requirements, as well as Decommissioning Plan commitments. HP personnel will verify the validity of posted radiological warning signs during the conduct of these surveys. Surveys will be conducted in accordance with procedures utilizing survey instrumentation and equipment suitable for the nature and range of hazards anticipated. Equipment and instrumentation will be calibrated and, where applicable, operationally tested prior to use in accordance with procedural requirements. Routine surveys are conducted at a specified frequency to ensure that contamination and radiation levels in unrestricted areas do not exceed license, federal, state, or site limits. HP staff will also perform surveys during decommissioning whenever work activities create a potential to impact radiological conditions. 4.9 Processes and Systems for Handling, Storing, and Disposing of Radioactive Waste The processes of decontamination and remediation (in Approaches B and C) may result in solid and liquid radioactive waste, mixed waste, and hazardous waste. Soil remediation, if require, could also result in solid radioactive waste. The radioactive waste will be contact-handled low-level waste. This waste will be handled (processed and packaged), stored, and disposed of in accordance with applicable sections of the Code of Federal Regulations, Code of California Regulations, San Diego County and City Regulations, disposal site i Waste Acceptance Criteria, respective State Administrative Codes, GA Licenses and Permits, and the applicable decommissioning implementing plans and procedures. p Radioactive waste management incorporates disciplines that assure all processes and systems for handling, U storing, and disposing of radioactive waste comply with applicable regulatory requirements. This includes 4-10

waste minimization or volume reduction, radioactive and hazardous waste segregation, waste characterization, disposa' site waste acceptance criteria certification, and packaging and shipping compliance with applicable Code of Federal Regulations (10 CFR,40 CFR, and 49 CFR). 5 4.9.1 Conformance to Requirements of 10 CFR 61,10 CFR 71, and 10 CFR 20.2006, 10 CFR 61, Licensing Requirementsfor Land Disposal ofRadioactive Waste, Subpart D-Technical Requirements for Land Disposal Facilities, establishes minimum radioactive waste classification, characterization, and labeling requirements. These requirements will be met through the implementation of Project Packaging and Characterization Procedures, Disposal Site Certification Plan (s), and Quality Assurance Program Documents. Training will be provided for Project Waste Certification Officials, Waste Packaging personnel, and Waste Characterization personnel to assure conformance to applicable 10 CFR 61 requirements as stated in the specific implementing procedures and plans. Quality Assurance conducts audits and surveillances per the Quality Assurance Program Doc'iment based on ASME NQA-1-1989, which confirms conformance with Disposal Site Acceptance Criteria and applicable 10 CFR 61 requirements. 10 CFR 7l, Packaging and Transportation ofRadioactive Afaterial, establishes requirements for packaging, shipment preparation, and transportation oflicensed material. The radicsv.ive waste that will be packaged and shipped will be LSA material. GA is authorized, as an NRC and State of California Licensee, to receive, possess, use, and transfer licensed special nuclear material (<350 grams), by-product and source materials. And, GA is authorized by its NRC license to possess and transfer licensed special nuclear material. 10 CFR 71 requirements will be met through the implementation of Project and GA's Nuclear Waste Processing Facility (NWPF) Packaging and Shipping Procedures. Training will be provided for Waste Packaging Personnel and Waste Shipping Personnel to assure conformance to applicable 10 CFR 71 requirements. LSNC's Nuclear Material Accountability Department provides compliance oversight and off-site shipment notices. Quality Assurance will confirm conformance to Subpart H (Quality Assurance) requirements through the implementation of the GA Quality Assurance Manual and Quality Assurance Program Documents. Title 10 CFR 71 applicable Quality Assurance requirements apply to design, purchase, fabrication, handling, shipping, storing, cleaning, assembly, inspection, testing, cperation, maintenance, repair, ami modification of corr.ponents of packaging which are important to safety. 10 CFR 20.2006. Transferfor Disposaland Afanifests, establishes requirements for controlling transfers of low-level radioactive waste intended for disposcl at a sand disposal facility; establishes a manifest tracking system; supplements requirements concerning transfers and record keeping; and requires generator certification that transported materials are properly classified, described packaged, marked, and labeled, and are in proper condition for transport. These requirements will be met through the implementation of Project and NWPF Packaging and Shipping Procedures with the oversight of GA's LSNC's Nuclear Material Accountability Department. O 4-11 l

4.9.2 Conformance to Disposal Site Requirements V Radiological and mixed wastes will be disposed of at designated disposal sites per the applicable Disposal Site's Acceptance Criteria. Certification Plans, Waste Minimization Plans, Quality Assurance Plans, etc. and associated implementing procedures will reflect the characterization, processing, packaging and transportation requirements specified in the applicable Disposal Site Acceptance Criteria. Appropriate application to designated disposal sites will be conducted including, as required, certification plans, qualification statements, assessments, waste stream analysis, evaluations and profiles, transportation plans, I and waste stream volume forecasts. Waste characterization, waste designation, waste traceability, waste segregation, waste packaging, waste minimization, and quality assurance and training requirements of the designated disposal sites will be incorporated into decommissioning project plans and implementing procedures to assure conformance to disposal site requirements. 4.9.3 Conformance to State Requirements Generator State (California) and Treatment / Storage /Dir;osal Facility States (Nevada, Utah, etc.) ] mquirements for radioactive and mixed waste management will be incorporated into individual decommissioning project plans and/or procedures and/or Nuclear Waste Processing Facility procedures, as necessary to assure conformance with applicable state regulations, licenses, and permits. Applicable state mgulations include California Hazardous Waste Management Regulations (Califomia Code of Regulations, Title 22), and Utah Department of Environmental Quality Rules (R313) for the control of ionizing radiation reflected in Envirocare's Utah Radioactive Material License, UT 2300249. Decommissioning projects will conform to GA's CAL-DHS, Radiological Health Branch (CAL-RHB) License (0145-80) to possess and use source and byproduct materials as directed by California Code of Regulations, Title 17. GA will also conform to the Califomia Environmental Protection Agency (CAL-EPA) requirements (EPA ID Number CAD 067 638 957) which permit / authorize GA to operate as a generator of hazardous waste, to treat hazardous waste on site under Ca'ifomia's Tiered Permit program Conditional Authorization (CA) or Conditional Exemption (CE) tiers, and to manage radioactive mixed wastes under Interim Status granted by the State of California Department of Toxic Substances Control (CA-DTSC). Decommission activities will also conform to the GA Health Permit to manage hazardous materials issued by tia County of San Diego Department of Health Services Hazardous Materials Management Division (SD-DHS-HMMD). Decommissioning procedures will also incorporate Metropolitan Industrial Waste Program (MIWP) requirements for the discharge of industrial waste waters into the sanitary sewer system managed by the City of San Diego (San Diego Metropolitan Water District). 4.9.4 Waste Characterization Projections and Volumes Waste generated from the various Individual facility / site decommissioning projects will vary greatly. The 4-12

_. - = A i i l. 10CFR61 radioactive waste classification anticipated for the various wastes is " Class A". The majority of !be radioactive wastes that will be packaged and shipped will be LSA material. It has been estimated that approximately 80,000 ft' oflow level waste will be generated during the course of the various 4 decommissioning projects. 3 4 i a f i 1 'l i j i 2 1 a i 4 i 4 f -1 1 1 1 I i 4-13

U C-m TABLE 4-1: TYPICAL LIST OF INSTRUMENTS USED DURING D&D PROJECTS F.ATEMETER DETECTOR RANGE (CPM) EFFICIENCY BACKGROUND DESCRIPTION (com) LuGJm Ludlum Model 43-37 gas Four Linear Ranges a = 20.15% Varies accordog Active Probe Area = 434cm

• The detector and ratemeter are combined and Model 2221 rvr.,i.v e (434 cm ')

0 - 500,000 & One Th-230 to surface being mounted on a rou around cart. The instnr it features a static-flow system, SN 97817 Alpha detector Log 50 - 500,000 scanned. quick connects, a portable gas bottle and a means to acqust the height of the SN 97817 See Tab 6e 4 detector f om the floor for optimum pmiv.n Ence. LuCJm Ludlum Model 43-37 gas Four Linear Ranges p = 21% Varies accordng Active Probe Area = 434cm

• The detector and ratemeter are combined and Mcdel 2221 eupviisu, e (".34 cm ')

0 - 500,000 & One St-90 to surface being mounted on a rod around cart. The instrument features a static-flow system, SN 73701 Beta detector Log 50 - 500,000 scanned. quick connects, a portable gas bottle and a means to adtust the height of the SN 83265 See Table 4 detector from the floor for optimum Wiirina LuCJm Ludlum Model 43-68 Four linear ranges 34.5 % Varles accorong 100 cm8 gas flowevpvilivie counter. Model 2221 100 cm8 propor%onal 0 - 500,000 & one St-90 to surface being SN 88423 counter SN 119444 log 50-500,000 scanned } See Table 4 Lucam Ludlum Model 43-5 Four Ranges 14.59% C Active Probe Area = 50 cm ' Mcdel 12 Alpha Scotillator 0 -500,000 Th-230 S/N 73936 ZnS(Aa) S/N 67311 Techmcal Technscal Associates Three Ranges 25.6% 40-120 @m Use to locate potential sources of D/y contamination on the floor and various Associates geiger mueHer pancake 0-50,000 Sr-90 items / equipment Window thickness is - 1.5 cm

• TBM 15 detector - T1190 (-15 8

cm active probe area) Ludlum RCA 6199 coupled to a Five Ranges N/A 10-18 pR/hr 1 inch x 1 inch Nal (TI) scintinator is mounted intemaNy Model 19 Nal(TI) Scintitator 0 - 5 mReh Micro-R Meter S/N 39764 Ebertine RO-2, lonization Chamber RO-2 0-5 R!hr N/A RO-2 02 mR/hr Used for beta / gamma exposure measurements. RO-2 and RO-RO 2A 0-50 R/hr RO-2A 20 mRehr 20 RO-20 0-50 R/hr RO-20 0 2 mR/hr i Ebartine SAC-4 Wipe Cmiter w/ ZnS 6 Decade scaler -40% 4 n -0.3 cpm or less Alpha wipe counter i f (Ag).1 Sator Pu-239 making the 47 mm samples (air or smer) t detectable count i rate -0.4 com Ebartine BC-4 Wipe counter w/ shielded 6 decade scaler -40% 4 n minimum Beta wipe r ounter i i GM pancake tube Sr-90 detectable count 47mm (air or smear) rate - 20 cpm High Purity Gamma spcicigmwpy N/A Varles with Variable Gamma measurement of water, air, smear and other media. Germansum system photon energy Detector and sample Canberra S-100 meda 4-14

TABLE TYPICAL LIST OF INSTRUMENTS USED DURING PROJECTS RATEMETER DETECTOR RANGE (CPM) EFFICIENCY BACKGROUND DESCRIPTION (com) SAIC RADeCO Hgh Volume Ak Sampler 1-30 cfm NA NA Hgh volume air sampling for short term ak sampling. H809V HiVot* SAIC RADeCO Low Volume Air Sampler 0.5-3.5 cfm N//< N/A Low volume air sampling for bng term air samphng HD-29A Tacose Neck" Canberra Gas Flow Proportional N/A 26-30 % a < 0.5 Low Level a/ S gas proportional counting system Low Level Detector S < 2.0 alS Counter Model 2404 4-15

L O l Corporate Management Licensing, Safey Decommissioning Corporate ( and Project (s) Quality Assurance i Nuclear Compliance b Nuclear Material ta M y Waste Project j i Health Sa ty neering and Decomrnissioning Statistics and Hea ysics intenance AW a s, MWN p Nuclear Safety Measurement Cont I g I i } t i I I [ t i ~ I i I i }' I I Health Physics Operations i i Techncans Personnel i I I I I I I f I I ) 1 I l a i I i D & D Activities L 5 Figure 4-1 Decommissioning Organization j I . - =. r r

DR. KEITH E. ASMUSSEN O Director, Licensing, Safety and Nuclear Compliance QUALIFICATIONS Ten years in federal and state licensing activities involvir.g the use of radioactive materials More than 25 years of experience in nuclear design, analysis, and management Registered Professional Nuclear Engineer EDU C ATION Ph.D., Nuclear Engineering, Iowa State University of Science and Technology ] M.S., Nuclear Engineering, Iowa State University 1 B.S., Engineering Operations (Industrial Engineering), Iowa State University i EXPERIENCE i GENERAL ATOMICS: 1969 to present 1985 to present. Director, Licensing, Safety and Nuclear Compliance. Responsibilities include administering licenses, liaison with regulatory agencies, and reviewing and approving all work j involving radioactive material for compliance with applicable regulations and license conditions. In addition, coordinates and administers special nuclear material control, nuclear safety, health physics, and industrial safety programs. 1979 to 1985. Manager, Fort St. Vrain (FSV) Fust Engineering. Directed an the technical analyses i O required to design, manufacture, and license e:SV reload segment fuel. Other responsibilities in-cluded fuel accountability, core reactivity monitoring and monitoring the performance of the core and fuel. Revised technical specifications for the FSV reactor and obtained NRC release for unrestricted full power operation. Worked closely with licensing serconnel fr Public Service Company of Colorado on a variety of issues involving personne. Iction wit: 4f, 1973 to 1979. Site Physicist, High Temperature,.aas-cooled haacwr (HTGR) Fuel Engineering. Responsibilities involved planning, coordinating, and participating in the initial fuel loading, subcritical testing, zero power physics testing and nse-to-power testing. Coordinated all testing (in-pile and out-of-pile) related to resolving the FSV core temperature fluctuation problem. 1969 to 1973. Senior Reactor Physicisr. Performed nuclear fuel management analyses, reactor physics calculations, and themMI and fuel performance calculations. O

VIRGIL J. BARBAT Manager, Engineering and Facility Maintenance QU ALIFIC ATIONS Thirty-two years experience in engineering, research, technical management, and program + management using multiple engineering disciplines including developing designs, test programs, and testing a variety of rotating machinery components. Management experience includes operations, field installation, testing, and commissioning of complex systems. Proficient in program management software packages. Registored Professional Mechanical Engineer, California E D U C A TI O'd M.S., Nuclear Engineering, University of Califomia at Berkeley,1963 B.S., Engineering Physics, University of Michigan, Ann Arbor,1961 EXPERIENCE Engineering and Maintenance Manager, Hot Cell Facility Decontamination and Decommissioning (D&D) Project. Responsible for engineering tasks during the D&D Characterization Phase and facility maintenance. Tasks included logistics planning for all tasks at the Hot Cell Facility. Assistant Director, Radiation Services, TRIGA Group. Licensed Senior Reactor Operator. Supervised nine senior nuclear reactor operators performing all facets of nuclear research reactor operations and maintenance. Prepared emergency procedures for reactor facility, NEPA/ OSHA Compliance Plan for i c [] fuel fabrication facility, and contributed to reactor facility standard operation procedures. Project Manager, TRIGA Projects, TRIGA Group. Site Manager responsible for installation and acceptance testing of equipment at the Radioisotope /Radiopharmaceutical Facility in Jakarta, Indonesia. Supervised GA and GA's subcontract engineers and craft workers from Indonesia. Provided guidance to the staff in Health Physics compliance procedures. Site Manager responsible for installation and acceptance testing of on-destructive inspection equipment for military aircraft at the McClellan Air Force Base Nuclear Radiation Center. Extensive customer and subcontractor interface required for task. Section Manager, Manufacturing Engineering Section, Defense Logistics Support Division. Managed 15 engineers responsible for verifying the manufacturing capabilities of altemate sources of supply for jet engine parts for the Air Force. Project Manager, Torrey Pines Technology Division. Managed a wide variety of engineering services contracts for utilities with nuclear reactors, including: human factors reviews of control room design and power plant standard and emergency operating procedures, and motor operated valve assessment. Staff Engineer, Systems Engineering, Fort St. Vrain (Nuclear Power Plant) Project. Technical responsibility for analyzing primary and secondary side power plant performance during plant start-up. Staff Engineer, Rotating Machinery, Power Reactor Projects. Responsible for testing rotating machinery components. Managed a small group of test engineers. O

GEORGE C. BRAMBLETT Project Manager, D&D QUALIFICATIONS Thirty-six years of experience in project and engineering management, plant systems engineering, thermodynamic systems analysis and simulation. Twenty-three years of nuclear experience at General Atomics (GA). Registered Professional Engineer Mechanical and Nuclear, California i a l EDUCATION i Certificate, Executive Program for Engineers and Scientists, University of Califomia at San Diego, 1990 M.S., Engineering, University of Califomia at Los Angeles,1964 B.S., Engineering, University of California at Los Angeles,1959 EXPERIENCE Project Manager, Hot Cell Facility Decontamination and Decommissioning (D&D) Project, responsible for planning and direction of waste removal and D&D of the GA Hot Cell Facility under a cost-shared contract with U.S. Department of Energy (DOE). Director, Commercial MHTGR Project, responsible for engineering,' project, and support functions under the DOE contract for the modular high temperature gas-cooled reactor power plant design. Manager HTGR Project Operations, responsible for meeting HTGR program objectives under the DOE contract. Planned, organized, and directed work to develop a design which meets requirements in a manner consistent with company policies. Manager, Systems Engineering Department, responsible for HTGR plant systems analysis. safety analysis, and design of the primary coolant system as well as systems integration. Project Manager, responsible for Fort St. Nrain plant-related engineering services. Section Leader, responsible for performance studies and emergency cooling analysis for the Fort St. Vrain plant. Also performed HTGR power plant cycle optimization, system performance, and transient analysis for large plant designs. Staff Engineer, responsible for rocket engine system performance and transient analysis supporting the SATURN-APOLLO project and other advanced rocket engines at Rockwell Intemational, Inc. O v

PAUL R. MASCHKA HEALTH PHYSICS SUPERVISOR l l QUALIFICATIONS: Thirty-six years experience in radiation safety for research and development working with a large number of radioactive isotopes, both sealed and unsealed, in the form of aerosols, powders, liquids, solids, and several different radiation producing machines, Provided support and assisted in the development, design, construction and testing of facilities and devices that used radioactive sources, X-Ray machines, neutron radiography devices, gamma and neutron irradiators and linear accelerators. Prepared Broad scope license applications for the State of California, and Special Nuclear Materials license applications for the Nuclear Regulatory Commission. Created computer models for registration applications for X-Ray cabinets with the FDA and for registration of radiation devices with the NRC and the State of Califomia. Health Physics Supervisor for the decontamination and dismantlement of General Atomics' nuclear fuel fabrication facility, supervising a staff of 28 Health Physics Technicians and administrative personnel. Helped to prepare and edit the Phase i Pre-Dismantlement Report for submittal to the NRC, and prepared the first draft and helped complete the Phase ll Final Survey Report submitted to the NRC. EDUCATION: Two years of higher education at Creighton University in Omaha, Nebraska, 1953-1955. Completed the U.S. Army's 48 week Nuclear Power Training Course at Ft. Belvoir, Virginia,1961. Completed the SARA 40-hour Hazardous Waste (HAZWOPER) training,1995. EXPERIENCE: GENERAL ATOMICS March 1992 to Present Health Physics Supervisor responsible for: radiations safety inspections and ALARA evaluations, writing Health Physics Procedures and Radiological Safety Training Manuals, conduct Radiation Safety Training classes, respirator use training, and respirator fit tests. Health Physics Supervisor for the decontamination and dismantlement of General Atomics' nuclear fuel fabrication facility. Supervised a staff of 28 Health Physics Technicians and administrative personnel. Helped to write and edit the Phase l Pre-Dismantlement Report. Prepared the first draft and completed the Phase 11 Final Survey Report that was submitted to the NRC after dismantlement of the facility. SCIENCE APPLICATIONS Dec.1988 to Feb.1992 INTERNATIONAL CORPORATION (SAIC) Radiation Safety Officer (RSO) for the Advanced Technology Sector of SAIC responsible for: writing a radioactive materials license application for a Broad scope License from the State of Califomia, registration of X-Ray cabinet systems with the FDA, and assuring compliance with the various State ( ) and Federal Regulations,. Developed a computer model for registration of radiation devices with the NRC and State of Califomia. Was involved in R&D projects pertaining to the development of X-Ray

inspection cabinets and contraband detection devices. { } Prepared Radiation Safety Training Manuals and conducted Radiological Safety Classes. IRT CORPORATION May 1973 to Dec.1988 Radiation Safety Officer (RSO) and Nuclear Materials Manager for IRT Corp. responsible for: writing radioactive materials license application for a Broad scope License from the State of Califomia, and a Special Nuclear Materia!s License application from the NRC, the safeguard and accountability of special nuclear materials and for criticality safety for projects using fissile materials which included uranium-233 and plutonium, assuring compliance with the various State and Federal Regulations, and for all aspects of the radiation safety program. Wrote radioactive materials license applications to the State of Califomia and other States as a customer service. Developed a computer model for the registration of X-Ray cabinet systems with the FDA, Was responsible for designing the radiation shielding for X-Ray cabinets, X-Ray lead rooms, gamma emitting radioactive isotopes, source holders and shields for neutron emitting radioactive isotopes, and a neutron and gamma irradiation facility at that utilized 110 Ci (200mgm) Cf-252 and 6000 Ci Co-60. Prepared Radiation Safety Training Manuals and conducted Radiological Safety Classes for company employees and customer personnel. GENERAL ATOMICS DEC.1963 TO MAY 1973 1 l l Health Physics Technician: during this time at GA I was assigned the responsibility for radiation safety at the each of the various facilities at GA. U.S. AIR FORCE MARCH 1960 TO DEC.1963 Completed the U.S. Army Reactor Operators Training Course at Ft. Belvoir, Virginia. Worked as Health Physics Technician at two nuclear power plants and as reactor operator and shift supervisor j at the U.S. Navy's nuclear power station in McMurdo, Antarctica. j

3 VLADIMIR NICOLAYEFF Manager, Environmental Quality Assurance QU ALIFIC ATIONS Twenty-three years of experience in nuclear quality assurance and engineering Registered Civil Engineer, State of California No. C 23142, since 1973 Certified Quality Engineer, American Society for Quality Control No. 7949, since 1980 Certified ASME NOA-1 Lead Auditor, by GA, since 1983 ED U C ATION M.S., Civil Engineering, University of California, Berkeley,1968 B.S., Civil Engineering, University of California, Berkeley,1967 EXPERIENCE GENERAL ATOMICS 1972 to present: 1993 to present: Manager of Environmental Quality Assurance (OA). Responsible for managing OA activities on several projects to the requirements of ASME-NOA 1,10 CFR 50 Appendix B, and 10 CFR 71, Subpart H. Principal projects include the following: Decontamination and Decommissioning of GA Hot Cell. Responsible for development and maintenance of the OA and waste certification programs for the project including preparation of the QA Plan and review of all project documents. Responsible for maintaining a training program P for project personnel, OA inspections, audits and surveillances, and for certification of waste shipments. Decontamination and Decommissioning of GA SVA Fuel Fabrication Facility. Took over QA responsibilities for this project during the dismantlement phase, which included demolition of the building, sampling analysis of potentially contaminated soil and ground water, and shipping of nuclear waste to the Nevada Test Site and to Hanford, Washington. Processing and Disposal of Vlaste from New Production Reactor Fuel. Responsible for QA and Waste Certification Program for the project including sampling, analysis, characterization, and stabilization of waste, preparation of working procedures, characterization reports, and shipment of waste. Legal Weight Truck Cask. Responsible for QA during design, fabrication of half-scale model, and qualification testing of a modem cask-tractor-trailer system used for transportation of highly radioactive spent fuel from nuclear plants to repositories. 1972 to 1993: Manager of Reactor Quality Assurance and other QA and Engineering positions. Responsible for managing QA activities pertaining to design, fabrication, and testing of fuel and components for nuclear reactors, and construction of nuclear facilities. Responsible for QA during design, fabrication, construction, and acceptance testing of a neutron radiography facility. Responsible for QA on many nuclear projects. Performed design, analysis and testing of structural components for nuclear power plants. UNIVERSITY OF CALIFORNIA, BERKELEY 1968 and 1971 TO 1972. Development Engineer at the Structural Materials Laboratory. Assisted faculty with research on concrete and soils. AU /

LAURA R. QUINTANA C) GA HEALTH PHYSICS MANAGER, RSO QUALIFICATIONS: Twenty years experience in Health Physics. Fifteen years professional and managerial experience in health physics for a wide variety of nuclear facilities including nuclear fuel fabrication, uranium conversion, hot cell, TRIGA reactors, radiochemistry labs, Y-90 production, bioscience labs and nuclear waste processing. Over 12 years of decommissioning experience at General Atomics including former waste processing, fuel development, fuel fabrication, facilities as well as soil remediation projects. Knowledge of NRC regulations (including 10CFR19,10CFR20,10CFR70), DOT regulations (49CFR), and DOE Orders pertaining to radiation safety requirements. Prepared radiation safety and environmental monitoring sections for GA's NRC Special Nuclear Material License renewal application and GA's State of California Broad Scope Radioactive Materials License renewal application. Assisted with obtaining State of California Radioactive Material Licenses for two biotechnology companies. Possession of an active DOE "Q" clearance and an active NRC "L" clearance. O zauc^rio": Professional Certificate, Site Assessment and Remediation, UCSD, Spring 1996. Professional Certificate, Hazardous Materials Management, UCSD, Winter 1996. M.S., Applied Nuclear Science (Health Physics), Georgia Institute of Technology, December 1979. B.S., Biology, New Mexico Highlands University, June 1976. 1 EXPERIENCE: GENERAL ATOMICS May 1982 to Present Health Physics Manager and Radiation Safety Officer for General Atomics -- Manage the Health Physics group providing radiation safety services to various nuclear facilities at General Atomics (GA) including HTGR fuel fabrication for uranium and thorium fuel, TRIGA fuel fabrication, hot cell, TRIGA reactors, radiochemistry labs, Y-90 production, bioscience labs and nuclear waste processing. Implemented the new 10CFR20 regulations for GA. Develop health physics procedures. Develop and present radiation safety courses. Inspect and audit facilities. Maintain a health physics counting room for radioactive analysis of various media including low-level alpha / beta proportional counting systems, liquid scintillation counting and gamma spectroscopy. Other responsibilities include the review and approval of all activities involving radioactive material and/or radiation machines, providing external and internal nionitoring to workers, air sampling in the workplace, efiluent monitoring, environmental monitoring and emergency planning.

- -. -. - -. = q Responsible for ensuring compliance with 10CFR19,10CFR20, applicable 10CFR70 and DOT V regulations, as well as GA's NRC and State license conditions and requirements dealing with radiation safety. Interface with inspectors and other staff:nembers from the NRC, State of California Department of Health Services, DOE, American Nuclear Insurers, and other outside agencies. Have provided corporate oversight at Sequoyah Fuels Corporation (a uranium conversion facility) since 1988, including performing compliance inspections and ALARA audits, auditing health physics procedures and periodically reviewing the Contingency Plan and Implementing procedures. Have provided health physics services for the decontamination / decommissioning of various facilities at General Atomics including experience a Nuclear Waste Processing Facility, removal of underground storage tanks, an HTGR fuel manufacturing facility, a Y-90 production f. :lity and science laboratories. Have written or assisted in writing final survey reports in support of requests to the NRC and/or the State of California for release to unrestricted use. THE SALK INSTITUTE February 1980 to May 1982 Assistant Radiation Safety Officer - Assisted in the implementation of the radiation safety program for the use of radioisotopes (H-3, C-14, P-32,1-125 and a multi curie Co-60 source). Radiation Safety Officer - Responsible for the radiation safety program. Assisted in the radioactive material licensing of two affiliated companies. OAK RIDGE NATIONAL LABORATORY Uune 1976 to Seotember 1978) Worked as a summer intern (6/76-10/76) in the Environmental Science Division and laterjoined the Environmental Monitoring Group of the Health Physics Division as a Health Physics Technician (10/76-9/78). Collected and prepared environmental samples for counting, counted samples in the laboratory and assisted in a study of radioactivity in foodstuffs. LOS ALAMOS NATIONAL LABORATORY Summers of 1975 and 1976 Environmental Monitoring Group summer student-- Collected and processed environmental samples for counting. Conducted a study of the Cs-137 concentrations in lichen in Mortandad Canyon. PROFESSIONAL ASSOCIATIONS AND OTHER INFORMATION: Member, Health Physics Society Member, American Nuclear Society

1 JUDD M. SILLS Manager, Health Physics QUALIFICATIONS Twenty-three years of experience in the area of Health Physics management, research, and technical support Certified Health Physicist, Comprehensive, by the American Board of Health Physics $DUCATION NRC Workshop on Site Characterization for Decommissioning M.S., Radiological Physics and Health Fhysics, Colorado State University,1980 B.S., Biological and Physical Science, Colorado State University,1974 EXPERIENCE GENERAL ATOMICS, SAN DIEGO, CA: 1993 to Present. Health Physics Manager, Hot Cell Facility Decommissioning Project. Provides management and professional direction for all aspects of Health Physics for the decommissioning of the General Atomics Hot Cell Facility. Responsible for the Decommissioning Plan, the facility radiological characterization, direction of the project Health Physics staff, and development of al Health Physics procedures for the project. Also provides technical assistance to the corporate Health Physics program. ARIZONA PUBLIC SERVICE COMPANY, PALO VERDE NUCLEAR GENERATING STATION, PHOENIX, AZ: 1987 to 1993. Directed the activities of Unit Health Physics staff in provision of radiation protection services for all aspects of nuclear power plant operation. Interfaced with regulatory agencies in aspects regarding the Unit radiological performance. Coordinated and performed corporate Health Physics program assessments. PUBLIC SERVICE COMPANY OF COLORADO, FORT ST. VRAIN NUCLEAR GENERATING STAT /ON, PLATTEV/LLE, CO: 1981 to 1987. Supervised the Technical Services Unit and directed the site activities in the areas of reactor engineering, license regulatory compliance review, computer services, operating experience review, and emergency preparedness. Conducted the reactor startup testing program, core physics, accountability of all source and special nuclear material. STONE AND WEBSTER ENGINEERING CORPORATION, DENVER, CO: 1980 to 1981. Conducted the occupational radiation protection program for the Denver Operation Center and provided emergency planning consulting services and emergency plan development assistance to several nuclear utilities and to the State of Califomia. SCIENCE APPLICATIONS INC., SCHAUMBERG, IL 1979 to 1980. Developed large-scale software modifications to the Consequences of Reactor Accident Code (CRAC). Also responsible for initial siting studies for the Waste Isolation Pilot Plant. COLORADO STATE UNIVERSITY, DEPARTMENT OF RADIOLOGY AND RADIATION BIOLOGY, FORT COLLINS, CO: 1976 to 1979. Conducted research in the area of latent effects from radiation. 1972 to 1974. Laboratory Technician on latent radiation effects project. U. S. NAVY - MARE ISLAND NAVAL SHIPYARD, VALLEJO, CA: 1974 to 1976. Senior Health Physics Technician.

I p

5. APPROACHES TO DECONTAMINATION AND DECOMMISSIONING V

A summary of the GA sites to be decommissioned is provided in Table S-1, which provides a short description of each facility, the type of activity, the radioactive material used, the status and current activity, the regulatory jurisdiction (NRC and/or State of CA), whether ground contamination is suspected, the anticipated D&D effort and approach to be used, and the final survey anticipated to be required. These approaches are summarized below and followed by detailed descriptions of each approach. Approach A: Confirmation Survey or Scoping Survey is needed. If no contamination is found, no further action is needed. Requires only the removal of sealed radioactive sources. No facility contamination is likely due to the form of the radioactive material used in the facility (sealed or encapsulated sources, packaged material, form unlikely to become airborne, etc.). Approach B: " Minor" clean-up required. Removal of radioactive material (sources) is needed. Removal of contaminated equipment. Decontamination may include cleaning or 4 removal of contaminated hoods, ducts, and plenums. Aggressive decontamination of facility surfaces may be required (scabbling or otherwise abrading the surface), i The area (s) requiring aggressive decontamination are localized and is limited to a l few small labs and/or rooms. q \\> Approach C: " Major" clean-up required. Removal of radioactive material (sources) is needed. Removal of contaminated equipment. Decontamination may include cleaning or removal of contaminated hoods, ducts, and plenums. Aggressive decontamination of facility surfaces will be required (scabbling or otherwise abrading the surface). Measures to control airborne radioactivity are likely to be required and air monitoring is likely to be required Facility contamination is widespread. Approach to Ground Contamination: Soil sampling is required in order to determine if the area is "affected" or i I " unaffected". If soil is known to be contaminated (above background levels), a survey of the "affected" area is required after remediation. See Soil Sampling Plan in Section 6.2 of Chapter 6 for details. l l \\ b 5-1

. =. I l l 5.1 APPROACH A - CONFIRMATORY OR SCOPING SURVEY l O Summary Confirmation Survey or Scoping Survey is needed. If no contamination is found, no further action is necessary. May require the removal of sealed radioactive sources. No facility l contamination is likely due to the form of the radioactive material used in the facility (sealed or encapsulated sources, packaged material, form unlikely to become airborne, etc.). Obiectives Perform surveys sufficient to ensure that contamination of the facility / site has not occurred. Prepare a final report which documents the results of the survey, submit the report to the appropriate agency and obtain official release of the facility / site to unrestricted use. holect Pre-requisites 1. Remove all radioactive sources before performing confirmatory surveys. 2. No unsealed sources in a form that could become airborne used in this facility. 3. U-235 remaining in the facility expected to be less than 15 grams for this approach. 4. No contamination is known to be present. O 5. Pr cess and laboratory chemicals will be removed fr m the facility prior to the start of decommissionmg work. 6. A survey plan for the confirmatory survey will be prepared. 7. Class A radioactive wastes, as defined by the Code of Federal Regulations, Title 10, Part 61 10CFR61) will be shipped to an authorized low level radioactive waste disposal site. It is anticipated that no Class B or C radioactive waste will be generated as a result of D&D of any of these facilities with the exception of the TRIGA Reactor Facility. 8. Class A radioactive waste will be shipped by an authorized exclusive-use carrier. 9. Non-radioactive /non-hazardous waste will be removed to local landfills. 10. Hazardous wastes will be disposed of through authorized hazardous waste disposal firms. I 1. This approach requires that the following controls are not required: external or internal radiation monitoring, air monitoring, environmental monitoring, criticality safety, effluent monitoring, respiratory protection. 12. If at any time, contamination of the facility is detected, the area will be reclassified either l OV l 5-2 l l

l i as " minor" or " major" contamination required and Approach B or Approach C, g i U respectively, will be followed. Final Survey and Final Reoort Once all sources of radioactive material have been removed and preliminary surveys in biased locations indicate no contamination of the facility / site, the " unaffected area" survey described in Chapter 5 will be performed. 4 Perform surveys sufficient to ensure that contamination of the facility / site has not occurred. The i confirmatory survey will require a minimum of an " unaffected area" survey. In some cases, a more detailed survey may be performed in order to ensure that all radiation levels and/or soil concentrations meet the release criteria.. Prepare a final report which documents the results of the survey, submit the report to the appropriate agency and obtain official release of the facility / site to j unrestricted use. O O 5-3

l 5.2 APPROACH B - MINOR CLEANUP REQUIRED Summarv " Minor" clean-up required. Removal of radioactive material (sources) is needed. Removal of contaminated e.;uipment. Decontamination may include cleaning or removal of contaminated hoods, dacts, and plenums. Aggressive decontamination of facility surfaces may be required (scab 5'mg or othenvise abrading the surface). The area (s) requiring aggressive decontamination are localized and is limited to a few small labs and/or rooms. Obiectives To the extent possible, decontamination of facility equipment and structural components will be conducted to minimize radioactive waste. Comprehensive post decontamination radiological surveys will be conducted to confirm that the facility meets the approved NRC and State of California approved criteria for release to unrestricted use and documented in a Final Report with a request to release the facility / site to unrestricted use. Project Pre-reouisites 1. Radioactive materials, other than contamination found in process and support equipment, would be removed from the facility prior to the start of decommissioning work. 2. Approach B requires that the total amount of U-235 in the facility has been estimated to be less than 350 grams U-235. Therefore, no criticality controls are required. ]C 3. Approach B requires that no respiratory protection be needed. 4. All salvageable material and equipment will be removed from the facility prior to the start of decommissioning work. 5. Process and laboratory chemicals will be removed from the facility prior to the start of decornmissioning work. 6. Process chemical sources nearby but outside the area designated to undergo decommissioning, will be secured and sources emptied of any contents that might represent a hazard to the project (e.g., toxic or flammable hazards) prior to the start of decommissioning work. 7. Proven decontamination technologies will be used during the decontamination effort. 8. Site characterization will be performed prior to the start of decommissioning sufficient to determine the extent and depth of contamination on facility surfaces and affected soil in the area. 9. In affected areas, surfaces coated with paint or other fixatives will be assumed to be 5-4

l l l contaminated unless sampling and analysis is performed which demonstrates otherwise. O 10. Structures, or portions thereof, that can not be decontaminated will be dismantled by mechanical means and disposed of as radioactive waste. 11. Decontamination of contaminated equipment or other items will be conducted until the cost of further decontamination is judged to override the derived cost benefit. Decontamination will then be terminated and the affected item (s) would be prepared for disposal as radioactive waste. 12. Class A radioactive wastes, as defined by the Code of Federal Regulations, Title 10, Part j 61 (10CFR61) will be shipped to an authorized low level radioactive waste disposal site. It is anticipated that no Class B or C radioactive waste will be generated as a result of D&D of any of these facilities with the exception of the TRIGA Reactor Facility. 13. Class A radioactive waste will be shipped by an authorized exclusive-use carrier. 14. Non-radioactive /non-hazardous waste will be removed to local landfills. l 15. The primary mixed waste (radioactive and hazardous) anticipated will be contaminated lead based paints and contaminated asbestos bearing tile. Environmental Protection Agency (EPA) and waste disposal site requirements for such waste will be met. O 16. Hazardous wastes will be disposed of through authorized hazardous waste disposal firms. j l 17. Existing solidification, absorption, filtration and baling systems would be provided by GA for processing radioactive waste. Radiolocical Characterization A radiological characterization will be conducted to determine the extent, volume and nature of any radioactive contamination in the facility. A secondary objective of the characterization will be to identify any routes by which contamination might have migrated into and beneath facility concrete pads. The characterization will include the selection of several sample locations. These locations will be selected on the basis of suspected contamination, as determined from a review of historical data and/or interviews with knowledgeable persons. Samples of media will be collected under the direction of GA Health Physics. Samples will be identified by listing the name of the area sampled (taken from building floor plans), followed with code describing the sample. Samples will also be assigned a number designating the sequence of samples obtained from any given location. l Samples will be generally taken at or near surface levels within the facility, with a few samples i 5-5

taken at greater depths to assess the extent of contamination penetration. Sampling efforts will also be geared to locating any contamination hidden under paint, plaster, tile, concrete or other coverings. Sampling may include smears, as well as samples of paint, concrete and/or soil. Ifsubsurface contamination is suspected, then concrete core samples will be taken at a number of locations within and outside the facilities. The cores will penetrate concrete slabs and extend approximately three (3) feet into the ground. If contamination is detected at three (3) feet, additional samples beyond three (3) feet will be taken. The number of samples will vary depending on the facility and the number of samples taken outside the facility will be dependent on the " footprint" area of the site to be decommissioned and the potential for soil contamination. Biased sampling based on process knowledge of the locations with the greatest potential for contamination will be performed. The samples will be analyzed for the radioactive contaminants present at the facility. Details of the characterization will be documented in a report and the information will be used to determine the specific decontamination method to be utilized during D&D. Radiological Safety During D&D activities, Health Physics shall implement a radiation safety program commensurate with ongoing activities in accordance with 10CFR20. This program shall include an evaluation of the need for the following coverage: O V 1. External radiation monitoring - A prospective dose evaluation shall be performed to determine the need for external radiation monitoring. Monitoring will be required if individuals are likely to exceed 10% of the applicable limits. External monitoring (i.e., TLD badges) may be performed for information purposes. 2. Internal radiation monitoring - A prospective dose evaluation shall be performed to determine the need for internal radiation monitoring. Monitoring will be required if individuals are likely to exceed 10% of the applicable limits. Internal monitoring may also be performed for information purposes and to confirm the adequacy of the air sampling program. 3. Air Monitoring in work Areas - Air sampling equipment shall be maintained and used where there is a potential for airborne radi.wtivity to be present. At a minimum, this equipment shall consist of a sampling heal, filter, air volume flow measuring device, and pump. The standard method for evaluating the air samples shall be based on removal of the filter and counting on calibrated laboratory counting equipment. Various types of air sampling equipment are available for D&D projects. This equipment includes fixed air samplers, portable air samplers, high volume air samplers and lapel air samplers. Continuous air monitors may be used if needed. Air sampler placement sh'all conservatively represent the worker's breathing zone. Any one sample result exceeding 1 5-6 i 1 1

DAC shall be investigated. O Monitoring for the intake of radioactive material is required by 10 CFR 20.1502(b)if the j intake is likely to exceed 0.1 ALI (annual limit on intake) during the year for an adult worker or the committed effective dose equivalent is likely to exceed 0.05 rem (0.5 mSv) for the occupationally exposed minor or declared pregnant woman. Prospective estimates of worker intakes and air concentrations used to establish monitoring requirements will be based on consideration of the following: The quantity of material (s) handled The ALI for the material (s) being handled The release fraction for the radioactive material (s) The type of confinement being used for the material (s) being handled Other factors that may be applicable HP personnel will use technical judgment in determining the situations that necessitate air sampling regardless of generalized, prospective evaluations done for the Facility. When the work being performed is a continuous process, a continuous sample with a weekly exchange frequency is appropriate, except for situations where short-lived radionuclides are expected to represent a significant exposure. For situations where Cs short-lived radionuclides are important considerations, the exchange frequency will be adjusted accordingly. Longer sample exchange frequencies may be approved by Decommissioning Project HP management for situations where airborne radioactive rnaterial and nuisance dust are expected to be relatively low. Grab sampling for continuous processes may also be approved by GA (or Decommissioning Project) HP management based upon consideration of variability of the expected source term for the facility and process. Grab sampling is the appropriate means of airborne sampling for processes conducted intermittently, and for short duration radiological work that involves a potential for airborne release. 4. Radiation (dose rate) and contamination (removable) surveys - Required during D&D of contaminated areas. Required during final survey. 5. Environmental Monitoring-GA shall maintain environmental monitoring program as described in GA's SNM-696 license. This monitoring shall include effluent monitoring, environmental air sampling, sewage sampling, and external radiation monitoring. 6. Controlled Access-Access to radiation restricted areas shall be controlled for purposes of radiation safety. Posting of areas shall be in accordance with 10CFR20. 7. Protective Clothing - GA shall supply personal protective clothing and equipment to protect 5-7

against airborne contamination, skin contamination or absorbtion, clothing contamination, etc. This clothing and equipment shall be donned at the access area into the restricted area. Health Physics shall specify appropriate protective clothing and equipment based on the existing circumstances. Industrial safety / industrial hygiene may also specify protective equipment needed for a particular operation. Selection of equipment will be based on the degree of hazard presented by the contaminant (s) and the working conditions under which exposure may occur. Personnel entries into radiological contaminated areas will require the use of protective clothing. This clothing will consist of a suitable combination of the following, dependent upon the conditions outlined in the WA or RWP: Heavyweight lab coat Heavyweight canvas, cotton, or cotton / polyester coveralls Heavyweight hoods Plastic calf-high booties Rubber shoc covers Plastic or rubber gloves which may require cloth liners. Tyve'c paper coveralls or plastic rain suit disposable outer clothing Face shield or other protective device 8. Ventilation Systems-AV Personnel exposure to airbome radioactive materials will be minimized by utilizing the following engineering controls: (1) Ventilation devices-in-place or portable HEPA filters or Facility ventilation systems, local exhaust by use of vacuums. (2) Containment devices-designed containers, plastic bags, tents, and glove-bags. (3) Source term reduction-application of fixatives prior to handling, misting of surfaces to minimize dust and resuspension. Ventilation systems shall be maintained to confine hazardous materials. When aggressive decontamination work is in progress, room ventilation shall provide at least four (4) air changes per hour. Quarterly checks shall be performed and pressure differentials shall be maintained to ensure that air flow is from zones of lesser contamination potential to zones of greater contamination potential. Enclosures, including tents, may be used to contain and control airborne contamination in a localized area being decontaminated; the exhaust shall be filtered through HEPA filters as appropriate to the operation being performed. Hoods or other enclosures shall have a face velocity of 150 linear feet per minute over 90% of the opening and be equipped with HEPA filtration systems. Work shall be halted if the average face velocity falls below 100 ft/ min. Air flow measurements for hoods and other enclosures shall be performed at least quarterly and more often if a decrease in air flow is suspected. All 5-8

HEPA systems shall be rated at 99.95% efficient for particulates of 0.3 micron size, be fire resistant and be made of fire proof materials capable of operation at temperatures above 150 degrees F. For ventilation systems, GA shall conduct a visual inspection to verify housing integrity during changing of filters. Weekly checks of the magnehelic gauges to determine if the filters required changing shall also be performed and HEPA filters changed if pressure differentials fall below 4" of water. Prefilters shall be changed when differential pressure indicators indicate a reading greater than 0.9 inches of water.

9. Contamination Control--Contamination control measures that will be employed include the following:

Worker training will incorporate methods and techniques for the control of radioactive materials, and proper use and donning / doffing of protective clothing. Facility procedures incorporate HP controls to minimize spread of contamination during work. Radiological surveys will be scheduled and conducted by HP. Containment devices such as designed containers and plastic bags will be used to prevent the spread of radioactive material. O 1 Physical decontamination of Facility, areas or items. Physical barriers such as Herculite sheeting, strippable paint, and tacky mat step-off pads to limit contamination spread. Posting, physical area boundaries and barricades. Clean step off pads at the entrance point to contaminated areas. 10. Instrumentation - GA maintains a number of instruments for the detection and measurement of radiation. All instruments are calibrated using NIST-traceable sources at least semiannually. I 1. Records - Health Physics will maintain a Records and Reports program which will include maintenance of external and internal monitoring reports, personnel monitoring files, training records, radiation safety inspections, audits, incident reports, Work Authorizations, Radiation Work Permits, and surveys. 12. Inspections-During active D&D activities, the Health Physics Manager, or qualified 5-9

l designee shall conduct an inspection of the work areas on a quarterly basis, document all f Endings in a report and take proper corrective action as needed to correct noted denciencies. 1 Nuclear Criticality Safety Approach B does not require a nuclear criticality program because the quantities in the facilities must be less than 350 grams U-235 total. Accountability and tracking of U-235 will be maintained. Decontamination Methods Decommissioning activities will commence with the removal, transfer, or disposal of all l radioactive materials and radiation sources followed by the transfer, decontamination and/or disposal of all extraneous hardware, loose material and miscellaneous material, items and equipment. Non-load bearing interior walls and structures, as well as interior ceiling supports and materials may also be removed. Items being disposed of as " clean" must meet the NRC and State of California criteria for release 1 to unrestricted use. In addition to the use of existing ducting and HEPA systems, standard decontamination and dismantlement tools, materials, equipment and services, some specialized equipment and services ( may be required as follows: l l HEPA Filtered Ventilation Systems: HEPA filtered ventilation systems may be used to provide contamination control coverage l directed to a specific room or work location and for the collection ofloose (removable) i surface contamination. l-Abrasive Decontamination Eauinment: Surface decontamination operations are expected to be a major part of the overall decontamination effort. Aggressive decontamination methods will be required to remove existing surface coatings such as paints, varnishes, and similar fixatives. Base layers of these surface materials may also need to be removed because of the potential for embedded contamination. Decontamination equipment will be selected on the basis of efficiency and effective I contamination control. Equipment which has been used successfully at GA in the past and may be used in the future include: l Jack-hammering - Jack-hammers may be used to remove contaminated concrete or asphalt from a surface. This method may be used when the area to be decontaminated is O V 5-10 l

small. Scabbling - Scabbling as a decontamination technique on concrete surfaces has a long history of success. The technique uses tools having single or multiple bit piston heads, equipped with multi point tungsten carbide bits. The pneumatically operated tool drives the bits against surfaces, which causes the surface to abrade. Sectioning Eauinment: Plasma Arc Cutting - Large metal pieces, including process equipment (either in preparation for shredding or as volume reduction) may be cut with plasma arc cutting equipment. Flame Cutting - Oxy-acetylene cutting systems for the dismantlement and volume reduction of metal pieces. Mechanical Cutting Equipment - When modification or removal of structural material or equipment is required, it may be accomplished by using powered equipment. The following specialized equipment may be used: Volume Reduction Equinment: Volume reduction of radioactive waste is an important part of the decontamination effort. p Major volume reduction systems and techniques include: d Compactor - Compacts waste into boxes, obtaining a volume reduction factor as high as 10:1, depending on the type of material to be compacted. GA currently has a compactor on site. Core Drilling: Floor surfaces throughout some facilities contain female and male anchor bolts where contamination may be present. The anchor bolts can be, and have been (e.g., SVA Decommissioning Project), removed from the floors by core drilling. The resulting holes can then be checked for radioactive contamination and filled with grout, if levels meet the release criteria. Snecialized Services: Specialized services required in support of decontamination activities included the following: Analytical services for industrial hygiene and radiological safety. Employee training, instrument calibration and emergency preparedness. Transportation of non-radioactive waste to local landfills. 5-11

Transportation of radioactive waste to authorized waste disposal sites. O d Decontamination Approach Decontamination of equipment and other items will be conducted until it is no longer economically feasible, at which point decontamination will be terminated and the item prepared for disposal as radioactive waste. The decontamination approach will use simple and more passive decontamination methods first, advancing to aggressive decontamination methods as needs dictate. Where passive decontamination techniques apply, they include: vacuuming, damp cloth wiping, and to a limited degree washing / scrubbing operations. When the passive methods fail to reduce surface contamination levels to releasable levels, more aggressive decontamination methods, such as abrasive blasting and scabbling, will be used. Portable HEPA filtered ventilation units may be used to augment installed systems capabilities and to serve as an independent means of contamination control. Processing of Radioactive and Non-radioactive Waste Another element of decommissioning will be the management and disposal of waste material. An effective waste management program will be implemented; including the minimization of disposable volumes, as well as reconciliation of waste density and volume in regards to transport regulations and limits. Contaminated equipment will be either decontaminated, released and disposed of as non-radioactive waste at a local landfill, or volume reduced (if practical) and disposed of as radioactive waste. The choice between these two disposal options depends on activity levels, achievable decontamination, personnel exposure and decontamination costs (i.e., ALARA considerations). Radioactive waste may be subjected to various volume reduction techniques, including decontamination, segmentation, shredding and/or compacting. Strict contamination and ventilation controls will be used to prevent the spread of contamination to surrounding areas. To minimize the void volume in packaged waste, consideration will be given to nesting of contaminated piping and large components containing internal voids. Successively smaller diameter piping and tubing could be segmented to identical lengths and neaed together, one inside the other, to form a minimum void volume package for disposal. To further facilitate efficient waste disposal, internally contaminated items that are not easily volume reduced, may be filled with shredded or other contaminated material. Liquid waste generated during decontamination operations may contain relatively small amounts of radioactive and/or chemical contaminants. These liquids may be processed using one of the following methods: 5-12

Solidification - Solidification can be performed at GA's Nuclear Waste Processing Facility (Building 41 and 25). The solidification process consisted of taking approximately 30 gallons of aqueous waste and placing it into a 55 gallon drum where it can be neutralized j with an acid or base,if required. The contents of the drum can then be mixed while adding cement and expanded mica (filler), as needed. The drum can then be allowed to set up with the contents becoming a monolithic mass. Filtration - Filtration of some low level aqueous wastes can be performed on some liquid j wastes. After verification that local, state and federal regulations regarding discharge into the sanitary sewerage system have been met, the treated water can then be discharged and records of each discharge maintained by GA'. Absorption of radioactively contaminated organic liquids such as pump oils, solvents, etc. can be performed with solidification agents acceptable to radioactive waste disposal sites. The resultant i solid material will be packaged in 55 gallon drums. This waste will only be sent to authorized waste disposal facilities. Disposal of Radioactive Waste Radioactive waste from decommissioning activities is currently being shipped to two DOE low level radioactive waste disposal facilities. One is located at the Nevada Test Site and the other is at Hanford, Washington. Only approved disposal sites will be used for GA radioactive waste. ) 4 D () 5-13

5.3 APPROACH C - MAJOR CLEANUP REQUIRED O V Summary " Major" clean-up required. Removal of radioactive material (sources) is needed. Removal of contaminated equipment is involved. Decontamination may include cleaning or removal of contaminated hoods, ducts, and plenums. Aggressive decontamination of facility surfaces will be required (scabbling or otherwise abrading the surface). Measures to control airborne radioactivity are likely to be required and air monitoring is likely to be required. Facility contamination is widespread. Objectives To the extent possible, decontamination of facility equipment and structural components will be conducted to minimize radioactive waste. Comprehensive post decontamination radiological surveys will be conducted to confirm that the facility meets the approved NRC and State of California approved criteria for release to unrestricted use and documented in a Final Report with a request to release the facility / site to unrestricted use. Project Pre-reauisites 1. Radioactive materials, other than contamination found in process and support equipment, would be removed from the facility prior to the start of deco nmissioning work. 2. If the possibility exists that the U-235 remaining in the facility as hold-up in ducting, piping and in process equipment may exceed 700 grams, strict operating controls h (criticality safety requirements) will be implemented during removal of equipment and ducting and during decontamination activities to assure criticality safety. 3. All salvageable material and equipment will be removed from the facility prior to the start of decom.missioning v urk. 4. Process and laboratory chemicals will be removed from the facility prior to the start of decommissioning work. 5. Process chemical sources nearby but outside the area designated to undergo decommissioning, will be secured mnd sources emptied of any content.s that mighi represent a hazard to the project (e.g., toxic or fJammable hazards) prior to the start of decommissioning work. 6. Proven decontamination technologies will be used during the decontamination effort. 7. Site characterization will be performed prior to the start of decommissioning sufficient to determine the extent and depth of contamination on facility surfaces and affected soil in the area. (3) 5-14 1

8. In affected areas, surfaces coated with paint or other fixatives will be assumed to be contaminated unless sampling and analysis is performed which demonstrates otherwise. 9. Structures, or portions thereof, that can not be decontaminated will be dismantled by mechanical means and disposed of as radioactive waste. 10. Decontamination of contaminated equipment or other items will be conducted until the cost of further decontamination isjudged to override the derived cost benefit. Decontamination will then be terminated anL the affected item (s) would be prepared for disposal as radioactive waste. I 1. Class A radioactive wastes, as denned by the Code of Federal Regulations, Title 10, Part 61 (10CFR61) will be shipped to an authorized low level radioactive waste disposal site. It is anticipated that no Class B or C radioactive waste wili be generated as a result of D&D of any of these facilities with the exception of the TRIGA Reactor Facility. 12. Class A radioactive waste will be shipped by an authorized exclusive-use carrier. 13. Norcradioactive/non-hazardous waste will be removed to local landGlls. 14. The primary mixed waste (radioactive and hazardous) anticipated will be contaminated lead based paints and contaminated asbestos bearing tile. Environmental Protection Agency (EPA) and waste disposal site requirements for such waste will be met. 15. Hazardous wastes will be disposed of through authorized hazardous waste disposal Grms. 16. Existing solidiGcation, absorption, Gitration and baling systems would be provided by GA for processing radioactive waste. Radiological Charactenzation A radiological characterization will be conducted to determine the extent, volume and nature of any radioactive contamination in the facility. A secondary objective of the characterization will be to identify any routes by which contamination might have migrated into and beneath facility concrete pads. The characterization will include the selection of several sample locatio... These locations will be selected on the basis of suspected contamination, as determined from a review of historical data and/or interviews with knowledgeable persons. Samples of media will be collected under the direction of GA Health Physics. Samples will be identined by listing the name of the area sampled (taken from building floor plans), followed with a code describing the sample. Samples will also be assigned a number designating the sequence of samples obtained from any given location. 5-15

I t Samples will be generally taken at or near surface levels within the facility, with a few samples p taken at greater depths to assess the extent of contamination penetration. Sampling efforts will also be geared to locating any contamination hidden under paint, plaster, tile, concrete or other L> coverings. Sampling may include smears, as well as samples of paint, concrete and/or soil. Concrete core samples will be taken at a number oflocations within and outside the facilities. The i cores will penetrate concrete slabs and extend approximately three (3) feet into the ground. If l contamination is detected at three (3) fce:, additional samples beyond three (3) feet will be taken. l The number of samples will vary depending on the facility and the number of samples taken outside the facility will be dependent on the " footprint" area of the site to be decommissioned and the potential for soil contamination. Biased sampling based on process knowledge of the locations with the greatest potential for contamination will be performed. The samples will be j analyzed for the rr.dioactive contaminants present at the facility. l Details of the characterization will be documented in a report and the information used to determine the specific decontamination method to be utilized during D&D. Radiological Safety During D&D activities, Health Physics shall implement a radiation safety program commensurate with ongoing activities in accordance with 10CFR20. This program shall include an evaluation of the need for the following coverage: 1. External radiation monitoring - A prospective dose evaluation shall be performed to ( determine the need for external radiation monitoring. Monitoring will be required if individuals are likely to exceed 10% of the applicable limits. External monitoring (i.e., TLD badges) may be performed for information purposes. 2. Internal radiation monitoring - A prospective dose evaluation shall be performed to l determine the need for internal radiation monitoring. Monitoring will be required if individuals are likely to exceed 10% of the applicable limits. Internal monitoring may also be performed for information purposes and to confirm the adequacy of the air sampling program. 3. Air Monitoring in work Areas - Air sampling equipment shall be maintained and used where there is a potential for airbome radioactivity to be present. At a minimum, this equipment shall consist of a sampling head, filter, air volume flow measuring device, and pump. The standard method for I evaluating the air samples shall be based on removal of the filter and counting on calibrated laboratory counting equipment. Various types of air sampling equipment are available for D&D i projects. This equipment includes fixed air samplers, portable air samplers, high volume air samplers and lapel air samplers. Continuous air monitors may be used if needed. Air sampler placement shall conservatively represent the worker's breathing zone. Any one sample result exceeding i DAC shall be investigated. Monitoring for the intake of radioactive material is required by 10 CFR 20.1502(b) if the intake is O 5-16 1

l likely to exceed 0.1 ALI (annual limit on intake) during the year for an adult worker or the committed /^- effective dose equivalent is likely to exceed 0.05 rem (0.5 mSv) for the occupationally exposed minor \\ or declared pregnant woman. Prospective estimates of worker intakes and air concentrations used to establish monitoring requirements will be based on consideration of the following: The quantity of material (s) handled The ALI for the material (s) being handled The release fraction for the radioactive material (s) { The type of confinement being used for the material (s) being handled Other factors that may be applicable HP personnel will use technicaljudgment in determining the situations that necessitate air sampling regardless of generalized, prospective evaluations done for the Facility. When the work being performed is a continuous process, a continuous sample with a weekly exchange frequency is appropriate, except for situations where short-lived radionuclides are expected to represent a significant exposure. For situations where short-lived radionuclides are important considerations, the exchange frequency will be adjusted accordingly. Longer sample exchange frequencies may be approved by Decommissioning Project HP management for situations where airborne radioactive material and nuisance dust are expected to be relatively low. Grab sampling for continuous processes may also be approved by GA (or Decommissioning Project) HP management based upon consideration of variability of the expected source term for the facility and process. Grab sampling is the appropriate means of airborne sampling for processes conducted g intermittently, and for short duration radiological work that involves a potential for airborne release. 4. Radiation (dose rate) and contamination (removable) surveys - Required during D&D of contaminated areas. Required during final survey. 5. Environmental Monitoring-GA shall maintain environmental monitoring program as described in GA's SNM-696 license. This monitoring shall include effluent monitoring, environmental air samplin', sewage sampling, and external radiation monitoring. g 6. Controlled Access-Access to radiation restricted areas shall be controlled for purposes of radiation safety. Posting of areas shall be in accordance with 10CFR20. 7. Protective Clothing - GA shall supply personal protective clothing and equipment to protect against airborne contamination, skin contamination or absorbtion, clothing contamination, etc. This clothing and equipment shall be donned at the access area into the restricted area. Health Physics shall specify appropriate protective clothing and equipment based on the existing circumstances. Industrial safety / industrial hygiene may also specify protective equipment needed for a particular operation. Selection of equipment will be based on the degree of hazard presented by the contaminant (s) and the working conditions under which exposure may occur. .m() 5-17

Personnel entries into radiological contaminated areas will require the use of protective (" clothing. This clothing will consist of a suitable combination of the following, dependent upon the conditions outlined in the WA or RWP: Heavyweight lab coat Heavyweight canvas, cotton, or cotton / polyester coveralls Heavyweight hoods Plastic calf-high booties Rubber shoe covers Plastic or rubber gloves which may require cloth liners. Tyvek paper coveralls or plastic rain suit disposable outer clothing Face shield or other protective device 8. Ventilation Systems-Personnel exposure to airborne radioactive materials will be minimized by utilizing the following engineering controls: (1) Ventilation devices-in-place or portable HEPA filters or Facility ventilation systems, local exhaust by use of vacuums. (2) Containment devices-designed containers, plastic bags, tents, and glove-bags. (3) Source term reduction-application of fixatives prior to handling, misting of surfaces to minimize dust and resuspension. O Ventilation systems shall be maintained to confine hazardous materials. When aggressive decontamination work is in progress, room ventilation shall provide at least four (4) air changes per hour. Quarterly checks shall be performed and pressure differentials shall be maintained to ensure that air flow is from zones of lesser contamination potential to zones of greater contamination potential. Enclosures, including tents, may be used to contain and control airborne contamination in a localized area being decontaminated; the exhaust shall be filtered through HEPA filters as appropriate to the operation being performed. Hoods or other enclosures shall have a face velocity of 150 linear feet per minute over 90% of the opening and be equipped with HEPA filtration systems. Work shall be halted if the average face velocity falls below 100 ft/ min. Air flow measurements for hoods and other enclosures shall be performed at least quarterly and mere often if a decrease in air flow is suspected. All HEPA systems shall be rated at 99.95% efficient for particulates of 0.3 micron size, be fire resistant and be made of fire proof materials capable of operation at temperatures above 150 degrees F. For ventilation systems, GA shall conduct a visual inspection to verify housing integrity during changing of filters. Weekly checks of the magnehelic gauges to determine if the filters required changing shall also be performed and HEPA filters changed if pressure differentials fall below 4" of water. Prefilters shall be changed when differential pressure indicators indicate a reading O 5-18

l greater than 0.9 inches of water. V) l

9. Contamination Control-Contamination control measi

. hat will be employed include the following: Worker training will incorporate methods and techniques for the control of radioactive materials, and proper use and donning / doffing of protective clothing. l Facility procedures incorporate HP contrels to minimize spread of contamination during l work. Radiological surveys will be scheduled and conducted by HP. Containment devices such as designed containers and plastic bags will be used to prevent the spread of radioactive material. Physical decontamination of Facility, areas or items. Physical barriers such as Herculite sheeting, strippable paint, and tacky mat step-off pads to limit contamination spread. 1 Posting, physical area boundaries and barricades. Clean step off pads at the entrance point to contaminated areas. O 10. Respiratory Protection Program-Respiratory protective equipment may be used when airborne concentration limits in 10CFR20 cannot be practically achieved by engineering controls. GA will implement the respiratory protection program described in a detailed written Health Physics procedure (HP-182) and a detailed Respiratory Protection Training Manual maintained in conformance with the requirements in 10CFR20. 11. Instrumentation - GA maintains a number of instruments for the detection and measurement of radiation. A typical list of equipment used during D&D projects is provided in Table 4-1. All instruments are calibrated using NIST-traceable sources at least semiannually. 12. Records - Health Physics will maintain a Records and Reports program which will include maintenance of external and internal monitoring reports, personnel monitoring files, training records, radiation safety inspections, audits, incident reports, Work Authorizations, Radiation Work Permits, and surveys. 13. Inspections-During active D&D activities, the Health Physics Manager, or qualified designee shall conduct an inspection of the work areas on a quarterly basis, document all findings in a report and take proper corrective action as needed to correct'noted deficiencies. /O Q 5-19

(O Nuclear Criticality Safety ) The quantity of U-235 remaining in the facility will be conservatively estimated. If the amount is estimated to be greater than 700 grams, a Nuclear Safety Program will be implemented during the i decontamination effort to pieclude any inadvertent criticality in the event that actual quantities of U-235 were greater than anticipated or if, however unlikely, decontamination activities resulted in concentrations of U-235 in one place. The Nuclear Safety Program will include the following: 1. Appropriate surveys and analysis for the presence of U-235. Accountability and tracking of U-235 will be maintained from initial identification to packaging. 2. Criticality safe containers will be used for packaging decontamination liquid and solid residue from areas where U-235 had been processed during facility operations and or from areas where the presence of U-235 had been established by radiological characterization. 3. The use of HEPA filtered vacuum cleaners, which are not critically safe, will be administratively controlled to prevent the accumulation of unacceptable quantities of U-235. 4. All dismantled sections of HEPA system ducting will be assayed to establish U-235 content prior to disposal. gb 5. Dismantled HEPA system ducting will be volume reduced by compaction. Ducting will not be shredded since this tecit,ve could result in the accumulation of unacceptably high conceatrations of U-235, of a waste package in which the content of U-235 could n ;t be determined wkh reasonable accuracy. 6. All pre-filters or HEPA iilters reraoved from existing HEPA ventilation systems or fem portable HEPA ver. -ilation. sptems will be assayed for U-235 content prior to disposal. 7. Criticality warning alarm systems for strategic locations will be installed and maintained. 8. Nuclear criticality safety will b; mphasized to all decontamination personnel through nuclear safety trainir 6-9. The Manager of Nuclear Safety will review and approve all decommissioning procedures. If required, the Criticality and Radiation Safety Committee, will also approve procedures that impact nuclear safety. This review and approval will er.sure the adeqcacy of measures taken for nuclear safety during decontamination O 5-20

activities. (D V 10. The Nuclear Safety Program will continue until the GA Manager of Nuclear Safety determines that a criticality accident is no longer a credible event and NRC concurrence is obtained. Decontamination Methods Decommissioning activities will commence with the removal, transfer, or disposal of all radioactive materials and radiation sources followed by the transfer, decor. amination and/or disposal of all extraneous hardware, loose material and miscellaneous material, items and equipment. Non-load bearing interior walls and structures, as well as interior ceiling supports and materials may also be removed. Items being disposed of as " clean" must meet the NRC and State of California criteria for release to unrestricted use (Table 1 criteria). In addition to the use of existing ducting and HEPA systems, standard decontamination and dismantlement tools, materials, equipment and services, some specialized equipment and services may be required as follows: HEPA Filtered Ventilation Systems: HEPA filtered ventilation systems may be used to provide contamination control coverage directed to a specific room or work location and for the collection of loose (removable) surface contamination. Abrasive Decontamination Equioment: Surface decontamination operations are expected to be a major part of the overall decontamination effort. Aggressive decontamination methods will be required to remove existing surface coatin,gs such as paints, varnishes, and similar fixatives. Base layers of these surface materials may also need to be removed because of the potential for embedded contamination. Decontamination equipment will be selected on the basis of efficiency and effective contamination control. Equipment which has been used successfully at GA in the past and may be used in the future include: Jack-hammering - Jack-hammers may be used to remove contaminated concrete or asphalt from a surface. This method may be used when the area to be decontaminated is small. Blastrac Machine - The Blastrac Machine may be used for cleaning concrete floors. The delivery system consists of an enclosed centrifugal blast wheel inside a cleaning head. As O s-21

the wheel spins, metallic shot is hurled to the floor surfaces being cleaned. Abrasive media (] and contaminants are drawn into a separation system where contaminants are removed by an attached dust collector and abrasive media is recycled. Travel speed and shot size may be adjusted to control the depth of surface removal. Residual metal shot left on floor surfaces is recovered by using a magnetic broom. Vacublast Machine - The Vacublast machine may be used for cleaning vertical surfaces and along interfaces between walls and floors. It uses compressed air to convey abrasive media from a pressure generator through a hose and blast nozzle to the surface being cleaned. The media and debris is vacuum recovered at the point ofimpact. Air then transports the collected media, dust and debris to a reclaimer where it is air washed. The media is recycled through the equipment. Dust and debris are drawn into a secondary cyclone separator and deposited in a collection chamber. The depth of abrasion is controlled by adjusting the size of the shot and travel speed of the unit. Scabbling - Scabbling as a decontamination technique on concrete surfaces has a long history of success. The technique uses tools having single or multiple bit piston heads, 4 equipped with multi point tungsten carbide bits. The pneumatically operated tool drives the bits against surfaces, which causes the surface to abrade. Sectioning Equioment: Plasma Arc Cutting - Large metal pieces, including process equip: rent (either in g preparation for shredding or as volume reduction) may be cut with plasma arc cutting V equipment. Flame Cutting - Oxy-acetylene cutting systems for the dismantlement and volume reduction of metal pieces. Mechanical Cutting Equipment - When modification or removal of structural material or equipment'is required,it may be accomplished by using powered equipment. The following specialized equipment may be used: Power Blade Covering Remover - for the removal of tile, roofing, tar paper, etc. Sectioning Saw-to section off structures. Volume Reduction Eouioment: Volume reduction of radioactive waste is an important part of the decontamination effort. Major volume reduction systems and techniques include: Shredder - Used to shred a significant quantity of contaminated materials packaged on the project. Typical materials procc,2d through the shredder include electrical conduit and small diameter piping, desks,. airs, benches, metal wall studs, metal sheet and beams and 5-22

small pieces of equipment. Though a shredder was used very successfully on GA's SVA Decommissioning Project (e.g., Building 37-North D&D), GA does not currently have a r shredder onsite. 1 Compactor - Compacts waste into boxes, obtaining a volume reduction factor as high as 10:1, depending on the type of material to be compacted. GA currently has a compactor on site. Liquid Abrasive Decontamination System - A trailer mounted system using recyclable metal media delivered in a water stream to the surface being cleaned. The operation would be performed in a stainless steel chamber having HEPA ventilation installed. The media and debris is collected in a sump, pumped back into the supply and cleanup system and reused. This unit would be used primarily to decontaminate steel. GA currently does not have a system on site. Core Drilling: Floor surfaces throughout some facilities contain female and male anchor bolts where contamination may be present. The anchor bolts can be, and have been (e.g., SVA Decommissioning Project), removed from the floors by core drilling. The resulting holes can then be checked for radioactive contamination and filled with grout, iflevels meet the release criteria. Specialized Services: O Specialized services required in support of decontamination activities included the following: Medical coverage to supply routine first aid services and to perform physical examinations, as needed. Analytical services for industrial hygiene and radiological safety. Employee training, instrument calibratiors and emergency preparedness. Transponation of non-radioactive waste to local landfills. Transportation of radioactive waste to authorized waste disposal sites. Decontamination Approach Decontamination of equipment and other items will be conducted until it is no longer economically feasible, at which point decontamination will be terminated and the item prepared for disposal as radioactive waste. The decontamination approach will use simple and more passive decontamination' methods first, advancing to aggressive decontamination methods as needs dictate. l ,O () 5-23

I 1 i Where passive decontamination techniques apply, they include: vacuuming, damp cloth wiping, and to a limited degree washing / scrubbing operations. When the passive methods fail to reduce surface contamination levels to releasable levels, more aggressive decontamination methods, such as abrasive blasting and scabbling, will be used. Typical local contamination containment measures include the use of tents, surface fixatives and i local ventilation. Tents - Containment tents are effective for controlling the spread of airborne and surface contamination. The enclosures can be fabricated from reinforced plastic fabric attached to j aluminum pipe frames, PVC pipe frames, existing structural framework or other suitable framing material. 4 Surface fixatives - It is sometimes prudent to fix otherwise transferable contamination on j surfaces to be handled. For example, fixative can also be used to contain contamination in areas where relatively high contamination levels introduce a potential for cross l contamination during disassembly activities and to reduce the potential for airborne l radioactivity in areas where workers are present. 1 \\ j Use of local ventilation - Portions of the initially or specially installed HEPA filtered j ventilation systems will be maintained for use throughout all phases of aggressive decontamination. Ifinstalled ventilation systems have to be removed, decontamination lg efforts will cease until a suitable temporary HEPA filtered ventilation system can be ! U installed. The use of local ventilation systems will be administered through training i programs and approved procedures. Portable HEPA filtered ventilation units may be used j to augment installed systems capabilities and to serve as an independent means of j contamination control. l' i i j Processing of Radioactive and Non-radioactive Waste l Another element of decommissioning will be the management and disposal of waste material. An l effective waste management program will be implemented; including the minimization of disposable volumes, as well as reconciliation of waste density and volume in regards to transport regulations and limits. Contaminated equipment will be either decontaminated, released and disposed of as non-radioactive waste at a local landfill, or volume reduced (if practical) and disposed of as radioactive waste. The choice between these two disposal options depends on activity levels, achievable decontamination, personnel exposure and decontamination costs (i.e., ALARA considerations). 4 Radioactive waste may be subjected to various volume reduction techniques, including i decontamination, segmentation, shredding and/or compacting. Strict contamination and j ventilation controls will be used to prevent the spread of contamination to surrou'nding areas. i 5-24 J ?

l To minimize the void volume in packaged waste, consideration will be given to nesting of (] contaminated piping and large components containing internal voids. Successively smaller diameter piping and tubing could be segmented to identical ler.gths and nested together, one inside the other, to form a minimum void volume package for disposal. To further facilitate efDeient waste disposal, intemally contaminated items that are not easily volume reduced, may be filled with shredded or other contaminated material. Liquid waste generated during decontaraination operations may contain relatively small amounts of radioactive and/or chemical contaminants. These liquids may be processed using one of the following methods: Solidification - Solidification can be performed at GA's Nucleu Waste Processing Facility l (Building 41 and 25). The solidification process consisted of taking approximately 30 gallons of aqueous waste and placing it into a 55 gallon drum where it can be neutralized with an acid or base, if required. The contents of the drum can then be mixed while adding cement and expanded mica (filler), as needed. The drum can then be allowed to set up with the contents becoming a monolithic mass. Filtration - Filtration of some low level aqueous wastes can be performed on some liquid wastes. After verification that local, state and federal regulations regarding discharge into the sanitary sewerage system have been met, the treated water can then be discharged and records of each discharge maintained by GA. Absorption of radioactively contaminated organic liquids such as pump oils, solvents, etc. can be performed with solidification agents acceptable to radioactive waste disposal sites. The resultant solid material will be packaged in 55 gallon drums. This waste will only be sent to authorized waste disposal facilities. Disposal of Radioactive Waste Radioactive waste from decommissioning activities is currently being shipped to two DOE low level radioactive waste disposal facilities. One is located at the Nevada Test Site and the other is at Hanford, Washington. Only approved disposal sites will be used for GA radioactive waste. Quality Assurance Program GA's quality assurance program will include requirements for procedure reviews, control of measuring and test equipment, routine audits and surveillances, in-process surveillance of radioactive waste packaging activities and other activities that ensure a project-wide consistency in QA approach and compliance with project requirements. n v 5-25

6. PLANNED FINAL RADIATIONSURVEY The purpose of a Final Radiation Survey is to demonstrate that the radiological condition of the Site and Facility are at or below established release criteria in anticipation of State and NRC approval of license amendments removing a facility as a location to handle licensed materials and remove restrictions from use of a facility or property and permit its unrestricted use.

The Planned Final Radiation Survey discussed in this chapter deals with release of the facility and any facility yard areas to unrestricted use following removal of extraneous equipment and removal of identified contamination through the most cost-effective means necessary. Specific release criteria for surface contamination, soil and other bulk materials are included in this chapter. The anticipated final survey needed for each facility was provided in the summary Table S-1. During actual decommissioning the classification may change based on characterization survey results. GA has developed the Final Survey Plan using the guidance presented in the NUREG/CR-5849. ' 6.1 Release Criteria for Items, equipment and Facility This section provides the specific criteria for release of items, materials and equipment and the facility. These criteria are shown in Table 6-1. The beta / gamma emitter release criteria shown in Table 6-1 can be applied for Sr-90 if it is in mixed fission products that has not been technologically enhanced above what would be expected to be present due to fission yields and radioactive decay. C 6.1.1 Release of items and Equipment All materials leaving a facility Restricted Area will be surveyed to ensure that licensed materials are not inadvertently released from the Facility. Applicable decommissioning project and GA HP procedures will be adhered to in performing these evaluations. These evaluations will include the following types of evaluations. Materials and Eouioment-Direct frisk (p-y and a) with portable detectors and indirect survey for smearable activity will be conducted as needed using appropriate instrumentation typical of those provided in Table 4-1. Materials and equipment will be released in accordance with GA and Project HP procedures in accordance with criteria specified in GA's NRC (SNM-696) and State of California (0145-80) licenses. Those criteria are summarized in Table 6-1. Items painted with other than original manufacturer's paint will be reviewed on a case-by-case basis. Normally, the item will be assumed to be contaminated unless process knowledge demonstrates that the paint was applied to a clean, non-radioactive surface prior to use in the Restricted Area or an acceptable suivey (i.e., paint sampling and analysis and/or fixed readings before and after paint was removed) demonstrates that levels are below the release criteria. If the potential exists for contamination on inaccessible surfaces, the equipment will be assumed to be internally contaminated unless (1) the equipment is dismantled allowing access for surveys, (2) appropriate tool or pipe monitors with acceptable detection capabilities are utilized that would provide sufficient confidence that no licensed materials were present, or (3) it may readily be concluded that surveys from accessible areas are representative of the inaccessible surfaces NUREG/CR-5849, Manual for Conducting Radiological Surveys in Support of License Termination, Draft for Comment, June 1992. 6-1

. - -. ~._ 1 (i.e., surveying the internal surface from both ends of a straight pipe from a non-radioactive ( process system with cotton swabs could be representative of the inaccessible areas). 6.1.2 Release of a Facility The acceptable surface contamination levels (above background levels) for facilities are provided i l in Table 6-1. Appropriate background levels for each type of surface will be established. l GA may apply the soil release criteria for asphalt, concrete, or other similar construction media that have been reduced to rubble, l 6.1.3 Description of Final Radiation Survey Plan Once all identified affected areas are evaluated and cleaned up as necessary, a final radiation survey must be performed to demonstrate compliance with the release criteria. Each handling area (or group of handling locations) will have a formal survey plan developed prior to initiating final release survey. The survey plan will describe the survey design in detail. A well-documented survey plan will be the basis for meeting these objectives and will be prepared prior to performing the final survey. The plan will vary for each facility and will be based upon the physical characteristics of the facility, site, or laboratory being surveyed. These characteristics include the number and size of buildings, type of building construction, building or lab condition, total area, and structures (including overhead structures) in each room. Features such as ceiling height, ducts, piping, lights, drain lines and walls surfaces will be considered in determining the number and type of sampling required to demonstrate compliance with the release criteria. j O' The plan will include, (1) a list of the types, numbers, and locations of measurements and i samples to be obtained; (2) information on the equipment and techniques to be used for measuring, sampling, and analyzing data; and (3) the methods to be used to interpret and evaluate the survey data. An example of a survey plan completed for the General Atomics Group 8B labs is provided at the end of this chapter and is representative of what is prepared for release of laboratories. i O 6-2

_~ 7 1 i II i Table 6-1: ACCEPTABLE SURFACE CONTAMINATION LEVELS ' Nuclides* Average *" Maximurrf" Removable **' j (dpm/100cm') (dpm/100cm" (dpm/100cm" ] U-nat, *U, 'U, & associated decay products 5,000 a 15.000 a 1,000 a l Transuranics, Ra, "'Ra, *Th, areTh, Pa, Ac, 100 300 20 inq, usi Th-nat, '"Th, "Sr, 82'Ra, 88'Ra, U, "*l, "'!, "'I 1,000 3,000 200 Beta / gamma emitters (nuclides with decay modes 5,000 15,000 1,000 4 ) other than alpha emission or spontaneous Assion) except Sr and other noted above. a Where surface contamination by both alpha-and beta / gamma-emitting nuclides exists, the limits established for alpha and beta / gamma-emitting nuclides should apply independently. i b As used in this table dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by j correcting the counts per minute observed by an appropriate detector for background, efficiency, an geometric factors 4 associated with the instrumentation. c Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each such object. d The maximum contamination level applies to an area of not more than 100 cm. 8 s e The amount of removable radioactive material per 100 cm ' of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, then pertinent levels should be reduced proportionally and the entire surface should be wiped. f The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 mradhr at 1 cm and 1.0 mradhr at 1 cm, respectively, measured through not more than 7 milligrams per square centimeterof totalabsorber, Guidelines For Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses For byproduct, Source, or Special Nuclear Material, USNRC, July 1982, incorporated into GA's SNM 696 license. O 6-3

6.1.4 Classification of Areas by Contamination Potential 4 . O i The survey will be designed so that areas with higher potential for contamination receive a higher degree of survey effort, the process will be both effective and efficient. Three classifications of the types of surveys anticipated for each facility have been identified and provided for each facility in Table S-1. These are " scoping or confirmatory survey", "affected area survey" and " unaffected area survey" t areas. These classifications are defined as follows: 6.1.4.1 Scoping or Confirmatory Survey The scoping or confirmatory classification is intended for locations where there is no present of use of radioactive material or known contamination but this needs to be confirmed (see Table S-1 for facilities / sites where a scoping or confirmatory survey is needed). The type of survey needed will vary with each facility and must be done on a case-by-case basis. In no case will the scoping or confirmatory survey be less than the type of survey described below for an 4 unrestricted area survey but in some cases additional surveying will be required to determine if contamination exists such as in the case of Building 35 where the extent of contamination, if any, is unknown. 6.1.4.2 Affected Area Surveys Affected Areas are areas that have potential radioactive contamination (based upon plant operating history) or known radioactive contamination (based upon past or preliminary radiological surveillance). This would normally include areas where radioactive materials in a form which could become airborne was used, where liquid radioactive materials were handled, and where records indicate spills and other unusua! occurrences that could have resulted in i spread of contamination. This could also include areas immediately surrounding, or adjacent to, these areas because of the potential for inadvertent spread of contamination. Reference Grid Svstems are normally established at the site to (1) facilitate systematic selection of measuring / sampling locations, (2) provide a mechanism for referencing a measurement / sample back to a specific location so that the same survey point can be relocated, and provide a convenient means for determining average activity levels. A grid consists of a system of intersecting lines, referenced to a fixed site location or bench mark. 2 For surveys of structures the basic grid system for affected areas is 1 m. For surveys of outside 2 areas, the basic grid system is 100 m Gridding inside structures may be limited to the floor and lower (up to 2 m height) walls. Survey locations are referenced to the grid system; surveys of ungridded surfaces are referenced to the floor or to prominent building / area features or landmarks. O The grids described above are intended primarily for reference purposes and do not necessarily dictate the spacing of survey measurements or sampling. Clocar spacing survey locations may 6-4

be required to demonstrate that average and elevated area guideline values are met to the O survey techniques. required level of confidence. Larger spacing may be acceptable, ba Structure Survevs for Affected Areas The floors and lower walls (up to 2 m height) of affected areas will receive 100% coverage during the final status survey. The coverage provided for upper walls and ceilings will be dependent upon the contamination potential for these surfaces. The survey measurements for surface activity will consist of a combination of surface scans, direct measurements, and measurements of removable activity. Scans of 100% of affected area floor and lower wall surfaces will be performed for all radiations which may be emitted from the radionuclides of interest. Locations of areas of elevated activity are identified and direct measurements are performed to define their extent and activity levels. Residual activity which exceeds 3 times the guideline value (see section describing the release criteria), results of external radiation in excess of 2 times the guideline value above background measured at 1 m from the surface, or average activity above the guideline value in 2 any 1 m area will be remediated until these conditions are satisfied. 1 systematic measurements of surface activity are performed. Systematic measurements (a combination of direct measurements and measurements of removable activity) are performed at a spacing of 2 m or less and provide at least 30 data point locations for a large facility and at 2 least 10 for a small lab or room (i.e., < 700 ft ). One approach may be to obtain data from grid O' line intersections or grid block centers. In cases where the surface was remediated (and in the immediate surrounding area), systematic direct measurements will be performed at 1 m intervals. Upper walls, ceilings, and other overhead surfaces which are suspected of having residual activity, based upon operating history and previous surveys, are surveyed in the same manner as floors and lower walls. For upper walls, ceilings, and other overhead surfaces which are not suspected of having residual activity, based upon operating history and previous surveys, an average of at least 1 a measurement location per 20 m of surface area will be conducted with a minimum of 30 measurement locations on vertical and horizontal surfaces where radioactive material would likely accumulate (i.e., air exhaust vents and horizontal surfaces where dust would settle). Portable instruments will be used in on the various surfaces (as appropriate) to survey for the presence of elevated activity levels, if gamma emitting radionuclides are among the potential contaminants,1xposure rate measurements at 1 m from floor and lower wall surfaces are performed at a frequency of 1 2 systematic measurement per every 4 m. If potential contaminants did not include gamrna emitters, exposure rate measurements will be performed at a minimum spacing of 1 2 measurement per 10 m, n U Qutside Surveys for Affected Areas (Concrete or Asohalt Surfaces) 6-5

Exposure rates are not to exceed 10 micro-R/hr above background at 1 m above the surface p (concrete or asphalt surfaces). For open land areas, exposute rates (measured at 1 m above the surface) can be averaged over 100 m grid areas. The maximum exposure rates over any a v discrete area may not exceed two times the limit above background. It is GA's intent to remediate all areas where micro-R readings exceed 10pR/hr at 1 m above the surface. However, in the event that reasonable efforts have been made and measurements continue to remain elevated, GA may apply the averaging criteria described above to determine compliance. 6.1.4.3 Unaffected Area Surveys All areas not classified as affected are considered " unaffected." These areas are not expected to contain residual radioactivity, based upon a knowledge of site history and survey information. Table S-1 shows the facilities / sites anticipated to be unaffected areas. It is recognized by General Atomics that as a Final Release Survey progresses, an area's classification may require changing based on accumulated survey data. Structure surveys for Unaffected Areas Unaffected areas do not require gridding for the purposes of establishing measurement or sampling locations; however, grids systems may be helpful in order to facilitate referencing of survey locations in those areas to a common site reference system. Scans of unaffected surfaces will cover a minimum of 10% of the floor and lower wall (up to 2 m i height) surface area. At least 30 randomly selected measurement locat;ons (combination of direct and smear 8 measurements), or an average measurement of 1 per 50 m of building surface area, whichever is greater, for total and removable activity, will be performed. These locations will include all interior building surfaces. Identification of activity levels in excess of 75% of the guideline, either by scans or measurements, will require reclassification of the area to the "affected" category. Exposure rate measurements at 1 m from the floor are performed at each location of survey activity measurement or at approximately evenly-spaced intervals throughout the lab or facility. i Outside Survevs for Unaffected Areas (Concrete or Asohalt Surfaces) Unaffected open land areas will be uniformly scanned for radiations from the radionuclides of interest. Spacing intervals between scanning paths will be such that a minimum of 10% of the surface is scanned. Exposure rates are not to exceed 10 micro-R/hr above background at 1 m above the surface (concrete or asphalt surfaces). For open land areas, exposure rates (measured at 1 m above the surface) can be averaged over 100 m grid areas. The maximum z exposure rates over any discrete area may not exceed two times the limit above background. 6.2 SollSampling Plan O 6-6

-.. - - - - - - - - - - = - I l \\ l The objective of soil sampling is to demonstrate compliance with approved soil release criteria. This plan was developed using the guidance in NUREG/5849.2 6.2.1. Release Criteria Soil Concentration Limits Table 6-2 shows release criteria based upon the most limiting pathway for a variety of radionuclides that may be encountered on the GA site (or those that conceivably could be encountered). Decommissioning projects at GA over the past 12 years have shown that the predominant contaminants on the GA site are Cs-137, Co-i } 60, enriched uranium and thorium. The soil concentrations are acceptable values above normal background levels. l If additional nuclides are encountered during the remediation or Final Release Survey activities, their respective release criteria would be determined in the same manner as the values provided above. If more than one radionuclide exists, the sum of the fractions must be less than one in order for the soil to meet the release criteria. The sum will be calculated as follows: [ C' L; r.s C, The average soil concentration of radionuclide i. = L, The maximum soil limit fori(pCi/g). = Exposure Rate Limits Exposure rates are not to exceed 10 microR/hr above background at I m above the surface. For open land areas, exposure ratds (measured at I m above the surface) can be averaged over 100 m grid 2 areas. The maximum exposure rates over any discrete area may not exceed two times the limit above background. 6.2.2 Soil Background Concentrations Typical soil concentrations are provided in the table below which represent the average results of seventeen (17) surface soil samples and ten (10) concrete samples collected in undisturbed areas from the region surrounding the GA site. l 1 l 2 Manual for Conducting Radiological Surveys in Support of License Termination (Draft for Comment), NUREG/CR-5849, ORAU-92/C57, Oak Ridge Associated Universities, June 1992. 6-7

Media Type Cs-137 U-238 U-235 Th-232 V (pCi/g) (pCi/g) (pCi/g) (pCi/g) Soil 0.21 0.20 1.26 0.78 0.0810.04 1.72 0.92 Concrete 0.04 0.02 4.27 10.63 0.12 0.03 3.62 0.24 6.2.3 Affected Areas - Open Land Surveys Grounds and open land areas classified as affected areas are gridded at 10 meter intervals. As with structure surfaces, GA will perform 100% coverage of affected open land areas (soil). Scanning will be performed to identify locations of elevated activity levels. Areas of suspected elevated activity, identified in this manner, are evaluated by sampling and analyses to determine their activity level and extent of contamination, and results are compared with criteria, cleanup is performed, as required, and scanning repeated. After scanning has indicated the guidelines and conditions have been satisfied, systematic soil sampling of each affected area grid block is performed at locations equal distant between the center and each of the four grid block corners or on a 5 meter triangular grid system recommended by EPA procedure (EPA 2 1989) for a 95% assurance that elevated areas in excess of 10 m surface area are identified. If scanning is not capable of detecting surface areas with activity levels <; 75% of the guideline values for the radionuclides ofinterest, the 5 meter triangular grid system will be used. ) ~) Exposure rates are measured at I m above the surface on the grid pattern. Underneath a concrete slab In cases where contamination is suspected underneath a concrete stab, biased samples will be collected from underneath the concrete slab (under cracks and/or drains where the soil appears affected; i.e., discolored, odiferous or otherwise abnormal or suspected of contamination). Scanning (along the surface of the soil) will be performed to identify locations of elevated activity levels. Areas of suspected activity, identified by scanning or visual inspection, will be evaluated to determine their activity levels and the extent of contamination. Cleanup will be performed, as required, and the scanning repeated until remediation is accomplished as demonstrated by additional soil sampling, analysis and comparisons with the guidelines. After scanning and remediation of known contaminated areas, systematic soil sampling will be performed on a triangular grid with a sampling interval of 5 m on a side. Additional remediation will be conducted if release criteria are not met. If elevated area (areas above release criteria) are identified during the final survey, they will be evaluated for acceptability using NUREG/CR-5849 averaging methods, regardless of whether or not remediation will be conducted. OV Underneath drain lines 6-8

If underground drain lines are removed and sampling is needed (i.e.,in trenches created during mmoval of potentially contaminated drain lines), biased samples will be collected as follows:

1) Soil samples will be collected from underneath and around any drain lines which appear broken, corroded or otherwise deteriorated.

2) Soil samples will be collected whenever exposure rates are elevated (measured using microR meters and/or Na! (TI) detectors /ratemeters).

3) Soil samples will be collected if the soil appears affected, i.e., discolored, odiferous or i

otherwise abnormal. In addition, systematic samples will be collected approximately every 5 m (about every 15 feet) from underneath the drain lines. Subsurface Samples Remediation of soil will continue to a depth required to reduce the concentrations to levels below the release i criteria. A final sample (s) after remediation will demonstrate that residual activity is Lelow the release l criteria. D Subsurface samples undemeath the concrete slab may be collected to a depth of three (3) feet. Subsurface samples will be collected in biased locations and willinclude: 1) each location (larger than 5 m ) where soil 2 contamination above the guidelines was discovered and remediated and 2) any location where exposure rate measurements were elevated (greater than two times the external radiation exposure limit, above background). These measurements will be made using a microR meter or NaI (TI) detector /ratemeter. Subsurface samples may also be collected underneath drain lines as necessary to assure that subsurface contamination above the release criteria does not exist. Normally, subsurface sampling in affected areas where drain lines were removed will be conducted every 20 feet to a depth of 2 feet. Additional sampling at further depths and/or at other locations will be conducted, if contamination above the release criteria is present or suspected. Subsurface samples may also be collected in other suspect locations, if warranted by exposure rate measurements or remediation efforts. Outside Areas of Buildings Scanning (along the surface of the soil) will be performed in all exposed soil locations to identify locations of elevated activity levels. Spacing intervals between scanning paths should be such that a minimum of 50% of the surface is scanned. b v 6-9

Table 6-2-Soll and Concrete /Asphsit Rubble Release Criteria' Isotope Release Criteria Based upon External Release Criteria Based upon Internal Exposure Limitations Exposure Limitations l (pCi/g) (pCi/g) 6"Co 82 '"Cs 10 '37Cs 152 '52Eu 11 '"Eu 10 '"Eu 635 'dNb 7.5 i25Sb 37 "Sr 18002 23"Pu 2 64 23'Pu 2 74 24oPu 274 24'Pu 43264 242Pu 2 84 2"Pu 2 84 24' Am 254 Natural Uranium 353 Enriched Uranium (234U & 30 3 235U) 3 (] Thorium (232Th & 22sTh) 1 03 V ' The release criteria shown in this table without annotation by footnotes 2,3, or 4 wem calculated by the licensee using RESRAD version 5.18 adhering to the same assumptions that were provided in the correspondence listed in note 2, below. This corresponds to conservative calculation of the homogenous concentration of an isotope in the soil that by itself would give approximately 10 uR/hr external exposure rate i above background for the maximum year of exposure. It is the licensee's intent to apply criteria from this table l to concrete, asphalt, or similar construction media materials that have been ground to a coarse rubble. These criteria were approved by the NRC for the Hot Cell Decommissioning project by letter dated May 1,1996, Robert C. Pierson to K. E. Asmussen. 2 These release criteria are based upon past precedent through NRC and State of California approved release limits for the GA site. See Correspondence K. E. Asmussen to W. T. Crow, dated October 1,1985, cormspondence identification 696-8023,

Subject:

" Docket 70-734: Plan for Obtaining Release of Certain Areas I

to Unrestricted Use." 5 l These release criteria are based upon past precedent established by NRC through NRC Policy Issue l SECY-81-576, dated October 5,1981,

Subject:

" Disposal or on-site storage of residual thorium or uranium (either as natural ores or without daughters present) from past operations."

' Numbers were established using the most limiting of lung dose (20 mrem /yr) or bone dose (60 mrem /yr) using Dose j Conversion Factors from NUREG/CR-0150, Volume 2, with an alpha quality factor of 20, where applicable, lung mass l of 580 grams, and AMAD of 1.0. 8 For enriched uranium, GA shall determine the U-234:U-235 ratio by uranium isotopic analysis in order to then use gamma spectroscopy results of U-235 to demonstrate compliance with the release criteria for enriched uranium. A ) V 6 10

i 6.2A Unaffected Areas - Open Land Surveys O (,/ Unaffected open land area will be uniformly scanned for radiations from the radionuclides ofinterest. Spacing intervals between scanning paths will be such that a minimum of 10% of the surface is scanned. Identification of hot-spots or individual locations with activity levels in excess of 75% of the guideline value requires reclassification of the area as "affected" 6.2.5 Sample Collection A 15 cm " surface" soil sample will be collected with a sample size of approximately I kilogram. The sampling locations will be identified on drawings. The samples will be properly logged, labeled, packaged and tracked. All debris (grass, rocks, sticks, and foreign objects) will be removed from the sample. Samples i will be dried and counted by gamma spectroscopy. Results will be reported in pCi/g for each radionuclide. Shallow sampling may be conducted using manual equipment (post-hole diggers, small-diameter split barrel or Shelby tube samplers, and portable hand-operated or motorized augers). For depths below several meters, heavier equipment, such as a drill rig with an auger and/or a core sampler will be required. 6.2.6 Direct Radiation Measurements To determine compliance with the external radiation limit of 10 microR/hr at 1 m above the surface, exposure rate measurements will be taken at I meter at all systematic soil sampling locations (after soil remediation has been completed). The results will be compared with the release criteria shown in Table 1 (and discussed above). A calibrated microR meter will be used to determine exposure rate measurements in microR/hr. p It is GA's intent to remediate areas containing elevated activity levels in the soil. However, in the event that reasonable efforts have been made and soil concentrations continue to remain elevated, GA may establish the guideline that areas of residual activity exceeding the guideline value, known as " elevated" areas, are acceptable, provided they do not exceed the guideline value by greater than a factor of (100/A)", where A is 2 the area of residual activity in m, and provided the activity level at any location does not exceed three times the guideline values. In addition, radionuclide concentrations will be averaged to demonstrate the average is 2 at or below guideline values, established as acceptable to NRC. Averaging will be based on a 100 m (10 m x 10 m) grid. 6.3 Methods to be Employedfor Reviewing, Analyzing, and Auditing Data 6.3.1 Laboratory / Radiological Measurements Quality Assurance During decommissioning survey activities, many direct and indirect measurements and sample media samples will be collected, measured, and analyzed for radiological contaminants. The results of these surveys will be utilized to evaluate the suitability of the material or item for release to unrestricted use, or whether decontamination of structures, components, and the surrounding site have achieved the desired result. Sample collection, analysis, and the associated documentation will adhere to written procedures and meet the guidance of the NRC. Outside (i.e., non-GA) laboratories selected to analyze facility decommissioning samples will be approved by the GA Quality Assurance organization and listed on the Non Safety-Related QA Suppliers List or other similar document maintained by the GA Quality Assurance Department. Quality control records for laboratory counting systems will include the results of measurements of radioactive check sources, calibration sources, backgrounds, and blanks. Records relating to overall laboratory performance will include the results of the analysis of quality control samples such as analytical blanks, replicates, and other quality control analyses. O g 6.3.2 Supervisory and Management Review of Results 6-11

Radiological surveys are conducted by HP Technician staff members who are trained and qualified in [d'N accordance with General Atomics' SNM and State of Califomia Byproduct Material License. In addition, radiological surveys and sample results are reviewed by the HP Management or designated Health Physics Technician (other than the individual that performed the survey). 6.4 Final Survey Report All survey results will be documented and provided to the Nuclear Regulatory Commission and the State of California in a final report. Noic: For areas w here remediation was conducted, the report will include the results of surveys conducted prior to the area being remediated as well as the final survey results. O N, oO 6-12 .~

O O O Example Survey Plan (from Group 8B Labs Final Report) 635/637/639 Type of 506 506A 508 508A 515 519/521 523 530/532 635 637/639 Mezzanine Survey 144 n' 132 n 144 ft 121 n 2ss n 576 ft2 2 2 2 2 2 2 2 2 168 n 576 ft 312 ft 648 ft 663 ft2 X-ray diffraction and electron microscopy Two gamma Ion Ar-41 gas. Scaled Pu-238 sources. U-of samples containing U-235, U-238, calibration Nohistory of accelerator sogis,o,y or 235. U-238 and/or thorium in the form llistory of thorium and/or depleted uranium. Last radioctive S "'#** "# ' used. Last of metal, fuel particles and/or fuel Use used 12/95

• * 'I I "'*'
• 8C material use.

used in compacts. Used for rad work until work uptd 1983. 1986. 1982. Floor 100% Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No a scan Floor 100% Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No pscan i Lower Walls Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes (1xwtom 2m) 100'A p scan Upper Walls Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes -10% scan

1. of Fixed 32 15 27 10 28 12 27 28 Measurements (2 min)

(2 min) (5 min) (2 min) (5 min) (5 min) (5 min) (5 min)

1. of Paint 4

None 4 4 4 None 4 4 2 None None b"*E #8 l I (original (original or no (original or (original or no paint)

1. 1-4 pain )

(#9-12) (#5-8) (#13-16)

1. 17-20
2. 21-24
3. 25-26
4. of Smears 72 26 56 36 60 28 60 64 (See List)
5. of MicroR 4

4 4 4 8 16 6 16 8 16 16 Readings & Scan entire surface 6-13

i' g v v V 635/637/639 'rype of 506 506A 508 508A 515 519/521 523 530/532 635 637/639 Me Survey 144 n' 132 n 2 2 2 2 144 n2 121 n 2ss n 576 ft: 168 n 576 ft2 312 ft: 648 ft2 663 ft2 X-ray diffraction and electron microscopy Two gamma Ion Ar-41 gas. Sealed Pu-238 sources. U-calibation Nohistory of accelerator 235, U-238 and/or thorium in the form of samples containing U-235, U-238, Nohistory of llistory of thorium and/or depleted uranium. Last radioctive used. Last of metal, fuel particles and/or fuel '"**"*d* Use '*j 8 used 12/95 material use. used in compacts. Used for rad work until work uniin 1986. 1986. 1982. Floor Al " None None None None None None None None None None Drains? noor drain Floor Concrete Surface ~ % mncrete Concrete unoleum unoleum conaete ceaese Wood Suiface -H tinoleum Total s or 104 41 83 46 88 40 87 92 n.. _S (Fued Measurernents & snears) 6-14

d i l i i l Example Survey Plan (Detailed Locations of Fixed Measurements and Smears) 1 l 1 Laboratory Fixed Measurements Smears i Labs 506,506A, Fixed Measurements (32) Smears (72) 508 and 508A 12 Floors - 3 in each room 20 Floors-5 in each room f 16 Walls 1 on each wall (4) of each room 16 Walls - 1 on each wall (4) of each i (4) room (4) i i Inside Square Duct in Lab 506A 10 Blinds in 508 1 Inside Round Duct in Lab 508 8 Light fixtures (2/ room) l 1 Inside Square Duct in Lab 508 4 Ducts in 506A f 1 On top of drain in 506 (drain is above 2 Ducts in 508 ground) 6 Ducts in 506A i 2 I-beams in 506 1 1 1 Above ground drain in 5% 3 Exhaust Vents t Lab $15 Fixed Measurements (15) Smears (26) 5 Floor 10 Floor 4 Walls (1 on each wall) 8 Walls (2 on each wall) 4 Lights (2/ light) 4 Lights (2 on each light) 2 I Beam 2 I-Beam 1 On Vent 1 Top of the closed duct Labs $19/521 Fixed Measurements (27) Smears (56) 10 Floor 20 Floor 8 Walls (2/ wall) 16 Walls (4 per wall) 3 Each opening of the duct 6 Duct (one in each of 3 openings and 3 on top of the duct) 4 Lights (one on each) 8 Lights (2 per light) I box (on wall) 3 Wall exhaust ducts ( square duct, 1 Round exhaust duct in wall) round duct and exhaust vent out) 3 I-beam O 6-15

" * " ~ " ' ' ' " ' ' ' ' " ' " " ' " ' ' " ' ' ' ' ' " ' " " " " " ' ' ' ' ' ' " ' " ' " ' ' ~ ' " ' ' " " ' ' ~ ' " ' ' ' Cl Laboratory Fixed Measurements Smears Lab 523 Fixed Measurements (10) Smears (36) 4 Floors 12 Floors 4 Walls (one per wall) 4 Walls (one per wall) 2 Lights (one per light) 4 Lights (one per light) 8 I-beams 8 Window ledge Labs $30/532 Fixed Measurements (28) Smears (60) 16 Floors 20 Floors 4 Walls 16 Walls 2 I beams 4 I-beams 2 Inside ducts 8 Light Fixtures 4 Lights (1 each light) 10 " Hood Umbrella" 2 Roof Drain (drain goes through the lab only - no entrance or exit to lab) Lab 635 Fixed Measurements (12) Smears (28) ) 5 Floor 10 Floor 4 Watts 8 Walls (2 per wall) 1 Inside the large duct 6 Ducts (2 inside each duct) 1 Square duct 4 Ducts (top of ducts) 1 Inside the open vertical duct Labs 637/639 Fixed Measurements (27) Smears (60) 16 Floor 20 Floor 8 Walls (2 per wall; I on unpainted area,1 16 Walls (4 per wall) on painted area - no paint samples are 10 Stairway needed) 2 Handrail 1 Top of the electrical panel 12 Inside of ducts 2 Ducts OV 6-16

4 Example Survey Plan (Detailed Locations of Fixed Measurements and Smears) Laboratory Fixed Measurements Smears 635/637/639 Fixed Measur ments (28) Smears (64) 20 Floor 20 Floor 4 Wa:!s (2 per wall) 4 Walls (2 per wall) Note: one wall Is windows and the other wall is part oflower labs. 2 I-beams 4 Railing 1 ts 16 Blinds (4 on each of the 3 larp blinds; 2 on each of the 2 smali blinds) 8 I-beams 4 Lights i 4 Inside ducts 4 Top of ducts l bv 6-17

7. FUNDING Estimates of the costs of decommissioning all of General Atomics' NRC (and State of California) licensed facilities and sites in San Diego were provided GA's May 20,1996 submittal 8

to NRC. That submittal also described the method by which GA preposed to provide financial assurance for funding its total cost of the subject decommissioning, By letter dated July 9,1996 2 the NRC acknowledged acceptance of GA's proposal, t i i l j I Asmussen, Keith E. Letter No. 696-2581 to Document Contiol Desk, U.S. Nuclear Regulatory Commission, ATFN: Mr. Alexander Adams, Jr. and Mr. Charles E. Gaskin," Docket Nos. 70-0734,50-89 and 50-163; Decommissioning Financial Assurance," dated May 20,1996. 2 Weiss, Seymour H. and Robert C. Pierson Letter to Dr. Keith E. Asmussen," Financial Assurance for NRC Licenses SNM-606, R-38, R-67/ Docket Nos. 70-0734,50-89,50-163," Dated July 9,1996. 7-1 -}}