ML20128L639

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Proposed Changes to Tech Specs to Permit C-E to Allow GE to Maintain Getr in Possession/Nonoperating Status
ML20128L639
Person / Time
Site: Vallecitos File:GEH Hitachi icon.png
Issue date: 06/26/1985
From:
GENERAL ELECTRIC CO.
To:
Shared Package
ML20128L612 List:
References
NUDOCS 8507110398
Download: ML20128L639 (19)


Text

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APPENDIX A PROPOSED TECHNICAL SPECIFICATIONS  :

LICENSE TR-1  !

GETR 1.0 Definitions  !

1.1 Channel. A channel is the combination of sensor, line, amplifier, and output devices which are connected for the purpose of measuring the value of a parameter.

1.2 Channel test. A channel test is the introduction of a signal into the channel for verification that it is operable.

1.3 Channel calibration. A channel calibration is an adjustment of the channel such that its output corresponds with acceptable accuracy to known values of the parameter which the channel measures. Calibration shall encompass the entire channel, including equipment actuation, alarm or trip, and shall be deemed to include a channel test.

1.4 Channel check. A channel check is a qualitative verification of acceptable performance by observation of channel behavior. This verification, where possible, shall include comparison of the channel with other independent channels or systems measuring the same variable.

1.5 Confinement. Confinement means a closure on the overall facility which controls the movement of air into it and out through a controlled path.

1.6 Operable. Operable means a component or system is capable of performing its intended function.

1.7 Operating. Operating means a component or system is performing its intended function.

1.8 Shall, should and may. The word "shall" is used to denote a require-ment; the word "should" to denote a recommendation; and the word "may" to denote permission, neither a requirement nor a recommendation.

1.9 Facility Specific Definitions

a. Restricted activity. A restricted activity is an activity inside the ,

reactor building involving activated and/or contaminated reactor facility structures, components or systems that could cause within the reactor building airborne radioactive material concentrations in excess of the limits in 10CFR20, Appendix B Table 1, Column 1.

b. Reactor building. The reactor building is the same structure described in the SAR as the containment building. The new name is more appropriate, as a leak-tight building with isolation capability is not required for the shut down facility.

8507110398 850626 PDR ADOCK 05000070 A-1 P PDR

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c. Reactor facility. The reactor facility is defined as the reactor building and its ventilation system, the cooling tower, the tank farm, the experiment exhaust system (EES) tanks, north half of Building 202, and contaminated piping connecting these components.

2.0 Safety Limits and Limiting Safety System Settings 2.1 Safety Limits Not applicable.

2.2 Limiting Safety System Settings Not applicable.

3.0 Limiting Conditions For Operation 3.1 Reactor Core Parameters Not applicable.

3.2 Reactor Control and Safety System Not applicable.

3.3 Coolant Systems Not applicable.

3.4 Confinement 3.4.1 Applicability This specification applies to the reactor building.

3.4.2 Objective The objective of this specification is to define the activities which require confinement and to specify the actions taken and the equipment provided to achieve confinement.

3.4.3 Specifications 3.4.3.1 Activities That Require Confinement Restricted activities are defined in Section 1.0, Paragraph 1.9.a. These activities require confinement.

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. l 3.4.3.2 Equipment To Achieve Confinement (1) When the ventilation system is not operating, the reactor building shall be maintained in a condition such that there are no airflow pathways open directly to the environs except the airlock doorways when the doors are open.

(2) The airlock outer doors shall be kept closed except during personnel access or egress or while equipment is being passed through the doorway.

(3) The airlock outer doors shall be locked or blocked closed to prevent unauthorized entry except when authorized personnel are inside the reactor building or outside with the door in view.

(4) When restricted activities are in progress, the direction of airflow through pathways open directly to the environs shall be into the reactor building and discharge to the environs shall be through an operating ventilation system.

3.4.4 Bases Measurements of airborne radioactivity by monitors and samplers inside the reactor building and in the ventilation discharge indicate that the reactor building in its present condition does not require a confinement system.

4 Because of the activation and contamination levels, it is possible to perform activities, i.e., restricted activities, that could cause airborne concentrations in excess of 10CFR20 limits. Specification 3.4.3.1 ensures that a confinement system will be provided for such activities.

The restrictions and limitations in Specification 3.4.3.2 are necessary to provide assurance that the reactor building and ventilation system provide an

, effective confinement system.

3.5 Ventilation Systems 3.5.1 Applicability This specification applies to the reactor building ventilation system.

3.5.2 Objective i

l This specification describes the minimum requirements of the reactor building ventilation system.

3.5.3 Specification (1) A reactor building ventilation system shall be operating whenever restricted activities are in progress.

(2) The reactor building ventilation system shall discharge through a particulate filter system.

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(3) When the system is required to be operable, the exhaust air downstream of the filters shall be continuously monitored and sampled to show that the specified release rate limits in Specification 3.7.3.2 are not exceeded. If the release rate limits are exceeded, activities causing the release will be discontinued and corrective action taken to ensure further release is within limits.

(C) The ventilation system shall be capable of maintaining the direction of airflow into the reactor building through any existing pathways open directly to the environs.

3.5.4 Bases The extremely small source term at the GETR is adequately confined by the reactor building. Whenever restricted activities are in progress, a filtered and monitored ventilation system provides assurance release rates are maintained within limits.

3.6 Emergency Power Not applicable.

3.7 Radiation Monitoring Systems and Effluents 3.7.1 Applicability Tids specification applies to those devices either permanently installed or portable and used to detect radiation and/or contamination levels and to the effluents released through the reactor building ventilation system.

3.7.2 Objective

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To describe the minimum radiological instrument capabilities that must be available for use at the reactor facility and to state the airborne radioactivity limits for effluent released through the reactor building ventilation system.

3.7.3 Specifications 3.7.3.1 Monitoring Systems The radiological instrumentation capability that must be available for use at the reactor facility are given in Table 3-1. These instruments shall perform the following functions.

i (1) Stack Particulate Sampling (Monitoring) System. During performance of restricted activities, the stack effluent shall be continuously monitored or sampled.

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i ~ (2) Radiation Monitoring System. Gamma-sensitive detectors shall be

employed at specifled locations. These detectors will be located where significant and/or rapid changes in radiation level can occur while personnel are present or where it is desired to have remote monitoring of an area. The remote area monitors provide alarms in the event the level exceeds a predetermined set point. This system i is a backup rather than a substitute for the hand-held portable instruments which provide an indication of the exposure rate level.

(3) Airborne Activity Monitors. Mobile and/or stationary continuous air monitors and samplers shall be used as necessary in the reactor building and are located as necessary to support the activities in progress.

Whenever such monitors are inoperable, portable instruments, surveys or analyses may be substituted for any of the normally installed monitors in Section 3.7.3.1 for periods up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

TABLE 3-1 GETR Radiological Instrumentation

a. Portable Instrumentation Activity Detected , Maximum Range Beta-Gamma 250 R/h; 1,000 Rad /h Gamma 1,000 R/h Beta-Gamma 1,000 R/h; 20,000 Rad /h Beta-Gamma 70,000 cpm
b. Fixed Instrumentation Activity Maximum Detected Range 0

Stack Particulate Beta-Gamma 10 cps 4

Area Monitors Gamma 10 R/h CAM's (continuous air monitor) Beta-Gamma 50,000 cpm A-5

3.7.3.2 Effluents The limits for radioactive material discharged through the reactor building ventilation system to the atmosphere shall be as specified in Table 3-2.

TABLE 3-2 Stack Release Rate Limits Isotope Group Annual Average (uCi/sec) Short-Term (uCi/see)

Particulate > 8d T 11 12 Beta-Gamma 1.04 x 10 MPC /1400 1.04 x 10 MPC /700 Alpha 11 1.04 x 10 MPCa/1400 1.04 x 10 12 MPCa /700 where MPC = the concentration in pCi/ml shown in Table II, Appendix B, a

10 CFR Part 20.

3.7.4 Bases The instrumentation described in 3.7.3.1 will provide assurance that the concentration of airborne radioactive material in the working areas and the stack effluent are measured and that when there is a potential for the creation of high gamma fields as a result of the conduct of restricted activities, the radiation level will be monitored and an alarm actuated if necessary.

The stack release rate limits are based on computer calculated dilution-dispersion factors using two years of site recorded meteorological data.

The above listed annual average contains a reduction factor of 2 to account for discharges from other VNC stacks and a reduction factor of 700 to account for reconcentration in the environs.

3.8 Experiments Not applicable.

3.9 Facility Specific LCO Not applicable.

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4.0 Surveillance Requirements 4.1 Reactor Core Parameters Not applicable.

4.2 Reactor Control and Safety System Not applicable.

4.3 Coolant Systems Not applicable.

4.4 Confinement 4.4.1 Applicability This specification applies to the surveillance requirements for the reactor building confinement system.

4.4.2 Objective To assure that the reactor building is maintained in a condition that provides

' an effective boundary for the confinement system.

4.4.3 Specifications (1) During periods when the ventilation system has not operated, the facility records shall be reviewed and the reactor building shall be visually inspected at least annually to determine that there are no pathways open directly. to the environs except the airlock doorways.

This determination also shall be made prior to the initiation of any restricted activities.

(2) Weekly a check shall be made to determine the airlock outer doors are locked or blocked closed whenever no one is inside the reactor building.

(3) Whenever the reactor building ventilation system is required to be operating, there shall be verification at least weekly that the direction of flow through pathways open directly to the environs is into the reactor building.

4.4.4 Bases Compliance with these specifications provides assurance that the reactor build'ng is maintsined as an effective confinement boundary.

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4.5 Ventilation Systems 4.5.1 Applicability Applies to the reactor building ventilation system.

4.5.2 Objective To specify surveillance requirements that will provide assurance the reactor ventilation system is operable when required.

4.5.3 Specification (1) Pai ticulate filters shall be visually inspected and tested by the standard filter dioctyl pthalate (DOP) or dioctyl sebacate (DOS) efficiency test for 99.97% removal of 0.3 um particles by the vendor. Each filter shall be visually inspected prior to and after installation and at least annually thereafter.

(2) A channel calibration of the ventilation effluent sampler or monitor shall be performed prior to placing into service, after major maintenance, and at least annually while in service. A channel check shall be performed monthly while the sampler or monitor is in service. These tests need not be performed if operation of the ventilation system was not required during the year.

(3) At least annually direction of airflow through pathways open directly to the environs shall be verified to be into the reactor building while the ventilation system is operating. This test also shall be performed prior to the initiation of any restricted activity; it need not be performed if operability of the ventilation system was not required during the year.

4.6 Emergency Power Not applicable.

4.7 Radiation Monitoring Systems and Effluents 4.7.1 Applicability This specification applies to the equipment and systems installed to detect radiation and/or contamination, e.g., laboratory counting instruments and portable radiation measuring instrumentation used for the reactor facility.

4.7.2 Objective To describe check and calibration frequencies of monitoring instruments, laboratory counting instruments, and portable radiation measuring instrumentation.

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4.7.3 Specifications (1) Monitoring instruments shall be calibrated upon initial acquisition; and in-service instruments shall be calibrated upon installation, after major maintenance, and at least annually. A channel check of in-service instruments shall be performed monthly.

(2) Background and efficiency using standard sources shall be measured at least quarterly on all laboratory instruments used for counting health physics samples.

4.7.4 Bases These specifications provide assurance that monitoring and analytical instrumentation will be functional when needed.

4.8 Experiments Not applicable.

4.9 Facility Specific Surveillance Not applicable.

5.0 Design Features 5.1 Site and Facility Description The GETR facility shall be located on the site of the Vallecitos Nuclear Center which is owned and controlled by the General Electric Company. The minimum distance from the facility to the posted site boundary shall be approximately 2,800 feet. The restricted area as defined in 10CFR20 of the Commission's regulations shall be the Vallecitos Nuclear Center.

5.2 Reactor Coolant System Not applicable.

5.3 Reactor Core and Fuel Not applicable.

5.4 Fissionable Material Storage Not applicable.

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M t 6.0 Administrative Controls l 6.1 Organization 6.1.1 Structure The organization for the management and operation of the reactor facility shall include the structure indicated in Figure 1. Other organizational levels / staffing may be added to meet specific facility needs. Additional description of levels follows:

(1) Level 1. Individual responsible fcr the reactor facility's licenses (i.e. , Organizational Head).

(2) Level 2. Individual responsible for reactor facility activities (i.e. ,

Facility Manager).

(3) Level 3. Individual responsible for day-to-day supervision (i.e. ,

Facility Supervisor).

As indicated in Figure 1, the review and independent examination group shall report to Level 1. Radiation safety personnel shall report to Level 2 or higher. ,

Level 1 Organization Head I

Level 2 Independent Redew h Facility Manager Examination I

Radiation Safety Level 3 Facility Supervisor Figure 1. Organization Chart l

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  • 6.1.2 Responsibility Responsibility for the safety of the reactor facility shall be with the chain of command established in Figure 1. Individuals at the various management levels, in addition to having responsibility for the policies and activities conducted in the reactor facility, shall be responsible for safeguarding the public and facility personnel from undue radiation exposures and for adhering to all requirements of the facility license and technical specifications.

In all instances responsibilities of one level may be assumed by designated alternates or by higher levels, conditional upon appropriate qualifications.

6.2 Review and Independent Examination 6.2.1 Composition and Qualification Independent review functions shall be performed by technically qualified

personnel responsible to a management position other than the facility manager.

6.2.2 Charter and Rules The independent review function shall be performed under a written charter or directive containing the following information as a minimum:

a. subjects reviewed;
b. responsibilities;
c. authorities;
d. records;
e. other matters as may be appropriate.

6.2.3 Review Function Activities requiring independent review shall include the following:

a. Proposed activities that could affect personnel or facility safety or result in an uncontrolled release of radioactivity in excess of 10CFR20 limits, to be conducted without prior NRC apprc, val, and reviewed and approved pursuant to 10CFR50.59 to verify the proposed activity does not constitute a change in the Technical Specifications or an unreviewed safety question.
b. Proposed changes to the procedures or the facility, to be completed without prior NRC approval, reviewed and approved pursuant to 10CFR50.59 to verify the activity does not constitute a change in the Technical Specifications or an unreviewed safety question.
c. All new procedures and revisions thereto having safety significance.
d. Proposed changes to the Technical Specifications or the facility license.

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e. Violations of the Federal regulations, Technical Specifications, and facility license requirements.

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f. Unusual or abnormal occurrences which are reportable to the NRC under provisions of the Federal regulations.

6.2.4 Independent Examination Function The independent examination function shall include selective (but comprehensive) examination of activities records and other documents, i Discussions with cognizant personnel and observation of operations also should

, be used as appropriate. In no case shall personnel immediately responsible to Level 2 management perform the examination. The following items shall be examined:

(1) Facility activities for conformance to the technical specifications and license, at least once per calendar year (interval between examinations not to exec.ed 15 months).

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(2) The qualifications of the staff, at least once every other calendar year (interval between examinations not to exceed 30 months).

(3) The results of action taken to correct those deficiencies that may occur in the reactor facility equipment, systems, structures, or methods of operations that affect facility safety, at least once per l calendar year (interval between examinations not to exceed 15 months).

(4) The reactor facility emergency plan and implementing procedures, at least once every other calendar year (interval between examinations not to exceed 30 months).

Deficiencies uncovered that affect facility safety shall immediately be reported to Level 2 management. A written report of the findings of the examination shall be submitted to Level 2 management and the manager of the radiation safety function within three months after the examination has been completed.

i 6.3 Procedures Written procedures shall be prepared, reviewed and approved prior to initiating any of the activities listed in this section. The procedures shall be reviewed by the review function (see 6.2.3) and approved by Level 2 management or designated alternates, and such reviews and approvals shall be documented in a timely manner. Several of the following activities may be included in a single manual or set of procedures or divided among various manuals or procedures.

(1) Routine maintenance of major components of systems that could have an effect on facility safety.

(2) Surveillance tests and calibrations required by the technical specifications or those that may have an effect on facility safety.

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1 (3) Personnel radiation protection, consistent with applicable regulations.

(4) Administrative controls for maintenance and for the conduct of activities that could affect facility safety.

(5) Implementation of required plans such as emergency or security plans.

Substantive changes to the above procedures shall be made effective only after documented review by the review group and approval by Level 2 or designated alternates. Minor modifications to the original procedures which do not change their original intent may be made by Level 3 or higher, but the modifications must be approved by Level 2 or designated alternates within 14 days. Temporary deviations from the procedures may be made by Level 3 in order to deal with special or unusual circumstances or conditions. Such deviations shall be documented and reported to Level 2 or designated alternates.

G.4 Experiments Review and Approval Not applicable.

6.5 Required Actions 6.5.2 Action To Be Taken In the Event of An Occurrence of the Type Identined In 6.6.2(1)a. and 6.6.2(1)b.

(1) Reactor facility conditions shall be returned to normal or the activities in progress stopped. If it is necessary to stop the activities in progress to correct the occurrence, operations shall not be resumed unless authorized by Level 2 or designated alternates.

(2) Occurrence c. hall be reported to Level 2 or designated alternates and to the NRC as required.

(3) Occurrence shall be reviewed by the review function.

6.6 Reports 6.6.1 Annual Report Annually submit to the NRC a report containing the following:

(1) A narrative summary of facility activities.

(2) Tabulation of major preventive and corrective maintenance operations having safety significance.

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(3) A brief description of major changes in the reactor facility and procedures and activities significantly different from those performed previously and not described in the Safety Analysis Report , and a summary of the safety evaluation that shows no unreviewed safety questions were involved.

(4) A summary of the nature and amount of radioactive effluents released or discharged to environs beyond the effective control of the licensee as determined at or before the point of such release or discharge. The summary shall include to the extend practicable an estimate of the major individual radionuclides present in the effluent. If the estimated average release after dilution or diffusion is less than 25 percent of the concentration allowed or recommended, a statement to this effect is sufficient.

(5) A summarized result of environmental surveys performed outside the facility.

6.6.2 Special Reports Special reports used to report unplanned events as well as planned major facility and administrative changes shall be submitted in accordance with the following schedule:

(1) There shall be a report not later than the following working day by telephone and confirmed in writing by telegraph or similar conveyance to the NRC to be followed by a written report that described the circumstances of the event within 14 days of any of the following:

a. Release of radioactivity from the site above allowed limits (see j 6.5.2).

l b. Any of the following (see 6.5.2):

(i) Activities in violation of limiting conditions for conduct of activities established in the technical specifications unless prompt remedial action is taken.

(ii) An observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to facility operations.

p (2) A written report within 30 days to the NRC of:

a. Permanent changes in the facility organization involving Level 1-2 personnel.
b. Significant changes in the accident analysis as described in the Safety Analysis Report.

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6.7 Records Records may be in the form of logs, data sheets, or other suitable forms.

The required information may be contained in single or multiple records or a combination thereof.

6.7.1 Records To Be Retained For A Period of At Least Five Years Or For the Life of the Component involved If Less Than Five Years (1) Normal facility operation (but not including supporting documents such as checklists, log sheets, etc. , which shall be maintained for a period of at least one year).

(2) Principal maintenance activities.

(3) Reportable occurrences.

(4) Surveillance activities required by the Technical Specifications.

(5) Reactor facility radiation and contamination surveys where required by applicable regulations.

(6) Approved changes in operating procedures.

(7) Records of meeting and independent examination reports of the review and independent examination group.

6.7.2 Records To Be Retained For the Lifetime of the Reactor Facility (NOTE: Applicable annual reports, if they contain all of the required information, may be used as records in this section.)

(1) Gaseous and liquid radioactive effluents released to the environs.

(2) Off-site environmental-monitoring surveys required by the Technical Specifications.

(3) Radiation exposure for all personnel monitored.

(4) Drawings of the reactor facility.

(5) Records of disposal of licensed material.

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APPENDIX B STATUS REPORT - GETR The current status of the GETR facility is reflected in this report.

I. All irradiated and unirradiated reactor fuel, fueled experiments, and targets containing SNM have been removed from the reactor facility and shipped from the VNC site.

II. Containment GETR technical specifications have been changed so that building integrity and surveillance tests are not required as long as there is no reactor fuel or fueled experiments in the containment.

The building ventilation system is operating continuously with the supply fan off and the exhcust fan on low speed (47,000 cfm). This maintains a satisfactory environment for people and equipment. Particulate filters are still in the exhaust filter banks.

All four ventilation isolation valves (inner and outer valves on both the supply and exhaust lines) are blocked open but can be closed if necessary

, when activities that could cause airborne activity are conducted. They were blocked open when the service air system was shut down.

The stack gaseous activity monitor has been turned off, but the particulate monitor and sampler systems are in service.

Outer doors on both airlocks have been sealed by static foam rubber seals because the inflatable seals for the airlock doors are not operable without an air supply. The outer door of the equipment airlock is blocked closed with a removable brace placed inside the airlock in order that this door can serve as an emergency exit; this brace is designed to be removable without the use of tools. The outer door of the personnel airlock is chained and padlocked closed from outside. Both inner doors are blocked open.

III. Primary Cooling System The reactor vessel contains irradiated hardware such as control rods (shocks and guide tubes), beryllium fillers, peripheral pieces, reactor vessel specimens, and core plugs.

To provide radiation shielding, the water level in the vessel is maintained 2 to 4 feet above the top of the core. The pool remote area monitor (radiation detector located below the missile shield) indicates s200 mR/hr with the pool level at its allowed maximum and 600 mR/hr at the minimum.

Radiation level around the bottom of the missile shield is about 15 mR/hr with the current water level.

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i The primary coolant recirculation pump has not been operated since the 1977 shutdown.

When the primary water level was lowered, some water remained in the primary system piping. The cleanup system demineralizer (D-101) contains no resins.

IV. Pool System The pool contains irradiated hardware including experiment facilities, neutron detector guide tubes, and pool shuttle hardware.

Pool water level is the same as that of the primary water which is 2 to 4 feet above core top. Totai primary / pool water volume is about 5,000 gallons.

The pool coolant recirculation pumps have not been operated in recent months. Because of the open 10-inch emergency coolant check valves, the reactor vessel water and the pool water can mix and should have essen-tially the same characteristics. Analysis of a water sample taken 9/13/84 iV ted the following:

Conductivity 1.7 pmho_s 4

Beta-gamma 6.7 x 10-8 pCi/ml Alpha < 3 x 10 pCi/ml pH 6.4 Dip tubes installed in the pool and the canal facility pit (see below) connect to a manifold and then to a common pressure gage and air bottle system. This system can be used to measure water level of either the pool or pit. The air bottle and pressure gage are located on the third floor.

Pool piping still contains water. The pool cleanup system demineralizer (D-102) contains no resins.

V. Canal Facility The canal has been drained and the walls and bottom cleaned with a high pressure water jet (hydrolazer). After cleaning and draining were completed, some contaminated hardware was stored in the canal (fuel storage baskets and tanks, work tray, capsule storage basket, canal vacuum system filter housing, etc.). Pool water level is maintained below the bottom of the canal gates to prevent the generation of loose contamination by wetting and drying action of water that would leak past the unsealed gate door. Hot spots in the canal were shielded with lead.

Radiation levels currently are:

Location Radiation Level At the Top of Canal 90 mR/hr General On 3rd Floor 3-7 mR/hr Hot Spots In Canal (Unshielded) 0.4-7 Rem /hr B-2

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There has been no evidence of airborne activity from the dry surfaces of the canal.

Canal water recirculation and cleanup system piping has been drained.

The demineralizer (D-104) contains no resins.

The water level in the canal pit is about one to two feet below the canal floor. At this level there is about 1,000 gallons in the pit.

VI. Secondary Coolant System Operation of the secondary system has been discontinued. The cooling tower and above grade piping were drained. The chemical addition system was shut down and chemicals disposed of.

The isolation valves are blocked open but can be closed if necessary.

VII. Demineralized Water System Practically all of the demineralized water system remains operable but not routinely used. Major components still used include the two fill and flush pumps; one of two 25,000-gallon underground storage tanks; and the 50,000 gallon above-ground hold tank (TK-104).

The demineralizers have been emptied and the resins shipped to a licensed radioactive waste disposal facility. Resins can be replenished if needed for decontamination testing exercises.

VIII. Sump Water System u

The sump water system includes the tanks, pumps, demineralizers, etc. ,

that collect and process water collected in sumps located inside the containment building and in the tank farm area. Major components in service include the 25,000 gallon underground tank (TK-103); 21,000-gallon above-ground tank (TK-115); and the tank farm, barrel pad, elevator, and basement sump pumps.

This system currently handles very little water, but the volume could increase as a result of decontamination testing exercises.

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l IX. , Safety Equipment A. Remote Area Monitor System (RAMS)

The following six RAMS channels remain in service:

Channel No. Location 4 3rd Floor Zone 5 Pool 11 1st Floor - Equipment Room 20 Resin Transfer Pad 22 Equipment Building 23 D-106, Tank Farm B. High Radiation Areas High radiation areas are posted and controlled as required by 10CFR20.

C. Airborne Radioactivity Sampling The containment building basement and third floor each have a fixed particulate sampler.

D. Air Supply Systems The two service air compressors and the breathing air compressor have been turned off.

E. Emergency Systems GETR accidental criticality alarm system is deactivated.

X. Radiation and Contamination Status Comprehensive surveys have been made of the GETR. Field dose rate readings and contamination levels are commensurate with the status of the facility. The chief components of the removable contamination are Co-60 and Cs-137. No alpha contamination was detected. The surveys also indicated that there was no migration of removable contamination.

XI. Administrative Controls A. Organization Manager, IPO, is responsible for the reactor facility license. He has designated Manager, Engineering & Support Services, as the facility manager, a position required by Technical Specification No. 9.1.1.

VNC Nuclear Safety function provides the independent review function required by Technical Specification No. 9.2.1 and radiation protection services and environmental monitoring for the VNC site, including the shut down GETR facility.

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