ML20137E652
| ML20137E652 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 03/24/1997 |
| From: | Reda R GENERAL ELECTRIC CO. |
| To: | Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| TAC-L30906, NUDOCS 9703280158 | |
| Download: ML20137E652 (4) | |
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?'0 US 5000 March 24,1997 Mr. M. F. Weber, Licensing Branch, NMSS U.S. Nuclear Regulatory Commission Mail Stop T 8-D Washington, DC 20555-0001
Dear Mr. Weber:
Subject:
Request for Delay of Decommissioning of CaF2 Basin Area (TAC NO. L30906)
Reference:
- 1) NRC License SNM-1097, Docket 70-1113
- 2) Letter, RJ Reda to RC Pierson,9/13/96
- 3) Letter, RJ Reda to RC Pierson,10/24/97 GE's Nuclear Energy Production (NEP) facility in Wilmington, N.C., hereby submits the following information in support of our request for an additional 120 days to review the submission of a request of delay of decommissioning or an altemative schedule of decommissioning.
Backcround GE voluntarily began a long term program of CaF2 removal from in-ground storage in 1995. GE initially met with the NRC on 2/1/95 to discuss its plans and determine a way forward for the program. In that meeting, GE reviewed its plan to remove CaF2 from the Northwest Storage area and seek free release of that area as Phase I of the CaF2 removal program. Phase II was described as the removal of CaF2 from the central basin area with no plans for free release until decommissioning of the Wilmington facility based on the proximity of other operations in that area. Phase Ill would deal with CaF2 located in lined lagoons at the waste treatment facility.
During the 2/1/95 meeting, the NRC indicated that CaF2 could be removed from the Northwest and central basin areas within the scope of the GE license SNM-1097. The NRC also pointed out that free release of the Northwest Storage area would require an approved Survey and Release Plan. The NRC did not take issue with the stated plan not to seek free release of the central basin g
area.
9703280158 97032'4 PDR ADOCK 07001113' PDR.
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Mr. M. F. Weber March 24,1997
. Page 2 of 3 Subsequently, GE prepared and submitted a Survey and Release Plan for the Northwest Storage area that was approved by the NRC on 4/16/96. The CaF2 has been removed from the Northwest area and final survey and release activities are expected to begin in the second half of this year.
On 9/13/96, GE submitted notification to the NRC pursuant to 10 CFR 70.38 that the central basin area had been inactive for 24 months, and it was our intention to remove the CaF2 from this area but to not seek decommissioning of the area until final plant closing. This request was consistent with the position taken in prior discussions about the fate of the central basin area.
During a conference call on 10/3/96, GE and the NRC discussed four questions regarding the intended final closure date for the central basin area, timing for CaF2 removal, anticipated dose rates, and residual contamination levels. GE submitted a written response to these four questions on 10/24/96.
On 1/23/97, the NRC notified GE that it could not grant a request for delay, because GE had not adequately justified such delay in accordance with requirements in 10 CFR 70.38(f).
Discussion of each of the criteria in 70.38(f) is provided:
(1) record of regulatory compliance - GE has maintained CaF2 material in the central basin area in compliance with our license SNM-1097. The CaF2 is entirely located inside a Controlled Access Area (CAA) along with active site process lagoons, a sanitary basin, and a lagoon spoils area. All are operating in support of ongoing principal activities.
(2) maintenance and monitoring of the area - The fenced CAA is maintained as an active part of the Wilmington facility and is routinely monitored and maintained by operations, maintenance, and regulatory personnel. The Lagoon CAA is an active and integral part of plant operations.
(3) decommissioning financial assurance for the area - This area is covered within the scope of the Wilmington Facility Decommissioning Plan.
(4) plans for resuming operations of the area - There are no specific plans for resuming j
operations of the central basin area as a CaF2 storage location.
(5) availability of waste disposal facilities - Envirocare is currently the only available disposal facility for the CaF2.
(6) reduction in dose or waste volume due to radioactive decay - Due to the halflife associated with uranium, this is not an option.
(7) technical feasibility of decommissioning - Removal of CaF2 from this area appears to be feasible. Establishing background and confirming free release of the area after material removal may be technically difficult due to the following:
- a. The hydrogeolic complexiy of the area
- b. Shallow dewatering may induce groundwater migration from one of the adjoining active areas
- c. Groundwater restoration in the cental basin area to background levels may be infeasable due to adjacent activities (Map of the area attached)
(8) regulatory requirements of other government agencies - See (10)
(9) lawsuits - There are no lawsuits pending.
Mr. M. F. Weber March 24,1997
. Page) of 3 (10) groundwater treatment and restoration activities - GE is currently monitoring and managing -
groundwater lying below the central basin area.
(11) other factors that demonstrate a clear public interest in delaying decommissioning - GE believes that prompt decommissioning of the central basin area at the current time is public d
interest neutral. Groundwater and soil monitoring in this area strongly suggest the central basin area is not creating a down gradient risk. However, GE has begun removing the source CaF2 from the central basin area per its previously communicated plan.
Reauest We are requesting an additional 120 days to review the submission of a request of delay of-decommissioning or an alternative schedule for decommissioning. We believe this is the minimum time needed to adequately evaluate the potential impact of activities associated with cleaning the central basin area to free release levels, to reevaluate the possibility of recontamination due to ongoing plant activities in adjacent areas, for investigation ofless intrusive methods for removal of residual contamination down to release levels (phytoremediation), and to review additional groundwater monitoring data during the removal of CaF2 from the central basin area.
1 Please contact Dave Brown on (910) 675-6745 or me on (910) 675-5889, ifyou have any questions or would like to discuss this matter further.
Sincerely, GE NUCLEAR ENERGY Ralph J. Reda, anager.
Fuels & Facility Licensing
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