ML20141P152

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Forwards Request for Addl Info Re 851029 Reactor Decommissioning Plan.Response Requested by 860321
ML20141P152
Person / Time
Site: 05000142
Issue date: 03/12/1986
From: Berkow H
Office of Nuclear Reactor Regulation
To: Wegst W
CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
NUDOCS 8603190069
Download: ML20141P152 (5)


Text

March 12, 1986 Docket No. 50-142 Dr. Walter Wegst, Director Office of Research & Occupational Safety University of California, Los Angeles Los Angeles, California 90024

Dear Dr. Wegst:

SUBJECT:

STAFF COMMENTS AND REQUEST FOR ADDITIONAL INFORMATION REGARDING UCLA DECOMMISSIONING PLAN The staff is in the process of reviewing the UCLA reactor facility decommissioning plan, dated October 29, 1985 and has developed the enclosed questions and comments.

Please submit your responses by March 21, 1986.

Following receipt of your responses we will continue our review. Should you have any questions concerning this request, contact Harold Bernard, our Project Manager for your facility, at (301) 492-8529.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, original signed by Herbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B

Enclosure:

As stated cc w/ enclosure:

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WASHINGTON, D. C. 20655 March 12, 1986 Docket No. 50-142 Dr. Walter Wegst, Director Office of Research & Occupational Safety University of California, Los Angeles Los Angeles, California 90024

Dear Dr. Wegst:

SUBJECT:

STAFF COMMENTS AND REQUEST FOR ADDITIONAL INFORMATION REGARDING UCLA DECOMMISSIONING PLAN The staff is in the process of reviewing the UCLA reactor facility decomissioning plan, dated October 29, 1985 and has developed the enclosed questions and comments..Please submit your responses by March 21, 1986.

Following receipt of your responses we will continue our review. Should you have any questions concerning this request, contact Harold Bernard, our Project Manager for your facility, at (301) 492-8529.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, Herbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B

Enclosure:

As stated cc w/ enclosure:

See next page l

~

t University of California Docket No. 50-142 at Los Angeles 4

cc: Mr. Neil C. Ostrander, Manager Committee To Bridge The Gap Nuclear Engineering Laboratory 1637 Butler Avenue #203 School of Engineering and Los Angeles, California 90024 Applied Science University of California Mr. John Bay at Los Angeles 1022 Peralta Street Los Angeles, California 90024 Albany, California 94706 Director, Energy Facilitie.s Attorney General Siting Division ~

555 Capitol Mall Energy Resources Conservation and Sacramento, California 95814 Development Commission 1516 - 9th Street Mr. James R. Heelan Sacramento, California 95814 Director, Society Services American Nuclear Society California Department of Health 555 N. Kensington Avenue ATTN: Chief, Environmental La Grange Park, Illinois 60525 4

Radiation Control Unit Radiological Health Section Roger Kohn, Esq.

714 P Street, Room 498 524 lith Street Sacramento, California 95814 Manhattan Beach, California 90266 Mr. Daniel Hirsch Robert M. Meyers 3489 Branciforte Drive City Attorney Santa Cruz, California 95065 Lynn Naliboff Deputy City Attorney William H. Cormier, Esq.

1685 Main Street, Room 310 Office of Administrative Vice Santa Monica, California 90401 Chancellor University of California Roger L. Kohn 405 Hilgard Avenue 524 Eleventh Street Los Angeles, California 90024 Manhattan Beach, CA 90266 t

Christine Helwick, Esq.

Glen R. Woods, Esq.

Roger Holt, Esq.

Office of General Counsel Office of City Attorney 590 University Hall 200 North Main Street 2200 University Avenue City Hall East, Room 1700 Berkeley, California 94720 Los Angeles, CA 90012 l

Dean Hansell 6601 W. 5th Street Los Angeles, California 90048 L

a.

1 Enclosure Questions for UCLA Facility Decomissioning Plan dated October 29, 1985 1.

Referring to Section 1.5 of the Plan, provide resumes showing the required education, training and experience for all positions that are important to safety during the decommissioning (i.e., Manager of Operations, Health Physicist, etc.).

2.

Describe the method you will use (e.g., GeLi spectrometer) to identify radioactivenuclidesfoundinswipes,coresampjes,etc.,thatwillbe taken during dismantling.

3.

The UCLA Plan indicates the use of only one hi-vol air sampler. The staff finds that one such sampler is not adequate; two will be required.

Please amend your plan accordingly.

4.

Page 7, Table P The radiation protection equipment specified in the table does not include survey meters that can be used to measure dose rates down to 5 pr/hr. Staff criteria for release for unrestricted use of equipment, release of contaminated structures, surfaces, etc.,

required for termination of a license, is Table I, of Reg Guide 1.86 and 5 pr/hr above natural background at one meter.

Indicate how you assure that the survey meter used in radiation surveys to measure dose rates is energy independent over a wide range of energies. Additionally, the inventory in the table does not include monitors for self examina-tion of extremities, face, clothing, etc. for contamination.

5.

Indicate how you will dispose of the lead and graphite bars that are removed from the core.

6.

Page 6, Section 1.7; Page 9, Section 3.3.1; Page 9, Section 3.3.2 -

Please state whether the experienced radiation workers in the three sections specified are the same people.

Explain how they will take a more active role, in the Decomissioning Plan, than training contractor technicians. Provide details of their experience with respect to the Decommissioning Plan (e.g., experience with respiratory protection equipment, large area and volume contamination control, measurement of pr/hr radiation levels, supervising people performing the dismantling and decommissioning function).

7.

We note that student volunteers have been used for dismantling the core for maintenance.

From this, it appears that volunteers will again be used for core dismantlement.

Please specify how these volunteers have been and will be trained for this work in accordance with 10 CFR 19.12, 8.

Appendix B, Pages 2 & 3 - Detailed diagrams of the reactor system and environs are needed to follow the Decommissioning Plan.

Please provide such drawings showing measurements at the locations specified in Tables B-3 and B-4 and relevant areas specified in Section B-3 and B-4 (e.g., steel blade drive support bearings and structure, core centervoid).

I

Comments for Final Report - Phase 1 The following information can be included as part of the Phase 1 report.

9.

For each task in Table p-5, " Task Identification," provide a description of the procedures for accomplishing the major activities. Any special health and safety considerations should be addressed for each task as appropriate.

Include a table describing each task and associated exposure in person-rem and the total cumulative exposure for the entire decommissioning effort.

10. Describe how pipes, drainlines and ductwork will be surveyed for contamination on the interior to assure conformance with Regulatory Guide 1.86 dose limits.

If no appropriate access point for these surveys is available, indicate what survey plan would be used to make the measurements necessary to identify potential contamination of the interior of pipes, drain 11nes and ductwork.

11. Provide a discussion of the final decommissioning alternatives, DECON and SAFSTOR.

Include (1) cost estimates for each alternative, l

(2) availability of funds, (3) major tasks and schedules (in particular, the estimated data for completion of decommissioning or major interrup-tions in the plan),'(4) items subject to quality assurance, (5) tasks that may be performed by a contractor, (6) the final radiation survey i

plan, (7) and the collective dose equivalent (person-rem) for performing the selected decommissioning plan as compared to each alternative plan considered.

12. Section 1.0 Background - Surveys in the areas indicated in this section could include activity from fission products as well as activation products. Please describe any fission products that would be a probable contaminant in the reactor area.

If none is expected, please so state and justify your position.

13. Page 2 - 6th paragraph - In specifying items subject to QA, no mention is made of QA being applicable to radiation survey and sample analysis instrumentation. The licensee must assure the accuracy of all measurements made as part of his final report to the NRC. Consequently, instruments used to measure le/els of radiation for release of material, equipment, structure:, etc. is a prime item subject to QA. This must be addressed in the Phase 1 Final Report.

14.

Page 4, Section 1.4 - This section requires further clarification. The staff is assuming that the DECON alternative has been selected for the UCLA reactor decommissioning.

If the SAFTSOR option is selected because the DECON " decommissioning activity may have implications that go beyond the reactor facility," then the licensee will be required to submit his plan for decommissioning under the SAFSTOR alternative.

In any event, Section 1.4 needs further explanation in the Phase 1 Final Report.

15.

If tritium is identified, provide the origin and degree of tritium contamination within the reactor facility.

Indicate how tritium decontamination will be performed.

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