ML20195C629

Forwards NRC Guidance for Releasing Equipment &/Or Facilities Such as Those at Goodyear Aerospace for Unrestricted Use

ML20195C629
Person / Time
Site:	07001489
Issue date:	07/22/1985
From:	Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Mcmahon W OAK RIDGE NATIONAL LABORATORY
Shared Package
ML20195C597	List: ML20195C591 ML20195C607 ML20195C617 ML20195C629
References
505744, NUDOCS 8811030252
Download: ML20195C629 (17)

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JUL 2 21985 MEMORANDUM FOR: Walt McMahon Oak Ridge Operations Enrichment Technology Division P.O. Box E Oak Ridge, TN 37830 FROM: Bruce S. Mallett, Chief Materials Licensing Section Region !!!

SUBJECT:

Release Of Equipment And Facilities At Goodyear Aerospace Corporation, NRC License Number ShM-1461 (Docket Number 070-01489) For Unrestricted Use As per our telephone conversation, attached is the NRC's guidance for releasing equipment anJ/or facilities such as those at Goodyear Aerospace for unrestricted use. The current NRC License for Goodyear Aerospace (No. SNM-1461) is under timly renewal, since the Itcensee filed a renewal application with the NRC in proper form 30 days prior to the expiration date (August 31,1984). Consequently, Goodyear Aerospace's existing license shall not expire until the NRC takes final action upon the renewal application. As discussed, Goodyear Aerospace should notify Region I!! in writing if a decision is made to tenninate activities involving materials authorized under the NRC license.

Original Signed By Bruce S. Mallett, Chief

Materials Licensing Section

Enclosures:

1. SRP for termination 2.10 CFR Part 70 8911030252 860327

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Department cf En:rgy 5 g ,. g ook R% operatens

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l Mr. G. E. Paler, Manager Business Development ace Corporation Goodyear Department Aerosp/CED 942 .

1210 Massillon Road Akron, OH 44315

Dear Mr. Paler:

RELEASE OF EQUIPMENT AND FACILITIES AT GAC, NRC LICENSE NO.

l SNM-1461 FOR UNRESTRICTED USE Enclosed for your information and use is a copy of a letter we l

received from Dr. Bruce S. Mallett, Chief, Materials Licensing l Section, NRC Region III which provides NRC guidance for releasing equipment and/or facilities such as those at GAC for unrestricted use. Please note that GAC's current license shall not expire until the NRC takes final action on GAC's renewal application.

Also, GAC should notify the Region III office in writ.ing if a decision is made to terminate activities involving materials authorized under the NRC license.

Pleat.e advist if ,te can be of further ase!.0tance.

Sincerely, e

William W. Wistrom Contracting officer Special Projects Branch Procurement & Contracts Division Enclosure cc w/cy enclosures  :

D. B. Howard, SE-33 l I, f3.'S..Mallett, NRC,xRegionEIII 7

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. JUL 2 21985 f1Et',0RANDUM FOR: Walt McMahon Oak Ridge Operations Enrichment Technology Division P.O. Box E Oak Ridge, TN 37830 FROM: Bruce S. Hallett, Chief Materials Licensing Section .;

4 Region III .

SUBJECT:

Release Of Equipment And Facilities 'At Goodyear Aerospace Corporation, NRC License Number SNM-1461 (Docket Number 070-01489) For Unrestricted Use As per our telephone conversation, attached is the NRC's guidance for releasing equipment and/or facilities such as those at Goodyear Aerospace for unrestricted i use. The current NRC License for Goodyear Aerospace (No. SNil-1461) is under

timely renewal, since the licensee filed a renewal application with the NRC in proper form 30 days prior to the expiration date (August 31,1984). Consequently, Goodyear Aerospace's existing license shall not expire until the NRC takes j final action upon the renewal application. As discussed, Goodyear Aerospace should notify Region III in writing if a decision is made to terminate activities involving materials authorized under the NRC license.

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i Bruce S. Mallett, Chief

Materials Licensing Section

Enclosures:

1. SRP for termination

2. 10 CFR Part 70

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, STAf.DARD REVIEW PLAN

• ) FOR TERMINATION OF SPECIAL NUCLEAR MATERIAL LICENSES -

1, Introduction This Standard Review Plan (SRP has been developed to provide guidance to the staff engaged in reviewing) applications for the termination of special nuclear material licenses and the release of facilities for unrestricted use. This plan includes a discussion of NRC policy and technical review criteria for temination of a license. This plan does not address the following issues:

o Onsite disposal of residual radioactive material (other than residual concentrations in soil determined acceptable for unrestricted release).

o Contamination levels higher than those specified for release for unrestricted use, o Possess 4n of discrete quantities of SNM in excess of critical mass quantitles.

o Detemination of Sfd holdup in the facility.

HQ technical assistance and guidance should be requested .if these issues should arise during the review. .

II. Policy It is policy of NRC prior to termination of a naterial license to possess and use sta that facilities and grounds shall be decontaminated to such levels so that they can be released for unrgstrictea use.

!!I. Review Procedure

, Under current NRC regulations, each licensee is required to notify the Commission, in writing, when the licensee decides to pemanently discontinue activities involving special nuclear raterial. Prior to license termination, the licensee is required to:

o Submit Fom NRC-314 that describes the disposal of licensed materials.

o Conduct a final radiological survey, o submit a radiological survey report which describes the scope of the h survey, general procedures followed, and presents the s'avey results. '

Appendix ! to this SRP, "Guidelines for Decentamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of License for ,

Byproduct. Source, or Special Nuclear Ma:erial," July 1952, provides acditicnal

• guidance as to what should be contairec in the survey report.

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2 In evaluating an application for termination, the NRC must verify that:

o A reasonable effort has been made to decontaminate the facility to levels below those specified in Table 1 "Acceptable Surface Contamination . '

Levels" of Appendix 1.

o Residual soil contamination (including any radioactive material buried onsite by the licensee in accordance with 10 CFR 20.302 or 10 CFR 20.304) shall not exceed the following concentration levels:

Soil Concentration Level Kind of Material (pCi/cm of s00) for unrestrir.ted area i) Natural Uranium (U-238 10

+ U-234) with daughters

- present and in equilibrium ii) Depleted Uranium or Natural 35 i Uranium that has been sepa.

rated from its daughters Soluble or Insoluble f

iii) Enriched Uranium 30 Soluble or Insoluble iv) Plutonium (Y) or (W) com. 25 pounds .

v) Am 241 (W) compounds 30 o Guidance for evaluating radioactivity in surface and groundwaters can be found in footnote 5 of Appendix B to 10 CFR 20 anc in (PA's !;ational Interim Primary Drinking Water Regulations (EPA 570/9-76 003).

If contamination levels are higher than those specified above, HQ guidance .

should be requested prior to deciding whether those levels are acceptable for unrestricted release.

Definitions A. Facility For the purpose of this procedure, "facility" is defined as buildings, grounds, equipment, instruments, furniture, vehicles, scrap and appur-tenances thereto, and, if necessary, groundwater. .

'p B. A discrete quantity is defined as measurable quantities of hhM in a liquid or solid form that can te accumulated into a single 1dentifiable mass or volume. This does not refer to 5!;M in the form of contamina: ion e on facilities or equipment. i

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[ C. Critical nass quantities are as specified below:

>350 g U-235, or F200 g U-233, or .

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,,7200 g Pu, or g 35 g U-g 2

+ >l for mixtures, or 1450 g Pu as sealed sources Review Criteria Although the fiRC's review of an application for license termination centers around the final radiological survey report which the licensee submits in support of the application, the reviewer should also review the operating history of the f acility to assess the potential for residual contanination at the site. This should include a review of the licensing files, inspection reports, prior NRC and other survey reports, if applicable, and facility incident reports.

The review of the licensee's close-out survey report should include an evaluation to assure:

o proper use of radiaton detection instruments, o overall adequacy of the survey, and -

o that residual contamination levels in the facility are less than tiRC's criteria for release of unrestricted use.

A. Instrumentation

1. All instruments used in the survey ~ should have been calibrated by qualified personnel, using accepted practices under the license.

2. Instruments should have suf ficient detection sensitivity so that the reasured data can be used to verify compliance with acceptable con-tanination levels. Guidance concerning the detection sensitivity fer different types of radiation detection instreents is included in Chapter 4 of NUREG/CR-2082 and NCF.P Report Nc. 50. Environmental Radiation Measurements.'

B. Scope of Surveys All indoor areas (such as floors, walls, ceilings) of the building and s

outdoor areas (such ss roofs. ground area, etc.) should be surveyed for '

radiation contanination levels and reported in the proper units lin the applicant's survey report. Prior to surveying the facility it should be divided into specific areas suitable for surveying. Guidance concerning the e choice of grid sizes and the total sample size 'equireo can be found in

• Chapter 3 of NUREG/CR-20S2.

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1. For ledoor Areas I' In each survey block which is formed by the grid, the following '

4 set of measurements'should'be conducted and reported:

a) Direct readings 'for' aloha 'and beta-gamma:

The average and the maximum contpination levels at the surface shouldbereportegindpm/100cm for the alpha counting mode; and in dpm/100 cm and urads/hr for the beta-gamma counting node.

b) Smear testing for determining a'spha and beta-gamma repovable contamination levels should be reported in dpm/100 cm . .

2. For Outdoor Areas - -

For the outdoor area radiation turvey, the following sample neasure-ments should be conducted and reported:

a) Direct reading for beta-gamma measurement at I cm above the i surface ano for gamma measurement at 1 meter above the surface at eacn grio point:

Both measurements should be expressed in urads/hr. (The external exposure rate at 1 meter above the surface should be less than 10 urads/hr above the background level.)

] b) Surface soil sanoles (0-5 cm): f

, The average soil concentration of radioactivity in' the facility may be measured by either taking systematic soil samples at all j blocks of the grid system or by taking randomly selected samples fer an unb:ased estimate.

1 Guidance concerning the number"of samples required for an unbiased estimate nay be found in Chapter 3 of NUREG/CR-2082.

If there is any reason to suspect (such as frem the site record i

indicating any radioactive spill incident or any elevated external exposure level, etc.) that certain discrete areas may centain e=tra-4 ordinary contaminatica, soil sateles shculd te collected from thesa areas. The radioactivity in all soil sar;1es shall be reported in picocuries per gram of dry soil, c) Subsurface soil samples:

Subsurface soil sample measurements are required if there is any p' reason to suspect that subsurface contamination existi in the outdoor area or under the building. Standard core sanpling tqchniques may

! be used in the suspected contaminated area to assess the subsurface soil contamination as a function of depth. The existence of any of ,

the following cenditions nay require analysis of subsurface samples

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(i) kecord showing that racicactive raterial has been curied at that area. ~ F>

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• 5 l (ii) Radioactive material (such as dry or liquid wastes) had been stored in the arer.s. underground, or in a pond. ,

i s (iii) Any unex' plainable, elevated, direct'su6ey'.rea' ding 'in the

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area. ,

l (iv)' Creeks, streams or under' ground transfer pipes were used as,a pathway for contaminated liquid. ef fluent release.

d)Watersamoles:

Samples shall be taken from each source of potable water, surface water, and groundwater on the site, including water found in core holes drilled for subsurface soil samples.

Additional onsite and offsite groundwater samples may be required

! if there is any reason to suspe;t that subsurface contamination j exists. c The result of measured water samples shall be reported in pC1/1.

Sediment samples frca streams or ponds into which'11guid effluents I i are released shall be sampled to measure the undissolved radio- t nuclides in the liquid . effluents. The sample , result shall be expressed in pCi/gm of ' dry weight.' ' ' ' i

, If af ter reviewing the site history and the'applicantTfinal radiological survey report the reviewer determines that the residual contamination. ,

levels in the fccility meets NRC's criteria for unrestricted release, the reviewer should perform or have performed a confirmatory survey of the facility to verify the licensee's close-out survey. The results of the ,

confirmatory survey should be compared to the close-out survey to determine ,

l that either: (1) the facility has been decontaminated to levels accept. l able for unrestricted release and therefort, the facility may be released l for unrestricted use, or (2) that aJoitional specified decontamination is l required. l

. l If the confirmatory survey indicates that further decontamination is required  !

the reviewer should so infom the literste and reqv.*:st that additional decon. l tamination be performed so that the facility reets levels acceptable for unre.  ;

stricted release. L If the confirmatory survey indicates that the f acilities are acceptable for unrestricted release, the reviewer should prepare a safety evaluation report L (SER) to support the termination action. l l The SER should clearly reveal the extent of the NRC review and technical b I

basis for the licensing actions. The format and centent of the,SER should be as follows: ,'

t, o Background { ,

e Discu:sion of the history of 9.se of the facility including a description ~

< of the kinds and anount of racioactive aterial that were usec in the facility and the type of chemical and pr.ysical processing on the#rYdio-active material. ,

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o Discussion .

Discuss the instruments and. methods of survey used in the..lict m t'

• survey of the facility. The licensae's menured residual cont,'-- M on i for each area and how it compares with NRC's criteria for unrestrkted release. .

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o Cenfireatory Survey 1 Discuss the results of the confirmatory survey and how it cenpares with i the close out survey. j o Conclusion  ;

Based on the findings in the discussion section of the SER, the conclusion may be drawn that the release of the facility for unrestricted use repre- i

, sents an insignificant risk to the public health and safety and to the j j environment and therefore, the revi(wer may recommend that the facility be released for unrestricted use and the license be terminated. ,

l 1 r Af ter the SER is completed, the reviewer will prepare a license termination '

letter for transmittal to the licensee. The letter SER, licensee's survey  ;

report and NRC's confirmatory, survey report forms a "license packag(," to i i support the licensing action. - '

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The termination letter is issued to the licensee and. filed in the docket ,s, l room with the "license package." -

1 . , j An example of a license termination letter and supporting SER is attached as Appendix 11. j

! Questions and Answer Section l

l This section presents more inform cion about the details of managing a j licensing case than was covered in the preceeding sections of this review '

plan. It is presented in a question and answer format for ease of reference. . ,

O. During the decontamination /decomissioning phase of the licensee's i

operation, the licensee may request a* enc 9ents to the license. khat I

! dces the reviewer need to do to process those amenenents?

i A. In general, the amendment applications are minor in nature and do not l

! require sophisticated technical analysis to support or deny the amend.

rent request. The types of license anencments that may be involved .

are as follows: ,

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1. Possession limit change. J' i

2. Modificattien and/or deletion of one or more of tr.e authorized L e

activities.

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3. Modification and/or elimination of license cenditions associateo [

with process suppcrt systems (i.e., ventilation requirements),.

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L 4. Modification an'd/or elimination of criticality control requirem,ents.

5. Provision for interim storage of contaminate'd material and/or ' " ' .

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. r. .: s.w .. .' a 6.. Modification and/or elimination of survey / monitoring requirements as related to safety and/or environmenta' issues that are normally associated w~ith an operating facility but not during or near the completion of the 080 phase.. . .

Prior .3 performing a technical review, the reviewer must assure that the -

administrative requirements are met. This includes docketing, fee assess-

. ment and payment, and distribution. The details of this should be checked with the appropriate administrative group in the Regions.

h The technical review requires an evaluation of the amendment request to ,

determine how it affects process safety, radiological safety, and ,

environmental impact. This evaluation should be documented in the form of a SER similar to the format presented in Section V of this review plan. Appendix III provides several SERs written for various types .

of amendments. These SERs should also should illustrate the type of issues that were considered in the review of various types.of amendment applications.

Q' Q. A licensee may' request a portion of the facility to,be released for unrestricted use. What requirements does the licensee need to meet prior to approval of this request and how should the reviewer handle that request?

A. Upon completion of the decontamination of the portion of the facility that is desired to be released for unrestricted use, the licensee shall submit ,

a report thtt assesses the results of the decommissioning activities and

.:he enviror.nental impacts of any residual contaminctior.. The raport shal'.

include final contamination survey oata for the portion of the facility under consideration and grounds that"provide the basis for unrestricted t el ea se. ,

The reviewer shall review the request applying the same review criteria where applicable as presented in Section V of this *eview plan. The parts that would not be applicable are outdoor $1 .sy requirements. All other segments of the procedures should apply.

In addition to these review requirements, the reviewer must determine that ongoing decontamination activities or stvrage of materials in other areas will not change the final survey status of the structure (s) to be releaseo. ,

The licensee must demonstrate positive controls in this regard. If not p~

the request snould not be approved. i l

Dependir.g on the specifics of the license, thre reviewer may'be required to issue a license amendment. If so, the procedures presented in the first part m of Section VI are applicable. If the license amendment is 'not required, the '

review and documentation of the results of the review is still r,equired.

An exanple of. both cases are presented in Appendix IV.

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0. A licer.see may request guidance on the radiological surveys that 'need to be performed. What guidance should the reviewer provide?, _,

4. The reviewer should provide the. licensee with the following'two documents

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as the guidance of the radiblogical sdrvey!'

.l. ' NPC's "Guidelines. for.Decontarir.ation of Facilities land Equipment ) 1 .

Prior to Release for' Unrestricted Use of Termination.of-Li. cense :for

Byproduct.. Source , Special Nuclear. Material ,"; July .1982.

2. Monitoring for Compliance with Decommissioning Termination Survey -

Criteria, NUREG/CR-2082.

Q. What is the general interpretation of the acceptable. surft.ce contamination

- levels specified in Table 1 of NRC's "Guidelines for Decontamination qf Facilities and Equipment Prior to Release for Unce.stricted Use?"

i A. In addressing this issue, one has to apply the ALARA concept. The : acceptabl e" l surface contamination levelt presented in Table 1 are minimum goals .the licensee should attempt to acnteve. In applying the ALARA concept, it is not enough for the licensee to just' meet the defined levels but to do

- the best job he can to reduce the contamination levels as low as reasonably

., achievable. However, a case may arise where the licensee cannot meet the defined levels. presented .but hts applied .the ALARA. principle. Such cases. t .s. ,,

should be referred to HQ for technical assistance.

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n APPENDIX 1

.. Guidelines for Decontamination of Facilities and Equir ent Prior to Release for Unrestricted Use or Termination of License for Byprcduct, Source, or Special Nuclear Material U S. Nuclear Regulatory Co=nission Division of Fuel Cycle and

, Material Safety, NMSS k'a shington , D.C. 20555 July 1952 O

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