ML20196C349

Application for Amend to License R-67,deleting License Conditions 3 & 4 Which Duplicate Requirements Now in Proposed TS

ML20196C349
Person / Time
Site:	General Atomics
Issue date:	06/16/1999
From:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Alexander Adams NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20196C354	List: ML20196C349 ML20196C357
References
67-3097, TAC-M98498, TAC-M98499, TACM98498, TACM98499, NUDOCS 9906240009
Download: ML20196C349 (4)

Text

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CENERAL ATORNCS June 16,1999 67-3097 Via Express Delivery Service Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Mr. Alexander Adams, Jr.

Subject:

Docket No. 50163; License No. R 67: Submittal of Revised Proposed Technical Specifi-cations and Request to Delete License Conditions 3 and 4 - (TAC Nos. M98498 &

M98499)

References:

1) Adams, Alexander, Jr., Letter to Dr. Keith E. Asmussen, Request For Additional Information (TAC Nos. M98498 and M98499), dated April 14,1999

2) Asmussen, Keith E., Letter No. 38/67-3084 to U.S. Nuclear Regulatory Commission ATTN: Mr Alexander Adams, Jr., " Docket Nos. 50-89 and 50-163t License Nos. R-38 and R-67 Respectively: Submittal ofResponse to item No. 2 of Requestfor Additional Information Dated April 14,1999 (TAC Nos. M98498 and M98499)," dated May 12,1999

Dear Mr. Adams:

In response to Item 2 of your request for additional information (Ref.1), General Atomics (GA) previously submitted proposed changes to the Technical Specifications for its TRIGA* Mark I and Mark F non-power reactor Licenses R-38 and R-67 (Ref. 2). As a result of, and in response to, subsequent recent telephone conversations between GA and yourself on the subject of the proposed Technical Specifications for GA's Mark F reactor, GA has revised the previously proposed Mark F Technical Specifications. In a few instances, the latest changes reinstate praiously proposed deletions.

Item 2 of your request consisted of six (6) parts designated "a" through "f." Each part involved the need to address an issue associated with GA's Technical Specifications. Accordingly, and in order to reflect the above mentioned feedback on GA's previous submittal, the proposed Technical Specifications )

for GA's Mark F reactor have been further revised and are submitted herein for your review and approval. /

To assist you in your review, enclosed is a " mark up" of the previously submitted " strike-out" version of the Technical Specifications. The " mark up" shows the latest changes that were made to the 7 ,d previously submitted proposed Technical Specifications and corresponding " strike out" version. Thus,  ;

with the " mark up" you can see what changes have been made to the previously submitted (Ref. 2) proposed Technical Specifications. The " mark up" version is also annotated with capital letters "A" "F' in the margin. These letters correspond to the justification for the change. Also enclosed is an " Evaluation of Safety Significance of Specific Changes" which gives the correlation between the annotating letters and the corresponding justification for the change. For those few instances where the justification for a specific change does not fall into one of the A - F categories, the specific justification is written on the

" mark up" version of the proposed Technical Specifications.

Following are specific responses corresponding to each of parts "a" through "f" of Item 2 of your initial request (Ref.1):

Part "a" : The proposed changes to the record keeping and reporting requirements are such that the requirements are now the same for the Mark I and Mark F facilities. For example, t ' -} 2, g' the proposed Mark F Technical Specifications (Ref. 2) are consistent with those prepared for the Mark I and require the submittal of an annual report. See proposed 9906240009 990616 PDR 7

ADOCK 05000163 3 P PDR j 3550 GENERAL ATOMICS COURT. SAN DIEGo. CA 921211194 PO DoX 85608. SAN DIEGo, CA 92186-5608 (619)455-3000

Mr. Alexander Adams, Jr., U.S. NRC June 16,1999 38-3097 Page 2 Technical Specification 8.5 and 8.6 (and in palticular,8.6 d.).

3 Part "b" : The proposed Technical Specifications for the Mark F facility have been revised to include a statement consistent with GA's decommissioning plan with respect to maintaining the work area at a negative pressure with respect to the surrounding areas during decommissioning. See proposed Technical Specification 3.5.

Part "c" : The proposed Technical Specifications have been revised to require the exhaust pathways to the environment be controlled and monitored. See proposed Technical Specification 3.0, and in particular 3.5. See also proposed Technical Specification 6.2.

Part "d"

• The proposed Technical Specifications have been revised by replacing the previous organization chart in the " Organization" Section of the Technical Specifications with an organization chart consistent with the decommissioning organization chart found in )

Figure 2-7 of the Decommissioning Plan. This change makes the organization (defined by the organization chart), as reflected and used in the proposed Technical i Specifications, consistent with that in the Decommissioning Plan.

Part "e" : The proposed Technical Specifications have been revised to include a requirement for written procedures for radiation protection and for " decommissioning activities (consistent with the Decommissioning Plan)." See proposed Technical Specifications 8.3 a. and f. Note that " consistent with the Decommissioning Plan" includes commitments for a radiation protection program including having applicable work procedures and Health Physics procedures in placa (See, for example, Sections 3.1.1 and 3.1.2 of Chapter 3 of the Decommissioning Plan).

/

Part "f" : The proposed Technical Specifications include a definition of an " abnormal i occurrence"(See Technical Specification 1.8). Further, Section 8.6 a. 2. of the j proposed Technical Specifications requires reporting within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC any  !

abnonnal occurrence. ]

GA wishes to delete License Conditions 3 and 4 which duplicate requirements now in the proposed Technical Specifications. There is no need to duplicate requirements and in fact it could contribute to confusion if a change is required at a later date. Therefore, for the sake of clarification and simplification, GA hereby requests that the Mark f reactor license R-67 be amended by deletion of License Conditions 3 and 4.

If you should have any questions regarding this submittal, please do not hesitate to contact me at (619)455-2823.

Very truly yours,

, Keith E. Asmussen, Director i

Licensing, Safety and Nuclear Compliance Encl: 1) Proposed Revised Technical Specifications for GA's Mark F TRIGA* Reactors, dated June 1999 (3 copies)

2) " Mark up" of previously submitted " Strike-out" Version of Enclosure 1 (3 copies)

3) " Evaluation of Safety Significance of Specific Changes"(3 copies) cc: Mi. Ellis W. Merschoff, Director, NRC, Region IV (w/o enclosures) l

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• 8236 Remmet Ave P.O. Box 7184

• Carioga Park, CA 9130&7184 Prod. No. 3907

Mark F (Proposed Amendment No. 45)

Because of the large number of changes, a number of categories of change are noted here with a letter designation. These are keyed to the strikeout copy of the Technical

' Specification (Attached) to indicate the basis for each change.

A Editorial change only. No impact on content or intent.

B Deletes reference to reactor operation and experiments, a reactor condition, equipment, or fuel which is no longer applicable or required for safety related functions smce the reactor license has been amended to withdraw authorization to operate and all fuel has been permanently removed from the reactor and placed in the Fuel Storage Area of the reactor pool in the facility.

Since the deleted requirements are not applicable and the license has been amended to withdraw authorization to operate and since there is no fuel in the reactor and there will be no fuel in the reactor, there is no reduction in safety.

C A definition or requirement that had been associated with the reactor has been added or revised to apply instead to the facility including the Fuel Storage Area rather than to the reactor.

These revisions are appropriate since the reactor has been disabled and dismantled by removing all fuel from the grid plate to the Fuel Storage Area in the facility.

Fuel storage in the Fuel Storage Area of the pool has already been addressed under the license. Since the requirement remains applicable to the Facility, and since the reactor has been permanently disabled and defueled, there is no reduction in safety.

D Adds requirements associated with decommissioning activities as described in an NRC approved decommissioning plan. There is no safety significance for the reactor as the fuel has been permanently removed. Decommissioning activities planned prior to fuel removal from the Fuel Storage Area of the pool are addressed in the Decommissioning Plan. Safety considerations for decontamination and decommissioning activities are addressed in the TRIGA*

Decommissioning Plan.

E Clarification. Improves consistency or clarity.

There is no relaxation of requirements and hence no reduction in safety.

F Incorporates a current license requirement and may add conservatism.

There is no reduction in safety.