ML20196D379

Application for Amends to Licenses R-38 & R-67,to Revise Proposed TS & Request Deletion of License Condition 2.B.(2). Mark-up of Previously Submitted strike-out Version of TS Showing Latest Changes Made

ML20196D379
Person / Time
Site:	General Atomics
Issue date:	06/15/1999
From:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Alexander Adams NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20196D385	List: ML20196D379 ML20196D395
References
38-3095, TAC-M98498, TAC-M98499, NUDOCS 9906240267
Download: ML20196D379 (4)

Text

I hEENERAL ATOM 9CE June 15,1999 38-3095 l

Via Express Delivery Service Document Control Desk l U.S. Nuclear Regulatory Commission J Washington, D.C. 20555 i ATTN: Mr. Alexander Adams, Jr. j

Subject:

Docket No. 50-89; License No. R-38: Submittal of Revised Proposed Technical Specifi-eations and Request to Delete License Condition 2.H.(2)-(TAC Nos. M98498 & M98499) i 1

References:

1) Adams, Alexander, Jr., Letter to Dr. Keith E. Asmussen, Request For Additional i 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 50-163; License Nos. R-38 and R-67 Respectively: Submittal ofResponse to Item No. 2 ofRequestfor Additional Information DatedApril14,1999 (TAC Nos. M98498 and M98499)," dated May 12,1999 l

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 I reactor, GA has revised the previously proposed Mark I Technical Specifications. In a few instances, the latest changes reinstate previously proposed deletions. /

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ltem 2 of your request consisted of six (6) parts designated "a" through "f." Each part involved the j need to address an issue associated with G A's Technical Specifications. Accordingly, and in order to l reflect the above mentioned feedback on GA's previous submittal, the proposed Technical Specifications for GA's Mark I reactor have been further revised and are submitted herein for your review and approval. j To assist you in your review, enclosed is a " mark up" of the previously submitted " strike-out" f version of the Technical Specifications. The " mark up" shows the latest changes that were made to the previously submitted proposed Technical Specifications and corresponding " strike out" version. Thus,

• 7)g)) j 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 thejustification for the change. Also enclosed is an " Evaluation of Safety Significance of Specific Changes" which gives the correlation between the annotating letters and the correspondingjustification 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 specificjustification 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 tbt the requirements are now the same for the Mark I and Mark F facilities. For example, I 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 Technical Specification 7.5 and 7.6 (and in particular,7.6 d.).

9906240267 990615 PDR ADOCK 05000089 P PDR 2 3550 GENERAL ATOMICS COURT. SAN DIEGo. CA 92121-1194 PO BOX 85608. SAN DIEGo. CA 92186 5608 1619)455 3000

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Mr. Alexander Adams, Jr., U.S. NRC June 15,1999 38-3095 Page 2 4 Part "b" : The proposed Technical Specifications for the Mark i 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.

See proposed Technical Specification 3.3.

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 3.3.

l 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 1 by the organization chart), as reflected and used in the proposed Technical Specifications, consistent with that in the Decommissioning Plan.

l l Part "e" : The proposed Technical Specifications have been revised to include a requirement for written procedures for radiation protection and for " decommissioning activities

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(consistent with the Decommissioning Plan)." See proposed Technical Specifications 7.3 a. and e. Note that " consistent with the Decommissioning Plan" includes commitments for a radiation protection program including having applicable work y' procedures and Health Physics procedures in place (See, for example, Sections 3.1.1 and 3.1.2 of Chapter 3 of the Decommissioning Plan).

Part "f" : The proposed Technical Specifications have been revised to include a definition of an

" abnormal occurrence"(See Technical Specification 1.8). Further, Section 7.6 a. 2. of ,

the 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  !

l eny abnormal occurrence.

1 In providingjustification, and a basis, for many of the proposed Technical Specification changes, I l GA makes reference to the fact that all fuel has been permanently removed from the Mark I reactor facility.

Since GA does not, and will never again, possess any special nuclear material under its Mark I reactor license, GA wishes to delete the corresponding license condition (LC 2.B. (2)) which authorizes the possession of special nuclear material. This license condition is meaningless under the circumstances.

Accordingly, GA hereby requests that the Mark I reactor license R-38 be amended by deletion of License Condition 2. B. (2). This deletion reinforces GA's justification for its proposed Technical Specification changes.

Finally, note that GA will be submitting similarly revised proposed changes to its TRIGA* Mark F l Technical Specifications within the next couple of days. If you should have any questions regarding this submittal, please do not hesitate to contact me at (619) 455-2823.

Very truly yours, I Keith E. Asmussen, Director Licensing, Safety and Nuclear Compliance Encl: 1) Proposed Revised Technical Specifications for GA's Mark i TRIGA* Reactors, dated June i 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: Mr. Ellis W. Merschoff, Director, NRC, Region IV (w/o enclosures)

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i Evaluation of Safetv Significance of Specific Changes

, Mark I (Proposed Amendment No. 36)

Because of the hirge number of changes, a number of categories of change are noted here I j

with a letter designation. These are keyed to the strikeout copy of the Technical (

SpeciGcation (Attached) to indicate the basis for each change.

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

H Deletes reference to reactor operation and experiments, a reactor condition, equipment, or fuel which is no longer applicable or required for safety related functions since the reactor license has been amended to withdraw authorization to operate and all fuel has been permanently removed from the reactor and 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 fuelin the reactor or facility and there will be no fuel in the reactor of facility, there is no reduction in safety.

4 C A definition or requirement that had been associated with the reactor has been added or revised to apply instead to the Facility rather than to the reactor.

These revisions are appropriate since the reactor has been disabled and dismantled j by removing all fuel from the grid plate and from facility. 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 from the facility. Safety considerations for decontamination and decommissioning activities are addressed in the TRIGA* Decommissioning Plan.

E ClariGcation. Improves consistency or clarity.

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

l F Incorporates a current license requirement and may add conservatism.

There is no reduction in safety, i

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