ML20198P342
| ML20198P342 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 12/22/1998 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Wesley D CALIFORNIA, STATE OF |
| References | |
| CAL-3020, NUDOCS 9901070035 | |
| Download: ML20198P342 (4) | |
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j CENERAL ATDMN*S m e December 22,1998 CAL-3020 VIA OVERNIGHT DELIVERY SERVICE (in Duplicate)
ATTN: Mr. David Wesley State of California Department of Health Services i
Radiologic Health Branch 601 North 7th Street Sacramento, CA 95814-0208
Subject:
Radioactive Materials License No. 0145-37; Request to Release General Atomics' I ilding 22 (TRIGA* Fuel Fabrication Facility) to Unrestricted Use and Delt
. From License
References:
1)
NRL nspection Report 70-734/98-01, dated February 13,1998
- 3) ~ NRC Inspection Report 70-734/98-02, dated July 31.1998 2)
Asmussen, Keith E. Letter No. 696-3019 to Charles E. Gaskin, " Request to Release General Atomics' Building 22 (TRIGA* Fuel Fabrication Facility) to Unrestricted Use and Delete it from License," dated December 22,1998
Dear Mr. Wesley:
J General Atomics' (GA's) State of California broad scope Radioactive Materials License 1
No. 0145-37 and U.S. Nuclear Regulatory Commission (NRC) Special Nuclear Material License ll No. SNM-696 both describe the " authorized place of use" simply as "The licensee's San Diego, j
I California site at 3550 General Atomics Court." As you are aware, GA is continuing its efforts to decommission and obtain the release to unrestricted use of certain of its facilities and portions p
of its site (i.e., facilities for which GA has no plans for conducting future activities involving the use of radioactive materials).
Q In the case of GA's special nuclear materials license (SNM-696), the goal is license termination. In the case of GA's radioactive materials license (0145-37), the objective is to focus j
and limit the scope to a selected few facilities and portions of GA's site where activities involving the use of source and/or by-product material will continue to be conducted for some time into the future. (An example of a continuing project being the facility housing GA's nationally recognized magnetic conGnement fusion research project.)
9901070035 981225 Fl PDR ADOCK 07000734!
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3550 GENERAL, ATOMICS COURT. %* N DIEGO CA 92121 1194 PO BOX 85608. SAN DIEr.O. CA 92186 6608 (619) 455-3000
' Mr. David Wesley, State of California, Radiologic Health Branch December 22,1998 696-3020 Page 2 Most recently, GA completed the decontamination and final radiological surveys ofits Building 22, i.e., GA's former TRIGA* Fuel Fabrication Facility. This facility was built in 1974 for the purpose of housing GA's TRIGA* fuel manufacturing operations which involved the use of special nuclear material (typically ~ 19.9 % enriched uranium - though there was one campaign in which highly enriched uranium, i.e., greater than 20%, was down-graded to less than 20 % by blending with depleted uranium). These operations and the use of special nuclear material were authorized under the jurisdiction of GA's Special Nuclear Material License No.
SNM-696. TRIGA* fuel fabrication related activities were conducted in this facility from 1974 until September 30,1995, when GA ceased its principal NRC licensed activities and requested a possession only license amendment.
GA's NRC-and State-approved Site Decommissioning Plan identifies Building 22 as being under the jurisdiction of the NRC. Accordingly, the NRC has inspected the facility, made independent radiological measurements, split soil samples with GA and compared analytical results, and observed GA conduct decontamination and final survey activities (Refs. I and 2).
Furthennore,it is GA's understanding that during the recent NRC and State of California coordination meeting held in San Diego on December 9,1998, it was reaffirmed that NRC would continue with the lead in releasing Building 22.
As mentioned above, GA has recently decontaminated its TRIGA* Fuel Fabrication Facility (Building 22) and is in the process of seeking NRC release of the facility to unrestricted use (Ref. 3).
Since GA's radioactive materials license issued by the State of California refers in j
general terms to GA's site as the authorized location for conducting activities involving the use of radioactive materials, and since GA has no intention to ever use Building 22 for activities involving the use of Source or By-product material, GA hereby requests that the State of California also release Building 22 to unrestricted use and delete it from GA's Radioactive Materials License No. 0145-37.
During decommissioning activities at the TRIGA* fuel fabrication facility, enriched uranium contamination was detected in the building and in soil at certain locations beneath the concrete floor slab. The contaminated surfaces were decontaminated or removed from the facility and dispositioned as low level waste. Similarly, the impacted soil was remediated by excavation and removal. Following these remediation activities, final radiological surveys (measurements and sampling and analyses) were conducted to demonstrate that the NRC-and l
State-approved criteria for release were met.
The results of GA's extensive and comprehensive h :al radiological contamination j
surveys, measurements, sampling, and analyses demonstrate that, with the temporary exception i
of the direct radiation exposure rate limit, Building 22 and the site (asphalt and soil) under and immediately surrounding the building (out to a distance of about one (1) meter from the exterior L
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Mr. David Wesley, State of California, Radiologic Health Branch December 22,1998 696-3020 Page 3 walls) meet the NRC-and State-approved criteria for release to unrestricted use. These results are documented in a report titled," FINAL RADIOLOGICAL SURVEY PERFORMED AT GENERAL ATOMICS' BUILDING 22," dated December 21,1998. This report (copy enclosed) was submitted to the NRC in support of GA's request for the release of Building 22 to unrestricted use (Ref. 3).
The NRC-and State-approved exposure rate release criterion states that the " exposure rates are not to exceed 10 microR/hr above background at one (1) meter above the surface." As mentioned above, the exposure rate at building 22 currently exceeds this release criterion.
However, this is only a temporary circumstance and it is not because of residual contamination associated with Building 22 itself. Rather, the exposure rate at Building 22 currently exceeds the release limit by approximately 10-20 microR/hr because of the temporary, nearby presence of sources of radiation on the adjacent site where GA's (now demolished) hot cell facility is being decommissioned. Items such as boxes of contaminated soil and other debris resulting from the decontamination and demolition of GA's hot cell facility are the sources of radiation that cause the exposure rate limit to be exceeded at Building 22. These items / materials will soon be removed from the area. Once these materials have been removed, and remediation is completed on the hot cell site, the exposure rate at building 22 will be below the release criteria.
Under normal circumstances, GA would wait until it was able to demonstrate compliance with all release criteria - including exposure rates - before submitting a request for a release.
However, GA has an urgent need for space into which to relocate ongoing projects, and Building 22 itself has been remediated to levels below the release criteria. GA has reached the point where the only space available to relocate projects is space that is awaiting release. Thus, GA needs the use ofits Building 22.
GA has requested (Ref. 3) NRC's concurrence with the conclusion that the facility (Building 22)itselfis " clean"in the sense that the previously contaminated surfaces and soil have been remediated to levels below their respective release criteria. GA hereby requests the same of the State of California.
GA also requested (Ref. 3) that its Building 22 be released by NRC to allow GA to repair / refurbish /remodel the facility and allow it to be occupied by GA employees. GA hereby requests the same of the State of California.
In the meantime, the items on the nearby hot cell facility site which are causing the l
exposure rate limit at Building 22 to be exceeded, will be moved out of the area. After those sources of radiation have been removed from the area, GA will conduct and document measurements demonstrating compliance at Building 22 with the exposure rate release criterion.
A report documenting such compliance will be submitted at that time to complete the record of information necessary to support GA's request for Building 22 to be released to unrestricted use and deleted from its Special Nuclear Materials and Radioactive Materials Licenses.
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l Mr. David Wesley, State of Califomia, Radiologic Health Branch December 22,1998 696-3020 Page 4 If you should have any questions regarding this request, please contact me at (619) 455-2823 or Paul Maschka at (619) 455-2959. Once again, your assistance in responding to our request is very much appreciated.
Very truly yours, Y S.
~'
Keith E. Asmussen, Ph. D., Director I
Licensing, Safety and Nuclear Compliance
Enclosure:
" FINAL RADIOLOGICAL SURVEY PERFORMED AT GENERAL ATOMICS' BUILDING 22," dated December 21,1998 cc:
Mr. Wayne L. Britz, U.S. NRC, Region IV (letter only)
Mr. Charles E. Gaskin, U.S. NRC, Headquarters (letter only)
Ms. Kathleen Henner, State of California, Department of Health Services, Los Angeles i~
Dr. Ronald Rogus, State of California, Dept. of Health Services, Sacramento (letter only)
Dr. D. Blair Spitzberg, U.S. NRC, Region IV (letter only)
Dr. Gerard Wong, State of California, Dept. of Health Services, Sacramento (letter only)
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