ML20198P542
| ML20198P542 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 12/22/1998 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Gaskin C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20198P547 | List: |
| References | |
| 696-3019, NUDOCS 9901070075 | |
| Download: ML20198P542 (3) | |
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+$+ camnemt aronnes December 22,1998 h, d,.
696-3019 if VIA EXPRESS MAIL SERVICE Mr. Ch:Aes E. Gaskin l.
Licensing Section 1/ Licensing Branch p
Division of Fuel Cycle Safety l
and Safeguards, NMSS U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Docket No.70-734; SNM-696: Request to Release General Atomics' Building 22 l
(TRIGA* Fuel Fabrication Facility) to Unrestricted Use and Delete it from License
References:
- 1) NRC Inspection Repon 70-734/98-01, dated February 13,1998 1
- 2) NRCInspection Report 70-734/98-02, dated July 31,1998 l
Dear Mr. Gaskin:
As you are aware, General Atomics (GA) is continuing its effort directed at decontaminating, as appropriate, and obtaining the release to unrestricted use of selected facilities on its San Diego site (i.e.,
facilities for which GA has no plans for conducting future activities involving the use of radioactive materials).
l' Most recently, GA completed the decontamination and final radiological surveys ofits Building j
22, i.e., GA's former TRIGA* Fuel Fabrication Facility. This facility was built in 1974 for the purpose of l
housing GA's TRIGA* fuel manufacturing operations which involved the use of special nuclear material (typically ~ 19.9% enriched uraniunt These operations and the use of special nuclear material were authorized under the jurisdiction a. 2 A'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.
Building 22 is divided into a northern portion and a southern portion which are separated from j
each other by a storage vault, walls and % inch thick steel plating. The northern portion of the building was used for TRIGA* fuel fabrication related activities and the southern ponion (room 113) was used for non-TRIGA*, non-radioactive material related activities, such as storage.
Building 22 has external dimensions of ~ 60 ft x 125 ft (18.3 m x 38.1 m) and encompasses an l
area of ~ 7500 ft (697 m ). Located adjacent to the north end of the building is a concrete pad that has an
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2 2
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area of ~ 1320 ft (123 m ). The footprint which is the subject of this request extends ~ l meter outward from the building and the north pad. The exterior footprint around the building has an area of ~ 1365 ft j,,/
2 2
2 2
(127 m ). The total area associated with this requested release to unrestricted use is ~ 10,185 ft (947 m ),
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Enriched uranium contananation was detected in the facility and in soil at cenain 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 State-approved criteria for release were met.
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B 35$0 GENERAL ATOMICS COURT, SAN DIEGO. CA 92121-1194 PO BOX 85608, SAN DIEGO CA 92186 5608 1619)455 3000 M
U.S. Nuclear Regulatory Commission December 22,1998 696-3019 Page 2 The results of GA's extensive and comprehensive final radiological contamination surveys, measurements, sampling, and analyses demonstrate that, with the temporary exception of the direct radiation exposure rate limit, Bui; ding 22 and the site (asphalt and soil) under and immediately surrounding the building (out te a distance of about one (1) meter from the exterior walls) meet the NRC-and State-approved criteria fre release to unrestricted use. These results are documented in the enclosed repott titled," FINAL RADIOLOGICAL SURVEY PERFORMED AT GENERAL ATOMICS' BUILDING 22," dated December 21,1998.
The 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 o. esidual 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. TI'ese items / materials will soon be removed from the j
area. Once these materials have been removed, and remediation is completed en 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 l
projects is space that is awaiting release. Thus, GA needs the use ofits Building 22.
GA hereby requests NRC's concurrence with the conclusion that the facility (Building 22) itself is
" clean" in the sense that the previously contaminated surfaces and soil have been remediated to lefels below their respective release criteria GA fur 6er requests that its Building 22 be released to allow GA to repair / refurbish /remodel the facility and allow it to be occupied by GA employees.
In the meantime, the items on the nearby hot cell facility site which are causing the 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 License.
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). Furthermore, 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 reaff4med that NRC scould continue with the lead in releasing Building 22.
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U.S. Nuclear Regulatory Commission December 22,1998 696-3019 Page 3 i
Since GA's radioactive materials license issued by the State of California refers in general terms to l
GA's site as the authorized location for conducting activities involving the use of radioactive materials, and since GA has no intention to ever u,e Building 22 for activities involving the use of Source or By-product material, GA is also requesting, under separate cover, that the State of California release Building 22 to unrestricted use and delete it from GA's Radioactive Materials License No. 0145-37.
Please note that GA has an urgent need to be allowed to re-occupy Building 22 as soon as l
possible. GA needs to relocate certain of its projects from other GA laboratories that have not yet been i
rele.ased, to make those laboratories accessible for decontamination, if necessary, and final surveys. Thus, timely authorization to refurbish and re-occupy Building 22 is crucial to the decommissioning schedule to whicia GA has committed its resources. It is also important from the point of view of the projects which must relocate, since they must plan their relocation and "down time"in sync with the decommissioning and release schedule.
If you should have any questions regarding our request or the enclosed report, please contact Mr.
Paul Maschka at (619) 455-2959, or me at (619) 455-2823. Once again, as in the past, your assistance in responding to our request is very much appreciated.
Very truly yours,
{
v_ -
Keith E. Asmussen, Ph. D., Director Licensing, Safety and Nuclear Compliance
Enclosure:
Report titled," FINAL RADIOLOGICAL SURVEY PERFORMED AT GENERAL ATOMICS' BUILDING 22," dated December 21,1998 cc: Dr. D. Blair Spitzberg, Chief, Nuclear Materials Safety Branch 3, NRJ Region IV Mr. Wayne L. Britz, Fuel Cycle Inspector, NRC Region IV Mr. David Wesley, State of California, DHS (letter only, enclosure under separate cover) l i
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