ML20198S806

Forwards Request for Addl Info Re Licensee 970418 Request for Amends to Licenses R-38 & R-67.Response Requested within 90 Days of Ltr Date

ML20198S806
Person / Time
Site:	General Atomics
Issue date:	01/16/1998
From:	Alexander Adams NRC (Affiliation Not Assigned)
To:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
References
TAC-M98498, TAC-M98499, NUDOCS 9801260294
Download: ML20198S806 (6)

Text

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1 January 16,'-1998 Dr. Keith E. Asmussen, Director "s

Licensing, Safety and Nuclear Compliance General Atomics P.O. Box 85608 San Diego, Cellfornia 92186 9784

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC NOS, M98498 AND M98499)

Dear Dr. Asmussen:

We are continuing our review of your amendment request for Amended Facility License Nos. R 38 and R 67 for the General Atomics TRIGA Mark I and Mark F Research Reactorc which you submitted on April 18,1997. Durirg our review of your amendment request. ,3 questions have arisen for which we require additionalinformation and clarification. Please provide responses to the enclosed request for additionalinformation within 90 days of the date of this letter, in accordance witti 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Followir.g receipt of the additionalinformation, we will continue our evaluation of your amendment request.

If you have any questions regarding this review, please contact me at (301) 415-1127. i Sincerely, ORIGINAL SIGNED BY:

Alexander Adams, Jr., Senior Project Miinager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Rogulation Docket Nos. 50-89 and 50-163

Enclosure:

As stated .

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Dr. Keith E. Asmussen, Director -

Licensing, Safety and Nuclear Compliance General Atomics P.O. Box 85608 San Diego, California 92186-9784

$UBJECT: REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. M98498 AND M98499)

Dear Dr. Asmussen:

We are continuing our review of your amendment request for Amended Facility License Nos. R-38 and R-67 for the General Atomics TRIGA Mark I and Mark F Rusearch Reactors which you submitted on April 18,1997. During our review of your amendment request, questions have arisen for which we require additionalinformation and clarification. Please provide responses to the enclosed request for additionalInformation within 90 days of the date of this letter, in accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your amendnient request.

If you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely, Alexander Adams, Jr., Senior Project Manager Non-Power Reactors and Decommissioning Project Directoiate Division of Reactor Progrem Management Office of Nuclear Reactor Regulation Docket Nos. 50-89 and 50-163

Enclosure:

As stated.

cc w/ enclosure:

See next page s

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Gen 9tal Atomics Docket Nos. 50-89/163 cc:

Califo nia Department of Health ATTA. Chief, Environmental Radiation Control Unit Radiologic Health Section 714 P Street, Room 498 Sacramento, California 95814

ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION GENERAL ATOMICS TRIGA MARK l AND MARK F RESEARCH REACTORS DOCKET NOS. 50-89 AND 50-163

1. Section 1.2. On Figures 13 and 1-4 please show the boundaries of the Mark I, Mark F and Star., of California licenses.

2. Section 1.2.1. Because it is not Ilcensed by the NRC, the NRC cannot approve decommissioning of the remaining components of the Mark til reactor Please describe what steps, if any, have been take^ with the State of California to decommission the Mark Ill and terminate that license.

3. Sections 1.2.1 and 2.3. It appears from your decommissioning plan (DP) that you propose to cortpletely demolish the reactor building. Your termination survey and

, NRC's confirmatory survey would be of the site. NRC normally approves DPs that propose complate demolition of structures when removing the activated and contaminated material threatens the structuralintegrity of the building and could have an impact on non-radiological safety. However, section 2.2.2 cf your DP shows that the radioactive portions of the f acility are confined to the reactor internals and biological shield. Also section 3.3 appears to show a decommissioning process where the radioactive materialis removad without jeopardizing the structuralintegrity of the reactor t,ailding. Please jastify demolition of the reactor building before the confirmatory survey is requested from NRC or revise your DP to show the conduct of the termination and confirmatory surveys on the decontaminated and dismantled building. Please revise other portions of your DP as needed.

4. Section 1.2.2, What oart of the '.otal cost shnwn in the table is related to the decommissioning of the Mark I and Mark F reactors?

5. Section 1.2.2. It is mentioned that removal and shipment of fuel are not coasidered decommissioning tasks. However, pcssession, on-site handimg, and transportation must comply with NRC regulations and may require NRC authorizations. Explain how these functions are to be managed whenever fuelis on site before and during actual dismantlement and decontamination of the TRIGA reactor facilities.

6. Section 1.2.3. Please provide information that shows that General Atomics Technologies Corporation has been meeting the terms and conditions of their external sinking fund discussed in your submittal of May 20,1996 (Reference 10,5). If the sinking fund does not contain sufficient funds to carry out decommissioning, where wil' actual funding come from for decommissioning activ! ties?

7. Sestion 1.2.4. Please provide a copy of the Quality Assurance Program Document T prepared for decommissioning of the reactors.

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8. Table 21. Does the information in this table consider the activation of reactor structure and components such as the reactor tank, concrete and soil surrounding the reactor? For example, Europium-152 is a common isotope from the irradiation c) concrete, but according to your table, is not an expected radionuclide. Do your calculations show that soil was activated by operation of the reactor? If so, what volume of sollis activated?

9. Sections 2.2.3 and 4. Please discuss the difference between criteria to release the site and structures for unrestricted use at the end of decommissioning activities and the criteria to dispose or remove potentially contamin ed materials from the site during the decommissioning process.

a. Please clearly discuss criteria for release of the site, structures and components for unrestricted use at the time of license termination. Address both contamination and radiation fields. Please see the new Subpart E of 10 CFR Part 20, " Radiological Criteria for License Termination." Because, as discussed in 10 CFR 20.1401(b)(3), you have subml(ted your DP before August 20,1998, the release criteria applicable to your application are the appropriate sections of

" Cleanup Criteria" for reactor licensees in the " Action Plan to Ensure Timely Cleanup of Site Decommissioning Management Plan Sites" dated April 16,1992 (57 FR 13389). Please note that some guidance in th!s document is for materials licensees and may not be appdcable to your situation,

b. Please discuss your plans for disposal of radioactive material created by decommissioning activities. This question refers to material that will not be released for unrestricted use by termliation of the reactor licenses.

10. Section 2.3.1 Table 2-4. The items in this list are normally considered facility components that are removable only after the decommissioning amendment is approved. For the NRC licensed reactors please commit to not removing these components until the decommissionin'g amendment is issued or provide justification for removing th-

• components under the possession only amendment. If removal of these components will occur under the decommissioning amendment, please revise the DP accordingly.

11. Section 2.3. Under 10 CFR 50.82(b), an amendment to existing reactor licenses will be issued by NRC to authorize dismantlement and decommissioning. These amended licenses will include relevant Technical Specifications (TSs) and other features, including applicable Pnysical Protection and Emergency Plans. Please submit proposed documents for our review and evaluation. If you wish to use the existing documents please state this. You may want to censider developing these documents to address relevant issues both while any fuel is on site, and after fuel removal.

12. Section 2.3 Use of a localized fine mist of water is mentioned. How will the contaminated water be disposed of ?

13. Section 3.1.2. The DP refers to approved procedures. Please explain the approval process and its relatic'1 ship to the reactor TSs.

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d-4 114.' Section 3.1.3. Please discuss a dose estimate to members of the pubic from decommissioning activities.

15. Table 3-2. Please revise this table to clearly show the collective dose from - ,

decommissioning the NRC licensed reactors separate from the State of California -

licensed material. . l o 16. Section 3.3: Please discuss the potentist consequences to the public and the workers, ,

assuming's pool leak while fuel is still on the site, perhaps initiated by nearby. 1 dismantlement activities, or even by a seismic event. . '

17. Figure 4-3. Please discuss the use of the sampling system depicted in this figure.

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' 18. Section 6. Please discuss continued compliance with Parts 50 and 73 for your

, physical security pian, t

19. Section 9. -Your definition of unreviewed safety question is different from that in 10 CFR 50.59. Amendments to the regulations in August 1996 extended the application of 10 CFR 50.59 to NPRs whose licenses no longer authorize operation of ,

the reactor. Please amend this section of your DP to be in accordance with the regulLtions.

20. Appendix A. With tne change in license status of the Mark I to possession-only, do you plan to conduct additional chara::terization measurements if so, please desci ;;,e

the results of those measurements, or if not yet conducted, described the planned measurements.

21. - Appendix B,-Section 2.2, page 8 8: Please give best estimates for the schedule for fuel shipme.nt off-site, and for submitting the request to NRC for license terminations.

' 2 2. Appendix B, Suction 3.1.2. Are any of the hazardous materials discussed in this #

section activated or contaminated? Please discuss types and quantities of any mixed wastes that result from decommissioning.

23. - Appendix B, Section 4.1.2, page B 19: Please discuss further your bases for

estimating zero potential exposures to the public after license termination. What release criteria are assumed?' Should NRC consider this to be GA commitment?-

24. . Sectiom4.1.3, page 0 20: . Please discuss the basis for the number of truck trips for

~ her.ordous and radiologicht waste.- What total quantities of these materials are assumed to be involveJ? How many trips will be required to transfer all irradiated vTRIGA fuel off the site?:

11, 125.' cSection 4.2.3, page B-20: Please give the basis and best estimates of quantities of

- - ' uncontaminated co..struction debris to be trucked off the site, 4

?26.1 Section 4.8, page.B-22:: Please d!scuss human health effects on decommissioning y workers; ' Please give best estimate.(and explanation) of internal doses to the public.

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