ML20205P425

Discusses Continuing Review of Amend Request for Amended Facility License Numbers R-38 & R-67 Submitted 970418. Forwards Rai.Response Requested within 30 Days of Date of Ltr

ML20205P425
Person / Time
Site:	General Atomics
Issue date:	04/14/1999
From:	Alexander Adams NRC (Affiliation Not Assigned)
To:	Asmussen K AFFILIATION NOT ASSIGNED
References
TAC-M98498, TAC-M98499, NUDOCS 9904200177
Download: ML20205P425 (5)

Text

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April 14, 1999 Dr. Kcith E. Asmuss:n, Dir:ctor Licensing, Safety and Nuclear Compliance General Atomics P.O. Box 85608 San Diego, California 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 Reactors which you submitted on April 18,1997, as supplemented. During our review of your amandment request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additionalinformation within 30 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 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.

Sincerely, ORIGINAL SIGNED BY:

Alexander Adams, Jr., Senior Project Manager Events Assessment, Generic Communications and Non-Power Reactors Branch Division of Regulatory improvement Programs l Office of Nuclear Reactor Regulation i Docket Nos. 50-89 and l 50-163 i

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,e wassisoTon. o.c. 2oswoooi April 14, 1999 Dr. Keith E. Asmussen, Director Licensing, Safety and Nuclear Compliance General Atomics P.O. Box 85608 San Diego, California 921PC 9784

SUBJECT:

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

Dear Dr. Asmut,

sen:

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 Reactors which you submitted on April 18,1997, as supplemented. During our review of your amendment request, questions have arisen for which we require additiona!information and clarification. Please provide responses to the enclosed request for additionalinformation within 30 days of the date of this letter. In accordance with 10 CFR 50.30(b), your 4

resp >nse must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your amendment request.

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

Sincerely, h .

Alexander Adams, Jr., or Project Manager Events Assessment, Generic Communications and Non-Power Reactors Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-89 and 50-163

Enclosure:

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! General Electric Company l 6705 Vallecitos Road Suno!, CA 94586 l

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

1. By letter dated November 20,1998, you replied to question 6 of our request for additional information dated January 16,1998, concerning financial assurance for decommissioning. It is not clear if the accounts referred to in your reply are held in trust to be used only for decommissioning. Please address.

2. Because decommissioning of both reactors will be authorized by the license amendment approving the decommissioning plan, technical specifications (TSs) requirements for the two reactors during decommissioning should be similar,

a. Please propose changes to the recordkeeping and reporting requirements of the reactor licenses and technical specifications (TSs) that will result in similar requirements for both reactors. For example, there is no requirement for the submission of an annual report in the Mark F TSs.

b. On page 2-12 of your decommissioning plan, you state that the reactor room will be maintained at a negative pressure with respect to the surrounding area to ensure that air will travel from the non-contaminated area to the increasingly contaminated areas. Please propose a TS to capture this requirement during the performance of decommissioning activities or justify the need not to have j this as a TS. You may want to consider adding a definition to the TS to define decommissioning activities.

c. Please propose a TS that would require monitoring of airborne effluents from the facility during decommissioning activities or justify not needing this TS.

Consider the need to monitor particulate effluent from decommissioning activities and the potential for gaseous effluent from fuel elements.

d. Figure 2 7 of the decommissioning plan shows the decommissioning organization. Please add this figure to the TSs and insure that other organizational TSs follow this figure and the discussion in your decommissioning plan.

e. The TSs for the reactors refer to written procedures. However, there does not appear to be a TS requirement for written pro',edures about radiation protection and decommissioning activities. Please address.

f. The TSs for the Mark F reactor do not appear to have a section on " action to be taken in the event of a reportable event" or a definition of reportable events. Please address.

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3. Your decommissioning plan has identified acceptable releace criteria for the residual facility. Your plan also recognizes the regulatory requirements for disposal of radioactive material from the facility as required by 10 CFR Part 20. However, there remains some ambiguities concerning the application of these concepts in your decommissioning plan.

a. Table 2-6 presents information on acceptable surface contamination levels from Regulatory Guide (RG) 1.86 for release of the residual facility to unrestricted use. However, you have added footnotes f and g. Footnote g, in particular, gives the appearance that the limits in this table are also used for the release of material from the facility for unrestricted use. The use of the limits in this way are not discussed in RG 1.86. Please address.

b. Please review sections 2.8 and 3.1.3 of your decommissioning plan and make any necessary changes to eliminate ambiguities about using residual facility crite-ia to release known radioactive materials for disposal as clean waste. For example, the statement at the top of page 2-23 indicates that the residual i

facility criteria for release will be used to determine if items are low-level I

waste. The survey method discussed in Section 3.1.3 for bulk liquids or bulk materials uses a methodology, based on a dose rate limit, to set a

! corresponding gamma spectrometry system detection limit instead of discussing the minimum level of detection for the system.

c. Will the instruments in Table 3-1 be used to determine if material leaving the l facility contains licensed radioactive material? If so, please discuss the minimum detectable activity for those instruments. For example, Table 3-1 contains information on a Canberra low-level alpha / beta counting system used to count low level smear samples. However, this system is not referenced in Section 3.1.3 for smear samples. The instruments referred to in Section 3.1.3 do not appear on Table 3-1. Is the equipment referred to in Section 3.1.3 optimal for the samples to be analyzed? Please address.

4. Figure A-2 refers to release criteria. Please elaborate considering your discussion in section 2.8 of the decommissioning plan.

5. Please propose changes to license condition 2.C.1 for the TRIGA Mark F that removes reference to reactor operation.