ML20206F414

Responds to Recent RAI Re Submittal of Decommissioning Plan & Request for Termination of Triga Mark & Mark F non-power Reactor Licenses R-38 & R-67.Decommissioning Plan,Encl

ML20206F414
Person / Time
Site:	General Atomics
Issue date:	05/03/1999
From:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Alexander Adams NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206F419	List: ML20206F414 ML20206F424
References
38-67-3080, TAC-M98498, TAC-M98499, NUDOCS 9905060118
Download: ML20206F414 (5)

Text

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HNMAL ATORNCE May 3,1999 38/67-3080 Via Express Delivery Service Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Mr. Alexander Adams, Jr.

Subject:

Docket Nos. 50-89 and 50-163; License Nos. R-38 and R-67 Respectively:

Submittal of Response to Item Nos. 3,4, and 5 of Request for Additional {<

Information Dated April 14,1999 (TAC Nos. M98498 and M98499)

References:

1) Adams, Alexander, Jr., Ixtter to Dr. Keith E. Asmussen, REQUEST FOR ADDITIONAL INFORMATION (TAC Nos. M98498 and M98499), dated April 14,1999 i i

2) Asmussen, Keith E., Letter No. 38/67-3073 to U.S. Nuclear Regulatory Com-mission ATTN: Mr Alexander Adams, Jr.," Docket Nos. 50-89 and 50-163; License Nos. R-38 and R-67 Respectively: Submittal of Response to Item No.

I of Request for AdditionalInformation Dated April 14,1999 (TAC Nos.

M98498 and M98499)," dated April 22,1999

Dear Mr. Adams:

This letter is in response to your recent request for additional information (Ref.1) regarding General Atomics' (GA's) submittal of a decommissioning plan and request for termi-nation of its TRIGA* Mark I and Mark F non-power reactor licenses R-38 and R-67. There were five (5) items in your request for additional information. While GA is preparing responses to each of the five items, the purpose of this letter is to address only Items 3,4, and 5. GA's response to Item No. I was submitted previously (Ref. 2) and its response to Item 2 will be submitted under separate cover in the near future.

Item 3 of your request consists of 3 parts designated as a, b, and c. These are each ,

addressed separately below, as are items 4 and 5. In each case the item is restated, then followed by GA's response. f Please note that the following responses to Items 3 and 4 involve revisions to GA's TRIGA* Reactor Facility Decommissioning Plan. A correspondingly revised version of the decommissioning plan, dated April 1999, with the changes incorporated, is enclosed with this letter. ]1

[O Item 3.a.

Item 3.a. States: " Table 2-6 presents information on acceptable surface contamination levelsfrom Regulatory Guide (RG) 1.86for release of the residualfacility to unrestricted 9905060110 990503' 9 I PDR ADOCK 05000089 '

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3550 GENERAL ATOMICS COURT, SAN DIEGO, CA 92121-1194 P O. BOX 85608. SAN DIEGO. CA 92186 9784 (619)455-3000 4

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use. However, you have addedfootnotesfand g. Footnote g, in particular, gives the appearance that the limits in this table are also usedfor the release ofmaterialfrom the facilityfor unrestricted use. The use of the limits in this way are not discussed in RG 1.86. Please address."

GA's Resnonse to Item 3.a.: Footnotes f and g are not appropd.de in the context of the subject decommissioning plan. Therefore, they have been deleted.

Item 3.b.:

Item 3.b. Ststcs: "Please review sections 2.8 and 3.1.3 ofyour decommissioning plan and make any necessary changes to eliminate ambiguities about using residualfacility criteria to release known radioactive materialsfor disposal as clean waste. For example, the statement at the top ofpage 2-23 indicates that the residualfacility criteria for release will be used to determine afitems are low-level waste. The survey method discussed in Section 3.1.3for bulk liquids or bulk materials uses a methodology, based on a dose rate limit, to set a corresponding gamma spectrometry system detection limit instead ofdiscussing the minimum level ofdetectionfor the system."

GA's Resnonse to Itemh: First, GA reviewed sections 2.8 and 3.1.3 of the decommissioning plan and made revisions to eliminate such ambiguities. In particular, the sentence at the top of page 2-23 and the last sentence of section 3.13 in the January 1999 version of the plan were deleted.

Second, the discussian in Section 3.1.3 of the survey method for bulk liquids or bulk materials was re-written to address bulk materials only. Liquids (e.g. reactor tank water) will be transferred to other appropriate licenses and/or managed pursuant to 10 CFR 20.

The revised Section 3.1.3 specifies the gamma spectrometry system's detection capability in terms of its lower limit of detection (LLD), above system background. The LLD, for bulk materials, is given in terms of picoCuries per kilogram, dry (i.e., pCi/kg). The predominant contaminate in the TRDS is "7Cs, therefore, the lower limits of detection for the system are established by specifying the LLD for "7Cs as the calibration standard.

The LLD for "7Cs is specified in Section 3.1.3 as being equal to or less than the environmental LLD contained in Table 4.12-1 " DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS / LOWER LIMIT OF DETECTION" found in NUREG-0472 and NUREG-0473. The environmental LLD for "7Cs is 180 pCi/kg, dry (0.18 pCi/g).

Third, the minimum level of detection given in Section 3.1.3 for " Smear Samples" in the January 1999 version of the plan was stated in error to be 5,000 dpm/100 cm2 . This error

. was corrected by changing the 5,000 dpm/100 cm2 to 1,000 dpm/100 cm2 ,

Finally, a one-sentence paragraph was added at the end of Section 3.1.3 which addresses the option of transferring radioactive material (s) to other licenses that authorize their possession.

38/67 3080 / Page 2 of 4 i

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Item 3.c.:

Item 3 c: Stntes: "Will the instruments in Table 3-1 be used to determine if material leaving thefacility contains licensed radioactive material? Ifso, please discuss the minimum detectable activityfor those instruments. For example, Table 3-1 contains information on a Car.berra low-level alpha / beta counting system used to count low level smear samples. However, this system is not referenced in Section 3.1.3for 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 optimalfor the samples to be analyzed? Please address."

GA's Response to Item 3.c.: It was not intended that Table 3-1 would constitute a list of the instruments that will be used to determine if material leaving the facility contains licensed radioactive material. That information is provided entirely within Section 3.1.3

" Radioactive Material Controls," which discusses GA's program for radioactive material control. Section 3.1.3 lists the instruments to be used for determining if material leaving the facility cautains licensed radioactive material along with their corresponding minimum levels of detection or lower limit of detection. However, as indicated in Section 3.1.3, other instruments, including some listed in Table 3-1, could be used for such purpose if they have a minimum level of detection or a lower limit of detection equal to or less than the corresponding values specified in Section 3.1.3.

Additional information regarding detection capabilities was added to Table 3-1. In particular, such information was added for the Eberline RO- 2,2A and 20, the Canberra low-level alpha / beta counting system, the Ludlum Model 19 microR, the REGE Canberra S-100 or equivalent gamma spec system, and the Eberline personnel contamination ,

monitor PCM-2. l i

The erroneously listed minimum level of detection for the instruments to be used for 2

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analyzing smear samples, i.e., less than or equal to 5,000 dpm/100 cm , clearly would not have been optimal for the samples to be analyzed. However, the corrected value of 1,000 dpm/100 cm 2s a reasonable standard for this application. The instmments and their corresponding detection capabilities listed in the revised Section 3.1.3 are appropriate for their stated purpose and correspond to industry practice / standard.

Item 41 Item 4. States: " Figure A-2 refers to release criteria. Please elaborate considering your discussion in section 2.8 of the decommissioning plan."

GA Resoonse to Item 4: Figure A-2 is a map that simply gives a graphic presentation of the relative values of the detailed data given in Tables A-2 and A-3. The data in Tables ,

I A-2 and A-3 are the results of analyses of samples collected as part of an initial radiological scoping study conducted to characterize soil and asphalt on and nearby the TRDS. The intent of the data was to provide information useful in assessing the scope of soil and asphalt contamination.' Such information is important to the planning for  !

decommissioning. Figure A-2 has been revised by deleting all reference to " release ]

38167 30801Page 3 of 4

l criteria" and referencing instead to " natural background" values.

Further, the second scritence in the second paragraph on page A-5 was deleted in its entirety. This sentence had made reference to " established release criteria."

Item 5.

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

GA Response to Item 5: Upon further discussion, GA's Director of Licensing, Safety and Nuclear Compliance and the NRC Project Manager mutually agree that this question was msolved by License Amendment No. 43 to the Mark F facility license.

If you should have any questions regarding this submittal, please do not hesitate to contact me at (619)'455-2823.

Very truly yours, Y h.

Keith E. Asmussen, Directot Licensing, Safety and Nuclear Compliance

Enclosure:

General Atomics' TRIGA* Reactor Facility Decommissioning Plan, dated April 1999 (3 copies)

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. cc: Mr. Ellis W. Merschoff, Director, NRC, Region IV (1 copy)  !

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