ML20206H568

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Responds to ,Which Discussed 981209 Meeting with Members of California Dept of Health Svcs at Ga Site.Meeting Was Held to Examine Each Agency Respective Roles in Decommissioning Oversight of Ga Facilities
ML20206H568
Person / Time
Issue date: 04/23/1999
From: Lohaus P
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Bailey E
CALIFORNIA, STATE OF
References
NUDOCS 9905110252
Download: ML20206H568 (9)
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Text

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  1. Mt j +4 UNITED STATES y j g

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30se6-0001 -

%y +/ April 23, 1999 Mr. Edgar D. Bailey, Chief ,

Radiologic Health Branch  !'

Division of Food, Drug & Radiation Safety California Department of Health Services P.O. Box 942732, MS-178 Sacramento, CA 94234-7320

Dear Mr. Bailey:

This is in response to your letter of January 13,1999, discussing the meeting of December 9,

.1998 between members of your staff and the NRC at the General Atomics (GA) site. The December meeting was held to examine each agency's respective roles in the decommissioning oversight of the GA facilities and to discuss possible means to reduce duplication of effort.

As was discussed during the meeting, we agree that to the extent possible, the NRC and State of California should share inspection results, including confirmatory surveys, and where

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appropriate should apply results to the respective State and NRC licensed facilities at GA for 4 f

decommissioning inspection purposes. This can prevent unnecessary duplication of effort.

Subsequent interactions between our inspection and licensing staff have shown this approach to be viable and efficacious.

In regard to the issues raised conceming lead regulatory responsibility, we agree with the following points:

e Areas where the major contamination is known to result from operations conducted under the NRC license, the NRC should have the lead for decommissioning. This would include the example noted in your letter where contamination resulted from the breach of an irradiated fuel element. The lead jurisdiction for this facility should remain with the NRC and the contamination remediated in accordance with the licensee's NRC approved decommissioning plan.

  • Areas where only State licensed activities were conducted, the State has sole jurisdiction.
  • Areas where contamination may be from either NRC or State of California licensed activities, the NRC and State'will jointly determine on a case-by-case basis which organization should assume the lead for decommissioning. The decision should be based primarily on a determination as to the predominant licensed activities which were undertaken at the facilities and the sources of radiological contaminants remaining at the cessation of operations. During the December 9,1998 meeting, there was general consensus as to which organization should be lead for the major facilities left to be g

decommissioned at GA. When we reach agreement as to the lead regulatory organization, it would be appropriate for the rion-lead organization to accept the findings )

and conclusions of the lead organization as to the suitability for release of the facilities.

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Edgar D. Bailey 2 I

The attachment to this letter indicates the major facilities remaining to be released at GA and the NRC's current understanding as to which agency should have lead responsibility for decommissioning oversight. We welcome your comments on the attached list.

e in instances where the State licensed the possession and use of small quantities of unsealed special nuclear material (SNM), the State will retain the responsibility for the SNM unless it is determined that the primary use of SNM in the area being decommissioned is from NRC licensed SNM activities.

  • Your letter discussed the possibility of NRC taking full jurisdiction for the TRIGA Reactor Facility (Building 21) to avoid duplication of decommissioning oversight. This would be difficult to accomplish under the reactor licenses. During its evaluation of the decommissioning plan for the GA Mark I and Mark F research reactors, the NRC staff was concerned about jurisdictional issues raised by the multiple (State and NRC) licenses applicable to the TRIGA Reactor Facility. In reply to questions from the NRC staff concoming license jurisdiction, GA clearly indicated the areas of the TRIGA Reactor Facility that are covered under the two NRC reactor licenses. NRC staff has reviewed the identified areas and agrees with the designations. A figure from the revised GA decommissioning plan for the research reactors is enclosed which shows the areas of the TRIGA Reactor Facility under the NRC reactor licenses (Enclosure 2).

Because these areas are clearly marked, the potential for duplication of effort in performing confirmatory surveys between the State of California license and the NRC reactor licenses will be minimized. To extend the NRC reactor licenses to the areas of the TRIGA Reactor Facility under the State of California license and NRC SNM license

-would require amendment of a reactor license. Those areas of Building 21 that are not shaded in Enclosure 2 will need to be jointly determined between the State and NRC based on the materials present.

The specific designations provided in Enclosures 1 and 2 should enhance the timely response to any requests from the licensee for action on specific portions of the decommissioning project. If you have specific questions on the materials areas, please contact Charles Gaskin, at 301-415-8116 or CEG10NRC. GOV. If you have specific questions on the reactor areas, please contact Alexander Adams at 301-415-1127 or AXA@NRC. GOV. If you agree to the responsible party designations in Enclosures 1 and 2 for the areas specified, please provide an acknowledgment to me, and I will notify the other NRC staff who will be working with you in the decommissioning of the GA facilities.

If you have any questions on this letter, pl ease contact me at 301-415-3340, PHLO NRC. GOV or Dennis Sollenberger at 301-415-2819, DMS4@NRC. GOV.

rely, W-Paul H. Lohaus, Director hW .

Office of State Programs

Enclosures:

As stated

Edgar D. Ball:y 2 APS 23 fggg l

Th3 att: chm nt to this littir indicatts tha mijor fIciliti:s rimiining to be ral:tsed at GA and the NRC's current understanding as to which agency should have lead responsibility I for decommissioning oversight. We welcome your comments on the attached list. i e in instances where the State licensed the possession and use of small quantities of l unsealed special nuclear material (SNM), the State will retain the responsibility for the 1 SNM unless it is determined that the primary use of SNM in the area being decommissioned is from NRC licensed SNM activities.

1 o Your letter discussed the possibility of NRC taking full jurisdiction for the TRIGA Reactor .

Facility (Building 21) to avoid duplication of decommissioning oversight. This would be l difficult to accomplish under the reactor licenses. During its evaluation of the l decommissioning plan for the GA Mark I and Mark F research reactors, the NRC staff was concerned about jurisdictionalissues raised by the multiple (State and NRC) licenses applicable to the TRIGA Reactor Facility. In reply to questions from the NRC staff concerning license jurisdiction, GA clearly indicated the areas of the TRIGA Reactor Facility that are covered under the two NRC reactor licenses. NRC staff has ,

reviewed the identified areas and agrees with the designations. A figure from the i revised GA decommissioning plan for the research reactors is enclosed which shows the areas of the TRIGA Reactor Facility under the NRC reactor licenses (Enclosure 2).

Because these areas are clearly marked, the potential for duplication of effort in performing confirmatory surveys between the State of Califomia license and the NRC reactor licenses will be minimized. To extend the NRC reactor licenses to the areas of the TRIGA Reactor Facility under the State of Califomia license and NRC SNM license j would require amendment of a reactor license. Those areas of Building 21 that are not  ;

shaded in Enclosure 2 will need to be jointly determined between the State and NRC 1 based on the materials present.

The specific designations provided in Enclosures 1 and 2 should enhance the timely response to any requests from the licensee for action on specific portions of the decommissioning project. If you have specific questions on the materials areas, please contact Charles Gaskin, at 301-415-8116 or CEG10NRC. GOV. If you have specific questions on the reactor areas, please contact Alexander Adams at 301-415-1127 or AXAONRC. GOV. If you agree to the responsible party designations in Enclosures 1 and 2 for the areas specified, please provide an acknowledgment to me, and I will notify the other NRC staff who will be working with you in the decommissioning of the GA facilities, if you have any questions on this letter, please contact me at 301-415-3340, PHLO NRC. GOV or Dennis Sollenberger at 301-415-2819, DMS4@ NRC. GOV.

Sincerely, OrigirmisignedBr.

PAULH.tJOHAUS Paul H. Lohaus, Director Office of State Programs

Enclosures:

As stated Distnbution:

DIR RF (9-11) _ DCD (SPOS)

SDroggitis ' PDR (YES.f_ NO )

FILE NAME DOCUMENT NAME: G:\ CABAILE1.0SP *See previous concurrence.

n, ....n ,u w e.co -ooi. - e u r.co - . ,,,,,,y o, v.no. ,n; OFFICE OSPrW%l NMSS l NRR l OGC l O$ACQ l NAME DSollenberfe'rik1c ETenEyck JLyons STreby PLohdu F '

DATE 04/T/99 04/21/99

  • 04/14/99 * . 04/15/99

Edgar D. Bailiy 2 Th3 Etttchm:nt to this I tttr indicates tha mIjor facilitir rsmiining to b3 r:larstd at GA and the NRC's current understanding as to which age should have lead responsibility for decommissioning oversight. We welcome your co ents on the attached list.

e in instances where the State licensed the possession nd use of small quantities of unsealed special nuclear material (SNM), the State I retain the responsibility for the SNM unless it is determined that the primary use of NM in the area being decommissioned is from NRC licensed SNM activitie .

e Your letter discussed the possibility of NRC taking f 11 jurisdiction for the TRIGA Reactor  ;

i Facility (Building 21) to avoid duplication of decom issioning oversight. This would be difficult to accomplish under the reactor licenses, uring its evaluation of the decommissioning plan for the GA Mark I and Mark F research reactors, the NRC staff was concerned about jurisdictionalissues raised b the multiple (State and NRC) licenses applicable to the TRIGA Reactor Facility. In reply to questions from the NRC staff conceming license jurisdiction, GA clearly I icated the areas of the TRIGA Reactor Facility that are covered under the two C reactorlicenses. NRC staff has reviewed the identified areas and agrees with th designations. A figure from the revised GA decommissioning plan for the resea h reactors is enclosed which shows the areas of the TRIGA Reactor Facility under t e NRC reactor licenses (Enclosure 2).

Because these areas are clearly marked, the tential for duplication of effort in performing confirmatory surveys between the te of Califomia license and the NRC reactor licenses will be minimized. To extend e NRC reactor licenses to the areas of the TRIGA Reactor Facility under the State of alifornia license and NRC SNM license would require amendment of a reactor licens Those areas of Building 21 that are not shaded in Enclosure 2 will need to be jointly termined between the State and NRC based on the materials present.

The specific designations provided in Enclosures 1 nd 2 should enhance the timely response to any requests from the licensee for action on spe ific portions of the decommissioning project. If you have specific questions on the mate ials areas, please contact Charles Gaskin, at 301-415-8116 or CEG10NRC. GOV. If you ha specific questions on the reactor areas, please contact Alexander Adams at 301-415-1127 or AXAONRC. GOV. If you agree to the responsible party designations in Enclosures 1 a 2 for the areas specified, please provide an acknowledgment to me, and I will notify the other RC staff who will be working with you in the decommissioning of the GA facilities.

If you have any questions on this letter, please ntact me at 301-415-3340, PHL @NRC. GOV  ;

or Dennis Sollenberger at 301-415-2819, DMS NRC. GOV. I Sincerely, Paul H. Lohaus, Director Office of State Programs

Enclosures:

As stated Distribution:

DlR RF (9-11) DCD (SP08)

SDroggitis PDR (YES_f_ NO )

FILE NAME DOCUMENTNAME: GA Twooelve a cop r of this document,inecato in the boa: "C' = Copy without a ment / enclosure T = Copy with attachmenvenclosure "N' = No copy OFFICE - OSPm%l q MIS!L l/ NRR l OGC l OSP:D l NAME DSollenberfeF.klc ESREycf ~ / SWeis STreby PLohaus DATE 04/T/99 04G/99 / 04/ /99 04/ /99 04/ /99  ;

y/g wr / OSP FILE CODE: SP-A-4

$dgtr D. Ball:y 2 ,

The Ettrchment to this istter indicates ths mijor faciliti:s, amiining to b3 rsl:astd at GA and the NRC's current understanding as to which agene should have lead responsibility for decommissioning oversight. We welcome your com ents on the attached list.

  • In instances where the State licensed the possession and use of small quantities of unsealed special nuclear material (SNM), the State wilf retain the responsibility for the SNM unless it is determined that the primary use of SNM in the area being decommissioned is from NRC licensed SNM activities.

e Your letter discussed the possibility of NRC taking f 1 Jurisdiction for the TRIGA Reactor Facility (Building 21) to avoid duplication of decom ssioning oversight. This would be difficult to accomplish under the reactor licenses. ,uring its evaluation of the decommissioning plan for the GA Mark I and Mark F research reactors, the NRC staff was concerned about jurisdictionalissues raised b the multiple (State and NRC) licenses applicable to the TRIGA Reactor Facility. In reply to questions from the NRC staff concoming license jurisdiction, GA clearly indicated the areas of the TRIGA Reactor Facility that are covered under the two GRC reactor licenses. NRC staff has reviewed the identified areas and agrees with the designations. A figure from the i revised GA decommissioning plan for the resealch reactors is enclosed which shows the areas of the TRIGA Reactor Facility under e NRC reactor licenses (Enclosure 2).  !

Because these areas are clearly marked, the potential for duplication of effort in performing confirmatory surveys between the ptate of California license and the NRC reactor licenses will be minimized. To extend'the NRC reactor licenses to the areas of the TRIGA Reactor Facility under the State o California license and NRC SNM license would require amendment of a reactor license. Those areas of Building 21 that are not shaded in Enclosure 2 will need to be jointly d/ etermined between the State and NRC based on the materials present.

The specific designations provided in Enclosures and 2 should enhance the timely response to any requests from the licensee for action on cific portions of the decommissioning project. If you have specific qcestions on the m erlais areas, please contact Charles Gaskin, at 301-415-8116 or CEG10NRC. GOV. If you h ve specific questions on the reactor areas, please contact Alexander Adams at 301-415-11 7 or AXAONRC. GOV. If you agree to the responsible party designations in Enclosures 1 nd 2 for the areas specified, please provide an acknowledgment to me, and I will notify the ot r NRC staff who will be working with you in the decommissioning of the GA facilities.

If you have any questions on this letter, plea contact me at 301-415-3340, PHLONRC. GOV or Dennis Sollenberger at 301-415-2819, D S4@NRC. GOV.

Sincerely, Paul H. Lohaus, Director Office of State Programs

Enclosures:

As stated Distribution:

DIR RF (9-11) DCD (SP08)

SDroggitis PDR (YES.f_ NO ) .

FILE NAME  ; Wf / ', . -

DOCUMENT NAME: G:\ g CI I

  • N' = No copy To receive e sept of thee document. indloots in the boa: "C" = Copy attachment / enclosure T = Copy with me enclos OFFICE OSPrg %l NMSS / l NRR l OGC.,M OSP:D l NAME- DSollenberfeF:kk ETenEyck / S W eis STreby TI 1. PLohaus DATE 04/4/99 04/ /99 04/ /99 04//i/99 04/ /99 OSP FILE CODE: SP-A-4

Edgar D. Bailly 2 Tha ettichmtnt to this latter indicat:s tha mIjor facilitirs rs ining to b3 ralsistd at GA and the NRC's current understanding as to which agency sh uld have lead responsibility for decommissioning oversight. We welcome your commen on the attached list.

e in instances where the S'nte licensed the possession and se of small quantities of unsealed special nucicar r iatorial (SNM), the State will re in the responsibility for the SNM unless it is detern.ined that the primary use of SNM n the area being decommissioned is from NRC licensed SNM activities.

  • Your letter discussed the possibility of NRC taking full j diction for the TRIGA Reactor Facility (Building 21) to avoid duplication of decommiss ning oversight. This would be difficult to accomplish under the reactor licenses. Duri g its evaluation of the decommissioning plan for the GA Mark I and Mark F r search reactors, the NRC staff was concemed about juilsdictional issues raised by t multiple (State and NRC)

!icenses applicable to the TRIGA Reactor Facility. In oply to questions from the NRC staff concoming license jurisdiction, GA clearly indi ted the areas of the TRIGA Reactor Facility that are covered under the two NR reactorlicenses. NRC staff has reviewed the identified areas and agrees with the signations. A figure from the revised GA decommissioning plan for the research reactors is enclosed which shows the areas of the TRIGA Reactor Facility under the RC reactor licenses (Enclosure 2).

Because these areas are clearly marked, the pot tial for duplication of effort in performing confirmatory surveys between the St e of California license and the NRC reactor licenses will be minimized. To extend th NRC reactor licenses to the areas of the TRIGA Reactor Facility under the State of C lifomia license and NRC SNM license would require amendment of a reactor license, hose areas of Building 21 that are not shaded in Enclosure 2 will need to be jointly de ermined between the State and NRC based on the materials present.

The specific designations provided in Enclosur6s 1 and 2 should enhance the timely response to any requests from the licensee for action on spe ic portions of the decommissioning project. If you have specific questions on the mate is areas, please contact Charles Gaskin, at 301-415-8116 or CEG1 @NRC. GOV. If you hav specific questions on the reactor areas, ploase contact Alexander Adams at 301-415-1127'or AXAO NRC. GOV. If you agree to the responsible party designations in Enclosures 1 an 2 for the areas specified, please provide an acknowledgment to me, and I will notify the other RC staff who will be working with you in the decommissioning of the GA facilities.

If you have any questions on this letter, please ntact me at 301-415-3340, PHLO NRC. GOV or Dennis Sollenberger at 301-415-2819, DMS ONRC.GQM.

Sincerely, Paul H. Lohaus, Director Office of State Programs

Enclosures:

As stated Distribution:

DlR RF (9-11) DCD (SP08)

SDreagitis PDR(YESJ_ NO )

FILE NAME DOCUMENT NAME: G:\

Ta receive e seer of this document, indeste in the bos: "C' = Copy attachment / enclosure "E'= C(cy with attachment / enclosure "N's No copy

OFFICE OSPmMl NMSS /f $85W OGC l OSP:D l NAME DSollenbergef:l& ETenEyck / SWe,44rb h/S STreby PLohaus L DATE 04/4/99 04/ /99 04f(/99 04/ /99 04/ /99 OSP FILE CODE: SP-A-4

Major Facilities to be Released at General Atomics Lead Agency List for Confirmatory Surveys Building Radioactive Material Use Lead Agency Sorrento Electronics, instrument manufacturer Byproduct State Building 9, Room 049; TRIGA fuel fabrication, SNM NRC experimental building Building 10; HP Lab, Calibration Lab Byproduct, sealed sources State Building 21; TRIGA Reactor Facility Licensed Reactor Facility NRC, Encl. 2 NRC and State licensed material State and NRC, TBD Building 22; TRIGA Fuel Fabrication Mostly SNM, some DU NRC Building 23; Hot Cell NRC and State licensed materia! NRC Building 25: Liquid Waste Treatment NRC and State licensed meterial State Building 41; Nuclear Waste Processing NRC and State licensed material State Building 27; radiochemistry labs NRC and State licensed material State Building 27-1; radiochemis'.ry R&D NRC and State licensed material State Building 30, Room 118; fuel storage NRC and State licensed material NRC Building 30; except for Room 118, Linac Activation Products State Building Building 31, Room 103; radioactive material NRC and State licensed material NRC storage Building 33; radiation machines and sealed Tritium State tritium source Building 33-1; HP Lab NRC and State licensed material State Building 34; fusion research Activation Products; Tritium State Building 35; testing and maintenance Mixed fission products; Activation State products Building 37; low level waste storage, sealed NRC and State licensed material NRC sources Building 39; pilot plant, fuel development SNM, Depleted U, Thorium NRC Building 42; calibration & radiography Cs-137 sealed sources State Building 2; R&D, testing, & exper. labs, service NRC and State licensed material State and core and drain lines, Lab 307 underground NRC;TBD storage tank Underground storage tanks for Buildings 9,31, Various NRC 21, & 2 Lab S40 Tank ENCLOSURE 1

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  • gTAy CALFORNtA-NEALTH AND HUMAN SERVICES AGENCY GRAY DAVI$, Governor DEPARTMENT OF HEALTH SERVICES gA j RADIOLOGIC HEALTH BRANCH i P.O. BOX 942732. MS-178
   '    SACRAMENTO, CA 94234-7320                                                                                                       l (916) 445-0931                                        January 13,1999                                        pHL               !

6C2) Mr. Paul H. Lohaus Office of State Programs U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

GENERAL ATOMICS DECOMMISSIO'NING

Dear Mr. Lohaus:

On December 9,1998, California Radiologic Health Branch (RHB) staff met with U.S. Nuclear Regulatory Commission (NRC) staff to discuss issues related to the decommissioning of i General Atomics in San Diego, CA. General Atomics is licensed by RHB to possess and use a l variety of radioactive materials at their facility. General Atomics is also licensed by the NRC. l NRC license number SNM-696 authorized nuclear research, fuel development and fuel fabrication activities. NRC licenses number R-38 and R-67 authorized the operation of General Atomics' two TRIGA reactors. Many of the buildings and land areas possessed by General Atomics had the potential to be contaminated by either RHB or NRC licensed material, or both. Until now, both agencies i have worked separately, conducting independent confirmatory surveys as deemed necessary by each agency. This often results in a duplication of efforts. RHB proposes that for certain l buildings at General Atomics, the agency which licensed the primary activities in that building l take the lead responsibility for releasing the building for unrestricted use, thereby conserving resources for both agencies, and minimizing the coordination efforts required of the licensee. During the December 9,1998 meeting between RHB and NRC staff, a question arose as to whether or not the NRC would take responsibility for Byproduct Material in areas where the , activities conducted were conducted primarily under authorization granted by the NRC. In particular, RHB would like confirmation from the NRC that Byproduct Material resulting from the breach of a spent fuel element remains under NRC jurisdiction, to be treated as high level j waste, and does not become Agreement State material. The altemative, of course, would imply that an Agreement State with commercial power reactors would have responsibility, for example, for leaking fuel elements at those reactors. Inasmuch as it may be impossible in some areas of General Atomics (e.g., Building 23, known as the Hot Cell) to as::ertain whether the Byproduct Material was transferred to General Atomics under the license granted by California, or it was produced as a result of activities authorized by the NRC (e.g., research involving irradiated HTGR fuel), RHB proposes that in those buildings for which the NRC had primary jurisdiction over the activities, the NRC also , retain full responsibility for the decommissioning activities. For example, General Atomics le recently requested that the office and restroom areas of Building 21 be released for unrestricte) So v> g -'O 3G PDR CVES (08)) cy 

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  ,'         January 13,1999                                                                                          ,

Page 2 of 2 ) I use. Building 21 houses the two TRIGA reactors licensed (now for possession only) by the NRC. According to General Atomics there is no history of radioactive material in this area. 

            - Since this area is contained within the building housing the TRIGA reactors, RHB proposes that the NRC take fulljurisdiction over this area of Building 21 as well. This would include the responsibility for ensuring that Byproduct Material and Source Material, as well as Special Nuclear Material is removed, and residual contamination from Byproduct, Source and Special Nuclear Material is removed to below those limits established in General Atomics' Decontamination and Decommissioning Plan, approved by both RHB and the NRC.

In certain areas at General Atomics, the situation is reversed. In those areas, California had primary jurisdiction over the activities conducted, and will retain responsibility for the decommissioning in those areas. To a limited extent California also licensed General Atomics to possess and use unsealed Special Nuclear Material, so our confirmatory surveys in those areas would include sampling and analysis techniques aimed at identifying residual Special Nuclear Material as well as Byproduct Material. My staff and I feel that an agreement between the NRC and RHB to avoid duplicative decommissioning oversight as noted herein for certain areas at General Atomics, in addition to sharing each agencies' confirmatory survey results and recommendations for the remaining areas at General Atomics would result in a more efficacious use of both our agencies' resources. Finally, we look forward to confirmation from the NRC that Byproduct Material resulting from nuclear fuel research, development and fabrication activities remains under the jurisdiction of the NRC. Please contact me with questions or comments regarding these issues and how we might expeditiously implement RHB's proposal. Sincerely, l 1 EdgarBailey, Chief & 

                                                            - Radiologic Health Branch California Department of Health Services 1

l 

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