ML20207M193

Forwards Request for Addl Info Re 880610 & 21 Phase II Decommissioning Plan.Response Requested within 60 Days of Ltr Date

ML20207M193
Person / Time
Site:	05000142
Issue date:	10/12/1988
From:	Alexander Adams Office of Nuclear Reactor Regulation
To:	Mclaughlin J CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
NUDOCS 8810180157
Download: ML20207M193 (6)

Text

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October 12, 1988 Docket No. 50-142 Mr. James E. McLaughlin Acting Director Research & Occupr,tional Safety University of C&lifornia at Los Angeles A6-060J Center for the Health Sciences 10833 Le Conte Avenue Los Angeles, California 90024-1765

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION We are continuing our review of the UCLA deconnissioning Phase II plan that was submitted on June 10, 1988, as supplemented on June 21, 1988. During our review of the information you had submitted, questions have arisen for which we require' additional information and clarification. Please provide responses to the enclosed Request for Additional Information within 60 days of the date of this letter. Following receipt of the additional information we will continue our evaluation of the plan. If you have any questions regarding this review, please contact me at (301) 492-1121.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefoie, OMB clearance is not required under P. L.95-511.

Sincerely,

/s/

Alexander Adams, Jr., Project fianager Standardization and Non-Power Reactor Project Directorate Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page DISTRIBUTION:

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%,,,,,# October 12, 1988 Docket No. 50 142 Mr. James E. McLaughlin Acting Director Research & Occupational Safety University of California at Los Angeles A6-060J Center for the Health Sciences 10833 Le Conte Avenue Los Angeles, California 90024-1765

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION We are continuing our review of the UCLA decommissioning Phase II plan that was submitted on June 10, 1988, as supplemented on June 21, 1988. During our review of the information you had submitted, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed Request for Additional Information within 60 days of the date of this letter. Following receipt of the additional information we will continue our evaluation of the plan. If you hr.ve any questions regarding this review, please contact me at (301) 492-1121.

The reporting and/or recordkeeping requirements contained in this lette-affect fewer than ten respondents; therefore, OMB clearance is not required under P. L.95-511.

Sincerely, Wh /.

Alexander Adams, Jr., Pr

• ct Manager Standardization and Non-Power Reactor Project Directorate Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Kegulation

Enclosure:

As stated cc: See next page

, s e University of California Docket No. 50-142 at Los Angeles cc: Mr. Neil C. Ostrander, Manager Connittee To Bridge The Gap Nuclear Engineering Laboratory 1637 Butler Avenue #203 School of Engineering and Los Angeles, California 90024 Applied Science University of California Mr. John Bay at Los Angeles 1022 Peralta Street Los Angeles, California 90024 Albany, California 94706 Mr. James R. Heelan Roger Kohn, Esq.

Director, Society Services 524 lith Street American Nuclear Society Manhattan Beach, California 60266 555 N. Kensington Avenue La Grange Park, Illinois 00525 .

Robert M. Meyers California Department of Health City Attorney ATTN: Chief. Environmental Lynn Na11 boff Radiation Control Unit Deputy City Attorney ,

Radiological Health Section 1685 Main Street, Room 310 114 P Street, Room 498 Santa Monica, California 30401 Sacramento, California 95814 Mr. Daniel Hirsch 3489 Branciforte Drive Santa Cruz, California 95065 William H. Cormier, Esq.

Office of Administrative Vice Chancellor University of California 405 Hilgard Avenue Los Angeles, California 90024 Christine Helwick, Esq.

Glen R. Woods Esq.

Office of General Counsel 690 University Hall 2200 University Avenue Berkeley, California 94720 Dean Hansell 302 fouth Mansfield Avenue Los Angeles, California 90036 1

Docket No. 50-142 Enclosure Request for Additional Information UCLA Decomissioning Phase II

1. The plan states "The facility is to be released for unrestricted use as defined by USNRC Regulatory Guide 1.86." Is the unrestricted use criteria for residual activation products of 5 micro-rem per hour above natural background at one meter from the surface to be applied to this decomissioning? If it is, the plan should describe how the licensee will determine that this standard has been fulfilled.

2. The plan states "Other support areas that were once a part of the facility were closed for general use prior to initiatien of decommissioning." If these "other support areas" were part of the originally licensed. facility restricted area, the licensee should conduct surveys to assure that residual contamination and radiation levels meet the criteria that will be established by the decomissioning order for release for unrestricted use. Results of such surveys should be included in the final licensee report. Also, these "other support areas" should be clearly identified.

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3. What is the date of the calculations shown in Table 1.17 How were these curie totals arrived at?

4. Figure 1.3 identifies background as less than 0.1 mR/h. UCLA should note that although this background expasure rate level may be acceptable for reactor operations, natural backgrond is typically much lower. If the exposure standard for residual activation products of 5 micro-rem per hour above natural background at one meter from the surface is to be applied to this decomissioning, more accurate determination of background must be made.

5. Describe how you plan to survey for contanination in the pipes, drainlines, and ductwork to assure conformance with Regulatory Guide 1.86 limits. How will swipes of inle.s and outlets assure that the balance of the pipe, drainline, or ductwork is wishin release Ifmits?

6. The plan states that certain swipes counted on a beta counter revealed that surface contamination levels were below the limits prescribed in Table 1 of USNRC Regulatory Guide 1.86. The plan does not, however, state which of the limits cecomended in Table 1 of USNRC Regulatory Guide 1.86 were selected to come to this conclusion. Sufficient details must be included in the final report for proper evaluation of your conclusions.

7. What is the date of the calculations shown in Table 1.27 What are the concentrations of the isotopes shown? How will the sump water and sediment be disposed? !> the isotope Cs-60 a typographical error of Co-60?

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8. Section 1.6 of the plan lists the applicable regulations, guidance, and '

standards for the decommissioning and part of Section 1 7 describes the training of radiation workers. In neither section is 10 CFR Part 19 men-tioned. Does UCLA intend to follow the regulations in 10 CFR Part 19? If  ;

the answer is yes, Regulatory Guide 8.13, Revision 2, "Instruction Con-cerning Prenatal Radiation Exposure," and Regulatory Guide 8.29, "Instruc- [

tion Concerning Risk from OccupationL1 Radiation Exposure" should be consi-dered when preparing the cor. tent of tne radiation health and safety training of personnel required ic t,e instructed by 10 CFR Part 19.12.

UCLA should consider providing addittoial training to workers on those aspects of the decommissi,nir.g trder fo" which compliance is dependent on proper action by the workers. These espects would include the limits set in Table 1 of Regulatory sufde 1.86, etc.

9. r Figure 1.4, tna e. Aip between the Director, NEL, and the Director, k: search & Occm 100- ' " ny is not clear. Does the Director, Research

& Occepational m Ly  :,o ' both to the Director, NEL, and the Assistant

' lice Chancellor?

10. Please provide resuNS 'b.19 the EdJeation, '. raining and experience for l all cositions that are impe. tant to sc'ety during Phase II decomissioning e (i.e., Director of Research and Occupat,onal Safety, Radiation Safety Officer, NEL support s uff)

11. Section 2.2 is titled "Indu:; trial Safety and Hygiene Program" and it dis-cusses the use of persconel protective equipment such as half-face dust respirators. It is not O'Nr f, an the discussion if this respiratory pro-

! tection program will oe used to protect workers from exposure to radio-active materials in air. Clarify f his point and describe your program in more detail if appropriate. Sca 10 CFR Part 20.103.

12. Section 3.1, TasO, e n not reference the remaining pipes, drafnlines, or duct work. Who wil be responsible for the removal of these components?

13. Room 201 will be used as a control point of entry to the reactor room during decommissioning. What area will be used for egress from contami-nated areas for removal of protective clothing, showering, etc.?

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14 You slan to use your 10 ton crane to move a 9.9 ton concrete block. What i is tie uncertainty associated with your calculation of the block weight?

What is the maximum load that the crane has moved to date? What was the date and results of the last crane inspection? Who conducted this inspec-tion? What tests did the manufacture perform and what certification was 4

given on crane capacity? What is the rating of the sling to be used to neve the blocks?

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15. We note that the structures identified in Section 1.3 do not include the radiological status of the pedestal, which in Section 3.3.2.4 is purported to be "the most radioactive object to be encountered in the demolition work." Describe the composition of the pedestal, the approximate neutron i fluence it was subjected to during its lifetime and the estimated activity of each activated component. Will it be cut up for packaging and cisposal?

Please describe the disposal procedure.

16. Although Section 7.0 is titled Technical and Environmental Specifications, it does not propose any specifications. As a minimum, the plan shculd state the proposed criteria for release of the facility to unrestricted use. The )lan should also specify the records that will be maintained to document t1at commitments made in the plan have been fulfilled. This section of the plan is inadequate.

17. Section 8.0 of the plan is inadequate. The plan should describe in

, greater detail the proposed surveys that will verify that the release criteria for unrestricted use has been ret. A statistically sound sampling and monitoring methodology acceptable to the NRC must be used.

A site survey plan must be submitted to the NRC prior to conducting final sampling and monitoring. This section or Section 7 should describe the report that will be submitted to the NRC when the work has been completed.

18. If, upon the termination radiation survey, "hot spots" are found that may require chipping of concrete for removal, what additional radiation protection precautions would be used to preclude spread of contamination and assurance of ALARA radiation exposures (airborne radioactivity pathway) to workers?

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