ML20210Q920

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Safety Evaluation Supporting Amends 36 & 45 to Licenses R-38 & R-67,respectively
ML20210Q920
Person / Time
Site: General Atomics
Issue date: 08/12/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20210Q861 List:
References
NUDOCS 9908160156
Download: ML20210Q920 (36)
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Text

{{#Wiki_filter:I= Ma uq\\ UNITED STATES 3" [ { ,j NUCLEAR REGULATORY COMMISSION f WASHINGTON, D.C. 2066M001 o%...../ l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 36 TO AMENDED FACILITY LICENSE NO, R-38 AND AMENDMENT NO. 45 TO FACILITY LICENSE NO. R-67 GENERAL ATOMICS DOCKET NOS. 50-89 AND 50-163 l l

1.0 INTRODUCTION

By letter dated April 18,1997, as supplemented by letters dated November 20,1998, and January 28 and 29, February 3, April 22, May 3 and 12, and June 15,16, and 22, 1999, General Atomics (GA or the licensee) submitted the GA TRIGA Reactor Facility Decommissioning Plan (DP). The licensee also applied for termination of Amended Facility License No. R-38 for the GA TRIGA Mark l Research Reactor and Facility License No. R-67 for the GA TRIGA Mark F Research Reactor (Docket Nos. 50-89 and 50-163, respectively) pursuant to 10 CFR 50.82(b)(1). 2.0 EVALUATION 2.1 Introduction The staff has reviewed and evaluated the licensee's DP and application for amendment to Facility Licenses No. R 38 and No. R-67 to authorize dismantlement and disposal of the components and materials from the licensee's two TRIGA non-power reactors. The l licensee also applied for termination of the two NRC licenses, and requested unrestricted use of the site. The licensee's DP is a supplement to the Safety Analysis Report in accordance with 10 CFR 50.82(b)(5). The licensee may make changes to the DP in accordance with the regulations in 10 CFR 50.59(a) through (c) as allowed by 10 CFR 50.59(e). 9908160156 990812 PDR ADOCK 05000089 l P PDR L

. The OP included the information required by 10 CFR 50.82(b)(4), namely, (i) the choice of the alternative for decommissioning with a description of activities involved, (ii) a description of the controls and limits on procedures and equipment to protect occupational and public health and safety, (iii) a description of the planned final radiation survey, (iv) an updated cost estimate, comparison of that estimate with present funds set aside for decommissioning, and plans for assuring the availability of adequate funds for completion of decommissioning, and (v) a description of technical specifications (TSs), quality assurance provisions and physical security plan provisions in place during decommissioning. The licensee also submitted an updated environmental report as required by 10 CFR 51.53(d). The licensee plans to remove and decontaminate the radioactive materials so that the residual radiological condition of the site meets the established criteria for release foi unrestricted use. Because the terms of a settlement agreement of a lawsuit concerning spent nuclear fuel and nuclear waste at the Idaho National Engineering and Environmental Laboratory (INEEL) severely constrain domestic spent nuclear fuel receipts at the INEEL, reactor fuel will remain on site during some decommissioning activities. Until the fuel has been appropriately removed, applicable license restrictions must remain in effect, and some decommissioning activities must be delayed. Termination of the two non-power reactor facility licenses requires NRC to determine in accordance with 10 CFR 50.82(b)(6) that (i) the decommissioning has been performed in accordance with the approved decommissioning plan and (ii) the terminal radiation survey and associated documentation demonstrate that the facility and site are suitable for release in accordance with the criteria for decommissioning in 10 CFR Part 20, Subpart E. The decommissioning of these reactors is part of GA's plans to conduct comprehensive decommissioning of the GA site. The licensee has already decommissioned a number of other facilities under NRC special nuclear material and State of California licenses. Because of this, the licensee has developed procedures and techniques for carrying out decommissioning activities and has extensive experience in applying their procedures and techniques. The licensee's performance during conduct of these other decommissioning activities has been acceptable. A " Notice of Application for Decommissioning Amendment" was published in the FEDERAL REGISTER on December 11,1997 (62 FR 65288), in accordance with the requirements of 10 CFR 50.82(b)(5). 2.2 Site and Facility Descriotion The two non-power reactors are located in the TRIGA Reactor Facility (TRF). The TRF occupies building No. 21 and an adjacent outdoor service yard on the grounds of the main site of General Atomics Corporation, located in San Diego County, about 21 km (13 miles) north of downtown San Diego, California (Figures 1, 2,3).

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_3-The TRF (Figures 4 and 5) was built in stages over the years, starting with the TRIGA Mark I reactor complex (License No. R-38) in 1958 (Figure 6). Subsequently, two other i TRIGA reactors were added, called the TRIGA Mark F reactor.(License No. R-67) (Figure 7) and the TRIGA Mark til reactor (License No. R-100). The TRIGA Mark Ill reactor was decommissioned and its NRC license terminated in 1975. Some of the reactor structure and reactor pool remains with the residual radioactive material possessed under an authorization from the State of California. Because the NRC license for the TRIGA Mark lli . reactor'has already been terminated, only the TRIGA Mark I and TRIGA Mark F reactors are subjects of this decommissioning review and evaluation. Op' erations have been terminated at the TRIGA Mark I and TRIGA Mark F reactors. The -TRIGA Mark I reactor license was amended on October 29,1997, and the TRIGA Mark F . reactor license was amended on March 22,1995, to remove authority to operate the reactors. The licenses allow possession-only of the remaining radioactive material. All irradiated fuel is stored in the TRIGA Mark F reactor storage canal under the TRIGA Mark F } reactor license. Some of the nonradioactive components (such as the control console) of the TRIGA Mark I reactor have been removed and shipped offsite to be reused in other TRIGA reactors. 2.3 Current Radioloaical Status of the Facility J The licensee has reviewed the operating histories of the TRF, and found no reports of spills or other events that could significantly contaminate surfaces such as floors and walls. After an extensive characterization survey / program, discussed in the DP, the licensee verified the absence of contaminated areas or components outside of the reactor pools and coolant loops, which are interconnected. The TRIGA Mark I reactor (250 kW) operated for a total lifetime of about 84 MW-days and the TRIGA Mark F (1.5 MW) operated for a total lifetime of about 4,200 MW-days. On the basis of the above information, and experience at previously decommissioned TRIGA reactors of nearly identicdl designs, the licensee has estimated the types and quantities of radionuclides expected to be encountered during decommissioning..This information is given in Tables 1 and 2. The licensee has extensive experience working with radioactive components and materials, and even though the current inventories of radionuclides are not recorded in detail, they plan to investigate and prepare adequately before removing and dismantling components. The TRIGA Mark I and TRIGA Mark F reactors contain different types of components in the region of the highest neutron fluences near the cores. The licensee is aware of these differences and is prepared to address them.

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1 l l Table 1: List of Expected Radionuclides Nuchee hen O o Decoy Notes (yr) assee

    • C 5730.

S' AP, from n-acevabon of graphite reflector structure (TRIGA Mkl only)

    • Mn 0 86 e,y AP; short-Hved specie; from n-acevabon of SS hardware "Fo 2.73 s

AP; from rwacevabon of SS hardware "Co 5.27 p', y AP; from n-acevabon of SS hartfware; expected to be predominant AP specie present

    • Ni 76000.

e, y AP, from n-acevation of SS hardware "Ni 100. p' AP; from n-actvabon of SS hardware "Sr 29.1 ~ FP; probable FP constituent; actvity expected to be proportional to that of '"Cs

    • Nb 20000.

p', y AP, unkkely AP inventory constituent; possible from n-activaton of SS hardware,if Nb impuntes are present

  • Tc 213000.

S', y FP, and minor AP inventory constituent; possible from n-activation of SS hardware,! Mo impuntos are present

  • Sb 2.76

$~, y FP; relatively short-hved specie C s 2.07 S', y FP; minor FP inventory constrtuent '#Cs 30.17 D', y FP; expected to be predominant FP specie present C e 0.78 p', y FP; short hved specie

  • Eu 13 48

$~, p*, e, y FP, and minor AP inventory constituent, possible from n-actvation of concrete,! Eu impuntes exist in biological shield structure Symbols / Abbreviations - = Beta p* Positron = Electron Capture e = Gamma Ray y a AP = Activaton Product FP = Fission Product Radionuchde Half-Life values and Decay Mode informaton used above are taken from Ref.10.15. The hst of expected radionuchdes provided above is based on the assumptson that operatons of the TRIGA Mark I and Mark F Reactors have resulted in the neutron actvation of reactor core components and other integral hardware or structural members wtyc are situated adjacent to, or in close proximity to, the reactor core dunng operations. Specific items which are considered to have been exposed to neutron actvation include rnatenals composed of aluminum, steel, stainless-steel, graptyte, cadmium, lead concrete and possibly others. Based on earher studies and expenence gained in similar research reactor decommissioning projects, and reactor specific calculations which considered measured values for neutron leakage fluence, integrated operating power histones, reactor core / pool structural configurations, and matenal compostbon of exposed pool structures, neutron activaton of matenals beyond the concrete hner/bsological shield structure (i.e., into surrounding soit volumes) is g expected for either the TRIGA Mark I nor Mark F Reactors.

i l l Table 2 Sources of Radiation Components with Potential Surface Contamination Purification System purification loop and deionizer tank piping domineralizer Other Components cables and conduits pool deck plates rotary rack drive reactor bridge structure pneumatic transfer system Components with induced Radioactivity Rotary Specimen rack (TRIGA Mark i reactor only) Control rod guide tubes and detector tubes j Top grid plate Bottom grid plate Reflector Core support Fasteners and connectors Pneumatic transfer system terminus i Reactor Tank Activated Components Reactor pit liner Concrete Anchors l Reinforcement bars Equipment Used in Decommissioning Operations General ventilation system Localized ventilation system Confinement barriers Contaminated tools und equipment Contaminated clothing

4 The fuelis stored in a canallocated off the pool of the TRIGA Mark F reactor. There is sufficient water above the fuel to provide adequate shielding to personnel working at floor level. This water is currently being circulated and purified to limit the corrosion of the fuel cladding and other submersed components so that contained radioactive materialis not likely to migrate to less contaminated areas. The fuel will continue to be stored and handled in accordance with the requirements of the TSs. TRIGA Mark F reactor components whose dismantlement could impact fuel safety will be left in place until after the fuel has been removed from the storage canalin preparation to ship offsite. .The staff has reviewed the licensee's methods used to assess radiological conditions, how they will plan to limit personal exposures as they dismantle, and how they will perform additional radiation measurements and surveys as the dismantlement proceeds. The staff ( concludes that the licensee's plans are acceptable. 2.4 Decommissionina Alternatives j The regulations in 10 CFR 50.82(b)(4)(i) require that the licensee discuss their choice of alternative for decommissioning. The three basic approaches to decommissioning are { (1) DECON, where the licensee dismantles and decontaminates their facility without j significant delay, (2) SAFSTOR, where'the f acility is placed and maintained in a condition that allows the facility to be safely stored and subsequently decontaminated to levels that permit release for unrestricted use, and (3) ENTOMB, where radioactive contaminates are encased in a structurally long-lived material, such as concrete, the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactivity decays to a level permitting release of the property for unrestricted use. The regulations in 10 CFR 50.82(b)(4)(i) further state that a decommissioning attemative is acceptable if it provides for completion of decommissioning without significant delay. The licensee has decided to dismantle and dispose of reactor-related radioactive material as soon as feasible (DECON option). The TRIGA Mark I 4eactor will be decommissioned without significant delay. Next, TRIGA Mark F reactor decomrnissioning activities that can be safely carried out with the fuelin the TRIGA Mark F fuel storage canal will be completed. After fuel is removed off site, TRIGA Mark F reactor decommissioning activities will be completed. SAFSTOR is not acceptable to the licensee because it would require long term monitoring and loss of property use, and because the quantity of radioactive materials at the site is relatively small, readily removed, and there is an available approved low-level radioactive waste disposal site. The long term ENTOMB decommissioning option suffers from the same disadvantages. Furthermore, the TRF was not adequately designed or sited to be a long term depository of radioactive material which would result from either the SAFSTOR or ENTOMB options.

5-The staff concurs that early dismantlement and removal of radioactive material to a planned and authorized disposal site is the preferred method to achieve limited - . environmental impact and long term protection of the health and safety of the public. The staff concludes that the licensee's choice of decommissioning alternative meets the requirements of 10 CFR 50.82(b)(4)(i). 2.5 Decommissionino Oraanization and Resoonsibil31 The DP contains ari organization chart, Figure 8, that demonstrates that GA management is fully aware that even though reactor decommissioning is less hazardous than reactor { i operation and use, its close involvement and control is still needed. Therefore, a decommissioning group reporting to the company Vice President for Research and Development is established, with responsibilities similar to the operations group when the reactors were in use. The management is aware and committed to its responsibility to ensure continued corripliance with all applicable regulations, and that controls on any . contractors also ensure compliance. Decommissioning deals mostly with radioactive waste and associated personnel protection, so the strong independent radiation protection program is stillin place, with adequate authority to ensure protection of both workers and the public.. Furthermore, many of the personnel who were knowledgeable and involved during reactor operations have been retained. Their knowledge and experience gives reasonable assuronce that decommissioning activities will be carried out safely and in accordance with the regulations. Because the decommissioning group is prominent in the GA management structure, the qualifications of key positions are high, and leadership positions are filled by experienced and well qualified personnel, the staff concludes that the organization and management structures are acceptable to successfully and safely complete the decommissioning of the TRF at GA. '2.6 Reaulations, Reaulatorv Guides. and Standards The DP acknowledges that GA is required to ensure that all actions by both its staff and any contractors comply with all applicable regulations, for example 10 CFR 50.82 for decommissioning activities,10 CFR Part 20 for radiation protection,10 CFR Part 71 for management of radioactive waste, and 10 CFR Part 73 for physical protection of fuel materials. Several NUREG and regulatory guide documents have been issued by NRC to help define acceptable decommissioning actions and results, including NUREG 5512, " Residual Radioactive Contamination From Decommissioning," NUREG-5849, " Manual for Conducting Radiological Surveys in Support of License Termination," Regulatory Guide j 1.86, " Termination of Operating Licenses for Nuclear Reactors," and the " Site j Decommissioning Management Plan (SDMP) Action Plan of April 16,1992" (57 FR 13389). The DP notes that the licensee is aware of, and intends to use these and other applicable guidance and regulations.

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. The staff considers the licensee's information, plans, and commitments are sufficient to give reasonable assurance that a well-planned and compliant decommissioning of the TRF at GA will result. 4 2.7 Trainino and Qualifications The DP discusses GA's plans for training both managers and workers in their respective roles. GA over the years has conducted training programs for outside groups and individuals in such topics as reactor operation and radiation protection. Therefore, there is still considerable interest at the management level and experience and competence at the worker levels to provide all needed training in-house. There continues to be general employee radiological training for all. There are established programs to increase workers' knowledge in handling radiological waste, including surveying, classifying, packaging, shipping, and preparing documentation. There is a continuing training program for health physicists in all aspects of radiation protection. As unique equipment is introduced to perform dismantlement and segmenting of components, operators will be trained if any work involving hazardous or mixed wastes is anticipated, workers will be trained as necessary. Training in applicable topics will be conducted for all contractors and subcontractors. Senior staff who have both work and teaching experience will be responsible for preparing and conducting the training. On the basis of GA's management commitment, historical activities at the site, and the planning stated in the DP, the staff concludes there is reasonable assurance that the individual members of the work force and staff will be trained acceptably to implement the TRF decommissioning while protecting the health and safety of the public. 2.8 Radiation Protection Prooram GA plans to use the existing company Health Physics (HP) Program while conducting the TRF decommissioning. This program emphasizes compliance with 10 CFR Part 20 in handling radioactive materials, and includes a policy to ensure that all radiation exposures are as low as reasonably achievable (ALARA). The qualification requirements for the position of Manager, health physics, and the key staff members ensure very knowledgeable and experienced personnel. Over the years, GA has dealt with some very complex radiological issues, including the decommissioning of other facilities at the GA site, so the existing staff should be well prepared to successfully manage protecting personnel and the environment during TRF decommissioning. The HP program addresses all aspects of radiation and exposure management, including methods of exposure reduction, radiation work permits, surveys, personal dosimetry, control and storage of radioactive material, respiratory protection, equipment and instrumentation, effluent monitoring, audits, quality control, radiological accident analyses, and general industrial safety. In order to conduct an effective ALARA program, the measurement instruments and methods of analysis should be appropriate and of high quality. The DP discusses the types of instruments, selection criteria, and calibration program that will be in place during decommissioning. The DP discusses confinement and control of possible airborne

F l l l radioactive material to be generated as a result of certain dismantlement activities, and concludes that this control, along with access control to the facilities, will ensure that members of the public will receive negligible (less than 0.1 person-rem) radiation exposure from reactor-related radiation due to decommissioning activities. The GA staff has predicted the radiation exposures of the workers on the decommissioning project to be less than 20 person-rem. Details of the estimated occupation exposure are provided in Table 3. ) On the basis of both prior history and the documented HP program at GA, the staff concludes that GA management has made radiation protection a high priority, and the planning is sufficient to provide reasonable assurance that the workers, the public, and the environment will be protected from significant radiological risk related to the GA TRF decommissioning project. 2.9 General Industrial Safety The GA management has emphasized and promoted a safe working environment in the past, and the DP includes discussions and commitments to continue those policies and practices during the TRF decommissioning. The DP cites specific guidance to be employed, as found in OSHA regulations and state of California regulations, and in the general GA Quality A.ssurance Plan. The staff considers these plans acceptable to control industrial risks. 2.10 Cost Estimates and Fundina The regulations in 10 CFR 50.82 require the licensee to submit an updated cost estimate for the chosen alternative for decommissioning, a comparison of that estimate with present funds set aside for decommissioning, and plans for assuring the availability of adequate funds for completion of decommissioning. The licensee estimates that decommissioning the two reactors will cost about $5.6 million. The estimate is reasonable, based on previous decommissioning projects of similar reactor facilities. GA has traditionally used a parent company guaranty to meet the decommissioning funding ragulations. Because of other decommissioning commitments and financial factors, in 1996, GA's parent company, General Atomic Technologies Corporation, could no longer qualify to provide a guaranty of the full amount of the cost of decommissioning the two reactors and other facilities under GA's nuclear material license. By letter dated May 20, 1996, GA proposed an alternative means of providing decommissioning funding assurance that combined a limited parent company guaranty (for an agreed upon amount that is less than the total cost of decommissioning) with a sinking fund into which money is contributed annually Of the money placed in the sinking fund, part of the money and interest can be used to pay for current decommissioning costs. The remaining money must stay in the fund with the fund balance growing each year until the fund balance

4 TABLE 3

  • OCCUPATlONAL RADIA110N DOSE ESTIMATES FOR TRIGA REACTORS DECOMMISSIONING TASKS Task fask &

Dusm8mn Ms. nug.Does Rees TeamlDoes Seentel Teemi O' ~ g g g, 1 ITR8GA Reactor Facility D&D l l l l 2 lNRC/ State approval of Decommissioning Plan l l 3 lDecer.iosion Mid Reactor 4 ! RadiologicalSurvey 112 l 2 0.0002 0.0448 0.04 l 5 l Remove Reactor Components above Pool l 80 4 0.0002 0.064 1 0.06 I 6 l Remove Reac1or Components in Pool l l 7 Grapple / Hoist

  • Survey.

72 3 0.005 1.08 l l I 8 Disassemble as necessary 72 3 0.005 1.08 9 Decontaminate or Package as LLW 64 3 0.005 0.96 3.12 l l' l 10 , Reactor Tank Water I 0.024 l 11 I Survey / Sample / Analyze 40 3 0.0002 + r 12 D:scharge/Futer as necessary 40 3 0.0002 0.024 0.05 l 13 Install Confinement Barrier around Reactor Pit i 40 3 i 0.0003 1 0.036 I 0.04 I l 14 Al Tank Removal f 15 Cut / Remove in sections 80 4 0.0025 0.8 l 16 Segregate clean sections 64 4 0.0025 0.64 l 1 1 17 Package LLW sections 56 4 0.002 1 0.448 1.89 l 18 Concrete Liner l 19 Demolish activated portion i 120 4 0.002 0.96 l 20 Rernove/ Package . 112 4 0.002 0.896 l 21 Survey remaining Concrete 32 2 0.0005 0.032 22 Demolish remaining portion to expose Soil 80 4 0.0005 0.16 23 Survey Soit presumed to be clean j 40 2 0 0002 l 0.016 24 Shore / Cover Pit l 40 4 0.0002 0.032 2.10 l 0.19 25 Survey / Remove Storage Wells,if contaminated I 160 l 4 0.0003 0.192 4 1 0.0002 0.032 I 0.03 i ! 40 _26 Disrrjantle Barrier / Package for LLW disposal i 4 I 0.0002 1 0.064 0.16 l _7 Decontaminate Mkl Reactor Room surfaces ! 80 l 28 Decommission remaining areas, except MkF l I 29 Remove Hot Drain Unes 104 !4 I 0.0003 0.1248 30 Remove contaminated sections, exc. from MkF Room j B0 l 4 l 0.0003 0.096 i 31 Reroute services to isolate MkF Room 224 4 0.0002 . 0.1792 f 1 f C 0002 l 0.064 I 32 Remove Make-Up Water Tank 80 l 4 0.0003 0.144 I 33 Dismantle / Dispose of remaining equipment in Yard ! 160 i 3 l l l t 34 Ship LLW to NTS 80 4 0.0003 0 096 0.70 i l Decommission Mkl Total. (person-rem): l 8.38 l (CONTINUED)

TABLE 3 : OCCUPAT10NAL RADIATION DOSE ESTIMATES FOR TNGA REACTORS DECOMMISSKN#NG TASKS,(CONTINUED) Task-TeekDe @ - thsenen zien,,, tag,DoesRah Teemi Does teenseml Teemi No. '^ ^ K screens anWhr p 35 IDecommission MkF Reactor l 36 ! Radiological Survey 120 2 0.002 0.48 0.48 i 37 l Remove Reactor Componente in Pool l 38 l Grapple / Horst' Survey 80 3 0.005 12 l 39 Disassemble as necessary 80 3 0.005 12 40 Decontaminate or Package as LLW 64 3 0.005 0.96 3.36 41 ! Prepare to Ship Fuel l l 42 l Ship Fuel stored in MkF Canal i 360 4 l 0.002 2.88 l 2.88 l 43 Reactor Tank and Storage Canal Water l l i 44 Survey / Sample / Analyze ! 40 3 0.0002 0.024 l 45 l Discharge / Filter as necessary I 40 3 0.0002 0.024 0.05 46 install Confinement Barrier around Reactor Pit i 40 i 3 I 0.0003 0.036 i 0.04 i 47 Tank Removal I l l 48 Cut / Remove in sections 72 4 0.0025 0.72 j' 49 Segregate clean sections I 64 I 4 0.0025 0.64 l 50 Package LLW sections I 40 4 0.002 0.32 1.68 51 i Concrete Liner l 52 Demolish activated porison l 112 4 0.002 0.896 53 Remove / Package ! 120 4 0.002 0.96 34 Survey remaining Concrete 40 2 0.0005 0.04 55 Demoksh remaining portion to expose Soil l 80 4 OD005 0.16 j $6 Survey soil presumed to be clean l 40 2 0.0002 0.016 { ) 57 Shore / Cover Pit i 40 1 4 0.0002 0.032 l 2.10 j i 58 Dismantle Barrier / Package for LLW disposal ! 40 l 4 l 0.0002 0.032 l 0.03 l 59 Decontaminate MjF Reactor Room surfaces 80 I 4 5 0.0002 l 0.064 0.06 I 60 Package contaminsW tools and equipment 40 6 1 0.0002 I 0.048 I 0.05 l 61' $ hip LLW to N1S 72 l 4 l 0.0002 0.0576 0.06 l i 62 Survey Soll i 112 !2 l 0.0002 0.0448 0.04 l l l I 63 Prepare Survey Report i 64 Submittal for Release to Unrestricted Use i I I l l Decommission MkF Total, (person-rom): l 10.83 l lMkl + MkF Decommissioning Project Total,(person-rem): l 19.22 l

p L c \\ - represents the difference between the remaining GA cost of decommissioning the site and the parent company guaranty. The NRC agreed to GA's proposalin a letter dated July 9, 1996. The NRC staff has reviewed GA's financial statements annually to verify that the licensee is meeting the requirements of the limited parent company guaranty. As part of the review for this licensing action, the staff reviewed financial records associated with ) the sinking fund and verified that the conditions of maintaining the sinking fund have been met. The staff concludes that GA is meeting the conditions of their alternative means of providing decommissioning funding assurance and that there is reasonable assurance that sufficient funds will be available for decommissioning the GA reactors. 2.11 Dismantlina and Decontamination Tasks and Schedules The DP provides a proposed schedule (Figure 9), estimated inventories of radioactive i nuclides, approximate distribution of radioacuve matenal by component and location, dismantlement actions to be taken, estimates of radioactive wastes to be produced, and projected worker radiation doses for completion of the decommissioning. All components of the TRIGA Mark i reactor that currently remain will be removed, segmented and packaged for shipment as radioactive waste, as necessary. The biological shield structure will be decontaminated as necessary, but it is not expected that biological shield decon+ amination will result in significant building structural changes. Then removal of the TRIGA Mark F reactor components will be started. However, until all fuelis removed from the storage canal, dismantlement of components that could pose a risk to fuel integrity or security will be delayed. After fuel removal, dismantlement and decontamination as necessary of the TRIGA Mark F reactor will resume. The TRIGA Mark I reactor accumulated only about two percent as many megawatt days as the TRIGA Mark F reactor. Because the TRIGA Mark I reactor will be decommissioned first, it can be used to develop additional expertise in decommissioning technics in a lower dose environment than the TRIGA Mark F. This expertise will contribute to efficient decommissioning of the TRIGA Mark F reactor. The staff considers that GA has conducted sufficient planning, radiological characterizations, and radiation exposure predictions so that there is reasonable assurance that decommissioning will be completed as planned in the DP. The staff has also examined GA's plans to conduct decommissioning activities at the TRIGA Mark F reactor with reactor fuel present in the TRIGA Mark F storage canal and concludes that the limited activities planned by the licensee can be carried out without significant risk of fuel damage or release of fission products.

-{ ~~ ~ ~ ~ - ~ ~ s m e t i - i. ,i s ~ ~ u m .u ].t E_ ~ Y %E ~ gJ Ilt _ jnL ) 3 a p t Mg'mm MgL _a Mgm'm e g m a 6_ f f' l g-m_- jE_ I %'E 'E [ E M_,Ef ) D g &D 4 Y J _. T A f % &A01 M ( I [ L g IC }- F T p ~ R 'l o ~ v O T _ r . o ,F . o C .k n_ tt. d M _ A e P __ t ts e p E em c e r_ _y en o r m R a c r -[ t p x o c a a s te s e, .r A R e o e s n D W d e n c c w s G n a s n a t r e a a r r a . a, u r L n I e D n o L u e o r R m o a n a Y l t s y o s lc .e r c a n o n o T N T P e a a e n e o v g u r y e s n e r g s o e o b w e o n c te t UD R a a e ie s it n p g e . im r H o s t s e C o s c e r n o r c o e c i e .s e I f s k c r e n r r t n R l o l B o n o e T gi a A k. v e a n t e d c O e c p o e c g n n m m m _. F a r c P J s c s a r ._E s n te 4._ r .e v a y-e r a p e gd. r. k r s_ i m a _ F R o M e-a n r e J_ e s e p r r s v o t fa e k n a v : ~n a e e O a r n r a w lp n i lc n a -te h S p S e te _ E T o o e em i

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n i .g. '2.12 Physical Securitv. Emeroency Plannina. Operator Reaualification, and Quality Assurance Over the years, GA has conducted many activities that required maintaining control of licensed materials and controlled access to facilities. Therefore, they have approved security plans and procedures in place, and have maintained a staff with security experience. _ GA plans to continue with these same procedures, as applicable, to protect

the radioactive high enriched uranium fuel from loss or diversion, and to maintain

~ restrictions to protect both workers and the public from unplanned radiation exposures. Because of GA's experience in this area and their NRC approved security plan, the staff considers their plans and provisions to be acceptable. The licensee continues to have an NRC approved Radiological Contingency Plan in place to respond to emergencies. The licensee updates the plan as needed. The plan was last-updated on October 9,1998, under the provisions of 10 CFR 50.54(q). The staff concludes that the. Radiological Contingency Plan is sufficient for responding to emergencies that may arise during decommissioning and fuel storage. Because the licensee continues to have irradiated fuel on site, GA is maintaining the qualifications of NRC-licensed reactor operators. With the permanent shut down of the reactors,'the licensee amended their TRIGA Reactors Facility Operator Requalification Program to focus on fuel handling safety and activities. The NRC staff reviewed the changes to the requalification program and approved the changes on March 3,1998. The licensee prepared a quality assurance program for the TRF decommissioning project. The program is based on the GA corporate quality assurance program which meets the requirements of 10 CFR Part 71, Subpart H, " Quality Assurance," and the guidance of ASME-NOA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities" and ANS-15.8, " Quality Assurance Program Requirements for Research Reactors." The GA corporate quality assurance program was reviewed and accepted by the NRC Spent Fuel Project Office. The staff reviewed the program for the TRF decommissioning project and concludes that the program is acceptable for TRIGA reactor decommissioning activities. 2.13 Radioloaical Accident Analysis The licensee has considered possible accidents during decommissioning that could cause radiation exposures or unplanned releases of radioactive material. Most of the accidents postulated and discussed in the DP could impact the stored fuel. These include: 1. fuel storage and handling: 2. seismicity; 3. fire; 4. other considerations, d OJ

+ ! Fuel storaae and handlino. The fuel will be both stored and moved by experienced licensed reactor operators in accordance with TSs and procedures previously in effect during reactor operations. Also, emergency procedures that address postulated stored fuel accidents will remain in effect. However, the licensee has proposed some dismantlement and removal of components, internal to the TRIGA Mark F reactor pool while fuelis still stored in the canal. The licensee has planned special precautions to avoid dropping such components and otherwise damaging the fuel, if precautions were 1 not sufficient and some fuel elements were damaged, any released fission products and fissile nuclides would be primarily retained in the pool water, to be decontaminated later. Because the fuel has undergone a period of decay of at least several years, many significant short-lived fission products either no longer exist or have had their inventories decreased significantly. Doses to the staff and members of the public from fuel cladding failure will be within previously accepted values for failures during reactor operation. Seismicitv. San Diego County is considered to be one of the moderate seismic risk regions in southern California. Therefore, a seismic event of magnitude close to seven on the Richter scale is not likely during the few years while fuel will still be stored in the canal. In the event of a damaging quake, water could be lost from the TRIGA Mark F reactor pool and the storage canal. The water is used for shielding, not fuel cooling, and currently is circulated through cleanup systems, so the concentration of radioactivity would fall within NRC regulations for release from the facility. The primary issue would be for GA staff to shield the reactor fuel. Therefore, no significant release of radioactive material would occur unless fuel cladding were ruptured. This would not be likely, because there is little heavy material that could collapse onto the fuel with damaging effect, in addition, protective deck plates cover the fuel storage canal. Fjig. The licensee has considered how fires during decommissioning could impact fuel integrity. However, accumulation of flammable materials will be monitored and avoided, and as long as the reactor pool is intact, the fuel is protected from the reactor room region under 15 feet of water. Other considerations. The licensee has addressed the possibility of radiological accidents due to mishandling radioactive components other than fuel. The GA staff has 3 considerable experience with such activities, and are committed to sufficient preplanning and precautionary procedures to keep the likelihood of such events acceptably low. The staff considers that with the history of GA's radiological experience and proposed preplanning, there is reasonable assurance that significant radiological risk to workers and j the public will be acceptably low. l

4 o 2.14 Radioactive Materials and Waste Manaaement The DP addresses the various sources of solid and liquid radioactive wastes, and their management and disposal. There is no source of airborne waste other than particulate dust resulting from dismantling procedures such as metal cutting and concrete demolition, which will be controlled by temporary barriers and local air handling and filters. Several components from each of the reactors, including the reactor tanks, were made radioactive by neutron irradiation during reactor operations. These will be removed,' segmented as necessary, packaged, and shipped offsite, all in accordance with applicable regulations. GA has an arrangement with the Department of Energy (DOE) to ship the low level radioactive waste to the Nevada waste disposal site. Some of the concrete in the biological shield is radioactive in the region close to the reactor cores. Some demolition and removal will be expected to reduce the residual contamination down to levels that meet the release criteria. This radioactive waste will also be shipped to the DOE or other licensed disposal facility. The pool water will be analyzed carefully and when it is sufficiently clean to comply with 10 CFR Part 20 lirnits, it will be released into the GA sanitary waste stream. GA maintains a radioactive waste processing facility that can be used to decontaminate liquid ) radioactive materials if necessary. ] The used reactor fuel will be returned to DOE. Much of this fuelis highly radioactive with fission products, and also many of the elements contain high enriched uranium. GA plans to continue adequate protective custody until DOE makes arrangements and retrieves the fuel. At this writing, DOE projects that this action is not likely to occur before 2003. The DP contains a discussion of the GA radioactive material controls program to ensure that radioactive material is disposed in accordance with 10 CFR Part 20, Subpart K, " Waste Disposal." This discussion includes information on the radiation detection instruments to be used to survey materialleaving the GA site and the sensitivity that these instruments will possess. The licensee may also transfer material from the reactor licenses to other GA radioactive materials licenses for additional processing or for final disposal. Considering the discussions in the DP and GA's experience with managing radioactive materials, the staff concludes that there is reasonable assurance that the radioactive wastes produced by demolition, dismantlement, and decontamination will be handled, packaged, and disposed offsite in accordance with all applicable regulations, and in accord with ALARA principles in protecting the health and safety of the public and the workers.

a ! 2.15 License Conditions The licensee has proposed changes to the license conditions commensurate with facility decommissioning, in addition to the changes proposed by the licensee, the NRC staff has amended severallicense conditions commensurate with decommissioning status. The NRC staff discussed these changes with the licensee who had no objections to the changes. TalGA Mark I. The licensee has requested that license condition 2.B.(2) be deleted in its entirety. This license condition authorizes possession of special nuclear material. With the TRIGA Mark I reactor fuel permanently transferred to the TRIGA Mark F license for storage in the TRIGA Mark F fuel storage canal, this license condition is no longer needed. The staff has amended license conditions 1.C.,1.D.,1.E., and 2.C.(2) to change reference to possession of the reactor to decommissioning of the reactor. These license conditions have been amended to read as follows: 1.C. The facility will be decommissioned in conformity with the application as amended, the provisions of the Act, and the rules and regulations of the Commission; 1.D. There is reasonable assurance that the reactor facility can be decommissioned (i) without endangering the health and safety of the public and (ii) in compliance with the regu!ations in this chapter: 1.E. General Atomics is technically and financially qualified to decommission the facility in accordance with the regulations in this chapter; 2.C.(2) Technical Soecifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 36, are hereby incorporated in the license. The licensee shall decommission the facility in accordance with the Technical Specifications. Because these changes to the license conditions reflect the change in status of the reactor to active decommissioning, these changes are acceptable to the staff. TRIGA Mark F The licensee has requested that license conditions 3 and 4 be deleted from the license it their entirety. License condition 3 contained requirements for record retention and license condition 4 contained requirements for reports. These requirements have been updated to reflect the decommissioning status of the reactor and placed in the amended TSs.

1 The staff has amended license conditions 1.B.,1.C.,1.D.,1.E., and 2.C.2 to change reference to possession of the reactor to decommissioning of the reactor. These license conditions have been amended to read as follows: 1.B. The reactor has been constructed in conformity with Construction Permit No. CPRR-59 and will be decommissioned in conformity with the application, as amended, and in conformity with the Act and the rules and regulations of the Commission: 1.C. There is reasonable assurance that the reactor can be decommissioned at the designated location without endangering the health and safety of the public; 1.D. General Atomics is technically and financially qualified to decommission the reactor; 1.E. The decommissioning of the reactor in the manner proposed in the application will not be inimical to the common defense and security or to the health and safety of the public; 2. Technical Soecifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 45, are hereby incorporated in the license. The licensee shall decommission the facility in accordance with the Technical Specifications. j Because these changes to the license relocate conditions from the license to the TSs and reflect the change in status of the reactor to active decommissioning, these changes are acceptable to the staff. 2.16 Technical Soecifications GA will maintain TSs to ensure control of important aspects of the of the decommissioning of the TRF. The licensee has proposed changes to the TS for the TRIGA Mark I and TRIGA Mark F reactor licenses. The changes to the TSs fall into five major categories: 1. Editoria. changes that have no impact on TS content or intent.

E 1 l

  • l 2.

Changes that delete reference to reactor operation and conduct of experiments, or a reactor condition, equipment requirement or fuel requirement which is no longer applicable or required for safety related functions. For the TRIGA Mark I reactor these f changes reflect the fact that authority to operate the reactor and possess fuel has been permanently removed from the license. For the TRIGA Mark F reactor these changes reflect the fact that authority to operate the reactor and maintain fuel on the reactor grid plate have been permanently removed from the license. Because of the permanent changes to the licenses, these deletions have no impact on reactor or decommissioning safety. 3. Requirements associated with the reactor that have been added or revised to apply to the f acility instead of the reactor to reflect the f act that the facility, and not just the reactor, is being decommissioned. 4. New requirements that are added to the TSs to capture important requirements of the D P. l 5. Changes that are proposed to provide clarification to existing requirements to improve consistency or clarity. In addition, changes were made to the administrative requirements sections of both licenses to make these sections of the TSs similar. Over the years, the administrative i requirements for the two reactors have not been consistently changed. For example, the TRIGA Mark I TSs contains a requirement for the submission of an annual report where the TRIGA Mark F TSs contains no annual reporting requirement (although the licensee has submitted an annual report for the TRIGA Mark F voluntarily). The licensee has proposed similar reporting requirements for both licenses. When the two reactor's operating licenses were amended to possession-only to remove the authorization to operate the reactor, only minimal changes in the TSs to requirements directly related to reactor operation were proposed by the licensee, and approved by NRC. Many specifications were left in the TSs that were not needed for a facility in possession-only status, but because of their wording, would not be effective again. The licensee now wants to remove these meaningless TSs to create a precise set of TSs. TRIGA Mark 1. Because fuel is not now permitted in the Mark I, all specifications related to fuel, reactor core, reactivity, reactor safety systems, reactor operating conditions, controlinstrumentation, experiments, and surveillances related to these topics are no longer applicable. The proposed specifications are discussed and evaluated below. Cover page and table of contents - Editorial changes were made to these sections to reflect other changes made to the TSs. TS 1.0 - Definitions: The licensee has proposed several new definitions related to the decommissioning status of the facility.

. A new definition 1.1 for " Facility" reads as follows: Facility means the building housing the disassembled reactor plus systems, components, etc. associated with possession and decommissioning of the reactor. A new definition 1.2 for " Facility Secured" reads as follows: 4 ) Facility secured shall mean that condition where no decommissioning j activities are in progress in the facility. A new definition 1.3 for " Facility Operation" reads as follows: Facility operation shall mean any condition wherein the facility is not secured. l A new definition 1.4 for " Decommissioning Activities" reads as follows: Decommissioning activities shall mean those activities required to remove I the facility safely from service and reduce residual radioactivity to a level that permits the release of the facility to unrestricted use and termination of the license. These activities will involve the handling, surveying, packaging, and dispositioning of radioactive materials in the facility. A new definition 1.5 for " Decommissioning Status" reads as follows: Decommissioning status means that the facility license has been amended to withdraw authorization to operate the reactor and authorizes possession only of the reactor, and that the fuel has been removed from the reactor and is maintained in a safe and secure manner in an approved location outside the Mark I f acility. The definitions of " Facility Secured" and " Facility Operation" replace similar definitions for the reactor to reflect the fact that the scope of decommissioning activities involve not just the reactor but the reactor facility. The new definitions of " Facility," " Decommissioning Activities" and " Decommissioning Status" help to define the scope of the TSs to decommissioning and are used in the TSs to determine equipment operability requirements.

. A new definition (1.7) for " operating" has been added to the TSs because some pieces of equipment must be operating during the conduct of decommissioning i activities. This definition uses the standard non power reactor wording of the definition. The licensee has proposed changing the definition of " Reportable Occurrence" to " Abnormal Occurrence" (old definition 1.10, new definition 1.8). The -definition was changed to refer to facility conditions instead of the reactor and to remove conditions that referred to fuel. These changes were requested because of the change of the facility to decommissioning status. Definitions for " Reactor Shutdown," " Reactor Secured," " Reactor Operation," " Standard Control Rod," " Transient Control Rod," " Cold Critical," " Experiment," " Experimental Facilities," " Reactor Safety Systems," " Experiment Safety Systems," " Standard Thermocouple," and " Standard TRIGA Core" have been proposed for removal from the definitions because they refer to equipment or conditions that are meaningless for a permanently shut down, defueled facility in decommissioning status. The definitions have been renumbered appropriately to reflect the changes proposed by the licensee. TS 3.0 - Reactor Building: This is a new specification that provides ventilation requirements to control possible airborne radioactive materials when decommissioning activities are in progress. TS 4.0 - Reactor Pool: This specification is a revision of the previous TS 3.0, " Reactor Pool." The revised version continues a requirement that the pool be nearly full of water at all times until drained as part of the decommissioning process to provide shielding of radioactive components. The specification also requires high pool water quality to limit corrosion of submerged radioactive materials that could promote j the spread of contamination, j TS 5.0 - Reactor Fuel: This specification replaces previous TSs 4.0, " Reactor Core," and 6.0, " Fuel Storage." This specification makes explicit that fuel possession or storage is not authorized in the TRIGA Mark I facility. TS 6.0 - Control and Safety Systems: This specification describes non-fueled control rods that are permitted to remain in the TRIGA Mark l facility, and retains the requirements of previous specifications 5.2.3(a) and 5.2.3(b) for monitors of area radiation and airborne radioactive material, respectively, and calibration requirements. The operability and operating requirements of these monitors is changed to focus on facility decommissioning activities instead of reactor operation. Requirements for reactor control and safety systems are removed from the TS due to the permanent shut down and removal of fuel from the reactor.

~ 17-TS 7.0 - Administrative Requirements: This specification is similar to the previous TS 9.0, " Administrative Controls," with the following exceptions: a) there are changes to the TS to accommodate the change from an operating or possession-only reactor to a decommissioning reactor facility; b) the organizational chart (Figure 8) is amended to that organization given in the DP; c) changes are proposed to TS 9.3 " Written Procedures," to delete procedures for fuel element and experiment loading and add procedure requirements for decommissioning activities and to add the requirement that the Criticality and Radiation Safety Committee approve temporary changes to procedures: and d) changes are proposed to TS 9.6, " Reporting Requirements" (renumt tred as TS 7.6), so that reporting operating reactor related information are deleted, ed information related to the shut down reactor being decommissioned is adde d to the TS reporting requirements. TS 8.0 - Facility Jperations: A new section is added to the proposed TSs that emphasizes that the activities to be conducted in the facility include maintenance, control of radioactive materials, protection of personnel, assurance of security, and decommissioning in accordance with the facility license and the approved DP. TSs on reactor operations and experiments are deleted in their entirety because the reactor will never operate again nor will experiments be conducted. The staff has reviewed all proposed deletions, additions, and other changes to the TRIGA Mark i TSs. The changes are consistent with the change in status from either an operating reactor or a nonoperating reactor in possession-only to a facility in decommissioning status. The requirements contained in the proposed TSs provide the same level of management controls and the same qualifications for decommissioning and radiation protection staff as previously existed during reactor operations. The TSs also includes a requirement to follow the approved DP during decommissioning activities. Based on these considerations, the staff concludes that the proposed TSs are ' commensurate with the change in f acility status to decommissioning and that compliance with the proposed TSs provides reasonable assurance that the decommissioning activities will be conducted with due regard to protecting the environment and the health and safety of workers, contractors, and the public. Therefore, the proposed TSs for the TRIGA Mark i i reactor are acceptable to the staff. I TRIGA Mark F. Because fuel storage in the core of the TRIGA Mark F reactor and reactor operation are not authorized, TSs related to the reactor core, reactor safety systems, reactor operating conditions, experiments and surveillances related to these topics are no longer applicable. However, fuel storage in the storage canal and manipulation of fuelin the fuel storage canal, in the TRIGA Mark F reactor pool, and in the reactor room are not prohibited and the TSs continue to reflect this fact. The proposed TS are discussed and evaluated below. i Cover page and table of contents - Editorial changes were made to these sections to reflect other changes made to the TSs. m.-

e . TS 1.0 - Definitions: The licensee has proposed several new definitions related to the decommissioning status of the facility. A new definition 1.1 for " Facility" reads as follows: Facility means the building housing the disassembled reactor plus systt as, components, etc. associated with possession and decommissioning of the reactor, including fuel storage. A new definition 1.2 for " Facility Secured" reads as follows: Facility secured shall mean that condition where no decommissioning activities or handling of fuel are in progress in the facility. A new definition 1.3 for " Facility Operation" reads as follows: Facility operation shall mean any condition wherein the facility is not secured. A new definition 1.4 for " Decommissioning Activities" reads as follows: Decommissioning activities shall mean those activities required to remove the facility safely from service and reduce residual radioactivity to a level that permits the re! ease of the facility to unrestricted use and termination of the license. These activities will involve the handling, surveying, packaging, and dispositioning of radioactive materials in the facility. A new definition 1.5 for " Decommissioning Status" reads as follows: Decommissioning status means that the facility license has been amended to withdraw ashorization to operate the reactor and authorizes possession only of the reactor, and that the fuel has been removed from the reactor and is maintained in a safe and secure manner in an approved location in the facility. The definitions of " Facility Secured" and " Facility Operation" replace similar definitions for the reactor to reflect the fact that the scope of decommissioning activities involve not just the reactor but the reactor facility. The new definitions of " Facility," " Decommissioning Activities" and " Decommissioning Status" help to define the scope of the TSs to decommissioning and are used in the TSs to determine equipment operability requirements. The definitions also account for the continued storage of fuel in the TRIGA Mark F fuel storage canal.

I 1 l A new definition (TS 1.7) for " operating" has been added to the TSs because some pieces of equipment must be operating during the conduct of decommit.sioning ) activities. This definition uses the standard non-power reactor wording of the definition. The licensee has proposed a new definition (TS 1.8) of "Abnormat Occurrence" similar to the definition in the TRIGA Mark i TSs to provide a basis for reporting defined events to the NRC. Such events as changes in reactivity of the L stored fuel and release of fission products from fueled components are included in the l definition. The licensee has proposed adding definitions for " Measured Value" (TS 1.9), " Measuring Channel" (TS 1.10), and " Channel Calibration" (TS 1.11). These definitions match those existing in the TRIGA Mark i TSs and are used in connection with systems such as radiation monitoring equipment. These changes j were requested because of the change of the facility to decommissioning status, l Definitions for " Reactor Shutdown," " Reactor Secured," ~%ctor Operation," " Standard Control Rod," " Transient Control Rod," " Experiment," " Reactor Safety Systems," " Experiment Safety Systems" and " Standard Thermocouple" have been proposed for removal from the definitions because they refer to equipment or conditions that are meaningless for a permanently shut down, defueled facility in decommissioning status. The definitions have been renumbered appropriately to reflect the changes proposed l by the licensee. J TS 3.0 - Reactor. Building: This specification has been revised to address ventilation conditions adequate to maintain control of airborne radioactive materials during fuel storage and decommissioning instead of during reactor operation. TS 4.0 - Reactor Pool: This specification has been revised to address the shielding and pool water quality requirements during fuel storage and decommissioning instead of during reactor operations. The licensee has added a proposed requirement to analyze the pool water tor ladioisotope content on a quarterly basis while fuel is in the pool to detect fuel cladding failure. TS 5.0 - Stored Fuel

Description:

This TS previously addressed the operable reactor core. The revised version retains specifications for fuel elements possessed under the license, but also prohibits storage of fuel elements and fueled control rods any place but the fuel storage area of the TRIGA Mark F. This proposed TS also prohibits fueled components from being stored in the reactor portion of the pool. l

. TS 6.0 - Control and Safety Systems: This specification describes the control rods, i either fueled or non-fueled that are permitted to be stored in the TRIGA Mark F l storage canal, and retains requirements for area radiation monitors and airborne radioactivity monitors including calibration and operability requirements. The operability and operating requirements of these monitors is changed to focus on facility decommissioning and fuel storage activities instead of reactor operation. Requirements for reactor control and safety systems are removed from the TS due to j the permanent shut down and removal of fuel from the reactor. l TS 7.0 - Fuel Storage: This specification has been retained to limit conditions of fuel storage. However, it has been revised to include conditions of storage placed on fueled control rods, as well as fuel elements. l TS 8.0 - Administrative Requirements: This section of the TS for the TRIGA Mark F was much less comprehensive than existed for the TRIGA Mark I. The licensee revised this section of the TSs to be consistent with the administrative requirements section of the TRIGA Mark i Tbs. This means that all mar.agement controls and l requirements, reporting requirements, and retention of records for both reactor licenses would be the same. This should result in uniformity in administrative requirements related to decommissioning the two reactor facilites. 1 i The licensee proposed changes to the TSs to accommodate the change from an I operating or possession-only reactor to a decommissioning reactor facility with fuel in storage. An organizational chart (Figure 8) identical to that in the TRIGA Mark i TSs j is added to these TSs. Organizational and Criticality and Radiation Safety Committee requirements between the two licenses are made the same. Changes are proposed in TS 8.3, " Written Procedures," to clarify requirements for fuel handling procedures, add procedure requirements for decomrnssioning activities and add the requirement that the Criticality and Radiation Safe +/ Committee approve temporary changes to procedures. The licensee has preposed adding TS 8.4, " Action to be Taken in the Urt of an AbnormM 0;carrence," TS 8.5, " Facility Records," and TS 8.6, l " Reporting Requirements." These sections did not exist in the TRIGA Mark F TSs. These new TSs are similar to the requirements in the TRIGA Mark i TSs, with the exception of several additional requirements to account for the storage of fuel under the TRIGA Mark F license. i TS 9.0 - Facility Operations: A new section is added to the proposed TSs that emphasizes that the activities to be conducted in the facility include maintenance, I control of radioactive materials, protection of personnel, assurance of security, safe storage and handling of fuel, and decommissioning in accordance with the facility license and the approved DP. l I

g o.. l I f TSs on reactor operations and experiments are deleted in their entirety because the reactor will never operate again nor will experiments be conducted. j l l l The staff has reviewed all proposed deletions, additions and other revisions to the TRIGA Mark F TSs. The changes are consistent with the chenge in status from either an operating reactor or a nonoperating reactor in possess,on-only to a facility in decommissioning status with temporary storage of used fuel. The requirements contained in the proposed TSs provide the same level of management controls and the same qualifications for decommissioning and radiation protection staff as previously existed during reactor operation. The TSs also includes a requirement to follow the approved DP during decommissioning activities. Based on these considerations, the staff concludes that the proposed TSs are commensurate with the change in facility status to decommissioning with fuel storage and that compliance with the proposed TSs provides reasonable assurance that the decommissioning and fuel storage activities will be conducted with due regard to protecting the environment and the health and safety of workers, contractors, and the public. Therefore, the proposed TSs for the TRIGA Mark F reactor are acceptable to the staff. 2,17 Termination Radiation Survey Plan i in 1997,10 CFR Part 20, Subpart E, " Radiological Criteria for License Termination" became effective. However,10 CFR 20.1401(b)(3) states that the criteria in this subpart do not apply to sites which submit a sufficient decommissioning plan before August 20, 1998, and such decommissioning plan is approved by the Commission before August 20, 1999, and in accordance with the criteria identified in the SDMP Action Plan. GA falls under this facet of the regulations. The SDMP Action Plan contains cleanup criteria to determine whether sites have been sufficiently decontaminated so that they may be released for unrestricted use pursuant to 10 CFR 50.82. The cleanup criteria are applied on a site-specific basis with emphasis on residual contamination levels that are ALARA. For reactor facility structures, the SDMP Action Plan refers to Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors," Table 1, for surface contamination of reactor facility structures. Reactor generated, gamma emitting isotopes that may exist in concrete, components, and structures should be removed so the exposure rate is less than 5 microroentgen per hour above natural background at one meter from the surface of interest. The DP contains these facility release criteria which meet the regulations. An extensive set of radiation measurements and analyses will be required to demonstrate that the GA TRF has been decontaminated sufficiently to comply with the established criteria for license termination and release for unrestricted future use. The DP discusses in detail the methods, instruments, principles, and guidance documents that are planned to be used in acquiring and documenting this information. The licensee has radiological characterization data and other operating history that indicate areas and components of concern. GA ha -:ommitted to using the best instruments reasonably available, and will employ statistical _ sampling when large areas of concern are being surveyed. The licensee is aware that release criteria relate to local natural background radiation levels, so

e a... l l [ ' l' appropriate effort is planned to determine those levels. The licensee will compare the evaluated residual radiation levels with the accepted release criteria in its final survey report that will be submitted to NRC to support termination of license. The staff finds the DP discussions of the termination survey plan to be in compliance with the regulations and are therefore acceptable. 3.0. ENVIRONMENTAL CONSIDERATION The Commission has prepared an Environmental Assessement and Finding of No Significant impact (EA), which was published in the Federal Reaister on August 5,1999, (64 FR 42730). On the basis of the EA and this safety evaluation, the Commission has determined that no environmentalimpact statement is required and that issuance of this amendment approving decommissioning will have no significant adverse effect or the quality of the human environment.

4.0 CONCLUSION

S On the basis of the review and evaluation of General Atomics' DP and proposed changes in their TSs, the staff concludes that the licensee is adequately cognizant of its continuing responsibilities to comply with applicable regulations and to protect the environment and the health and safety of its workers, contractors, and the public from undue radiological risk until the reactors licenses are terminated. The DP meets the requirements of 10 CFR l 50.82(b)(4) and provides reasonable assurance that the licensee has the resources to dismantle the TRIGA reactor facilities, dispose of the fuel and all the reactor-related radioactive material, and to meet criteria for termination of the facility licenses in accordance with applicable regulations and NRC guidance. The staff, therefore, finds the j licensee's plans and preparations acceptable. The staff has concluded, based on the considerations above that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed activities; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of this amendment will not be inimical to the common defense and security or the health and safety of the pu'lic. o Principal Contributors: R. E. Carter, INEEL A. Adams, Jr., NRC Date: August 12, 1999 o}}

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