ML20211B447

Forwards Evaluation & Request for Addl Info on Termination Survey of Facility.Response Requested by 860627

ML20211B447
Person / Time
Site:	05000375
Issue date:	06/02/1986
From:	Berkow H Office of Nuclear Reactor Regulation
To:	Remley M ROCKWELL INTERNATIONAL CORP.
References
NUDOCS 8606110661
Download: ML20211B447 (5)

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Juna 2, 1986 Docket No. 50-375 i

Dr. M. E. Remley, Director Rockwell International Corporation 6633 Canoga Avenue Mail Code LA 06 Canoga Park, California 91304

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE TERMINATION SURVEY OF THE ROCKWELL INTERNATIONAL RESEARCH REACTOR L-85

}' Region V and NRR staff have reviewed your submittals of your final termination survey and have several issues that still must be resolved (Enclosure 1).

Please respond to the enclosed evaluation and request for additional information by June 27, 1986.

If you have any questions, please contact Harold Bernard, our Project Manager for your facility, at (301) 492-8529.

, The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely,

, original signed by Herbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B l

Enclosure:

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, / June 2, 1986 Docket No. 50-375 i

i Dr. M. E. Remley, Director Rockwell International Corporation

{ 6633 Canoga Avenue Mail Code LA 06 Canoga Park, California 91304

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE TERMINATION SURVEY OF THE ROCKWELL INTERNATIONAL RESEARCH REACTOR L-85 Region V and NRR staff have reviewed your submittals of your final termination survey and have several issues that still must be resolved (Enclosure 1).

Please respond to the enclosed evaluation and request for additional information by June 27, 1986.

. If you have any questions, please contact Harold Bernard, our Project Manager for your facility, at (301) 492-8529.

The reporting and/or recordkeeping requirements contained in this letter

affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511 Sincerely, d -

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, rbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B

Enclosure:

As stated cc w/ enclosure:

See next page

- Rockwell International Incorporation Docket N0. 50-375 cc: Sacramento County Board of Supervisfors 827 7th Street, Room 424 Sacramento, California 95814 Office of Intergovernmental Management - State of California 1400 10th Street, Room 108 Sacramento, California 95814 California Department of Health ATTN: Chief, Environmental Radiation Control Unit  ;

Radiological Health Section 714 P Street, Room 498 Sacramento, California 95814 i

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Enclosure 1 A. Page 6 identifies the premises to be released as consisting of Buildings T093, T083, T074, and T453. As best we can determine, the activities authorized by the license were conducted in Building T093, and possibly T453. Buildings T083 and T074 were apparently used for activities under authorization other than the L-85 license. It appears the submittal has commingled NRC-licensed facilities with non-NRC facilities. To assure that NRC does not overstep its authorities and to assure efficient use of Region V resources, we request that Rockwell International clarify those facilities under license R-118.

B. Table 3 on page 21 notes that the average beta contamination reached a maximum value of 3102 dpm/100 cm2 and an " Inspection Test Statistic" value of 1000.2 dpm/100 cm r . These values exceed the limits in Table I of Regulatory Guide 1.86 for Sr-90, a pure beta emitter. You must demonstrate that Sr-90 is not the source of the beta radiation in order to justify the use of your contamination values.

C. Pages 22 and 33.6 state that you used the average value of measurements made in the reactor room as the value for background. This approach does not seem reasonable in that the so called " natural background" would be affected by possible existing contamination, and it is not

, consistent with the definition of background found in the footnote to Table 1 of the Safety Evaluation Supporting Order Authorizing Dismantling of the L-85 Reactor. The State of California, which has also reviewed the report, has raised this same issue to Region V. It should be noted that the page that includes Table 1 was omitted from your revised report.

D. Page 14 of the report implies that the sampling plan is consistent with NRC guidance on sampling for decommissioning radiation surveys.

You should specifically identify the referred-to guidance. We are not aware that there is specific NRC guidance on acceptable sampling plans for decommissioning radiation surveys. Notwithstanding the guidance that you may have, we believe that surveying only 11% of the surfaces is not sufficient to demonstrate that the release criteria have been met. A recent survey, conducted by an NRC contractor when evaluating Rockwell's Building 001 for unconditional release, included 100% beta-gamma scan of the floor, lower walls (up'to 2 meters), air ducts, piping, and equipment surfaces. Justify the basis for the minimal area you utilized.

E. Your resurvey of the reactor room, as described beginning on page 33.1, still relies on a NaI(TI) detector which, although very useful in identifying areas of relatively high radiation, is not a true dose rate instrument. Your comparison of the Na!(Tl) detectors with the HPICs only provides a one point crosscheck. A single point does not allow the identification of the slope of the response curve that relates meter reading to dose rates. The energy field that would

be present at the locations of the fixed HPIC, and therefore the instrument response, would be different. Accordingly you must relate your readings to those of readings from an HPIC which would detect radiation from products within a broad energy band.

I F. On page 33.8 you propose to cover those areas that exhibit dose l rates above 5 pr/hr with at least 15 inches of concrete to reduce the doses to acceptable levels. We will need to confirm your measurements following application of the concrete cover.

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