ML20217A769

Advises That Rocketdyne License Meets Criteria for Transfer Contained in NMSS Policy & Procedures Ltr 1-41

ML20217A769
Person / Time
Site:	07000008, 07000025
Issue date:	11/19/1990
From:	Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Joseph Austin NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9011210281
Download: ML20217A769 (1)

Text

. . .

• ' NOV 191990

MEtORANDUM FOR: John Austin, Chief

. F,egulatory Branch 4

. Division of Low-level Waste Management '

and Decommissioning, NMSS IFROM: Charles J. Haughney, Chief Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS

SUBJECT:

TRANSFER OF LICENSING AND DECOMMISSIONING RESPONSIBILITY FOR ROCKE1 DYNE LICENSE, DOCKE1 NO. 70 25 The Rocketdyne license meets the criteria for transfer contained in HMSS Policy and Procedures Letter 141, i.e., there are no known nuclear process safety problems (see Enclosure). 1herefore, at this time, this license is being offered for transfer to the Division of Low. Level Waste Management and Decommissioning (LLWit). .So as not to overload your staff, Rocketdyne is offered

-for transfer in lieu of Battelle Memorial Laboratories, Docket No. 70 8, which plans to continue certain operations for the foreseeable future. Battelle was included in the cases to be transferred by rqy September 14, 1990, meno to you.

This transfer of responsibility would serve to permit a more rapid !taff action  !.

to achieve the goal of ensuring timely and effective decommissioning of the site, ; There are several issues (see Enclosure) that must be resolved prior to approval _of the' decommissioning plan. Regardless of transfer, your Branch will have to be involved in the decisions on some of these issues.

1 request that you name a project manager who can take responsibility for.this case and identify an early date by which we can accomplish this transfer.

My staff will centinue to be available to discuss past activities at the site, 04nalSigned or Charles J. Haughney, Chief Fuel Cycle Safety Branch Division of Industrial and ,

Medical Nuclear Safety, NMSS

Enclosure:

Memo dtd 11/08/90 GBidinger to CHaughney w/ enc 1,  ;

cc:. R. Bangart, LLWM J. Greeves, LLWM R. Cunningham, IMNS.

G.,Sjoblom,IMNS R. Scarano, RV

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! Distribution w/ enc 15:

Docket-Mo. 70-25 NRC,Ei:le Center - wPDR o HMSS R/F +

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, , DATE:11/fj/90: 11/$90: 11/ l'I/90: 11/[90:

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NOV B1990 1

lI MEMORANDUM FOR: Charles J. Haughney, Chief Fuel Cycle Safety Branch I Division of Industrial and Medical Nuclear Safety, NMSS l

FROM: George H. Bidinger, Section Leader '

Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS l

SUBJECT:

TRANSFER OF ROCKETDYNE LICENSE AND DECOMMISSIONING  :

PROJECT TO DIVISION OF LOW-LEVEL WASTE MANAGEMENT -

AND DECOMMISSIONING (LLWM) q The Rocketdyne license appears to be a prime candidate for transfer to LLWM.. ,!.*, i Rocketdyne has terminated its operations and is currently in the proc ~ess of.

' decommissioning the hot cell facility. Transfer now would provide for the i smooth. transition between the operational project management and dt ommissioning i activities. Criticality considerations are no: longer an issue at.the facility. ,

The license has1been amended to remove all criticality safety requirements, and I there are no known nuclear process safety problems. -Therefore, according to NMSS Policy.and Procedures Letter 1-41 (P&PL-41), _this would be the appropriate ,

time for the-transfer, j

l

-_Rocketdyne has-recently submitted a revised decommissioning plan. It appears that the NRC group overseeing the decommissioning activities should also be the-group to review and' approve the decommissioning plan. There are several-issuesi that must be resolved prior to completion of decommissioning activities. .0ne is' I a pol. icy decision as to whether the " orphan facilities'.' should be handled by the Department of Energy (DOE) or N!' (see enclosed trip report). A single person' j or group should be the. contact for discussions with 00E; a change in.the middle l of discussions could be' disruptive. The decision on the-facilities and

.necessary coordination with 00E would appear to be LLWM responsibility per- .

P&PL-41. The decision on the orphan facilities would also affect the financial-assurance certification, therefore, this action should also be~ transferred. Two- '1 issues pertaining to decontamination'of the drain lines and the shielding. doors )

will=have to be. decided prior to approval of the decommissioning p.lar (see enclosed trip report'and letter).

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Charles J. Haughney 2 NOV s iggg As previously stated, in accordance with N.PL-41, this license appears to be a good candidate for transfer to LLWM. I recommend that this project be transferred prior to any further involvement by ray staff, s

George H. Bidinger, Section Leader llranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety. HilSS

Enclosures:

1. Trip Report memo dtd 10/29/90 MHorn to CHaughney

2. Ltr dtd 10/24/90 PRutherford to GBidinger

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I a e g utu\g UNITED STATES NUCLEAR REGULATORY COMMISSION d l WAGHINGTON, D. C. 20666

..... OCT 2 91990 1

l MEMORANDUM FOR: Charles J. Haughney, Chief l 1

Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS 1

FROM: Merri Horn I Uranium Fuel Section l Fuel Cycle Safety Branch i Division of Industrial and Medical Nuclear Safety, NMSS

SUBJECT:

TRIP-REPORT ROCKETDYNE DIVISION, ROCKWELL INTERNATIONAL, CAN0GA PARK, CALIFORNIA, DOCKET NO. 70-25 On October 9-10, 1990, Rockwell International's Santa Susana Field Laboratory was visited by George Bidinger and Merri Horn, NMSS, and Charles Hooker, Region V. During the visit, Mr. Hooker conducted an inspection. The visit consisted of a site licensing issues (the' familiarization decommissioning tour and plan,discussions on several financial assurance for'- pending 4 a "

decommissioning, criticality control, and an organizational change).

The' facility tour' included the hot cell (building 20), burn pit facility, and I buildings 5,-9, 11, 55, 100172, and 373. With the exception of areas

, l buildings 20, 55,.and 172, these areas are' considered " orphan" facilities.

Although the areas are physically located in Area IV, which is outside the  ;

DOE-controlled compound, the operations were generally DOE controlled. Because. l NRC-licensed activities were not conducted in the orphan facilities but the areas are outside the DOE-controlled portion of land, there is now some question.-

as to which agency should be overseeing the decommissioning of the facilities.

Some of the buildings have been decommissioned by Rockwell but have not been-officially released by DOE or NRC. Some of the buildings also contain State'of California licensed activities. Several of the areas are included in DOE's-5-year decommissioning plan. A brief description of the areas is provided l below.

In an attempt to work with DOE and determine which agency is responsible for the orphan facilities, a conference call was held with Roger Liddle, DOE (415-273-6439). Mr. Liddle is the DOE contact for decommissionin

' Prior to any decisions, further communication will be necessary.However, g of thean.

site.

agreement was reached that coordination of activities, such as the final surveys,.

should be pursued. Oak Ridge Associated Universities (0RAU) will be conducting.

both the NRC.and DOE confirmatory surveys. Merri Horn is the NRC staff contact.

By letter dated September 6,1990, Rockwell informed Region V of an organization / i management change.. However, the licensee has not submitted an amendment request.

Rockwell was; informed.that a license amendment was necessary and agreed to submit the amendment explaining the organizational changes. While the organizational structure is changing, the personnel remains the same.

O Lf -

Rocketdyne Division OCT 2 91990 2

Rockwell has submitted correspondence on financial assurance for decommissioning.

The licensee was informed that the information on Building 20 was satisfactory.

However, the question as to whether the orphan facilities should be covered by the financial assurance certificate is still an open issue. Rockwell does not need to take any further action on these other buildings until contacted by the NRC.

On the issue of decommissioning, Rockwell stated that the revised decommissioning plan for Building 20 would be submitted in the near future. i Decontamination of Cells 1 and 2 is nearly complete; all equipment has been removed, only discrete areas of contamination remain. Rockwell is in the {

process of removing equipment from Cells 3 and 4. Two potential problems were discussed during the tour and subsequent conversations with licensee personnel. l The first issue concerned decommissioning and the confirmatory survey of the drain lines in the hot cell. The drain system from the hot cells is an 1 all-butt-welded stainless steel piping system that runs from each cell and adjoining decontamination room to the manifold in the basement. This drain system is embedded in 5-f t thick, rebar-laced concrete between the main floor of the hot lab and its basement. The licensee would like to leave the drains in place and has developed a method for in situ decontamination and surveyt Rockwell inquired whether the method will be acceptable to the NRC. We informed the licensee that we would confer with ORAU and inform Rockwell of the decisidh ORAU will be conducting the confirmatory survey. The second issue concerned the shielding doors on the back of the hot cell. The 80-ton doors are too large to be removed through the decontamination area doors or to be laid on the floor.

Becaure there is a small area of the wall that is obstructed by the doors, the licensee cannot decon the entire room with the doors in place. Additionally, there is a problem with decon of the rollers and slide area under the doors.

It is necessary to remove the roof and part of the building to get the crane close enough to lift the doors out of the building. Therefore, in order to facilitate removal of the doors, it may be necessary to conduct the confirmatory survey on part of the building.

Orphan Facilities Old conservation yard - The conservation yard extends to both the DOE and non-D0E side. In 1989, soil with low levels of Cs-137 was removed from the 00E side. Rockwell has sent the final survey results to 00E. NRC action is probably unnecessary.

Decon been usedtrailer in-the Located trailer.on the non-DOE side. No radioactive material has ever No NRC action is needed.

AE6/L The reactor operated under NRC license. The facility was decounissioned in 1987, and the operating license terminated in April 1987, No further NRC action is needed.

T005 - This former fuel fabrication facility was operated as an exempt facility under the Atomic Energy Co; mission (AEC) Chicago operations. The facility never had an NRC license but is located on the non-00F side. DOE has placed

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OCT 2 9190 Rocketdyne Division 3 this facility in its 5-year plan for decommissioning. Contamination has been L removed from the facility with the exception of a few drain lines and the L ventilation system. The system consists of ducts, a filter house, and stack.

An underground storage tank and lines have been removed. Prior to termination of the NRC license, a decision on the decommissioning of this facility will have to be reached between NRC and 00E.

T011 - This building is used as a radiation instrument servicing laboratory.

No uncontained material was used. Further NRC action is unnecessary.

T172 - This is a shielded X-ray roon where plutonium fuel elements were X-ray inspected. During the last license renewal, this area was deleted from the NRC license. When deleted from the 11celse, a confirmatory survey was not conducted. NRC plans to include thh area in the confirmatory survey for the site.

I T373 - Located on the non-DOE side, this facility was used for low-power L testing of various SNAP reactor designs. About 1959, all radioactive material was removed and the facility surveyed. In 1988, Rockwell resurveyed this facility and documented the survey. A confirmatory survey of this facility by DOE or NRC is needed.

T055 - This building housed the plutonium fuel fabrication facility, in 1987, the facility was decommissioned and af ter a confirmatory survey by ORAU, deleted from the NRC license by Amendment No. I dated October 7, 1987. No further NRC action is needed.

T020 - This building contains the hot cell and is currently under NRC license.

Rockwell has submitted a decommissioning plan for this area. Some soil contamination exists outside the building. NRC action is necessary.

Old sodium burn pit - This area is located on the non-00E portion of the site.

Some radioactive contaminated material was apparently placed in the pit,

- resulting in some portions of the pit and the pond being contaminated with mixed fission products. There may be small quantities of SNM contamination present.

Rockwell has developed an assessment plan for this area. The burn pit is

-- included in the DOE 5-year decommissioning plan. Prior to license termination, a decision must be made on inclusion of the pit in the NRC decommissioning efforts.

T009 - From 1959 to about 1964, this building was used as a " critical experiment" laboratory for organic moderated and sodium-graphite reactors. All radioactivity associated with the operation has been removed. . Currently, the building is used for testing and development of contaminated equipment for in-service inspection of power reactors. A forging operation using depleted uranium was just recently completed.

under the State of California license.Both of these operations are conducted Since Rockwell plans to continue these operations and only State operations are being conducted, the State may be willing to take responsibility for this building. If the State takes control, further NRC action will not be necessary.

. OCT 2 91990 Rocketdyne Division 4 T100 - This building is currently used as the main office and laboratory for the radiation and nuclear safety group. The building did house the " critical experiment" laboratory to investigate a wide variety of fast-reactor compositions. All radioactive materials associated with that research were removed, and the facility was decommissioned in 1980, in October 1980, the NRC Office of Nuclear Reactor Regulation released the facility. Small amounts of radioactivity in samples and check sources are used in the laboratory.

Therefore, NRC will need to check the lab area, b,,j 2, + + J Merri Horn Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS 4

, v .' -

[ ! I' Rocketdyne Divleion Rockwell internat60nal Corporation 6633 Canoga Avenue Rockwell Canoga Park. Cahtornsa 91303 International Telex: 698478 ROCKETDYN CNPK October 24, 1990 In reply refer to 90RCl3899

,Mr. George 11. Biddinger

, - Uranium Fuel Section Division of Industrial and Medical Nuclear Safety U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Decommissioning RIHL, Optional Procedures. for Drain System and flot Cell Doors (SNM 21, Docket 70 25)

Dear George:

Q, As wer discussed on your recent tour of Rockwell International Hot-

- Laboratory (RlllL) decommissioning site on October 9,1990, we ; are considering two potential options in our decommissioning approach, as described- in the revised Decommissioning . Plan.

(1)' The stainless. steel hot cell dialni system, which is a -welded assembly in the 5 foot thick l concrete hot cell floor, is radioactively 4-contaminated. The - most cost effective; approach for removal of this system is . to partially decontaminatei the - systeme by water flushing,' sealing the open . cnds and removing the contaminated Jsystem as part of the demolition--

of the building after the building; was decontaminated and released' for unrestricted use.

-(2) Removable - surface" contamination will - be removed from the steel hot cell dous as best - as possiblet however, the most cost effective approach to remove fixed : contamination is - to : transfer the' doors - from . the.-

facility to a nearby decontamination,- facility at SSFL for decontamination.

Removal of the contaminated hot cell; doors as part of the demolition of the building is the most cost effective because they weigh in excess of 66,000 pounds cach, they do not fit through' the: cxisting doorways, and there is no equipment in the facility for- moving 'this size load.. The doors were c

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P 90RCl3899 October 24, 1990 Page-2 installed as part er the construction of the building and before the concrete decontamination room was constructed around the doors, A key item in these approaches is the release of the facility for unre-stricted use .before removal of the hot cell drain system and hot cell doors to a'llow the use of conventional demolition techniques. Please let us know if these approaches are feasible from a regulatory standpoint and if they are acceptable to you.

if you ' have any questions on the subject, please contact Fred Schrag at (818) 700 5310.

Very truly yours, h

P, D. Rutherford

- Manager.  ;

Radiation Protection and Health Physics Services cc: /

Merri Horn NRC Hq i Chuck Hooker NRC Region V 1:

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