ML20133D995

SER Conditionally Supporting Amend 2 to License SNM-696, Authorizing Mods to Radiation & Criticality Safety,Environ Surveillance Requirements & Criticality Alarm Sys Requirements

ML20133D995
Person / Time
Site:	07000734
Issue date:	07/30/1985
From:	Crow W, Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20133D966	List: ML20133D962 ML20133D995
References
NUDOCS 8508070541
Download: ML20133D995 (7)

Text

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JUL 3 0 1985 DOCKET N0: 70-734 LICENSEE: GA Technologies, Inc.

FACILITY: San Diego, California

SUBJECT:

REVIEW 0F LICENSE AMENDMENT APPLICATION DATED APRIL 23, 1985 AND SUPPLEMENTS DATED MAY 20, JUNE 3, AND JUNE 20, 1985

Background

GA Technologies, Inc. (GA), by application dated April 23, 1985, requested an amendment to its SNM-696 license to modify the radiation and criticality safety, the environmental surveillance requirements, and the criticality alarm system requirements.

GA requests these changes because the production of HTGR fuel has ceased, the

_ production of TRIGA fuel has been reduced (with periodic shutdown), and there is no scheduled Hot Cell work for the near future. The only activity in the SV-A Building (HTGR fuel manufacturing) will be research and development work with coated particles, work in the quality control laboratory, and in the non-destructive testing area of the building.

During NRC's review of the amendment application, GA requested an interim autho-rization for modification of the criticality alarm requirements of 10 CFR 70.24.

This interim authorization would allow GA to start on the modification of the criticality alarm system in the SV-A Building while the NRC continued its review.

The interim amendment (Amendment No. 1) to the license was issued on May 30, 1985.

Discussion A. Radiation Safety As part of the amendment request, GA has requested a number of reductions in radiation inspections and surveys. Table 1 presents a summary of these proposed reductions as well as those for nuclear criticality safety and environmental surveillance. During the shutdown of operations, areas of the SV-A Building have been decontaminated to justify reduced levels of surveys. By letter dated June 20, 1985, and in a subsequent telephone conversation, GA transmitted data on dose rates and surface contamination.

This data indicates that the areas where reduced surveillance has been re-quested have been decontaminated to levels below those found in Regulatory Guide 8.24 for removable surface contamination in uncontrolled areas ansite.

Despite reducing contamination to these levels, the areas will remain mider access control, and occupancy of the creas will be minimal.

8500070541 850730 gDR ADOCK 070 g 4

2 JUL 3 0 1985 Although the licensee plans minimal' activities, there may be times when maintenance or other activities are conducted. To assure that appropriate radiation safoty precautions and surveys are taken during these operations, the staff recommends that the following conditions be added to the license:

1. The survey frequencies and contamination control measures specified in the license shall be used whenever work is performed on or with equipment which handles radioactive material.

2. Any work performed on equipment which handled radioactive materials shall be authorized by and performed under a radiation work permit.

One area of the facility which has not been decontaminated is the interior of ducts and other ventilation devices. To prevent a migration of con-tamination to accessible areas, a minimum flow of air should be maintained in all ventilation ducts and enclosures unless these units can be completely sealed. The staff therefore recommends that the following condition be added to the license:

3. All openings of ventilation ducts and enclosures which are not completely sealed shall be maintained with a minimum airflow of 25 LFM. The licensee shall determine, on at least a semiannual basis, that this minimum airflow is maintained.

Although the reduced facilities activity should result in low and stable levels of airborne contam' nation, it is conceivable that air concentra-tions could be increased c;e to maintenance activities or to a failure of the ventilation systems. The staff therefore recommends that the following conoition be added to the license to require increased surveillance if an increase in contamination levels is observed:

4. If air sample results indicate an increase in airborne contamination to 10 percent or more of the appropriate MPC, survey frequencies shall be increased to the levels specified for Type II laboratories.

The staff concludes that GA's decontamination efforts and reduced activity levels justify a reduction in radiation safety surveys and investigations without compromising the health and safety of employees or the public.

The staff therefore recommends that, from a radiation safety standpoint, the amendment request be approved subject to the above conditions.

B. Nuclear Criticality Safety During this period of reduced activity, GA requested a reduction in the frequency of inspection of areas possessing more than 500 g of fissile material from quarterly to annually. At the present time, only areas pos-sessing s 500 g fissile materials are inspected annually. Since the Hot Cells will be shutdown and there will be very little, if any, production of TRIGA fuel, reducing the frequency of the inspections in these areas

TABLE 1 CHANGED REQUIREMENTS FOR SHUTDOWN FACILITIES Spec.

Vol. New

• Sec. Existing _Reauirement Reauirement Comment o r Cond i t i on Sub.lec t ites Internal inspections Health Physics 3.6.1 Quarterly Annual HTGR & Hot Cell Pa rt icu la te exposures essentially eliminated by nothing in storage Nuclear Safety

" Qua rte rly Annual Whe re at t is vault stored in stable fo rms, e.g. , oxide or encapsulated Personnel Monitorina Includes guards Eliminate gua rds buring shutdown of fuel fab U-235 bioassay 4.1.3 Su rveys Wipes 4.1.4.1 3 Daily Monthly in shutdown fuel fab areas in QC Weekly Lab & other Type i t workplaces

" Quarterly No Survey when hoods Enclosure cleaned to minimize poten-Ai r Veloci ty a re unused tial for a i rbo rne re lea se of ma te ria l Clove Box Air Samples Work place 4.1.4.2 Shift Monthly in shutdown fuel fab areas

" Weekly Weekly in QC Lab k other Type 11 work places Ana lysis interval

" Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1 week

" Weekey Monthly in . shutdown processing areas Stack .

Ma te r Samp l ina Collected weekly Sewage 4.1.4.3 Collected daily Samples evaluated Samples evaluated daily monthly plus sample and evaluate on days of discharge Alarm checks &

Ca l i b ra t ion functionally test monthly with "Ca l i b ra t i on 4.2.1 & Semi..inual recali- Eliminate CWAS from bration to NBS requirement of 4.2.1 builtin check or portable sources 4.2.1.4 Traceable sources or other system features Work Place Eliminate requi rement Ai r changes 4.1.2.1 Ai! work places 4 air changes /hr in areas when all mate-rial is stored and equip-ment is cleaned out.

HC1 Monitoring 6.6.1 Qua rte rly 0 No planned HC1 Furnace operations .

Envi ronmenta l Air Sampling 6.1 Weekly Monthly c_

c-Semiannual No change r-Suspruded Particulate 6.6.1 c.3 Ta p Wa te r Samp l i ng 4.1.4.3 Daily Evaluation Weekly Evaluation c3 4

Sewage Sampling 6.2 Daily Sampled daily Analyzed weekly OS on

• Requested change under all levels of operation Y

-s JUL 3 0 1985 4

of reduced activities to annually will not compromise nuclear criticality safety and is acceptable.

During the past few years, GA has been having problems with a number of criticality false alarms, particularly, in the SV-A Building. To correct this problem, GA has' replaced the criticality alarm system in the SV-A Building with coverage by a two-detector system. In addition, GA has requested authorization to modify the method of calibration of the criti-cality alarm monitoring system. GA desires to use the check sources built into the instruments to verify that the system responses and alarm levels are correct. Since the purpose of the test.is to confirm continuing instrument performance rather than for calibration, use of the built-in check sources is adequate. The licensee also added criteria for the

, recalibration of individual channels of the system. These include the requirement for calibration prior to reentry into ser'. ice following any i

required maintenance. The licensee specified the alarm trip level specifi-4 cations to comply with the criticality detection capabilities required by 10 CFR 70.24(a)(1) a'nd 70.24(a)(2). Each time the alarm system is tested, the trip levels are readjusted if the alarm point fails to activate within approximately 5; seconds more than once out of four trials. It is under-stood the test is failed if the alarm is not activated at all even one '

4 time out of the four trials. However, the licensee inadvertently stated the trip levels will be readjusted if the alarm point fails to activate within approximately 5 seconds on at least three of four trials.

It is recommended Condition 27 be added to clarify the test requirements.

Condition 27. Notwithstanding the statement in Section 4.2.1.4, Part II

/ of the license, the trip levels will be readjusted after each monthly test of the criticality alarm system if the alarm point fails to activate within approximately 5 seconds, more than once out of four trials.

When performing criticality alarm system repairs or modifications, the licensee specified the e shall be no fuel movement in the area while the alarms are inoperative unless: (1) such handling is needed to mitigate a health safety problem or provide required physical protection, and (2) unless, prior approval of operating management, the managers of Nuclear Safety and Health Physics, and the Chairman of the CRSC is received. Since no justification for this authorization was provided, the authorization cannot be granted. Therefore, it is recommended Condition 28 be added.

Condition 28. Notwithstanding the statements in Section 4.2.1.4, Part II of the license, no material handling shall be allowed in any area in which the required criticality alarm system is inoperative.

JUL 3 0 1985 5

The licensee has also requested exemotion from the 10 CFR 70.24 alarm audible requirements when planned operations will result in radiation levels above the 5-20 mr/hr monitoring system trip levels provided that:

1. The radiation level is continuously measured and is under observation during the interval of. bypass of the alarm's audio,

2. Any unrelated SNM handling in the area shall be suspended during the period of bypassed alarm audio,

3. The bypassing of the audio alarm is accomplished by or under direction of Health Physics, and

4. The system will be tested for complete operability at the time it is returned to normal service.

The transfer of radioactive material into the Hot Cell i_s an example of a condition where the above exemption may be required. Safety is not compromised under these conditions since the radiation level is continu-ously monitored during the time the alarm's audio is bypassed and unrelated fissile materials are not handled during this period. Therefore, the staff recommends the exemption be granted.

C. Environmental Effects The requested reduction in the surveillance of the environmental effects during the period of reduced activities was reviewed in connection with the issuance of Amendment No. 1, dated May 30, 1985, authorizing an exemp-tion from the criticality alarm requirements of 10 CFR 70.24(a) during the modifications of the GA criticality alarm system. It was found that dur-ing this period of reduced activity in the SV A Building, there should be a corresponding decrease in the effluents that may be released offsite and the individual and cumulative occupational radiation exposure in the potential for and consequences from radiological accidents. Therefore, in accordance with 10 CFR 51.22(:)(11), neither an Environmental Assessment nor an Environmental Impact Statement is warranted for this proposed action.

The staff recommends approval of the GA request for the reduced environ-mental monitoring requirements during this pariod of reduced operations.

General It is not clear from GA's application whether the reduced surveillance fre-quencies are requested only in these areas of reduced activity or for the entire facility. Therefore, it is recommended Condition 29 be added to limit the reduction in surveillance requirements only to the areas of reduced activity.

Condition 29 will include, as modifications, the recommendations described above

~

that are radiation safety and nuclear criticality safety related and apply only to the period of reduced activities in the areas as specified in the application dated April 23, 1985.

JUL 3 0 1985 Condition 29. The licensee may reduce the radiation safety, nuclear criticality safety, and environmental surveillance require-ments within the HTGR fuel fabrication and storage areas in the SV-A Building, TRIGA fuel manufacturing building, and in the GA Hot Cell, possessing fissile and/or other radioactive material, during a period of reduced activities as specified in the application dated April 23, 1985, subject to the following modifications:

a. The survey frequencies and contamination control measures specified in the license shall be used whenever work is performed on or with equipment which handles radioactive material.

b. Any work performed on eouipment which handled radio-active materials shall be authorized by and performed under a radiation work permit.

c. All openings of ventilation ducts and enclosures which are not completely sealed shall be maintained with a minimum airflow of 25 LFM. The licensee shall deter-mine, on at least a semiannual basit, that this minimum airflow is maintained.

d. If air sample results indicate an increase in airborne contamination to 10 percent or more of the appropriate MPC, survey frequencies shall be increased to the levels specified for Type II laboratories.

e. The Manager, Nuclear Safety, or his designee shall perform a critica'.ity inspection, at least annually, of all 3reas specified.

l The amendment application dated April 23, 1985, and its supplements dated May 20, June 3, and June 20, 1985, were discussed with Mr. J. L. Montgomery, Region V, Chief Nuclear Materials Safety and Safeguards Branch, July 12, 1985. He foresaw no safety or environmental problem with the requested authorization. .

Conclusion Issuance of an amendment authorizing modifications to the surveillance require-ments during the period of reduced activities and modifications to the critica-lity monitoring and alarm system is recommended subject to the following conditions:

Condition 27. Notwithstanding the statement in Section 4.2.1.4, Part II of the license, the trip levels will be readjusted after each monthly test of the criticality alarm system if the alarm point fails to activate within approximately 5 seconds, more than once out of four trials.

JUL 3 0 1985 7

Condition 28. Notwithstanding the statements in Section 4.2.1.4, Part II of the license, no material handling shall be allowed in any area in which the required criticality alarm system is inoperative.

Condition 29. The licensee may reduce the radiation safety, nuclear criti-cality safety, and environmental surveillance requirements within the HTGR fuel fabrication and storage areas in the SV-A Building,' TRIGA fuel manufacturing building, and in the GA Hot Cell, possessing fissile and/or other radioactive materirl, during a period of reduced activities as specified in the application dated April 23, 1985, subject to the following modifications:

a. The survey frequencies and contamination control measures specified in the license shall be used whenever work is performed on or with equipment which handles radioactive material.

b. Any work performed on equipment which handled radioactive materials shall be authorized by and performed under a radiation work permit.

c. All openings of ventilation ducts and enclosures which are not completely sealed shall be maintained with a minimum airflcw of 25 LFM. The licensee shall determine, on at least a semiannual basis, that this minimum airflow is maintained.

d. If air sample results indicate an increase in airborne contamination to 10 percent or more of the appropriate MPC, survey frequencies shall be increased to tha levels specified for Type II laboratories.

e. The Manager, Nuclear Safety, or his designee shall perform a criticality inspection, at least annually, of all areas specified. Origi::a1 Signed By:

L Xet lach Norman Ketzlach Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and origi::a1 signed By: Material Safety, NMSS

• * *1" Approved b

( W. T. Crow, Section Leader DISTRIBUTION OFC: FCUP :FCUP :FCUP, :FCUF :FCUP e' :

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