ML20236Y455

Responds to 980730 Request for Info,Providing Justification for Reducing Training Frequency

ML20236Y455
Person / Time
Site:	General Atomics
Issue date:	08/07/1998
From:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Alexander Adams NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
38-67-2953, TAC-M99842, TAC-M99843, NUDOCS 9808120208
Download: ML20236Y455 (2)

Text

"

4h C:NERAL ATDM9CS August 7,1998 38/67-2953 Document Control Desk ATTN: Alexander Adams, Jr., Senior Project Manager Non-Power Reactors, Decommissioning and Environmental Project Directorate Division of Advanced Reactors & Special Projects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Facility Licenses R-38 and R-67; Dockets 50-89 and 50-163 Response to Request for Information; TAC NOS. M99842 AND M99843

Reference:

Adams, Alexander, Jr., Letter to Dr. Keith E. Asmussen dated July 30,1998

Dear Mr. Adams:

The purpose of this letter is to respond to your recent request for information (Ref.). The requested information, providingjustification for reducing the training frequency, is provided in the attachment to this letter.

If you have any questions regarding this submittal, please do not hesitate to contact me at (619) 455-2823.

Very truly yours, Keith E. Asmussen, PhD Director, Licensing, Safety and Nuclear Compliance I!

l 1

,\ '

,e 'l !

' L

Attachment:

Response to Request for Information /

l l 980812O208 980807  !

l PDR ADOCK 05000089 )

P PDR

[

3550 GE NERAL ATOMICS COURT, SAN DIEGO, CA 921211194 PO box 85608. SAN DIE GO. CA 92186 5608 1619) 455 3000

l

• u i

Attachment to G A Letter No. 38/67-2953 Dated August 7,1998 Response to Request for AdditionalInformation NRC TAC NOS. M99842 AND M99843 General Atomics' (GA's) revised Radiological Continency Plan dated October 1997 was i submitted to NRC by letter dated October 10,1997 pursuant to 10 CFR 50.54(q). The revised I plan included a change in the frequency of required radiation safety refresher training for emergency response team members from annual to once every 2 years. The justification and rationale for this change involves a number of considerations. The justification for the change is the very significant reduction in the risk of a radiation safety related emergency at GA's TRIGA*

Reactors Facility as compared to the circumstances that existed when the annual training requirement was first imposed. The risk of a radiation safety incident is significantly reduced because of the notable marked reductions in the scope and number of activities conducted at the facility. These reductions are due to the fact that GA permanently ceased operation ofits research reactors and has had their licenses amended to withdraw authorization to operate. Thus, now and in the future, there will be no operation of the reactors and no conducting of experiments associated with the possession of the reactors. The potential for an airborne release (the type of event that might have triggered implementation of the emergency plan) has been essentially eliminated by the permanent shutting down and de-fueling of the reactors.

Consequently, the risk of a radiation safety emergency has been dramatically reduced and the reduced frequency of radiation safety training is warranted and justified.

I While the reduced risk of a radiation safety emergency justifies the subject change in frequency of refresher training, the change also makes the Radiological Contingency Plan requirement consistent with the nadiation safety refresher training frequency requirements of GA's State of California radioactive materials license and GA's NRC special nuclear material license. It also makes it consistent with the Red Cross guidelines for CPR and first aid training. This consistency of requirements is advantageous to the efficient use of GA's resources in scheduling, conducting, tracking and documenting appropriate training. It is also noted that the change in frequency of training is consistent with standards for training established by other emergency response and planning organizations (e.g., the Red Cross). l 1