ML20206J283

Safety Evaluation Supporting Amend 40 to License R-67

ML20206J283
Person / Time
Site:	General Atomics
Issue date:	11/18/1988
From:	Office of Nuclear Reactor Regulation
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ML20206J274	List: ML20206J269 ML20206J279 ML20206J283 ML20206J383
References
NUDOCS 8811280127
Download: ML20206J283 (10)

Text

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!na negg'o, UNITED STATES

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! NUCLEAR REGULATORY COMMISSION

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• WASHINGTON, D. C. 20644

$ i

%,o.***f SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION t

SUPPORTING AMENOMENT NO. 40 T0 FACILITY LICENSE NO. R-67 GA TECHNOLOGIES. INC.

DOCKET NO. 50-163

1.0 INTRODUCTION

TheLicensee(GATechnologies)hasdesignedseveralversionsofthe TRIGA Reactor for research purposes since the mid-1950s and has built and operated three such reactors at its facilities in LaJolla, California.

One of these, a Mark III, was operated primarily in connection with the development of uranium-fueled in-core-irradiated direct conversion themionic devices. That reactor was licensed by the Atomic Energy Commission, predecessor to the Nuclear Regulatory Comission (NRC),

under Operating License No. R-100, Docket No. 50-227 in 1971. In connection with the application for license, the applicant analyzed the

! potential radiation doses to a maximally exposed individual at the Licensee's boundary fence in the event of failure of one of these in-core devices containing the maximum potential fission product 3.

inventory. That analysis and its underlying assumptions were found to be acceptable by the staff of the licensing agency.

Subsequently, the Mark III reactor was decommissioned, and a direct-conversion program established in a TRIGA Mark F (License No. R-67) in the same GA facilities. As in the case of the Mark !!! TRIGA, the failure of the containment of a thermionic device is also the maximum credible accident for the current TRIGA Mark F operation. Currently, GA management is considering moving the boundary fence from the previous location approximately 350 m from the reactor site to a location no less than 100 m from the site. The Licensee, by letter dated December 22, 1987, has applied for*a license amendment that would provide for equipment and procedures that would provide assurance that potential doses to the public at and beyond the new fence would not exceed those previously reviewed and found acceptable by the staff.

2.0 EVALUATION By letter dated December 22, 1987, the Licensee requested an amendment to Its Mark F TRIGA reactor operating license that would make the following type of changes to the Technical Specifications:

(1) Include a new requirement providing for a limit on the resistance to air leakage f rom the reactor building, es11:so127 pM gg33,g p ADOCK o.XK)O l 63 FDC

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. 2 (2) Require verification that the limit is not exceeded.

(3) Require the installation of an activated charcoal filter system with forced air flow in the reactor room.

(4) Require periodic surveillance tests of the operability of the fan system and the activated charcoal.

The site boundary shall be 100 meters. If irradiated thermiele devices are present in the reactor room, an activated charcoal filter system is required to be operable. This amendment will become effective when the licensee installs and declares operable the charcoal filter system.

General Atomics will either own the land within 100 meters of the TRIGA facility or will enter into easement agreements that will give GA the exclusive right to control all access to the property and to exclude all personsfromtheproperty(Attachment 1).

To insure proper operation of the systems, surveillance requirements have been added to the Technical Specifications. The operability of the system is tested weekly (interval not to exceed ten days). This will ensure that the system will function if required. Samples of the activated charcoal will be tested at semiannual intervals (interval not '

to exceed 71 months) to confirm that moisture has not damaged the charcoal filter. The air flow rate will be verified annually (interval not to exceed 15 months) to ensure minimum airflow thru the system. In addition to these surveillances to test the filter system the reactor roomto not resistance exceed to leaka 15 months)ge of airhaswillbeen be opened.

seasured annually (inter or if the roof hatch The Licensee submitted a revised analyses of the same maximum hypothetical accident-failure of the gas cufinement system of a maximally irradiated direct conversion device and the release of the inventory of airborne fission products. These devices have been modified to some extent over the years since 1971, including decreasing the fuel loading and the associated inventory of releasable fission products. However, because the accident scenario postulates a device any design changes and failure and corputes potential doses therefrom, therefore any changes in the probability of fai lure are not relevant for this evaluation. Thus there are not unreviewed safety considerations associated with this license amendment other than the incorporation of the engineered safety system, the charcoal filter unit, and its impact on offsite radiation exposures.

The Licensee assumed an appropriate inventory of fission products in the direct conversion devices currently authorized by the Facility License No. R-67. Although modification of the device design has reduced the inventory of releasable fission products, the assumed fraction of fission products released into the reactor room air is as large as that use in previous analysis. The Licensee computed the leakage rate from the reactor room, computed the decrease in concentration of radioactivity as the cloud was transported as far as the assured distance to the new fence, and computed the potential whole-body imersion doses and doses to

i the thyroid by inhalation and retention of iodines. The adequate operation of the charcoal filter system was explicitly included in the assumptiens and computations of the scenarios. The unit to be used is a Barnebey-Cheney Model FD-11 filter with a bed of type 787 activated ,

carbonorequivalent(Attachment 2). The unit will be mounted approximately eight feet above the reactor room floor with the ductwork arranged to promote circulation of room air. The system has a HEPA filter to contain activated charcoal fines and air tight inlet and outlet seals on the charcoal filter to limit exposure to humidity in the air when nuc in use.

The staff has reviewed the design of tne system and finds it acceptable for the intended purpose. The staff has reviewed the methods and '

! assumptions of the analyses and finds them acceptable. The Licensee I

compared the maximum potential doses at 100 m from the reactor facility with both the values computed at 350 m previously without the charcoal system, and the doses that form the bases for 10 CFR 20, Appendix B, if integrated over a year. For both comparisons, the new doses are lower than previously calculated and still well within 10 CFR Part 20 guidelines and limits. The Licensee also showed that its computed maximum doses at 100 m were well below EPA guidelines for initiating protective accion for the public.

3.0 ENVIRON?tENTAL CONSIDERATION l This amendment involves changes in the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 l

and changes in inspection and surveillance requirements. The staff has determined that the amendment involves no significant increase in the '

amounts, and no significant change in the types, of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, this amendment 3

1 meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment. ,

4.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, l

that

(1) because the amendment does not involve a significant increase  !

in the probability or consequences of accidents previously evaluated, or  ;

create the possibility of a new or different kind of accident from any ,

I accident previously evaluated, and does not involve a significant reduction  ;

in a margin of safety, the amendment does not involve a significant hazards [

consideration, (2) there is reasonsble assurance that the health and safety j

, of the public will not be endangered by the proposed activities, and j (3) such activities will be conducted in compliance with the Commission's [

regulations and the issuance of this amendment will not be inimical to the corron defense and security or the health and safety of the public.

Principal Contributors: Robert Carter Alexander Adams, Jr.

Dated: November 18, 1988 ,

ATTACHMENT 1 When Recorded Return Tot James R. Edwards General Atomics 10955 John Jay Hopkins Dr.

San Diego, CA 92121-1194 Space above this line for Recorder's use EASEMENT AGREEMENT This Easement Agreement is entered into between Chevron Land and Development Company, a Delaware Corporation

("CLDC") the owner of that certain proper y ("CLDC's Proper-ty") described in Exhibit "A" hereto and General Atomics, a California Corporation ("GA") the owner and operator of a TRIGA Reactor, which is licensed by the U.S. NucJear Regula-tory Commission ("NRC") and located adjacent to CLDC's Prop-erty. The parties agree as follows:

1. For valuable consideration CLDC hereby grants to GA an easement over and to CLDC's Property.

2. The easem'ent granted herein gives GA the exclu- (

sive right to control all access to CLDC's Property and to exclude all persons from CLDC's Property. GA shall have the right to take any and all actions it or the NRC or any other regulatory agency deemn necessary to exclude all persons from CLDC's Property.

3. GA agrees to indemnify, protect, defend and hold CLDC, its affiliates and their directors, officers, employ-ees, agents, contractors and subcontractors, and all other parties having an interest in CLDC's Property (hereinaf ter the "Indemnitees"), harmless from and against any and all claims, demands, actions, causes of action, losses or lia-bilities arising out of or in any way connected with the easement granted herein or GA's exercise of its rights thereunder. Such indemnity shall include, without limita-tion, the obligation to indemnify, protect, defend and hold the Indema.iceea harmless from and against any and all claims, demands, actions, causes of action, losses or lia-bilities related to (a) injury to or death of persons, in-ciuding injury to or death of any personnel of CLDC or GA or of any other persons, (b) damage to or destruction of real or personal property, including damage to or destruction of CLDC's Property, (c) civil penalty (but not criminal penal-ty), and (d) the costs of correction, repair or decontamina-tion of CLDC's Property where such correction, repair or decontamination is required as a result of operation of the aforemontioned TRIGA reactor, and regardless of whether such

i

. correction, repair or decontamination obligation arises un-l- der federal, state or local statutes, ordinances, rules or

j. regulations.

4. In addition to the obligations of GA in Para-graph 3 above, GA shall obtain 401 maintain the following i

insurance coverage at all times while the easement granted herein remains in effect:

(a) comprehensivo geaeral liability insurance l with a limit of liability of not less than  !

Two Million Dollars ($2,000,000) per occur-

! rence and aggregate covering liability re-1 lating to the condition or use of CLDc's Property and any injury of damage occurring

I therein, thereon or thereabout; i t

j (b) such insurance as is required to be carried by GA (or any affiliate of GA which owns or operates the aforementioned TRIGA reactor) ,

pursuant to federal statutes (including I

.._.10 CFR S 140, "the Price-Anderson legisla. i

, tio, ) and regulations thereunder providing q- coverage in the amount so required; and 4

(c) nuclear liability insurance providing pro- [

j taction substantially comparable (in cover- l l

age and amount) to that rovided by the j

$174,000,000 policy carr ed by GA on April 1, 1988. 'i 4

l The insurance required under this Paragraph 4 l l shall be in form and content, and with companies, reasonably j j acceptable to CLDC. CLDC shall be named as an additional .

1 insured in such policy or policies and such policies, or  !

I certificates thereof, endorsed "Premium Paid," shall be de-  !

livered to CLDC prior to the exercise by GA of any rights l granted hereunder, and prior to their expiration thereafter so long as the easement granted herein remains in effect. ,

l GA shall obtain the written agreement of the insurers to no-j tify CLDc in writing at least thirty (30) days prior to any cancellation or material change of such policy or policies.

• If GA fails to purchase and maintain any of the insurance I

required to be maintained hereunder, CLDc, at its option, j may purchase such insurance and invoice GA for the cost I thereof, and GA shall pay such invoice within fifteen (15) i days from the receipt thereof.

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5. GA shall not alter, damage or commit any kind of i 1 waste upon CLDc's Property and shall not interfere ln any j manner with the operations or activities of CLDc outside the ,

4 easement area. GA shall not cause any worker's or material- 1 i men's liens to be placed upon CLDc's Property and agree to  ;

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. indemnify, defend and hold CLDC harmless from and against any such liens.

6. No fee interest of any kind is intended to be or is hereby given to GA by reason of the easement granted herein and GA shall never assert any claim or title to CLDC's Property inconsistent with the terms hereof.

7. The easement granted herein shall terminate when

, GA (or a more than 50% GA-owned affiliate of GA) ceases to own and operate the TRIGA reactor referred to above, or when such easement is no longer required by the NRC for GA's then current operations, or when such TRIGA reactor, together with the land and buildings in the immediate vicinity of and which serve such reactor, have been decommissioned, whicLc7-er first occurs. Upon the occurrence of any such event, GA shall cooperate with CLDC in executing and filing of record any document which is reasonably requested by CLDC to evi-dence the termination of the easement granted herein.

IN WITNESS WHEREOF, the parties have executed this instrument on this day of August, 1988.

CHEVRON LAND AND GENERAL ATOMICS DEVELOPMENT COMPANY

(

By By Its Its STATE OF CALIFORNIA )

) SS.

COUNTY OF SAN DIEGO )

On August 1988 befort, me, the undersigned, a Notary Pub-lie in and To,r said Stata, personally appeared personally known to me or proved to me on the i

besis of satisfactory evidence to be the person who executed the within instrument as or on behalf of the corporation therein named, and acknowledged to me that the corporation executed it.

WITNESS my hand and official seal.

I Notary's Signature i

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STATE OF CALIFORNIA ) .

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) SS.  !

! COUNTY OF )

1 on August 1988 before me, the undersigned, a Notary Pub- l J lic in and'7o,r said state, personally appeared I

personally known to me or proved to me.on the l basis of satisfactory evidence to be the person who executed  !

the within instrument as or on behalf I j of the corporation therein named, and acknowledged to me  !

i that the corporation executed it. l 1  !

j WITNESS my hand and official seal. ,

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! Rest'ticted easement area within that portion of Parcel 1 of I IL Parcel Map NO. 12921, in the City of sn3 Diego, County of i 1 San Diegc, State of California, filed in the Office of the  !

< County Recorder of San Diego County, September 23, ?,943 as i j Fila No. 83-341899 of Official Records, described as fol-  ;

lows:  :

i j Beginning at Point "A" designated in Parcel A gbove; thence ,

along the boundaries of said Parcel A South 82 51'42' West 23g.39 feet, and South 28"04'25" West 596.g5 feet and North 78 47'20" West 76.94 feet; tgenceNorth 02 16'01' East 1 217.73 fget; thence North 19 00'00" East 170.00 fget; thence ,

j North 38 00'00" East 190.00 feet;#thence North 74 00'00" East 290.48 feet; thence South 61 00'00* East 114.92 feet to i a the Point of Beginning. ,

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Specifications '

Material - 304 St. Stl.

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Pressure Drop - 1.50 in.W.C.

CCrbon Col.tset - 2.27 cu. ft.

Shippirig Weight - 240 lbs. ,

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