IR 05000057/2015001

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IR 05000057/2015001, Buffalo Materials Research Center, University at Buffalo, Buffalo, New York
ML16007A027
Person / Time
Site: University of Buffalo
Issue date: 01/06/2016
From: Racquel Powell
Division of Nuclear Materials Safety I
To: Vasbinder D
University of Buffalo
References
IR 2015001
Download: ML16007A027 (11)


Text

January 6, 2016

SUBJECT:

NRC INSPECTION REPORT NO. 05000057/2015001, BUFFALO MATERIALS RESEARCH CENTER, UNIVERSITY AT BUFFALO, BUFFALO, NEW YORK

Dear Mr. Vasbinder:

On January 27-29, February 3-5, August 17-19, and September 29, 2015, the U.S. Nuclear Regulatory Commission (NRC) conducted safety inspections at the Buffalo Materials Research Center (BMRC) in Buffalo, New York. Additional information in documents provided by BMRC was also examined as part of the inspection. The inspection was an examination of your licensed activities as they relate to radiation safety and to compliance with the Commission's regulations and BMRC license conditions. The inspection consisted of observations by the inspectors, interviews with BMRC and contractor personnel, a review of work plans and records, NRC confirmatory measurements, and collection of soil samples. The inspection also included confirmatory measurements and collection and analysis of soil samples by the NRCs contractor, the Oak Ridge Associated Universities (ORAU). Soil samples were sent to the ORAU laboratory for analysis. The ORAU confirmatory measurements and soil sample analytical results were documented in, Final ReportConfirmatory Survey Activities Associated With Phase 2 for The Buffalo Materials Research Center at The State University of New York, University at Buffalo, Buffalo, New York, ORAU, October 2015 (ADAMS Accession No.

ML16006A200). The October 2015 ORAU report was also reviewed as part of this inspection.

In addition, the inspectors participated in periodic telephone conference calls with staff from the BMRC and contractors, the NRCs Office of Nuclear Material Safety and Safeguards (NMSS),

and the New York State Department of Environmental Conservation. During these telephone calls, the status of decommissioning activities was discussed. The results of the inspection were discussed with you and other members of the BMRC staff via telephone on December 7, 2015, and are described in the enclosed report. No findings of safety significance were identified.

The enclosed inspection report will be provided to the NRCs Project Manager for BMRC in the Division of Decommissioning, Uranium Recovery, & Waste Programs, Office of Nuclear Material Safety and Safeguards for consideration on any request to terminate the BMRC license and release the site for unrestricted use. Please note that this report does not release the site for unrestricted use nor does it terminate the license.

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response, if provided, will be made available electronically for public inspection in the NRC Public Document Room or from ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Nuclear Reactors; Research and Test Reactors; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).

No reply to this letter is required. Please contact Steve Hammann at 610-337-5399 if you have any questions regarding this matter.

Sincerely,

/RA/ MRoberts f/

Raymond J. Powell, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety

cc:

State of New York In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response, if provided, will be made available electronically for public inspection in the NRC Public Document Room or from ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).

No reply to this letter is required. Please contact Steve Hammann at 610-337-5399 if you have any questions regarding this matter.

Sincerely,

/RA/ MRoberts f/

Raymond J. Powell, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety

cc:

State of New York

DISTRIBUTION:

B. Watson, DUWP, NMSS T. Smith, DUWP, NMSS J. Clements, DUWP, NMSS

DOCUMENT NAME: G:\\WordDocs\\Current\\Insp Letter\\LR-77.2015001.docx SUNSI Review Complete: MRoberts

ML16007A027 After declaring this document AAn Official Agency Record@ it will be released to the Public.

To receive a copy of this document, indicate in the box: AC@ = Copy w/o attach/encl AE@ = Copy w/ attach/encl AN@ = No copy

OFFICE

DNMS/RI

N

DNMS/RI

DNMS/RI

NAME MRoberts/mcr SHammann/sth RPowell/mcr via tele f/

DATE 1/6/16 1/6/16 1/6/16

OFFICIAL RECORD COPY

Document Name: C:\\RawFiles\\ML16007A027.docx

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

INSPECTION REPORT

Inspection No.

05000057/2015001

Docket No.

05000057

License No.

R-77

Licensee:

Buffalo Materials Research Center (BMRC)

Location:

220 Winspear Avenue

Buffalo, NY 14215

Inspection Dates:

January 28 - 29, 2015

February 3-5, 2015

August 17-19, 2015

September 29, 2015

Inspectors:

Stephen Hammann

Senior Health Physicist

Decommissioning and Technical Support Branch

Division of Nuclear Materials Safety

Mark Roberts

Senior Health Physicist

Decommissioning and Technical Support Branch

Division of Nuclear Materials Safety

Approved By:

Raymond J. Powell, Chief

Decommissioning and Technical Support Branch

Division of Nuclear Materials Safety

ii Inspection Report No. 05000057/2015001 C:\\RawFiles\\ML16007A027.docx

EXECUTIVE SUMMARY

Buffalo Materials Research Center

NRC Inspection Report No. 05000057/2015001

Announced inspections were conducted on January 27-28, February 3-5, August 17-19, and September 29, 2015, at the BMRC, in Buffalo, New York. Additional information in documents provided by BMRC was also examined as part of the inspection. The inspections reviewed BMRCs decommissioning activities, activities associated with the final status survey of the BMRC building excavation, and a review of waste disposal activities. The inspections verified that radioactive waste associated with the decommissioning project had been shipped offsite and that the decommissioning and final status survey activities were being conducted safely and in accordance with regulatory requirements, licensee commitments, and the NRC-approved Decommissioning Plan (DP). The inspections consisted of observations by the inspectors; interviews with BMRC and contractor personnel; a review of work plans, work instructions, and decommissioning records; and inspector confirmatory measurements. The inspection also included confirmatory measurements and collection and analysis of soil samples by the NRCs contractor, the Oak Ridge Associated Universities (ORAU). Soil samples were sent to the ORAU laboratory for analysis. The ORAU confirmatory measurements and soil sample analytical results were documented in, Final ReportConfirmatory Survey Activities Associated With Phase 2 for The Buffalo Materials Research Center at The State University of New York,

University at Buffalo, Buffalo, New York, ORAU, October 2015 (ADAMS Accession No.

ML16006A200). The October 2015 ORAU report was also reviewed as part of this inspection.

The inspectors also participated in periodic telephone conference calls with staff from the BMRC and their contractors, the NRCs Office of Nuclear Material Safety and Safeguards (NMSS), and the New York State Department of Environmental Conservation (NYSDEC) to discuss decommissioning and final status surveys activities. The NRC's program for overseeing the safe decommissioning of a research and test reactor (RTR) is described in Inspection Manual Chapter (IMC) 2545, "Research and Test Reactor Inspection Program.

Based on the results of this inspection, no findings of safety significance were identified.

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REPORT DETAILS

1. Summary of Facility Status

The BMRC RTR is owned by the State University of New York at Buffalo and is located on the south campus of the University. The RTR was placed into operation in 1961 and was shut down in 1994. In 1997, the license was amended to possession only. In 1998, the unused fuel was shipped to North Carolina State University, and in 2005, the spent fuel was shipped to the Idaho National Engineering and Environmental Laboratory.

On November 5, 2012, the NRC approved the DP for the BMRC RTR (ADAMS Accession Nos. ML12286A352 and ML12290A694). In December 2012, BMRC began decommissioning activities. BMRC has completed the dismantlement of the reactor and associated components, demolition of the reactor and administration building, and excavation of below grade structures. BMRC has completed the final status survey, has shipped demolition waste from the site, and completed backfill of the excavation.

2. Research and Test Reactor Decommissioning

a. Inspection Scope

(Inspection Procedures (IP) 69013 and 83890)

Announced inspections were conducted on January 27-28, February 3-5, August 17-19, and September 29, 2015, at the BMRC, in Buffalo, New York. The inspectors reviewed BMRCs activities associated with the test reactor decommissioning, final status survey activities associated with the building excavation, staging of excavated soil for expected re-use, and shipment of demolition waste. The inspection consisted of observations by the inspectors, interviews with BMRC and contractor personnel, confirmatory measurements, collection and analysis of soil samples, and a review of work plans and work instructions. The inspectors also participated in periodic telephone conference calls with staff from the BMRC and their contractors, NMSS, and NYSDEC to discuss decommissioning and final status surveys activities. The NRC's program for overseeing the safe decommissioning of an RTR is described in IMC 2545.

The NRC contracted with ORAU to conduct document reviews and perform confirmatory radiological survey activities at the BMRC decommissioning project. The objectives of the document reviews and confirmatory survey activities were to generate independent radiological data and field observations for use by the NRC in evaluating the accuracy and adequacy of the BMRC s procedures and Final Status Survey (FSS) data. ORAU performed confirmatory radiological surveys and sampling during the January 26-29, February 3-6, and August 17-21, 2015, site visits. Areas surveyed included the vertical and horizontal surfaces of the excavation and locations where excavated soil was stockpiled for intended use as backfill (subject to confirmatory analysis) of the excavation. ORAU provided their survey results and field observations in a report dated October 30, 2015 (ADAMS Accession No. ML16006A200). The October 2015 ORAU report was also reviewed as part of this inspection.

During the September 29, 2015, inspection visit, NRC inspectors conducted confirmatory radiological measurements in the areas where radioactive waste had been staged for Inspection Report No. 05000057/2015001 C:\\RawFiles\\ML16007A027.docx offsite shipment for disposal. The inspectors also made measurements of the backfilled excavation and soil stockpile areas and reviewed the waste disposal records for the completed radioactive waste shipments.

b. Observations and Findings

Inspectors noted that the radiation protection coverage during building demolition and final status survey activities was appropriate for the activities conducted. The inspections verified that decontamination and demolition activities were being conducted safely and in accordance with regulatory requirements, licensee commitments, and the NRC-approved DP.

The inspectors noted that the soil that was removed from Class 1, 2, and 3 areas

[impacted area classification in accordance with NUREG-1575, Multi-Agency radiation Survey and Site Investigation Manual (MARSSIM)] was stored adjacent to the building in separate piles. Radiation measurements by the inspectors at the perimeter of the soil piles were indistinguishable from the background exposure rates.

ORAUs confirmatory survey activities consisted of surface gamma scans, static gamma count measurements, static beta count measurements, alpha and beta analysis of smear samples from exposed bedrock surfaces, and soil sample collection and analysis.

Soil samples were obtained from the excavation area and from soil stockpiles. The detectors used for the surface gamma scans were coupled to global positioning system equipment that allowed for simultaneous gamma count rate and spatial data capture.

Some of the measurements conducted by the ORAU team were side-by-side measurements while BMRC staff and contractors were performing FSS measurements.

The inspectors observed the ORAU personnel prepare equipment to be used during confirmatory activities and verified that the survey meters used were appropriately calibrated for their intended use. The inspectors also noted that ORAU staff performed pre-and post-measurement checks on equipment to verify acceptable operability. The inspectors also observed the soil sample collection process and the manner in which samples were handled and controlled prior to packaging and shipment. The soil sample chain of custody was maintained by ORAU staff. Soil samples were transferred to the ORAU Radiological and Environmental Laboratory in Oak Ridge, Tennessee for radiological analysis. Sample analyses were performed in accordance with the ORAU Laboratory Procedures Manual. The requested analyses included quantification of strontium-90 (Sr-90) and gamma spectrometry. As a result of inclement weather during portions of the inspection visits and the presence of bedrock at the base of the excavation, the inspectors made small modifications to the project survey plan for safety concerns and sample availability.

Based on the results documented in the October 2015 ORAU report, the majority of the ORAU surface gamma scans were not distinguishable from background. Elevated count rates distinguishable from background were measured in the corner of BMRC survey units 3 and 5. The ORAU survey team identified this location to the inspectors, who in turn, identified the location of the elevated measurements to BMRC representatives.

The BMRC representatives noted the location and indicated that the area would be Inspection Report No. 05000057/2015001 C:\\RawFiles\\ML16007A027.docx further investigated. In a subsequent telephone conversation, BMRC representatives indicated that they removed additional soil from the area for disposal as radioactive waste and confirmed that their subsequent gamma scans of the area were not distinguishable from background. The results of the soil sample analyses for Sr-90 and by gamma spectrometry did not identify any detectable concentrations of any of the radionuclides of concern in excess of the Derived Concentration Guideline Levels (DCGLs) in the DP.

The inspectors toured the locations where all radioactive waste containers (intermodal containers and fabric super sacks) had been stored prior to shipment for disposal at an authorized facility. The inspectors observed that there were no waste containers remaining in the areas. All confirmatory measurements in these areas using a Ludlum Model 19 Micro R Meter were indistinguishable from the background exposure rate. The inspectors reviewed the waste disposal records for the completed radioactive waste shipments and noted that the completed records and manifests met the NRC and Department of Transportation regulations. The inspectors also reviewed signed acknowledgement copies of manifests returned to the shipper, confirming that the wastes had been received in good condition at the trans-shipping facility (Alaron Nuclear Services in Wampum, Pennsylvania) and no discrepancies reported. BMRC representatives indicated that the wastes had been subsequently transported via train from the Alaron facility to an authorized disposal facility in Utah.

The inspectors and ORAU representatives performed walkover gamma measurements in the areas where excavated Class 1, 2, and 3 soil had been staged for potential re-use as backfill for the excavation. BMRC and contractor representatives indicated that representative sampling from all of the staged soil piles confirmed that the residual radionuclide concentrations met the release criteria (DCGLs) in the DP and the soil was subsequently used for backfill of the excavation. As documented in the ORAU report, analysis of split samples from the Class 1 and Class 2 piles confirmed that residual radionuclide concentrations were less than DCGL release criteria in the DP. Gamma walkover measurements by the inspectors of the backfilled excavation were also indistinguishable from the background exposure rate.

In addition to the confirmatory measurements, sampling, and analysis conducted onsite by the ORAU team, ORAU staff was also requested to conduct document reviews of the DP, FSS plan, FSS survey packages, and FSS field documentation. ORAU documented their observations in the October 2015 Report, and noted any data quality issues with the inspectors. The NRC inspectors discussed these items with the BMRC staff. The inspectors requested that BMRC representatives include information in their FSS report to document resolution of the items identified for follow-up in the October 2015 ORAU report.

c. Conclusions

Based on the results of this inspection, no findings of safety significance were identified.

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3. Exit Meeting

The inspection results were discussed with David Vasbinder, BMRC Director, and other members of the BMRC staff on December 7, 2015.

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SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

Mark Adams, Safety Engineer

Nancy Hutchinson, Health Physicist

Jeff Slawson, RSO

David Vasbinder, Associate Director, Environment, Health & Safety Services

Rob Weller, Project Manager

Enercon Services (Licensees Contractor)

Chuck Beatty, Site Lead

Kevin Boyle, HP Technician

Frank Brown, Site Lead

Dennis Criswell, RPM

Gerry Williams, Project Manager

Oak Ridge Associated Universities

Erika Bailey, Health Physicist and Survey Projects Manager

Daniel Edds, HP Technician

Evan Harpenau, Health Physicist

INSPECTION PROCEDURES USED

Inspection Procedure 69013, Research and Test Reactor Decommissioning

Inspection Procedure 83890, Closeout Inspection and Survey

ITEMS OPEN, CLOSED, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED

BMRC Raw Data Counting Data Sheet, 2014 - 1 through 8, and 2015 - 1 through 28

BMRC Waste Tank Analysis Logs 2014 through 2015-28

BMRC Water Discharge Log, 12/18/2014 to 1/19/2015

ENERCON Services, Inc., Radiation Work Permit BMRC-020

ENERCON Map of site coded with MARSSIM Classes

ENERCON Services, Inc., Survey Package, SU1, SU2, SU3, SU4

ENERCON Services, Inc., Survey Package, SU5 and SU6 Soil Areas

ENERCON Services, Inc., BMRC Radiological Surveys, 126,127, 128, 129, and 130

for release of major excavation and soil moving equipment

ENERCON Services, Inc., Revised Work Instruction, Survey and Sampling of Class 1

Excavated Soil Material

ENERCON Services, Inc., Revised Work Instruction, Survey and Sampling of Class 2 and

Class 3 Excavated Soil Material

ENERCON Services, Inc., Work Instruction - Survey of Trucks Loaded with Demolition Debris

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Memo, University at Buffalo, 2014 Year to Date Summary of BMRC Environmental Dosimeter

Results and 2015 Year to Date Summary of BMRC Environmental Dosimeter Results

Memo, University at Buffalo, Approval of Revision to Enercon Work Instruction, dated

May 6, 2015

Memo, University at Buffalo, BMRC Personnel Dose Review, dated February 2, 2015

Memo, University at Buffalo, Review and Change to BMRC Decommissioning Plan, dated

January 14, 2015

Summary of Radiation Exposures at BMRC, 1/1/2014 - 12/31/2014

University at Buffalo, Health Physics Procedure #2, Water Analysis, Revision date 12/17/14

University at Buffalo, Sanitary Sewer Discharge of Water from the BMRC Decommissioning

Site, Revision date 12/18/14

New York State Department of Environmental Conservation - Waste Transportation Permit

Radioactive waste shipping documents - Completed Uniform Low-Level Radioactive Manifest

(NRC Forms 540 and 541), Exclusive Use Vehicle Instructions to Carrier, and DAW Distribution

Classification Worksheet for 21 waste shipments

Final ReportConfirmatory Survey Activities Associated With Phase 2 for The Buffalo Materials

Research Center at The State University of New York, University at Buffalo, Buffalo, New York,

ORAU, October 2015 [ADAMS Accession No. ML15316A466]

LIST OF ACRONYMS USED

BMRC

Buffalo Materials Research Center

DCGL

Derived Concentration Guideline Level

DP

Decommissioning Plan

FSS

Final Status Survey

IMC

Inspection Manual Chapter

MARSSIM

Multi Agency Radiation Survey and Site Investigation Manual

NMSS

Office of Nuclear Material Safety and Safeguards

NRC

Nuclear Regulatory Commission

NYSDEC

New York State Department of Environmental Conservation

ORAU

Oak Ridge Associated Universities

RTR

Research and Test Reactor

Sr-90

Strontium 90