IR 05000134/2012001
| ML13161A084 | |
| Person / Time | |
|---|---|
| Site: | 05000134 |
| Issue date: | 06/07/2013 |
| From: | Marc Ferdas Decommissioning Branch I |
| To: | Curley M Worcester Polytechnic Institute |
| References | |
| IR-12-001 | |
| Download: ML13161A084 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION une 7, 2013
SUBJECT:
NRC INSPECTION REPORT NO. 05000134/2012001, WORCESTER POLYTECHNIC INSTITUTE, WORCESTER, MASSACHUSETTS SITE
Dear Mr. Curley:
On July 11-12, 2012 and May 2-3, 2013, the U.S. Nuclear Regulatory Commission (NRC)
conducted a safety inspection at the Worcester Polytechnic Institute Leslie C. Wilbur Nuclear Reactor Facility in Worcester, Massachusetts. The inspection was an examination of your licensed activities as they relate to radiation safety and to compliance with the Commission's regulations and the license conditions. The inspection consisted of observations by the inspectors, interviews with personnel, and a review of procedures and records. Additional information provided in your correspondence dated May 8, 2013 was also examined as part of the inspection. The findings of the inspection were discussed with you at the conclusion of the inspection, on May 30, 2013, and are described in the enclosed inspection report. No health and safety concerns were identified.
Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Nuclear Materials; Med, Ind, & Academic Uses; 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).
The NRCs Safety Culture Policy Statement became effective in June 2011. While a policy statement and not a regulation, it sets forth the agencys expectations for individuals and organizations to establish and maintain a positive safety culture. You can access the policy statement and supporting material that may benefit your organization on NRCs safety culture Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/safety-culture.html. We strongly encourage you to review this material and adapt it to your particular needs in order to develop and maintain a positive safety culture as you engage in NRC-regulated activities. No reply to this letter is required. Please contact Mark C. Roberts at (610) 337-5094 if you have any questions regarding this matter.
Sincerely, Original signed by Marc S. Ferdas Marc S. Ferdas, Chief Decommissioning Branch Division of Nuclear Materials Safety Enclosure:
Inspection Report No. 05000134/2012001 cc: Commonwealth of Massachusetts
EXECUTIVE SUMMARY
Worcester Polytechnic Institute (WPI)
NRC Inspection Report No. 05000134/2012001 Announced inspections were conducted on July 11-12, 2012 and May 2-3, 2013, at WPI, in Worcester, Massachusetts. The inspectors reviewed WPIs decommissioning activities associated with their research and test reactor (RTR). The inspection consisted of observations by the inspectors, interviews with WPI and contractor personnel, and a review of procedures and records. The waste manifest information provided to the NRC on May 8, 2013, was also reviewed as part of this inspection. The NRC's program for overseeing the safe decommissioning of a 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 Leslie C. Wilbur Nuclear Reactor Facility (LCWNRF) was constructed by the General Electric Company as a standard 1-kW (thermal) open-pool training reactor, and first achieved criticality on December 18, 1959. The reactor license was upgraded to 10-kW (thermal) non-power in 1967, and the LCWNRF reactor first achieved 10-kW operation on January 31, 1968. The LCWNRF reactor license was renewed in 1982, which extended the operating license for 20 years. In 1989, the reactor was converted from High Enriched Uranium (HEU) fuel to Low-Enriched Uranium (LEU) fuel. The LCWNRF is located in the Washburn Shops and Stoddard Laboratories Building, a centrally located academic facility on the WPI campus.
The WPI reactor was shutdown at the end of June 2007. On March 29, 2011, the Nuclear Regulatory Commission approved the decommissioning plan (DP)
(ML103120034) for the WPI RTR. TLG Services, Inc., a decommissioning consultant/contractor, is providing field management and industrial and radiological safety services for the decommissioning activities. Based on the DP, the majority of the remediation will focus on components within the reactor pool, the biological shield surrounding the reactor, and connected support systems (i.e., exhaust ventilation system, pool water treatment system and floor drains adjacent to the reactor pool).
Based on discussions with the decommissioning contractor, no contamination was identified in other areas of the facility. Additionally, no contamination of soil or ground water was identified. Therefore, WPI staff and their contractor determined that decommissioning of the LCWNRF could be accomplished without dismantlement of the building.
The fuel was removed in July 2011, the pool drained in September 2011, and the reactor systems de-energized in November 2011. WPI representatives scheduled the principal decommissioning activities to occur during times that the university was not in session in order to reduce the impact on the academic schedule. Dismantling commenced in July 2012, and was completed in October 2012. Radioactive waste was shipped to a licensed facility in May 2013. The Final Status Survey Plan was submitted to the NRC on January 31, 2013.
2. Research and Test Reactor Decommissioning
a. Inspection Scope
Announced inspections were conducted on July 11-12, 2012 and May 2-3, 2013, at the LCWNRF, in Worcester, Massachusetts. The inspectors also performed an in-office review of the acknowledgment copy of the radioactive waste shipment receipt provided to the NRC on May 8, 2013. The inspections reviewed WPIs decommissioning activities associated with their RTR. The inspectors verified that dismantlement and decontamination activities were being conducted safely and in accordance with regulatory requirements, licensee commitments, and the NRC-approved DP. The inspection consisted of observations by the inspectors, interviews with WPI and Inspection Report No. 05000134/2012001 C:\RawFiles\ML13161A084.docx
contractor personnel, and a review of procedures and records. The NRC's program for overseeing the safe decommissioning of a RTR is described in IMC 2545.
The inspectors reviewed WPIs organization and temporary staffing to determine if it satisfied the DP requirements, license, and technical specification (TS) requirements.
The inspectors verified that WPI representatives adequately provided oversight and control of the contractors. The inspectors verified that pre-job briefs included a review of work plans/instructions and radiological and industrial hazards in the work areas. The inspectors reviewed training material and interviewed personnel to determine that they were adequately trained and knowledgeable for their assigned work activities. The inspectors reviewed work plans and procedures and observed decommissioning activities to determine if they were being implemented as specified in the DP and TS.
The inspectors verified that WPI and its contractors radiation protection and As Low As Reasonably Achievable (ALARA) programs were being conducted in accordance with site procedures, DP, and NRC regulations. The inspectors observed contractor personnel providing health physics job coverage for decommissioning activities and the performance of radiation and contamination surveys. The inspectors reviewed radiation work permits (RWPs) and associated radiological surveys and verified that areas were posted for the radiological conditions in accordance with 10 CFR Part 20 requirements.
The inspectors reviewed dosimetry records, radiation instrumentation calibration records, and the placement and use of air samplers within the facility. The inspectors verified that personnel were adequately trained to respond to emergency conditions as described in the emergency plan.
The inspectors reviewed waste classification procedures and observed the staging and temporary storage of waste to determine if the NRC regulations and DP requirements were being met. The inspectors reviewed the radioactive waste packaging and the waste disposal record for the completed radioactive waste shipment to determine if the record and manifest met the NRC and Department of Transportation (DOT) regulations.
b. Observations and Findings
The inspectors determined that personnel involved in the decommissioning activities at the WPI RTR have been adequately trained and were effectively implementing site procedures. Inspectors determined that engineering evaluations committed to in the DP were completed as required. Since the start of decommissioning, no abnormal conditions or reportable events have occurred.
On July 11-12, 2012, the inspectors observed the removal of the graphite blocks from the thermal column. Decommissioning contractor personnel were observed to be wearing the personnel protective equipment and dosimetry required by the RWP when performing this work. An air sample was being collected during this work evolution. The contractor surveyed the graphite blocks for dose rates and wipe tested each block for removable contamination. The graphite blocks were then labeled and placed on pallets in the radioactive waste storage area. All dose rates on the graphite blocks were less than 0.01 mR/hr. The Inspectors also verified that calibrated radiation detection instrumentation and dosimetry were being used.
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Based on discussions with the contractor, the inspectors noted that the radioactive inventory for the various components and waste material removed from the facility were calculated from radiological dose rate measurements and analytical data from samples of the various media. The inventory is estimated to be 12 millicuries and consists primarily of Fe-55, Co-60, Ni-63, Zn-65, Cs-134, Cs-137, Eu-152, and Eu-154. The inspectors noted that the regulating blade was the most contaminated component (80 mR/hr contact on the bottom end). The control rod blade shroud measured 1.2 mR/hr on contact and the reactor core box measured 0.4 mR/hr on contact. The contact dose rates for the remaining components were less than 0.16 mR/hr. Radiological surveys of the pool walls and floor did not identify any removable contamination. A small amount of neutron-activated concrete and the aluminum pool liner were removed from beneath the reactor compartment and in the vicinity of the beam port.
On May 2-3, 2013, the inspectors observed preparation and loading of the single radioactive waste shipment. The inspectors observed the contractor take wipe tests of the packages for removable contamination, dose rate surveys of the packages, and block and brace each package in the trailer. The inspectors also observed the contractor performing surveys of the truck exterior and completing of the waste manifest form and records associated with the shipments and determined that the shipment complied with regulatory requirements. Because the waste containers and pallets were being moved through the building, the contractors established appropriate controls to prevent access by unauthorized personnel.
On May 8, 2013, the inspectors obtained a copy of the acknowledgement that on May 6, 2013, the waste shipment had been received at the Toxco facility in Tennessee.
Toxco is a licensed facility for segregation and disposal of radioactive waste.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
3. Exit Meeting
The inspection results were discussed with Michael J. Curley, WPI Reactor Facility Director and University Compliance Officer, and other members of the decommissioning contractor staff, on May 3, 2013, at the conclusion of onsite inspection activities. On May 30, 2013, the inspectors held a telephone conference call exit with Mr. Curley.
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ATTACHMENT:
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
Michael
- J. Curley, Reactor Facility Director and University Compliance Officer
David Adams, Radiological Safety Officer (RSO)
David Messier, Chairman Radiation Health & Safety Committee
TLG Services / Entergy Nuclear (decommissioning consultant/contractor)
Joseph
- J. Adler, Senior Manager
Tim Arnold, Decommissioning Engineer/Health Physics Technician
Mark Houghton, Health Physics Technician
MHF Services (transportation contractor)
Douglas Hatch, Director ES&H/QA
Derek Stovall, Facilities Operations Manager
Joe Spann, Facilities Operations Support
Southern Pines Trucking Company
Kenneth Keas, truck driver
INSPECTION PROCEDURE USED
Inspection Procedure 69013, Research and Test Reactor Decommissioning
Inspection Manual Chapter 2545, Research and Test Reactor Inspection Program
ITEMS OPEN, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Decommissioning Plan dated September 2009 (ML092880231)
Environmental Assessment and Finding of No Significant Impact dated March 2010
Safety Evaluation Related to the Decommissioning of the Leslie C. Wilbur Nuclear Reactor
Facility at WPI dated December 2010 (ML103120511)
Revision to Decommissioning Plan Table 2.3 dated September 25, 2012 (ML12279A049)
Decommissioning Plan Approval dated March 29, 2011 (ML103120034)
Final Status Survey Plan dated January 31, 2013 (ML13046A107)
MHF Services, Standard Operating Procedure, Radioactive and/or Hazardous Material Shipping
Procedure, OPS-TEC-001, Rev. 4, dated April 3, 2013
Acknowledgment of radioactive waste shipment receipt by Toxco, dated May 6, 2013
List of WPI Radiation Protection Procedures for Decommissioning (RPP):
RPP-1, Radiation Protection Program Overview dated March 2, 2012
RPP-2, Radiation Protection Procedure Requirements dated March 2, 2012
LIST OF DOCUMENTS REVIEWED (Contd)
RPP-3, Radiation Work Permits dated March 2, 2012
RPP-4, Radiological Surveys dated March 2, 2012
RPP-5, Radiological Posting and Labeling dated October 24, 2011
RPP-7, Decommissioning Worker Training and Qualification dated March 2, 2012
RPP-8, Air Sampling dated November 23, 2011
RPP-13, Calibration and Quality Control of Portable Radiological Survey Instruments
dated March 2, 2012
RPP-18, Radiological Monitoring Program dated March 2, 2012
RPP-19, Routine Radiation Protection Activities dated March 2, 2012
RPP-20, Internal and External Personnel Monitoring dated March 2, 2012
List of WPI Decommissioning Work Procedures (DWP):
DWP-3, Reactor Core Structure Removal dated November 7, 2011
DWP-4, Remove Contents of Thermal Column dated May 4, 2012
DWP-5, Reactor Pool Equipment Removal dated May 7, 2012
DWP-6, Remove Reactor Pool Water Treatment System dated May 14, 2012
DWP-7, Remove Reactor Exhaust Ventilation System dated June 1, 2012
DWP-9, Removal and Turnover of Decommissioning Waste, dated April 19, 2013
Additional records reviewed on-site included:
Training records for all three decommissioning contractors
Internal and external dosimetry records for all three decommissioning contractors
Area TLD monitoring records
Air Sampling Data Log
Facility Radiation Survey data
Portable Radiological Instruments Quality Control Check Log
Instrumentation Calibration Records
Radiation Work Permits
Decommissioning and Dismantlement Material Inventory records
Routine Radiological Protection Checks and Inspection Log
LIST OF ACRONYMS USED
ALARA As Low As Reasonably Achievable
DOT Department of Transportation
DP Decommissioning Plan
IMC Inspection Manual Chapter
LCWNRF Leslie C. Wilbur Nuclear Reactor Facility
NRC Nuclear Regulatory Commission
RSO Radiological Safety Officer
RTR Research and Test Reactor
RWP Radiation Work Permit
TS Technical Specifications
WPI Worcester Polytechnic Institute
Attachment