ML090770604

Historical Site Assessment, Ford Nuclear Reactor, North Campus, University of Michigan

ML090770604
Person / Time
Site:	University of Michigan
Issue date:	01/31/2003
From:	CH2M Hill
To:	NRC/FSME, University of Michigan
Banovac, K. (415-5114)
References
Download: ML090770604 (46)

Text

Final Historical Site Assessment Ford Nuclear Reactor North Campus, University of Michigan Prepared for University of Michigan Ann Arbor, Michigan January 2003 Richland, Washington

Executive Summary The Ford Nuclear Reactor (FNR) is operated by the Michigan Memorial-Phoenix Project (Project) of the University of Michigan. The Project, established in 1948 as a memorial to students and alumni of the University who servedand the 588 who diedin World War II encourages and supports research on the peaceful uses of nuclear energy and its social implications. In 1957 the FNR went critical and has successfully maintained the Projects original charter over the last 45 years.

This Historical Site Assessment (HSA) investigated the FNR from operation startup in 1957 to the present time. Review of the operating license, safety analysis, reactor operations reports, reportable occurrences, facility drawings, and letters and internal memorandums was key to understanding the operational history, as were interviews of current and past FNR personnel. An onsite investigation was performed to gather additional information and digital photographs of current conditions.

As a result of this investigation, areas of the FNR facility were categorized into two distinct groupsimpacted and non-impacted. Impacted areas are known to be currently contaminated, were contaminated in the past, or have potential of having been contaminated. Non-impacted areas are not contaminated and there is no reason to believe they were ever contaminated.

The FNR facility in general is very clean. The levels of contamination are all very low.

Concerns around cleanup or disposal of materials are all relatively standard. There are no areas of concern that will not be addressed during future Data Quality Objectives (DQO) and sampling processes.

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Contents Section ..........................................................................................................................................Page 1 Purpose of the Historical Site Assessment..................................................................... 1-1 2 Property Identification....................................................................................................... 2-1 2.1 Physical Characteristics ............................................................................................ 2-1 2.1.1 Name/Owner ............................................................................................... 2-1 2.1.2 Location ......................................................................................................... 2-1 2.1.3 Topography................................................................................................... 2-1 2.2 Environmental Setting .............................................................................................. 2-2 2.2.1 Geology.......................................................................................................... 2-2 2.2.2 Hydrology ..................................................................................................... 2-3 2.2.3 Meteorology .................................................................................................. 2-3 3 HSA Methodology .............................................................................................................. 3-1 3.1 Approach and Rationale........................................................................................... 3-1 3.2 Site Boundaries .......................................................................................................... 3-1 3.3 Documents Reviewed ............................................................................................... 3-1 3.4 Property Inspections ................................................................................................. 3-2 3.5 Personal Interviews ................................................................................................... 3-2 4 History and Current Usage................................................................................................ 4-1 4.1 History......................................................................................................................... 4-1 4.1.1 Reactor Configuration ................................................................................. 4-1 4.1.2 Licensing........................................................................................................ 4-2 4.2 Current Usage ............................................................................................................ 4-5 4.2.1 Operative Cycles .......................................................................................... 4-5 4.2.2 OperationsReactor Core .......................................................................... 4-5 4.2.3 OperationsSupport Systems ................................................................... 4-6 4.2.4 Storage ........................................................................................................... 4-7 4.3 Adjacent Land Usage ................................................................................................ 4-7 5 Findings ................................................................................................................................ 5-1 5.1 Potential Contaminants ............................................................................................ 5-1 5.2 Potential Contaminated Areas................................................................................. 5-3 5.2.1 Impacted AreasKnown and Potential ................................................... 5-3 5.2.2 Non-Impacted Areas.................................................................................... 5-9 5.3 Potential Contaminated Media.............................................................................. 5-13 5.4 Related Environmental Concerns.......................................................................... 5-14 6 Conclusions.......................................................................................................................... 6-1 6.1 Impacted Areas .......................................................................................................... 6-1 6.2 Non-Impacted Areas ................................................................................................. 6-2 7 Works Cited.......................................................................................................................... 7-1 III

Exhibits 1 Topographic Map of the FNR Area, University of Michigan - North Campus 2 FNR Summary of Reportable Occurences IV

Acronyms and Abbreviations ACM asbestos containing material cfs cubic feet per second

°F degrees Fahrenheit DI Deionization DOD U.S. Department of Defense DOE U.S. Department of Energy DQO data quality objective EPA U.S. Environmental Protection Agency FNR Ford Nuclear Reactor g gram HSA Historical Site Assessment kW kilowatt L liter lbs pound MAP mobile air particulate monitor ml milliliter MPC maximum permissible concentration mph miles per hour MW megawatt NRC U.S. Nuclear Regulatory Commission OSEH University of Michigan Occupational Safety & Environmental Health PCB polychlorinated biphenyl PML Phoenix Memorial Laboratory Project Michigan MemorialPhoenix Project of the University of Michigan RIFLS Reactor Irradiation Facility for Large Samples USGS U.S. Geological Survey V

SECTION 1 Purpose of the Historical Site Assessment The Historical Site Assessment (HSA) is an investigation to collect existing information describing a sites history from startup of site activities to the present time. It identifies potential, likely, or known sources of contamination based on existing or derived information. It also identifies areas that may need further action as opposed to those areas that pose a threat to human health according to the U.S. Department of Defense (DOD), U.S.

Department of Energy (DOE), U.S. Environmental Protection Agency (EPA), and the U.S.

Nuclear Regulatory Commission (NRC) (DOD, DOE, EPA, and NRC, 2000). The HSA is also used to gather information that may not be located in one central location (for example, radiation reports located in another department, occurrence reports maintained by the reporting office, log-books stored in a control room, drawings, and institutional knowledge gained through interviews). This HSA summarizes information gathered during a site visit conducted the week of June 17, 2002, and data gathered from reports, letters, logbooks, drawings, and internal memorandums, as well as interview findings.

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SECTION 2 Property Identification The Ford Nuclear Reactor (FNR) and the contiguous Phoenix Memorial Laboratory (PML) are located on the North Campus of the University of Michigan in Ann Arbor, Michigan.

The North Campus is a tract of 900 acres located approximately 1 1/4 miles northeast of the central business district of Ann Arbor (University of Michigan, 1985). Ann Arbor has a permanent population slightly over 100,000 and a transient student population of approximately 35,000.

2.1 Physical Characteristics 2.1.1 Name/Owner Name: Ford Nuclear Reactor Owner/Operator: The Regents of the University of Michigan, a constitutional corporation Address: 2301 Bonisteel Boulevard Ann Arbor Michigan 48109-2100 2.1.2 Location The FNR is located on the North Campus of the University of Michigan. The street address of the FNR facility and grounds is 2301 Bonisteel Boulevard, Ann Arbor, Michigan 48109-2100, which is equivalent to U.S. Geological Survey (USGS) coordinates -83.715 longitude and 42.291 latitude.

2.1.3 Topography The topography in the vicinity of the FNR is level to gently rolling land. The site is located at an elevation of approximately 875 feet above sea, and about 100 feet above the Huron River, which lies to the south. The natural surface drainage flows toward the Huron River, although the natural topography was altered somewhat by grading during construction.

In the general area, the majority of areas located at elevations higher than the FNR elevation lie to the north and west of the facility. The highest ground elevation within 6,000 feet of the FNR is at elevation of approximately 940 feet. The Huron River is the lowest elevation within 6,000 feet (University of Michigan, 1985).

The USGS location for the FNR, taken from the web site Topozone.com, is 42 degrees 17 minutes 28 seconds North, 83 degrees 42 minutes 53 seconds West (see Exhibit 1). Exhibit 1 is for reference of the general area topography; street names and routing may not be current.

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EXHIBIT 1.

Topographic map of the Reactor Area of the University of Michigan - North Campus Ford Nuclear Reactor 2.2 Environmental Setting 2.2.1 Geology The FNR site is situated within an area overridden by continental glaciers of the Pleistocene (Great Ice) Age, and is well within the limits of the deposits of the Cary Age, a substadial of the Wisconsin Ice Age.

The site lies near the crest of an ice contact deposit known as kame. The material is stratified sand and gravel, but contains lenses and beds of more cohesive soil, as indicated by the rather high static level of the water table in some areas.

The predominant lithology of the stratified drift consists of quartz sand, limestone, and quartz gravel, as well as a variety of igneous, sedimentary, and metamorphic rock types.

The clay minerals are less abundant but are present in varying amounts.

The surface soils have been mapped by the U.S. Department of Agriculture as Bellfontaine sandy loam, a characteristic soil of this type of terrain (University of Michigan, 1985).

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2.2.2 Hydrology Surface and subsurface drainage flows toward the Huron River, and should be fairly rapid because the sites base soil is kamic, which has a fairly high permeability coefficient. The movement of subsurface water is facilitated by the lack of flat terrain in the surrounding area.

Both surface and subsurface drainage from the site eventually reach the Huron River, which, at this location has already passed through much of the City of Ann Arbor. It then flows in a southeasterly direction for 6 to 7 miles before reaching the next populated area, the City of Ypsilanti, Michigan. Along this water course, normal river velocities slow down because of three dams.

The average discharge for the Huron River at Ann Arbor, based on data from 1914-1947, is 451 cubic feet per second (cfs). Minimum flow for the 33-year period was 4 cfs. A flood of 5,000 cfs is estimated to occur on the average of once in 20 years (University of Michigan, 1985).

2.2.3 Meteorology Recorded Ann Arbor weather data cover the period from 1930 to the present. The highest temperature ever recorded is 105 degrees Fahrenheit (°F), the lowest is -21°F. Temperatures reach 90°F on the average of 15 days each summer and exceed 100ºF in about one summer out of seven. Temperatures fall below zero an average of twice per year. In about one winter in three, the temperature does not fall below zero.

Precipitation is heaviest during the summer months, averaging 58 percent of the annual total during the April-September period. Heaviest rainfall is in May, which has an average of 3.34 inches. The highest total monthly precipitation on record is 10.7 inches. The heaviest rainfall intensity occurs in connection with thunder shower activity and the heaviest recorded 24-hour rainfall was approximately 5 inches. Hourly intensities as high as 1.2 inches occur with a frequency of once every 2 years.

Average annual snowfall is 30.2 inches. Annual totals have ranged from 13 to 54 inches. The heaviest recorded snowfall for a single day was 6.2 inches.

Prevailing wind direction in the Ann Arbor area is from the southwest for all months except March, which has a prevailing direction of west-northwest. Highest average wind velocity is 12.9 miles per hour (mph) in March. The highest wind velocity ever recorded in the Ann Arbor area was 60 mph (University of Michigan, 1985).

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SECTION 3 HSA Methodology 3.1 Approach and Rationale This HSA was initiated to help determine the nature and extent of contamination associated with the operation of the FNR. The first step in determining the nature and extent of contamination is to evaluate past FNR operations and document those that relate to the next actions - characterization sampling and analysis, and characterization reporting. The HSA and subsequent characterization will provide a basis for the operational evaluation. The results of the characterization, along with proposed operation funding and FNR mission status, will be considered in determining the future of the FNR facility. Therefore, this HSA approach was tailored to assist in determining the future of the reactor operations.

3.2 Site Boundaries The site boundary for this assessment is the FNR facility proper. Systems shared by the FNR and the PML will be addressed in the FNR facility. For example, an air handling duct located on the beamport floor provides support to that floor and passes into the PML; thus this duct was evaluated as part of the FNR and will not be assessed in the PML. Other systems that support the FNR and release to the site environment (for example, exhaust stack, cooling tower evaporation) are included in the HSA boundary. Systems shared with the PML are excluded once the system crosses the boundary of the FNR into the PML; an exception is the sanitary sewer system, which is included because the FNR was the primary source for releases to this system.

3.3 Documents Reviewed The FNR manager and associated staff have maintained site records since operations began.

Documents associated with the reactor operations, occurrence reports, effluent releases, logbooks, annual operations reports, letters and internal memorandums were used for this HSA. Facility drawings also were reviewed. A summary of the documents reviewed follows:

• Ford Nuclear Reactor Operating License R-28

• Safety Analysis

• Reports on Reactor Operations (various years from 1968 to 1998)

• Retention Tank Release Data (various years from 1957 to 1987)

• University of Michigan FNR Reportable Occurrence (Numbers 1-22)

• FNR Site Demography, Topology, Geology, and Meteorology

• Memos to File

• Chemical Inventory Data Sheets

• Radiation Incident Files 3-1

• Retention Tank Worksheets

• Occupational Safety and Environmental Health Laboratory Analysis/Reports

• Facility Drawings 3.4 Property Inspections During the week of June 17, 2002, a detailed property inspection was performed. This inspection covered all accessible areas of the four FNR floors as well as the grounds around the FNR/PML structure. Certain areas were not accessible, such as the interior of vents and ducts; areas around the reactors primary cooling water holdup tank; and areas in and around the cooling tower, exhaust stack, and pipe runs. However, a large percentage of the facility and grounds was accessible. Each accessible area was inspected to determine current contamination potential as well as past contamination potential. The preliminary historical evaluation and personal interviews prompted detailed inspections of certain areas and vice versa. Information collected noted potential contamination, and digital photographs also helped capture current conditions; digital voice recordings were made in some areas to further explain the digital photographs. The property inspections, data collection, digital photographs, and voice recordings were used as the basis for this HSA. Details of these inspections are provided in Section 5 - Findings.

3.5 Personal Interviews Personal interviews were performed with various staff: those currently employed at the FNR, those who were previously employed at the FNR but are now employed in other departments of the University, and those who are now former employees of the University of Michigan. The interviews provided an understanding of operations conducted under both the current and past regulations and guidelines. The most useful interview was with a former FNR manager who was employed in varying reactor operation capacities over a period of more than 30 years.

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SECTION 4 History and Current Usage 4.1 History The FNR is operated by the Michigan Memorial-Phoenix Project (Project) of the University of Michigan. The Project, established in 1948 as a memorial to students and alumni of the University who served - and the 588 who died - in World War II, encourages and supports research on the peaceful uses of nuclear energy and its social implications. In addition to the FNR, the Project operates the PML. These laboratories, together with a faculty research grant program, are the means by which the Project carries out its purpose (University of Michigan, 1999).

The FNR building is a windowless, four-story, reinforced-concrete building with 12-inch-thick walls structurally integral with the footings in foundation mats. The building measures approximately 69 feet wide, 68 feet long, and 70 feet high, with approximately 44 feet of the building exposed abovegrade. The building has the following general features:

• The reactor is housed in a closed room designed to restrict leakage.

• The reactor room is equipped with a ventilation system designed to exhaust air or other gases present in the building atmosphere into a stack above the cooling tower, which exhausts approximately 54 feet above ground level.

• The ventilation system provides ventilation for certain storage and experimental facilities and exhausts these approximately 54 feet above ground level.

• The openings into the FNR building include an equipment access door; three personnel doors; an equipment access hatch; air intake and exhaust ducts; Room 3103 fume hood exhaust duct; a beamport ventilation duct; a sealed north wall door; a door between the hot cave operating face and the beamport floor; a sealed foundation tile drain to the cold sump; and a pneumatic tube system for sample transfer between the FNR and several laboratories in the PML.

The FNR began operation in 1957. The reactor is a 2-megawatt (MW), open pool reactor facility. The heterogeneous core is composed of aluminum and enriched Uranium-235. It is suspended 20 feet beneath the surface of the pool from a moveable bridge which is mounted on rails that lie on top of the concrete tank. The reactor is licensed to operate at a power level of 2 MW. The FNR generates no electricity and is used by students, faculty, and staff of the University of Michigan and non-University institutions and entities for research, experiments, and classes.

4.1.1 Reactor Configuration The rectangular reactor pool is 27 feet deep and is constructed of barytes concrete to a height of 15 feet; the remainder is ordinary concrete. The barytes concrete provides biological 4-1

shielding as does the thickness of the concrete in the lower 15 feet, which is 6 1/2 feet thick.

The tank is approximately 10 feet wide by 20 feet long and contains approximately 50,000 gallons of demineralized water. Biological shielding is provided above the reactor core by the pool water.

The pool lining consists of white ceramic tile sealed with white cement. The tile protects the concrete from spalling, aids visibility, and is more easily decontaminated than a concrete surface. Spent fuel is stored in racks along the walls of the reactor pool. Storage areas in the pool are used for depleted fuel, which is being prepared for shipment to a reprocessing facility, and for partially depleted fuel, which can be reused in the reactor core. A water lock system in the south end of the pool is used to transfer highly radioactive samples, experiments, and reactor fuel from the pool to a shielded hot cave. Experiment facilities for high-power operation include beamports, pneumatic tube stations, and a large space within the pool for sample irradiations (University of Michigan, 1993).

4.1.2 Licensing The reactor operates under a license issued by the NRC. The FNR operations are conducted under Operating License R-28, Docket 50-2. The operating license has been renewed one time, after approximately 20 years of operation, and has received 45 amendments. This license and associated Technical Specifications, as well as the Safety Analysis are the governing documents of reactor operations. In support of these documents there are a number of facility operating procedures, waste handling procedures, chemical management, and effluent discharge procedures.

During nearly 50 years of operation there have been relatively few reportable occurrences.

These are summarized in Exhibit 2.

Of the 22 reportable occurrences listed, 13 are categorized as either Operating License or Technical Specification violations resulting in no increased release to the environment. Eight are categorized as violations with insignificant changes in the operating releases to the environment. Only Reportable Occurrence No. 18 was considered of concern with regard to release to the environment in this report. Further details of this reportable occurrence are summarized in Section 5.3 - Potential Contaminated Media.

EXHIBIT 2.

FNR Summary of Reportable Occurrences FNR - Summary of Reportable Occurrences Occurrence No. Date Title Result 1 January 21, 1977 Alarm of FNR Mobile Air Release to the environment through Particulate Monitor (MAP) the stack of 0.8% of the Maximum Permissible Concentration (MPC).

2 January 26, 1977 Operation with No Coolant The reactor automatically shut down at 100 kilowatts (kW) and thus no damage occurred.

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EXHIBIT 2.

FNR Summary of Reportable Occurrences FNR - Summary of Reportable Occurrences Occurrence No. Date Title Result 3 February 2, 1977 Temperature Recorder Discovered during routine operations Malfunction check. No damage occurred.

4 November 16, 1977 High Temperature Switch No increased safety hazard resulted Set Too High from having the temperature switch set too high.

5 December 5, 1977 Building Exhaust Air Alarm Release of radioactivity, primarily Argon-41. Releases calculated as below release limits.

6 June 22, 1978 Bromine-82 Released in Release of approximately 300 Building Exhaust millicuries of Bromine-82 equating to 4% of the MPC.

7 June 22, 1978 Over Power Condition Operation at 112% of licensed power for 2 minutes. The cause was determined and corrected. No damage occurred.

8 July 24, 1978 Bromine-82 Released in Release of approximately 400 Building Exhaust millicuries of Bromine-82 equating to 6% of the MPC.

9 March 3, 1980 Bromine-82 Released in Release of approximately 47 Building Exhaust millicuries of Bromine-82 equating to 0.7% of the MPC.

10 June 9, 1981 Over Power Condition Operation at 110% of licensed power for 20 minutes. The cause was determined and corrected. No damage occurred.

11 January 7, 1983 Over Power Condition Operation at 100-120% of licensed power for 15 minutes. The cause was determined and corrected. No damage occurred.

12 January 16, 1989 Fission Product Release Fuel element leakage. Element removed from reactor core.

Release to the environment:

Liquid < 10% MPC Air < .01% MPC 13 August 6, 1990 Tritium Content Exceeds 50 Density calculation of Heavy Water Curies determined to be incorrect.

Calculation was modified. No significant safety hazard.

14 November 7, 1991 Fission Product Release Fuel element leakage. Element removed from reactor core. Release to the environment: Air < 1.3% MPC 4-3

EXHIBIT 2.

FNR Summary of Reportable Occurrences FNR - Summary of Reportable Occurrences Occurrence No. Date Title Result 15 June 11, 1992 Fuel Removed while Operator error. Operations were Reactor was Critical modified to avoid future occurrence.

Did not cause an unsafe condition.

16 November 25, 1992 Interlock Out of Service Modified service interlock discovered out of service less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after modification. Interlock was brought into service. Did not cause an unsafe condition.

17 March 24, 1993 Over Power Condition Operation at 115% of licensed power for 11 minutes. The cause was determined and corrected. No damage occurred.

18 August 5, 1993 Release of Reactor Water to Release of 7,500 gallons of water.

Drain Tiles Tritium detected outside the building in the groundwater at levels nearly 90% of MPC. Levels reduced over time.

19 July 20, 1998 Inoperable Radiation Radiation monitor disabled during Monitor reactor operations due to spurious alarms. Recorder remained functional and readings were not abnormal.

20 September 28, 1998 Inadequate Procedure Reactor power was adjusted and Implementation inaccurately set to 2.02 MW.

Operation at 101% of licensed power for 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. The cause was determined and corrected. No damage occurred.

21 November 13, 1999 Improper Retest of Radiation MAPs were not properly tested, Recorder resulting in a potential release of particulates without alarm.

MAPs were corrected and tested.

Particulate release during this 7-day period < 1% of MPC.

22 December 15, 1999 Log N Channel Inoperable Incorrect voltage connection to an ion chamber during reactor startup.

As power was increased the inoperable ion chamber was discovered and startup stopped. No limiting safety systems were approached.

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4.2 Current Usage The operation of the FNR provides major assistance to a wide variety of research and educational programs. The reactor provides neutron irradiation services and neutron beamport experimental facilities for use by faculty, students, and researchers from the University of Michigan, other universities, and industrial research organizations. Reactor staff members teach classes related to nuclear reactors (and the FNR in particular) and assist in reactor-related laboratories (University of Michigan, 1999). Additional usage includes neutron activation analysis, isotope preparation, radiochemical production, gamma irradiation services, neutron radiography, testing services, and training programs.

4.2.1 Operative Cycles In 1966 a continuous operating cycle for the FNR was adopted at its licensed power level.

The cycle consisted of approximately 25 days at full power followed by 3 days of shutdown for maintenance. In 1975 a reduced operating cycle was adopted consisting of 10 days at full power level followed by 4 days of shutdown for maintenance. A typical week consisted of 120 full-power operating hours. In 1983 the reactor operating schedule was changed to Monday through Friday at licensed power, with weekend shutdowns. Periodic maintenance weeks were scheduled during the year. In 1985 a cycle was established consisting of 4 days (or 96 full-power operating hours per week) at licensed power level, followed by 3 days of shutdown for maintenance. This was done in order to eliminate the periodic maintenance weeks needed in the previous cycle. Beginning July 1, 1987, the reactor operating cycle returned to 10-day operation at full power level followed by 4 days of shutdown for maintenance (University of Michigan, 1999).

4.2.2 OperationsReactor Core Targets (samples) of various sizes and shapes can be irradiated by placing them in or near the reactor core. The targets are typically placed within a Reactor Irradiation Facility for Large Samples (RIFLS) tube or a container which is then placed in or near the reactor core.

Sample irradiations can be conducted for periods as short as a few minutes and for as long as a year or more. At least one long-term experiment station has been fabricated and placed in the pool to support irradiation studies by the University of Tennessee/Battelle.

A pneumatic tube system exists that permits quick irradiation studies of samples, from one second to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, by placing and removing the samples at the edge of the reactor core.

Originally there were four separate systems consisting of two aluminum tubes each. In the current configuration, only one system remains operable and is accessed through Room 3103. Sample size is limited to less than one inch in diameter and less than two inches long.

Located on the floor below the reactor operating level, there are 10 horizontal beamports which can be used for long-term irradiations and neutron beam extraction experiments. The ports are labeled A through J. The beam ports penetrate the reactor pool wall and terminate at a heavy water tank adjacent to one face of the core. A most current experiment extracts a beam of neutrons used in the neutron radiography of turbine blades.

There is also a 6-foot-square thermal column located within the western side of the reactor pool. The column is covered by 5/8-inch-thick aluminum backed by approximately 4 inches 4-5

of lead and 3 feet of graphite (University of Michigan, 1993). The thermal column has not been used in years and was reported as having had approximately 50 percent of the graphite removed in the 1960s.

4.2.3 OperationsSupport Systems In addition to those operations directly in and around the reactor core, there are also the operations of the support systems: the primary and secondary cooling systems, the air supply and exhaust systems, and the sanitary sewer system.

The primary cooling system is a closed-loop system that consists of a collection header, hold-up tank, pump, heat exchanger, and associated piping. The primary cooling system maintains the bulk reactor pool water at less than 116ºF. If the reactor core coolant temperature exceeds 129ºF, or the bulk reactor coolant temperature exceeds 116ºF, the shim safety rods are automatically inserted, resulting in a shutdown of the reactor.

Approximately 25 gallons per minute are drawn out of the primary cooling loop and treated through the demineralizer system (hot deionization [DI]) prior to returning to the primary system (University of Michigan, 1993).

The secondary cooling system consists of a counter-flow heat exchanger which absorbs heat from the primary heat exchanger, a pump, associated piping, and evaporative cooling towers. The heat collected in the secondary cooling system dissipates to the atmosphere and makeup water is supplied from Ann Arbor city water. The secondary cooling water is monitored and treated as necessary to maintain quality and minimize growth of bacteria.

Water collected from either Hot DI column recharges, prior to 1992, or seepage from the reactor pool or floor drains is held in the hot and cold sumps located in the basement of the reactor building. When level indicators are tripped, liquids from the sumps are pumped to retention tanks located in the PML. Prior to 1992, the retention tank liquids were sampled, analyzed and released to the sanitary sewer. The liquids are now treated and used as makeup water in the primary cooling loop.

NRC regulations (10CFR20), permit the University of Michigan to discharge one curie per year of soluble radioactive liquids other than tritium and carbon-14 to the sanitary sewer system. The FNR-PML is allotted one-half curie per year by the University (University of Michigan, 1993). However, although permitted, neither FNR nor PML have discharged radioactive liquids to the sanitary sewer since 1992.

The supply air and exhaust air are primarily controlled through ventilation Room 2111, where all supply air enters the building and most exhaust air exits the building. Both the supply air and exhaust air can be isolated with interconnected isolation dampers. The supply air passes through a set of filters and is then distributed throughout the building.

The reactor building air is predominantly exhausted through the main building exhaust.

The beamport floor, pneumatic tube system, and hood in Room 3103 exhausts into PML Stack No. 2. The exhaust systems are continuously monitored for radioactive particulate.

Several other rooms containing systems or laboratories are used at varying levels of capacity in support of reactor operations. Counting, electronics and chemical laboratories; miscellaneous monitoring rooms; and chemical injection locations are part of the overall 4-6

operation of the FNR. These areas have various potentials for chemical and radiological contamination.

Solid radioactive waste is collected and stored in 55-gallon steel barrels. If waste materials are to be discarded, a health physicist provides assistance in transferring materials to designated storage areas (currently in the PML). The waste is placed in containers for storage or shipment. In temporary situations, radioactive waste materials can be stored in designated work areas. Radioactive waste containers that are to be shipped from the FNR-PML facility to an authorized disposal site comply with Department of Transportation regulations.

4.2.4 Storage The reactors irradiated fuel elements and fueled devices, when not in the reactor core, are stored in an array that permits sufficient natural convection cooling by water or air so that the fuel element or device temperature does not exceed 100 degrees Celsius. The array is also arranged to ensure subcriticality. These sources are sealed and have been suspected of leaking on only two separate occasions (See Exhibit 2, Reportable Occurrence Reports No.

12 and 14.)

Additional sample-holding devices, tools, experiments, and other items also are stored in various locations throughout the pool. Some are awaiting further use, others are awaiting removal at a later date.

4.3 Adjacent Land Usage The FNR is located on the North Campus of the University of Michigan at Ann Arbor, Michigan. The North Campus area is under the administrative control of the Regents of the University of Michigan. The North Campus is a tract of nearly 900 acres, approximately 1-1/4 miles northeast of the central business district of Ann Arbor. It is bounded on the north by Plymouth Road and on the south by Glazier Way. Open land and the Arborcrest Cemetery lie to the east. To the west are University athletic fields, municipal parks, and a wooded ridge. The Huron River flows through land bordering the area on the west and south and some marshland lies adjacent to the river on the south. There is neither housing nor buildings containing housing facilities within 1,500 feet of the reactor (University of Michigan, 1993).

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SECTION 5 Findings 5.1 Potential Contaminants There have been numerous potential contaminants associated with the FNR since operations began in 1957. The potential contaminants are a direct result of reactor operations as well as experiments performed over the years and are listed below. However, a large number of these radioisotopes have short half-lives. In addition to the radioisotopes there are a number of stored chemicals and potential chemical contaminants.

The potential contaminants listed below have been collected from the annual Reactor Operations reports, Reportable Occurrence reports, drawings, retention tank worksheets, radiation incident files, Chemical Inventory worksheets, and interviews with knowledgeable personnel.

Potential Radioisotopes and Associated Half-lives:

Antimony-122 (Sb-122) 2.7 days Antimony-124 (Sb-124) 60 days Antimony-125 (Sb-125) 2.8 years Argon-41 (Ar-41) 1.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Bismuth-210 (Bi-210) 5.01 days Bismuth-210m (Bi-210m) 3.5 x 104 years Bromine-82 (Br-82) 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> Cadmium-107 (Cd-107) 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Cadmium-109 (Cd-109) 462 days Cadmium-115M (Cd-115m) 44.6 days Carbon-14 (C-14) 5.736 years Cesium-134 (Cs-134) 2.1 years Cesium-137 (Cs-137) 30.2 years Cesium-138 (Cs-138) 32 minutes Chromium-51 (Cr-51) 28 days Cobalt-58 (Co-58) 70.78 day Cobalt-60 (Co-60) 5.3 years Europium-152 (Eu-152) 12.4 years Europium-154 (Eu-154) 8.5 years Flourine-18 (F-18) 1.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Iodine-123 (I-123) 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> Iodine-125 (I-125) 60 days Iodine-131 (I-131) 8 days Iodine-133 (I-133) 20.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Iron-55 (Fe-55) 2.7 years Iron-59 (Fe-59) 45 days Krypton-85 (Kr-85m) 10.7 years 5-1

Lead-209 (Pb 209) 3.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> Manganese-54 (Mn-54) 313 days Manganese-56 (Mn-56) 2.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Mercury-203 (Hg-203) 46.6 days Molybdenum (Mo-99) 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> Nickel-59 (Ni-59) 7.5 x 104 years Nickel-63 (Ni-63) 100 years Nickel-65 (Ni-65) 2.52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> Rubidium-88 (Rb-88) 18 minutes Scandium-46 (Sc-46) 83.8 days Silver-108 (Ag-108) 2.4 minutes Silver-108m (Ag-108m) 127years Silver-110M (Ag-110M) 250 days Sodium-24 (Na-24) 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> Tritium (H-3) 12.3 years Tungsten-187 (W-187) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Xenon-133 (Xe-133) 5.2 days Xenon-135 (Xe-135) 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> Zinc-65 (Zn-65) 244 days Chemicals used Onsite:

Asbestos Mercury Lead Cadmium Polychlorinated biphenyls (PCBs)

Hydrochloric acid Motor oils Sodium hypochlorite Alkane-A Bitumastic General janitorial supplies Unlabeled containers in various locations Chemicals Currently Stored in Room 3103 Laboratory (and Quantities):

Acetone 4 liters (L)

Alumina 400 grams (g)

Bromine 100 milliliters (ml)

Potassium Iodide 500 g Propanol-L 4L Uranium (IV) Oxide 25 g Methanol (2) 4 L H2O, HPLC Grade (4) 4 L HNO3 500 ml EuCl3 in H2O 250 ml 4M NH4Cl and NH4OH in distilled H2O (2) 475 ml 5-2

Ammonium Acetate 500 ml Sodium Borate 1 pound (lbs)

Calcium Sulfate 5 lbs Buffer Solution (13) 500 ml Phenol Red (2) 500 ml Bromothymol Blue 500 ml Note: Some of these chemicals may not necessarily be regulated, but need to be either confirmed prior to disposal or considered when determining the waste classification (pH levels, etc.). See reference Chemical Inventory as of February 11, 2002, for the chemical inventory of the FNR.

5.2 Potential Contaminated Areas 5.2.1 Impacted AreasKnown and Potential Impacted areas either have or potentially have radioactive contamination or activation.

These areas are known to either have contained or stored radioactive materials, or have been contaminated as a result of spills or standard operations. Areas surrounding or immediately adjacent to these impacted areas are included in this classification (DOD, DOE, EPA, and NRC, 2000).

During the survey design process, areas classified as impacted will be further classified as Class 1known to be contaminated or activated; Class 2suspected to be contaminated or activated; or Class 3not suspected to be contaminated or activated but no data are available proving otherwise. Each area classified as impacted will not necessarily be surveyed equally. These impacted areas are listed below starting from the basement of the FNR working towards the roof.

5.2.1.1 Basement Demineralization Systems: Past operations in support of the DI system have potentially contaminated the floor of the basement and walls around the DI systems. There are several containers of ion exchangers located in the basement. It also was recorded during an interview (Interview A) that resin water leaked in the past as a result of rusted drums. The area was cleaned; however, as a result of potential contamination, the DI systems and associated areas (old and new) are considered impacted.

Basement Sumps: Two existing sumps (hot and cold) collected radiological liquids from various locations within the reactor building. Floor drains in the basement lead directly to the sumps and because of potential collection of contaminated DI liquids or primary coolant, the drains are considered impacted. The piping from the sumps to the retention tanks located in the PML is also impacted.

Primary Coolant Piping: The piping to the holdup tank from the reactor pool and from the holdup tank to the pump and heat exchanger is impacted as a result of transporting the primary cooling water. Thus the primary coolant piping returning from the heat exchanger to the reactor pool is also impacted. Areas beneath the transportation piping are also 5-3

considered impacted because of potential contamination from suspected leaks during operation or maintenance.

Holdup Tank: The holdup tank is located behind the controls of a Grave Danger - Very High Radiation Area because of the dose rates associated with primary coolant held up in the tank. These elevated dose rates are a result of activated nitrogen, which has a 7-second half-life. Consequently, the holdup tank is impacted. There is a sump located directly beneath the holdup tank to collect any leakage of primary cooling water. Without the ability to confirm this area is free from contamination, it is considered impacted.

Heat Exchanger: The heat exchanger receives both primary and secondary cooling water.

The primary loop is impacted because of contact with the primary coolant and measurable dose rates when the reactor is shut down from activated sediments. It was recorded during an interview (Interview A) that there never has been a leak between the primary and secondary loops of the heat exchanger. This is not easily confirmed through surveys and the two loops cannot easily be separated; therefore, the entire heat exchanger is considered impacted.

Secondary Cooling System: There is secondary cooling piping that enters the basement, adjoins the heat exchanger, separates from the heat exchanger, then exits the basement. This piping has never been known to be internally contaminated. However, due to the tight quarters within the basement, which leaves the potential for personnel to spread radioisotopes from contaminated systems to non-contaminated systems, the secondary piping in the basement is considered impacted.

Basement Exhaust Systems: The exhaust ventilation systems from the basement potentially could have carried contaminants out of the basement over years of operation. The pneumatic tube exhaust system located in the basement does not connect with the main building exhaust, but does connect with the PML exhaust stack No. 2 (University of Michigan, 1993). The general exhaust system in the basement, however, does connect with the main FNR stack. The exhaust ventilation ductwork that remains within the FNR is considered part of this study and is listed as impacted.

Miscellaneous Piping: There are a number of different piping systems that enter or leave the basement areas. Some contain potentially contaminated media (sample lines, hot DI lines, holdup tank vent) and others supply non-contaminated media (city water supply, service air). However, because of the tight quarters in the basement, which results in the potential for the spread of radioisotopes from contaminated systems to non-contaminated systems, these miscellaneous pipe systems must all be considered as impacted.

Although each system has been addressed individually, the combined basement floors, walls, ceilings, systems, and containers should be addressed as a whole and listed as an impacted area. This is primarily because the basement is such a confined space and any potentially non-impacted areas are in close proximity to impacted areas. Secondly, the hot and cold sumps overflowed on at least one occasion when a large volume of rainwater entering the building (Simpson, 1997). Therefore, the potential exists for contamination spreading within the basement. Further characterization and surveys may permit certain locations and systems to be categorized differently; however, based on available information, the entire basement is categorized as impacted.

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Basement to Operating Floor Staircase: There is a staircase that leads from the basement to the reactor operating floor. Miscellaneous materials stored in the basement were moved through this staircase area. Within the staircase, there was an air compressor located on an equipment platform that left an oily residual. Although not currently contaminated, this area potentially could have been contaminated through past reactor practices. Therefore, the walking surfaces and the walls to a height of 2 meters, as well as the old compressor equipment platform, are classified as impacted.

5.2.1.2 Beamport Floor Beamports: The beamports provide an access path directly to the edge of the reactor. A portion of the beamport tube is located in the reactor pool and various experiments over the years have been performed within the beamports. As a result, the beamports are classified as impacted.

Reactor Pool Walls: The reactor pool walls are known to have seeped over the years, with that water being collected at the base of the reactor pool walls prior to being transported to the sumps. Because of contact with and subsequent transportation of primary coolant water, the reactor pool walls from floor to ceiling are considered potentially contaminated and are classified as impacted.

Beamport Experimental Equipment: A large portion of the experimental equipment is likely non-contaminated. A number of miscellaneous items including concrete bricks, experimental devices, storage racks, shielding equipment, electrical cables and panels, storage cabinets, pipes, drums, equipment trays, boral sheeting, and a storage/transportation cask are stored throughout the beamport floor. These items are stored against the beamport storage holes, against the north wall, and loosely around the reactor pool walls on the beamport floor. Without detailed information exempting these items from radiological surveys, and because of their inherent use, all items stored on the beamport floor are considered to be potentially contaminated and are therefore impacted.

Beamport Radiological Storage Area (southwest corner): A radiological materials storage area located on the southwest corner of the beamport floor contains several rad drums, a rad disposal box labeled Restricted Release, RIFLS tubes, and other miscellaneous items.

Because this area is used for rad storage, it and items within it are considered to be impacted. The south wall, floor to ceiling, associated with this storage area also is impacted because of long RIFLS tubes stored against the wall.

Beamport Floor and Walls Below the 2-meter Height (Rooms 1101, 1101-A, 1101-B): The beamport area floor was potentially contaminated over the years of operation. During interviews (Interviews A and B), it was acknowledged that experiments had been dropped and contaminants spread and subsequently cleaned up. Also, the beamport floor area has been flooded on at least one occasion when a large volume of water entered the building during a rain storm (Simpson, 1997). The water was returned to the storm drains having met release criteria; however, the potential for spread of contamination exists. Therefore, because the floor and lower walls were potentially contaminated, they are considered impacted. This includes the janitors closet (Room 1103) located on the southeast side of the beamport floor.

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Beamport Floor Drains: The floor drains and sumps located throughout the beamport floor area, janitors closet, and near the reactor pool walls are suspected of having received contaminated materials during years of operation. These are located below the 2-meter mark and therefore are included in the previously discussed impacted area.

Beamport Storage Ports: The beamport storage ports were designed and used to store items with elevated dose readings. Therefore, these storage ports are impacted by default. A number of these storage ports currently contain radioactive materials. Port No. 1 has stored for a number of years two 40 Ci PuBE sources, which makes the walls of the port potentially activated. The ports storing radioactive materials can be determined by the radiological tags attached to the handles of the storage port plugs/caps.

Beamport Exhaust System: The beamport exhaust system, much the same as the basement exhaust systems, has the potential to have carried contaminants out of the beamport areas over years of operation. The exhaust system does not connect with the main building exhaust, but does connect with the PML exhaust stack No. 2 (University of Michigan, 1993).

The exhaust ventilation ductwork that remains within the FNR is considered part of this study and is listed as impacted.

Beamport Equipment Hatches (in ceiling): Access to these equipment hatches is from the reactor operating floor level. Since the hatches are accessed from an area that is categorized as impacted and are stored on the floor of an impacted area (when removed), they also shall be categorized as impacted. Future surveys of the beamport side of these hatches likely will show them to be non-contaminated; however, until further surveys are completed they are considered as impacted.

Beamport Miscellaneous Piping: Service air is supplied to the beamport floor at a minimum to the J-port (University of Michigan, 1993). This piping can be categorized, as with other miscellaneous supply piping within the beamport area, like the walls and ceiling.

Any supply piping (water, service air, supply air) below the 2-meter height is considered impacted because of the potential for external contamination. Reactor operating level floor drains, primary cooling water piping, retention tank supply piping, and other impacted system piping that pass through the beamport area, regardless of location within the beamport area, are considered impacted.

Beamport to Operating Floor Staircase: Potential contamination exists in a staircase that leads from the north wall of the beamport floor to the reactor operating floor; thus walking surfaces and walls up to 2 meters in height are also classified as impacted. This staircase was recently painted and potential residual contamination may have been covered by the paint.

5.2.1.3 Second Floor of Reactor Hallway 2101: This hallway is a main passage between two staircases and provides access to the ventilation room. The floor of the ventilation room is impacted as are the floors of the staircases; as a result of this, contaminants may have been carried into the hall. The hallway currently does not show indications of contamination; however, the potential exists and thus the hallway and walls up to 2 meters in height are considered impacted. The hallway was recently painted and residual contamination may have been covered. Rooms, 2106, 2108, and 2109 open into this hallway. If contamination is found in the hallway, these 5-6

adjoining rooms, floors, and lower walls will be reclassified as impacted because of their proximity to known contamination in the hallway.

Room 2103: This is a janitors closet and is not known to be contaminated; however, it contains a sink and a floor drain that are readily accessible for disposal of materials. Without clear documentation that these drains did not receive radioactive materials, when a radioactive laboratory without a known sink existed several doors away, this room is potentially contaminated and therefore is impacted. It should be noted that the floor drain receives condensate from a reactor operating level room air conditioner (Room 3104), which is the radiological counting lab (Cook, 2002). Professional judgement dictates that this entire area should be classified as impacted.

Rooms 2102 and 2105: These rooms are the mens and womens restrooms. Without clear documentation that these sinks, toilets, and showers did not receive radioactive materials during years of operation, they are highly suspect and therefore are considered potentially contaminated. It is possible that over the years any personnel who were contaminated could have been decontaminated in this space. Therefore, professional judgement dictates that these restrooms should be classified as impacted.

Room 2107: This room is currently being used as an office space; however, previously it was used as a laboratory for radioactive materials (Cook, 2002). The room has been painted and carpeted, potentially covering any detectable radioactive contamination. Because of its prior use as a radioactive laboratory it is categorized as impacted.

Room 2109: This room contains a stack air monitoring system that measures the number of counts present in samples of air drawn from the exhaust stack. The readings are very low; however, the drum used to collect air samples contains air with known radioactive particles.

This drum and the associated sample collection equipment are listed as impacted.

Room 2111: This is the ventilation room containing the supply air handling equipment and the exhaust air fan. Access to the exhaust air stack and fan is provided through a hatch behind the supply air equipment. The area within the exhaust air access hatch is considered impacted as well as the walls directly around the access hatch. The likelihood of contamination is low; however, during years of operation, a number of incidents occurred during which the stack monitoring systems alarmed as a result of high radiation readings (see Exhibit 2). Room 2111 is currently being used to store drums of heavy water. Also located on a storage rack is a bottle labeled D-H2O. Because of known storage of radioactive materials, the floor and walls to a height of 2 meters in Room 2111, the storage rack and the entire wall behind the storage rack, as well as the walls around the exhaust air access hatch, are categorized as impacted.

5.2.1.4 Reactor Operating Floor Hallway 3101 and Room 3102: These two areas are not known to be contaminated; however, because of their proximity to reactor operations, they are suspected of having been in contact with contamination over the years. Both share an open space to the reactor operating floor which has alarmed in the past as a result of elevated mobile air particulate readings. These areas have a low potential for contamination; however, the potential exists.

The areas of concern are the floors and walls up to 2 meters in height, and are therefore classified as impacted.

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Room 3103: This room contains a laboratory hood that also supports a pneumatic sample line. It has been recorded, during an interview (Interview A) that a broken pneumatic sample vial spread contamination within the room, and was subsequently cleaned. The room also contains radiological counting equipment as well as shelves that currently store containers marked as radiological. Because the room at one time had a spill event, and the room is used to store radiological materials, the entire room is classified as impacted.

The pneumatic line located in Room 3103 and its entire length to the reactor and back is also impacted. This impacted classification also applies to all of the other pneumatic lines located within the FNR facility.

Room 3104: This room currently is being used as a radiological counting facility. The room contains counting equipment, computers, lead shielding, storage cabinets, containers, and other miscellaneous materials. Because radiological materials (samples, smears) have been known to be in this room, the floors and walls up to 2 meters in height are classified as impacted.

Rooms 3108 and 3109: These two rooms, the control room and the records storage room, are not known to be contaminated; however, because of their proximity to reactor operations, they are suspected of being exposed to contamination over the years. They share an open space with the reactor operating floor, and as mentioned previously, alarmed as a result of elevated particulate readings. These areas have a low potential for contamination; however, the potential exists. The areas of concern are the floors and walls up to 2 meters in height and are therefore classified as impacted.

Room 3166: This room is a janitors closet located outside the control room. It does not contain a sink; however, it does have a floor drain that drains to the sanitary sewer. Because the janitors closet received contaminated materials, the floor and walls up to 2 meters in height are considered impacted.

Reactor Pool Operating Floor (3101A): This is the main floor of operations. Any activities involving items being placed into or lifted out of the reactor pool were performed from this level. Also, the heavy water replacement activities were performed from this level. An elevated floor has been added at the eastern side of the reactor pool to cover the necessary electrical and piping related to a long-term experimental monitoring station. On the western side of the pool there is a pool skimmer sand filter, general floor storage, and an area called the bricks. This area is a lead-shielded space where irradiated items are held until they are shipped offsite. Because each of these areas has a potential to receive pool water spills, the entire floor of Room 3101A and all equipment stored on the floor are considered impacted.

All walls up to 2 meters in height are included in this classification. The southern wall is used to store tools and items removed from the pool and is considered impacted to the ceiling.

Reactor Pool: The reactor pool is automatically classified as impacted since this is where the reactor is physically located. The reactor rack, fuel manipulation tooling, storage racks, dividing door, hot cave pass-through piping, internal walls of the pool, heavy water tank, pool skimmer, etc., are all impacted because of contamination and/or activation. Any items currently in or that at one time were in the reactor pool are impacted. Also associated with the pool operations is miscellaneous piping located in the reactor walls. The vents to the 5-8

overflow trough, to the primary side of heat exchanger, and to the pool overflow drain lines all receive or have at one time received primary cooling water either directly or through ventilation; therefore, these are considered to be impacted. The reactor bridge, heavy water monitoring station, and handle rails around the pool are all impacted because of their proximity to the reactor pool water.

Overhead Crane Hook: During normal reactor operations, the crane hook and cable may be immersed in the reactor pool to move or remove items within the pool. As a result of contact with the primary cooling water, the crane hook, cable, spool, and motor are considered impacted.

Reactor Exhaust System: The reactor exhaust system receives exhaust air particulate that has in the past alarmed MAPs. Because it is known to have transported radioactive materials, the entire exhaust system is considered impacted. Although these radioactive materials, when diluted by a factor of 400 (permissible dilution factor), are well within the 10CFR20 release limits, this system will need to be classified as impacted until further surveying can prove otherwise. The exhaust system may traverse through several locations, rooms, and hallways and must be considered impacted throughout. If the system is breached in any location, the area immediately adjacent to the breached exhaust component also will be classified as impacted, if not already so classified.

Floor Drains: The floor drains are within the impacted areas of the reactor operating floor and are therefore impacted. The drains likely have received contaminated materials over the years and will need to be treated as contaminated. These floor drains, as they traverse the facility, are considered impacted throughout.

Operating Floor to Cooling Towers Staircase: There is a staircase that leads from the reactor operating floor to the cooling towers. At the operating floor level just inside the staircase there is a radiological storage area. Items such as air monitoring filter paper, an air pump, a 55-gallon polyethylene drum containing the pool cover, radioactive containers, and a lead pig are stored in this area. Also, there is a hatch to the exhaust stack within this staircase. Because the exhaust stack is in positive pressure and the hatch is not permanently sealed, the exhaust air leaks into this staircase (note that this area is still sealed within the reactor building). Because of the storage of radioactive materials and the presence of exhaust air, this staircase is impacted. This classification shall be applied to all areas from the floor to the ceiling.

5.2.1.5 Cooling Tower and FNR Roof No areas within the cooling tower or on the roof of the FNR are classified as impacted.

These areas are discussed further in Section 5.2.2, below.

5.2.2 Non-Impacted Areas Non-impacted areas are those areas where there is no reasonable possibility for residual radioactive contamination (DOD, DOE, EPA, and NRC, 2000). These have never been used as radioactive storage areas and have not ever been contaminated or activated. Areas immediately surrounding or adjacent to impacted areas may be classified as non-impacted; however, if contamination or activation is found in the impacted area, it is recommended that the non-impacted area immediately surrounding or adjacent to such impacted area be 5-9

reclassified as impacted and addressed accordingly. The non-impacted areas discussed below start with the basement of the FNR and work up to the roof.

5.2.2.1 Basement Almost no areas within the basement are non-impacted. The supply air, service air, and water line interiors are considered non-impacted; however; their exteriors are suspect and therefore are listed as impacted. There is, however, a void space beneath the staircase. It is enclosed by the reactor building foundation on the south and east sides and by concrete block partition walls that extend from the basement floor to the basement ceiling on the north and west sides. The partition walls are original construction and the enclosed space is not accessible. There are no systems or components that reside in, enter, or leave this space.

This space is therefore classified as non-impacted.

Upper Walls of the Basement to Operating Floor Staircase: The walls above 2 meters in height and the staircase ceiling are non-impacted, as is the old air compressor holding tank.

There is no reason to believe these areas were ever contaminated.

5.2.2.2 Beamport Floor Beamport Walls above the 2-Meter Height and the Ceiling: The floor of the beamport area is known to have been contaminated. The lower walls are categorized the same as the floor because of proximity. However, there is no known contamination on the upper walls and no reason to suspect they are contaminated. These upper walls are therefore classified as non-impacted. An exception is the reactor pool walls, which are impacted from top to bottom. If contamination is found on the lower walls during detailed surveys, the upper walls will be reclassified as impacted. There is no reason to believe the ceiling was contaminated so it is classified as non-impacted; however, if the upper walls are found to be contaminated, the ceiling will be reclassified as impacted.

Beamport Floor Miscellaneous Piping above the 2 Meter Height: The miscellaneous piping throughout the beamport floor will be treated the same as the walls and ceiling. Any piping above the 2 meters height, that was not previously classified as impacted as a result of contaminated materials transport, will be classified as non-impacted. If the lower or upper walls, or piping, are found to be contaminated, the piping immediately adjacent (upper piping and ceiling piping, respectively) will be reclassified as impacted.

Soil Around the Storage Holes: The storage holes are impacted and typically areas immediately adjacent to an impacted area are also considered impacted. The soil around the storage holes, however, will be listed as non-impacted. There is no evidence or reason to believe the storage holes leaked contamination into the surrounding soil. If it is determined the walls of any of the storage holes have been activated, the soils around those particular storage holes will be reclassified as impacted.

Upper Walls of the Beamport to Operating Floor Staircase: The walls above the 2-meter height and the staircase ceiling are non-impacted. There is no reason to believe these areas were ever contaminated. They were recently painted and if contamination is found beneath the paint on the lower walls, the upper walls will be reclassified as impacted.

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5.2.2.3 Second Floor of Reactor Hallway 2101 Walls above the 2-Meter Height and Ceiling: The upper walls and ceiling of the second floor hallway are non-impacted. There is no reason to believe these areas were ever contaminated. If, however, piping and ductwork from contaminated systems are opened in this area, the classification will be changed to impacted because of their close proximity to an open impacted system.

Rooms 2102 and 2105 Pipe Gallery: These rooms are the mens and womens restrooms.

They are listed as impacted because of potential contamination. The pipe gallery between the two restrooms that provides access to the supply water lines, drain lines, etc. (University of Michigan, 1993) is non-impacted; however, impacted lines pass through this area. If these impacted lines are found to have leaked into this space or are breached while still classified as impacted, the pipe gallery will be reclassified as impacted.

Rooms 2106 and 2108: These are office spaces and have been used as such since operations started. Recently they have been updated with carpet and paint; however, there is no reason to believe they were ever contaminated; therefore, they are listed as non-impacted. As noted earlier, if the hallway is determined to be contaminated, these room floors and lower walls will be reclassified as impacted.

Room 2109 (except air monitoring equipment): This room currently contains the secondary cooling water treatment injection system. It also contains an exhaust stack air monitoring system consisting of sampling equipment and a holding container. There is no evidence of contamination in this room and therefore the room is classified as non-impacted. The air sampling equipment is impacted, however, and if it is determined to have leaked into this room or breached while still classified as impacted, the room will be reclassified as impacted.

Room 2111 Walls above 2-Meter Height and Ceiling: There is no reason to believe the upper walls and ceiling are contaminated in this room; therefore, they are listed as non-impacted. The entire wall directly behind the storage rack, however, is not considered non-impacted because of its potential for having been contaminated.

Supply Air Ventilation: The supply air ventilation system begins at the inlet near the cooling towers, passes through ventilation filters and heaters in Room 2111, and then is distributed throughout the reactor spaces. Since the system is maintained at positive pressure, the interior of the ventilation system has only contacted air that is brought into FNR from the outside; there is no reason to believe this system has been contaminated and therefore it is listed as non-impacted. However, as is the case in the reactor basement, it is possible that the exterior of the ventilation system has been contaminated. Therefore, the ventilation system might be classified as impacted in contaminated areas upon further investigation.

5.2.2.4 Reactor Operating Floor Hallway 3101 and Room 3102 above the 2-Meter Height: This hallway and electronics lab are not known to be contaminated, however, the lower walls and floors are impacted because of potential contamination. There is no reason to believe the upper walls and ceiling have been contaminated, therefore they are classified as non-impacted.

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Room 3104 above the 2-Meter Height: There is no reason to believe the upper walls and ceiling are contaminated in this room; therefore, they are listed as non-impacted. This room, however, is currently used as a radiological counting facility and if contamination is found on the lower walls of the room, the upper walls and ceiling will be reclassified as impacted.

Rooms 3108 and 3109 above the 2-Meter Height: There is no reason to believe the upper walls and ceilings are contaminated in these rooms; therefore, they are listed as non-impacted. The lower walls and floor are listed as impacted only because of the potential for having been contaminated during years of operations.

Room 3166 above the 2-Meter Height: The lower walls and floor of this room are considered impacted because they potentially received radioactive materials in the past.

There is no reason to believe the upper walls and ceiling have been contaminated; therefore, the upper areas are listed as non-impacted. If the lower walls are determined to have radiological contamination, the upper walls will need to be reclassified as impacted.

Room 3101A Walls above the 2-Meter Height (except the southern wall): The lower portions of this space are classified as impacted because of the high potential for contamination over the years. The upper space (walls above the 2-meter height and ceiling) is very large, is not known to have been contaminated, and there is no reason to believe it has been contaminated. Therefore, the upper walls and ceiling are considered non-impacted. This also applies to the overhead crane rail. However, this does not apply to the south wall as it is used for storage of materials, tools, and equipment removed from the pool and the crane hook, cable, spool, and motor.

5.2.2.5 Other Areas Cooling Towers: The cooling towers located at the top of the staircase operate on a completely separate loop than the primary cooling loop. The towers are not known to be contaminated and as interview records indicate (Interview A and C), they have never been known to be contaminated. Therefore, the cooling towers, the associated piping and sumps, and the secondary cooling water is non-impacted (Cook, 2002). The secondary cooling piping traverses the building into the basement and then returns to the cooling towers.

When the secondary cooling system passes through or is located within an area that is classified as impacted, the secondary piping in that location also will be classified as impacted (for example, the basement). Also, the main exhaust air stack passes through the cooling tower area as it exits the building. This exhaust air system is considered impacted. If the exhaust system located in the cooling tower area is breached while it is still classified as impacted, the immediately adjacent area of the cooling tower will be considered impacted.

FNR Roof: The FNR roof is not contaminated and has never been known to be contaminated, as recorded during interviews (Interview A and D). Although the exhaust air stack is considered impacted, the release levels all have been within the releasable regulations as stated within 10CFR20. Therefore, the roof is non-impacted.

FNR Grounds (surface soils): There are no reports showing contamination escaped the confines of the FNR, resulting in contamination to the surface soils surrounding the reactor.

Several interviews (Interview A, C, and D) also indicated that the grounds around the FNR have never been contaminated. Therefore, the FNR surface soils are listed as non-impacted.

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5.3 Potential Contaminated Media Foundation Drain Tiles: The FNR drain tiles around the foundation of the building received approximately 7,500 gallons of cold sump radioactive water in 1993 (University of Michigan, 1994). This was previously referenced as Reportable Occurrence No. 18. The unintentional loss of reactor water came during a test to determine where excess water to the reactor cooling system was coming from. The cold sump water that was released to the environment was not tested prior to release; however, it was expected to be no different than water from normal operations. Five wells were drilled around the reactor building to sample and verify the extent of the groundwater contamination.

Diluted levels of tritium below the MPC were detected in the well closest to the release point. In a University of Michigan Occupational Safety and Environmental Health (OSEH) memorandum (Driscoll, 1996), it is evident that sampling the groundwater was part of a regular sampling procedure, and as directed by the memorandum would continue monthly for at least one more year. Additional monitoring wells were placed downgradient from the reactor and monitored for mobile radionuclides. Analytical data as late as 1999 show that no detectable tritium is present in the groundwater or the soils. During interviews (Interviews D and E), it was suggested that the wells had dried up because of the diversion of surface water and dewatering during and after the construction of a number of facilities around the reactor building. The wells either have been removed during adjacent construction or decommissioned because they are dry.

Therefore, the drain tiles around the reactor are classified as impacted. Further investigation is required before this area can be classified otherwise. The groundwater may no longer show levels of tritium; however, because the groundwater at one time contained tritium, which was released from the reactor, it is classified as impacted. Although a significant amount of data have been collected showing there is no radiological contamination in the groundwater, a confirmatory investigation is required before a classification other than impacted can be applied.

Sanitary Sewer System: Over years of operation, liquids captured in the cold and hot sumps were pumped to retention tanks located within the PML. These retention tanks collected these liquids until a tank was near capacity. The liquids were sampled to ensure they met release limits as required in 10CFR20, and were released to the sanitary sewer system. Every release was documented by date, time, sample analysis, and liquid quantity.

Each of these documented releases was maintained in files arranged for the most part by year. A review of these reports shows each release was within permissible release limits. An example of the Retention Tank Analysis Archive is the Retention Tank Data from 1978-1981 (University of Michigan, No date).

In 1991, the Ann Arbor Waste Water Treatment Plant contacted the University of Michigan Radiation Safety Services requesting radiological assistance since a dumpster of dried sludge and another of ash from the treatment plant had been rejected by a landfill because they contained radiation readings greater then 2x background. Analysis of the dried sludge and ash showed a number of radioisotopes, a few of which were known to have been released from the FNR/PML facility. The concentrations released from the facility were within release limits; however, a re-concentration of the isotopes apparently occurred 5-13

causing the sludge and ash to trigger radiological monitoring equipment at the landfill (Driscoll, 1991).

Although reactor releases to the sanitary sewer system were within regulatory limits, the reactor operations were modified in 1991 in order to avoid potential future re-concentration effects at the treatment plant. Reactor operations were modified so that retention tank water was filtered, treated, and then returned to the reactor pool for use as primary cooling water, and not released to the sanitary sewer.

Because there has been detection of radiological contamination at the waste treatment plant from isotopes released from the reactor, the sanitary sewer from the release location in the PML to the Ann Arbor Waste Water Treatment Plant will be classified as impacted until further studies prove otherwise.

5.4 Related Environmental Concerns An HSA typically focuses on potential radiological contamination and activation, just as this report has done. However, it should be noted that potential chemical contamination may be associated with the FNR. These chemicals may not receive the same level of concern, but they can become key components when consideration is given to decontamination and decommissioning operations, especially in the area of waste designation. Areas of potential concern are discussed below:

Lead Lead-based paint has been used for a number of years in all industries. Certain paint in the FNR facility has been tested and proven to contain lead (for example, the walls of the reactor pool on the beamport floor level) (Alexander, 2002). Because of the age of the facility, all paint should be considered suspect until proven negative for lead. Also, various types of paint in the industry have been shown to contain elevated levels of PCBs. This is an additional contaminant of concern.

Lead is used throughout the facility primarily as shielding; however, it is also used for other non-radiological purposes. If any lead is known to be non-radiologically contaminated it still must be regulated as a hazardous waste. Any lead that is radiologically contaminated is handled as mixed waste. Lead caulking in pipe joints is not uncommon in older facilities.

Cast iron pipe joints have been known to be packed with lead caulking. A lead caulk joint was used in the drain located in the bottom of the reactor pool (Smith Hinchman & Grylls Inc., 1955c).

Cadmium Cadmium is used in various applications as a thermal neutron filter and as neutron shielding. If the cadmium has become activated, or radiologically contaminated, the material is handled as a mixed waste. If the cadmium is known to be free of radiological isotopes, it still is handled as a hazardous waste material because of its heavy metal characteristics.

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PCBs The fluorescent light ballasts located throughout the reactor facility are suspected of having PCB oils. Until recently, all fluorescent light ballasts were considered suspect until proven otherwise. The newer ballasts now have markings that clearly state the oils do not contain PCBs. If this marking is not present, the ballast, any oils leaking from the ballast, and any surfaces with leaking oil are considered potentially contaminated with PCBs. A number of PCB light ballasts have been replaced with non-PCB ballasts, which eliminates the ballast concern; however the potential remains for light fixture contamination from a previously leaking PCB ballast. All light fixture surfaces with oils are considered potentially contaminated with PCBs and will be handled accordingly.

ACM Throughout the FNR facility there are steam lines wrapped in insulation. Based on the year the facility was constructed, any insulation wrapped to pipes or attached to heating/cooling ventilation ducts and equipment are suspected of being asbestos containing material (ACM). There was an extensive asbestos survey conducted of the FNR facility in May 1998 (University of Michigan, 1998). The analytical data/report will be used as a reference in determining the extent of ACM within the facility. Note: the service boxes (four) located in the reactor pool wall contain steam lines suspect of being wrapped in ACM (Smith Hinchman & Grylls Inc., 1955d).

The asbestos survey (University of Michigan, 1998) shows the cooling tower panels contain ACM. This report also shows floor tiles and associated mastics as containing asbestos.

Mastic materials used as sealers have been known to contain asbestos materials, particularly those associated with flooring materials. On the beamport floor level there is a knockout panel in the north wall to support a future door to a transformer room. This panel has been sealed with a mastic joint filler which is suspect of containing asbestos (Smith Hinchman &

Grylls Inc., 1955a).

Mercury Although no records have been found identifying mercury spills in the FNR, it was recorded during an interview (Interview A) that mercury spills did occur over time. The interviewee stated the mercury originally was cleaned up by reactor operations personnel; however, later these were cleaned up by the OSEH Hazmat Team. It is common to find mercury collected in drains after clean up of spills; therefore, professional judgment dictates that the floor drains within this facility be considered potentially contaminated with mercury. Through a separate interview (Interview G) it was noted that mercury was found in the sanitary sewer discharge; however, through further investigations it was not traced directly back to the FNR operations. The analytical results of these further investigations are presented in the Environmental Laboratory Final Report of Analytical Services (University of Michigan, 2000a; University of Michigan, 2000b).

Other Materials The service air system air/oil separator has not been properly maintained, as recorded through an interview (Interview F), and because of such, oil has contaminated the service air throughout the system. As a result, equipment using service air typically has oily films and 5-15

in some cases oily deposits located underneath (air cylinder used to control the air inlet damper). When the oil used in the compressors is tested, whatever waste classifications apply to the oil shall also be applied to the entire service air system.

Numerous pieces of equipment located throughout the basement, beamport floor, and reactor operating floor potentially contain oils that may be regulated.

Asphalt-based coatings potentially containing PCBs. An asphalt-based coating Bitumastic has been applied to the 14-inch-diameter exhaust air pipe (that goes to the PML) on the beamport floor (Smith Hinchman & Grylls Inc., 1955b). It has also been acknowledged that an asphalt-based flooring material was used on the second floor of the reactor facility (Cook, 2002).

The secondary cooling system was chemically treated to minimize growth of bacteria as well as maintain pH levels. Original water treatment was performed by pouring chemicals directly into the cooling tower water at the top of the cooling tower staircase. Later, these operations became automated by injection to the cooling water as it passed through Room 2109. The known chemicals are Alkane-A and sodium hypochlorite. These are currently injected on the 1-3 parts per million level and there is little concern about hazards within the water. However, the injection locations are suspected of having received spills over the years and need to be considered as potentially contaminated.

Various cleaning supplies are located in the janitors closets and throughout the FNR. Most are commonly known products, however, any bottles or containers that are not labeled will require analysis prior to disposal. Based upon that analysis, certain areas where the products were stored and potentially spilled will also require further analysis or treatment as they may be contaminated.

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SECTION 6 Conclusions The FNR, as part of the Michigan Memorial-Phoenix Project, has successfully maintained its original charter, established in 1948 to encourage and support research on the peaceful uses of nuclear energy and its social implications. The reactor became operational in 1957 and for 45 years has provided a resource for nuclear research to University staff and students, as well as making application to incorporate commercial needs. Through operational procedures and continuous oversight, the reactor has performed well within its NRC license, with a relatively small number of reportable occurrences.

The current conditions of the reactor show how well the facility is maintained. There is only one general area that requires personnel monitoring upon exiting, and that is the reactor operating room floor; this appears to be only precautionary. All other areas are maintained such that reactor personnel can perform duties without need for personal protective equipment or continuous personal surveys. The reactor operations appear to be well documented. Logbooks dating back to the original day of reactor startup are kept and maintained by the reactor personnel. Annual reactor operations reports, effluent release summaries, and radiation incident files are some of the records kept to document the reactor history.

Incident reports and spill reports from the early years either do not exist or are not known to current reactor personnel. It is possible there were no spills in the early years that would have led to development of reports; however, through interviews with past reactor operations personnel, it is evident that spills occurred and were immediately addressed, although documentation does not appear to be available.

This HSA has been written based upon review of the documents, logbooks, drawings, incident reports, letters and internal memorandums; interviews of current and past reactor operations personnel; and a week of onsite investigations. The FNR building has been separated into two distinct categories: impacted and non-impacted. Impacted areas are currently contaminated and/or activated, or have the potential to have been contaminated or activated. Non-impacted areas are those that have never been contaminated and there has not been any reason to suspect they have been contaminated. The areas associated with these two categories are summarized below:

6.1 Impacted Areas

• Basement Hot and Cold DI systems

• Basement Hot and Cold Sumps and associated Piping

• Primary Cooling System Piping

• Holdup Tank

• Heat Exchanger

• Exterior of Secondary Cooling System Piping located in Basement

• Basement Exhaust Systems 6-1

• Miscellaneous Piping in Basement

• All Basement Exposed Areas (floors, walls, ceiling)

• Basement Storage Items (drums, containers, tools, equipment)

• Staircase from Basement to Operating Floor (below 2-meter height)

• Beamports

• Reactor Pool Walls

• Beamport Floor Experimental Equipment

• Beamport Rad Storage Area

• Beamport Floor and Walls (below 2-meter height)

• Beamport Floor Drains

• Beamport Storage Ports

• Beamport Exhaust System

• Beamport Equipment Hatches

• Beamport Miscellaneous Piping (below 2-meter height)

• Staircase from Beamport to Operating Floor (below 2-meter height)

• Hallway 2101 and Room 2111 (below 2-meter height)

• Rooms 2102, 2103, 2105, and 2107

• Room 2109 Air Sample Equipment

• Room 2111 Exhaust Air Access

• Room 2111 Storage Rack and Wall Behind

• Hallway 3101 and Room 3102 (below 2-meter height)

• Room 3103

• Pneumatic Lines within the Reactor Building

• Room 3104, 3108, and 3109 (below 2-meter height)

• Room 3166 (below 2-meter height)

• Reactor Pool Operating Floor (3101A) (below 2-meter height and entire south wall)

• Reactor Pool and Contents

• Overhead Crane Hook, Cable, Spool, and Motor

• Reactor Exhaust System

• Reactor Operating Floor Drains

• Staircase from Operating Floor to Cooling Towers

• FNR Foundation Drain Tiles

• Groundwater directly adjacent to the Reactor Building

• Sanitary Sewer System 6.2 Non-Impacted Areas

• Void Space Beneath the Staircase

• Staircase from Basement to Operating Floor (above 2-meter height)

• Beamport Walls (above 2-meter height and Ceiling)

• Beamport Miscellaneous Piping (above 2-meter height)

• Soil around the Storage Holes

• Staircase from Beamport Floor to Operating Floor (above 2-meter height)

• Hallway 2101 and Room 2111 (above 2-meter height)

• Pipe gallery between Rooms 2102 and 2105 6-2

• Rooms 2106 and 2108

• Room 2109 (except air monitoring equipment)

• Supply Ventilation System

• Hallway 3101 and Rooms 3102, 3104, 3108, 3109 and 3166 (above 2-meter height)

• Room 3101A (above 2-meter height, except southern wall)

• Overhead Crane Rail

• Cooling Towers

• FNR Roof

• FNR Surface Soils The categorization of the FNR areas will be further investigated during the DQO development process and then further classified (Class 1, 2, or 3) during the detailed survey and sampling process. It is likely that areas initially categorized during this HSA can be down graded once current, detailed, information is available to support such action. Until then, areas that have the potential for contamination, by definition, are categorized as impacted. Conversely, areas that are currently characterized as non-impacted will be recharacterized as impacted if further investigation warrants such a change.

The FNR facility and surrounding grounds are generally very clean. The levels of contamination are all low. Concerns regarding cleanup or disposal of materials are all relatively standard. There are no areas of concern that wont be addressed during a standard DQO and sampling processes.

In conclusion, the facility has been well maintained over the years. The potential contamination levels within the facility are of a standard complexity. The groundwater, drain tiles, and sanitary sewer are of a greater complexity and deserve additional investigation prior to closure.

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SECTION 7 Works Cited Alexander, Terrance G. Letter to Ty Patton. February 20, 2002.

Chemical Inventory as of February 11, 2002. Ford Nuclear Reactor Lab, Michigan Memorial -

Phoenix Project. University of Michigan, Ann Arbor. 2002.

Cook, Andrew T. Letter to Steve Marske. August 26, 2002.

Demography, Topology, Geology, and Meteorology. Ford Nuclear Reactor, Michigan Memorial -

Phoenix Project. University of Michigan, Ann Arbor. 1985.

Driscoll, Mark L. Letter to Alan M. Jackson. March 12, 1996.

Driscoll, Mark L. Letter to Radiation Incident Files/Radiation Safety Service. July 3, 1991.

Environmental Laboratory Final Report of Analytical Services, February 21, 2000. Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan, Ann Arbor. 2000a.

Environmental Laboratory Final Report of Analytical Services, November 14, 2000. Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan, Ann Arbor. 2000b.

Homogeneous Area Report. Ford Nuclear Reactor, Michigan Memorial - Phoenix Project.

University of Michigan, Ann Arbor. 1998.

Report of Reactor Operations, January 1, 1993 to December 31, 1993. Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan, Ann Arbor. 1994.

Report of Reactor Operations, January 1, 1998 - December 31, 1998. Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan, Ann Arbor. 1999.

Retention Tank Data from 1978-1981. Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan, Ann Arbor. No date.

Safety Analysis. Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan, Ann Arbor. 1993.

Simpson, Phil. Memo to Files. July 28, 1997.

Smith Hinchman & Grylls Inc., 1955a, Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan project number 65, Reactor Building/ First and Second Floor:

Drawing A-3.

Smith Hinchman & Grylls Inc., 1955b, Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan project number 65, Reactor Building/ Mechanical Connections to Phoenix Building Services: Drawing M-4.

Smith Hinchman & Grylls Inc., 1955c, Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan project number 65, Reactor Building/ Process Piping - Details of Pool & Tunnel Piping: Drawing M-16.

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Smith Hinchman & Grylls Inc., 1955d, Ford Nuclear Reactor, Michigan Memorial - Phoenix Project. University of Michigan project number 65, Reactor Building/ Process Piping, 2nd & 4th FLS. Sections and Details: Drawing M-14.

U.S. Department of Defense, U.S. Department of Energy, U.S. Environmental Protection Agency, and U.S. Nuclear Regulatory Commission. Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM). 2000. DOE/EH-0624, Rev. 1; EPA 402-R-97-016, Rev. 1; NUREG-1575, Rev. 1.

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