ML091490106

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University of Arizona Nuclear Reactor Laboratory - Decommissioning Environmental Report
ML091490106
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Site: 05000113
Issue date: 05/20/2009
From: Sanders R
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Office of Nuclear Reactor Regulation, Univ of Arizona
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ENERCON Excellence-Every project.Every day.

University of Arizona Nuclear Reactor Laboratory Decommissioning Environmental Report Nuclear Regulatory Commission Facility Operating License R-52 Prepared for:

University of Arizona I*ITHE UNIVERSITY

. OF ARIZONA.

Prepared by:

Enercon Services, Inc.

4490 Old William Penn Highway Murrysville, PA 15668 May 20, 2009

UA NRL Decommissioning Environmental Report FEs ENERCON Rev. 0 Prepared by: *-L. .ri Date: 5/20/2009 Robert Sanders, Sr. Technical Specialist Reviewed by: Date:

5/20/2009 Scott LaBuy, Sr. Project L~ngineer Approved by: Date:

5/20/2009 Corey E. beWitt, Project Manager i

SE N E R C 0 NENE UA NRL Decommissioning Environmental Report0 RCONRev.

Table of Contents PAGE Acronyms and Abbreviations ...................................................................................... iv 1.0 Introduction ............................................................................................................................ 1 1.1. Purpose and N eed for A ction ........................................................................................... 1 1.2. The Proposed A ction ....................................................................................................... 1 1.3. Applicable Regulatory Requirements, Permits, and Required Consultations ................ 2 1.3.1 Federal Requirem ents ........................................................................................ 2 1.3.2 State of Arizona ................................................................................................. 4 2.0 Facility Description ........................................................................................................ 6 3.0 A lternatives ............................................................................................................................ 9 3.1 N o Action ............................................................................................................................ 9 3.2 Decom m issioning of the Reactor and Facility Reuse .................................................... 9 3.3 A lternatives Considered but Elim inated ...................................................................... 10 3.4 Cum ulative Effects ......................................................................................................... 10 3.5 Com parison of the Predicted Environm ental Effects .................................................... 10 4.0 Description of the A ffected Environm ent ...................................................................... 12 4.1 Land Use ................................................................................ 12 4.2 Transportation .................................................................................................................. 12 4.3 Geology and Soils ........................................................................................................ 12 4.4 Water Resources ............................................................................................................... 13 4.5 Ecological Resources .................................................................................................... 13 4.6 M eteorology, Clim atology, and A ir Quality .................................................................. 13 4.7 N oise ................................................................................................................................. 13 4.8 Cultural and Historical Resources ............................................................................... 13 4.9 Visual/Scenic Resources ............................................................................................... 15 4.10 Socioeconom ic ...................................................................................................... 15 4.11 Public and Occupational H ealth .................................................................................... 15 4.12 Waste M anagem ent ....................................................................................................... 17 5.0 Environm ental Im pacts .................................................................................................... 18 5.1 Land U se Impacts ............................................................................................................. 18 5.2 Transportation Impacts ................................................................................................. 18 5.3 Geology and Soils Impacts .......................................................................................... 18 5.4 Water Resource Impacts ............................................................................................... 18 5.5 Ecological Resource Impacts ......................................................................................... 18 5.6 Air Quality Impacts ............................................... 19 5.7 N oise Impacts .................................................................................................................... 19 5.8 Historic and Cultural Resources Impacts ...................................................................... 19 5.9 Visual/Scenic Resource Impacts .................................................................................. 20 5.10 Socioeconom ic Impacts ............................................................................................... 20 5.11 Environm ental Justice ..................................................................................................... 20 5.12 Public and Occupational H ealth Impacts ...................................................................... 20 5.12.1 N onradiological Impacts .................................................................................... 20 ii

-P EUA NRL Decommissioning Report Rev. 0 5.12.2 Radiological Im pacts ........................................................................................ 20 5.13 Waste M anagem ent Im pacts ........................................................................................ 21 5.13.1 Radioactive W aste D isposal ............................................................................ 21 6.0 M itigation M easures ...................................................................................................... 23 7.0 Environmental Monitoring and Measurement Programs ............................................... 24 7.1 Radiological M onitoring ............................................................................................... 24 7.2 Physiochem ical M onitoring .......................................................................................... 24 7.3 Ecological M onitoring ................................................................................................. 24 8.0 Cost Benefit A nalysis ..................................................................................................... 25 9.0 Summ ary of Environm ental Consequences................................................................... 26 10.0 References ............................................................................................................................ 27 iii

Eý E N E RC 0* N UA NRL Decommissioning Environmental Report Rev. 0 Acronyms and Abbreviations ER Environmental Report HEPA High-efficiency particulate air LLRW Low-level radioactive waste mrem millirem NEPA National Environmental Policy Act NMSS NRC Office of Nuclear Material and Safety and Safeguards NRC U.S. Nuclear Regulatory Commission NRL Nuclear Reactor Laboratory UA University of Arizona UARR University of Arizona Research Reactor iv

ENE R C 0~Rev.0 N UA NRL Decommissioning Environmental Report

1.0 INTRODUCTION

This Environmental Report (ER) describes the environmental effects related to the decommissioning of the University of Arizona Research Reactor (UARR). This ER was prepared in accordance with the guidance provided in Chapter 6.0 of the U.S. Nuclear Regulatory Commission (NRC) Office of Nuclear Material and Safety and Safeguards (NMSS) NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (NRC 2003b). This ER is designed to be used by the NRC in conducting its environmental assessment in accordance with the National Environmental Policy Act (NEPA) of 1969. NEPA requires Federal agencies, as part of their decision-making process, to consider the environmental impacts of actions under their jurisdiction. The NRC's NEPA requirements are provided in 10 CFR 51.

1.1. Purpose and Need for Action The Nuclear Reactor Laboratory (NRL) operates a nuclear reactor and two gamma-irradiation facilities in support of research and education and provides irradiation services for university and other regional users.

The reactor is one of 26 non-power reactors currently operating at universities in the U.S. Current users of the reactor and the gamma-irradiation facilities come from the Lunar and Planetary Laboratory, Arizona Research Laboratories Divisions, Atmospheric Sciences, Electrical and Computer Engineering, Chemical and Environmental Engineering, Aerospace and Mechanical Engineering, and General Dynamics Corporation, Scottsdale, AZ. Uses of the reactor and the gamma-irradiation facilities include neutron activation analysis of meteoritic and other geological samples, radiation induced chemical processing, testing of radiation effects in electronics, and radiation dosimetry research for homeland security and other applications. The nuclear reactor is currently licensed for operation until the year 2010, and the University plans to decommission the reactor after that date.

1.2. The Proposed Action The University plans to remove the UARR from service, dismantle the reactor and its ancillary support systems, remove all radioactive materials from the UARR facility, and reduce the radioactivity to levels that will permit release of the licensed area for unrestricted use and allow termination of NRC License R-52.

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E N E RC 0 N UA NRL Decommissioning Environmental Report Rev. 0 1.3. Applicable Regulatory Requirements, Permits, and Required Consultations Decommissioning of the UARR requires adherence to numerous federal, state, regional, and local regulations. Guidance for determining many of the applicable federal, state, regional, and local requirements are identified below. The information provided below is intended as a broad overview of applicable regulations and is not intended to be all-inclusive. The licensee or owner, UA in this case, is ultimately responsible for compliance with applicable federal, state, and local regulations. The DC is responsible for the costs associated with acquiring applicable permits and for the costs of implementing the necessary compliance programs during decommissioning activities.

1.3.1 Federal Requirements Decommissioning activities that are subject to federal regulations, permits, licenses, notification, approvals, or acknowledgments include:

  • Handling, packaging, and shipment of radioactive waste
  • Worker radiation protection
  • License termination and final site release
  • Worker, contractor, and the general public's health and safety
  • Liquid effluent releases
  • Hazardous waste generation and disposition
  • Handling and removal of asbestos
  • Handling and removal of lead paint Nuclear Regulatory Commission The majority of radiological activities fall under Title 10 of the Code of Federal Regulations (CFR) and are administered by the NRC. Applicable portions of Title 10 regulations are included within the following Parts:

" Part 20 - "Standards For Protection Against Radiation"

" Part 50 - "Domestic Licensing Of Production And Utilization Facilities" including decommissioning activities

  • Part 51 - "Environmental Protection Regulations For Domestic Licensing And Related Functions"
  • Part 61 - "Licensing Requirements For Land Disposal Of Radioactive Waste"

" Part 71 - "Packaging and Transportation of Radioactive Material" 2

SE N E RC 0 NE N R UA NRL C0 Decommissioning NRev. Environmental Report0 Many of the decommissioning requirements that involve activities for site control, characterization, and final status surveys are found within the following Parts of Title 10 of the Code of Federal Regulations (CFR) and are administered by the NRC. The Parts include:

  • Part 20.1401 - "General provisions and scope"

" Part 20.1402 - "Radiological criteria for unrestricted use"

  • Part 20.1403 - "Criteria for license termination under restricted conditions"

" Part 20.1404 - "Alternate criteria for license termination"

" Part 20.1405 - "Public notification and public participation"

  • Part 20.1406 - "Minimization of contamination"

" Subpart F-"Surveys and Monitoring" Part 20.1501 - "General"

  • Part 30.36 - "Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas"

" Part 40.42 - "Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas"

  • Part 70.38 - "Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas"
  • Part 72.54 - "Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas" Department Of Transportation The majority of radioactive material transportation activities falls under Title 49 of the CFR and are administered by the Department Of Transportation. Applicable portions of Title 49 regulations are included within the following Parts:

" Part 61 - "National Emissions Standards For Hazardous Air Pollutants"

  • Part 61 Subpart M - "National Emission Standards For Asbestos" pertaining to asbestos handling and removal

" Part 122 -"EPA Administered Permit Programs: The National Pollutant Discharge Elimination System" (NPDES) and Parts 123 to 125 in support of the NPDES

  • Parts 129 to 132 -Clean Water Act
  • Part 190 - "Environmental Radiation Protection Standards For Nuclear Power Operations" 3

SE N E RC 0ý' N -3Rev. UA NRL Decommissioning Environmental Report 0

  • Parts 260 to 272 -hazardous waste disposal and solid waste disposal as included in the Resource Conservation and Recovery Act (RCRA) 1.3.2 State of Arizona The State of Arizona regulations outlined in Arizona State Code Title 49 apply as follows:
  • Arizona State Code - Title 49 - The Environment o Chapter 1 GENERAL PROVISIONS o Article 1 Department of Environmental Quality o Chapter 2 WATER QUALITY CONTROL o Article 1 General Provisions o Article 2 Water Quality Standards o Article 5 Remedial Actions o Article 11 Local Stormwater Quality Programs o Article 12 Local Water Pretreatment o Chapter 3 AIR QUALITY o Article 1 General Provisions o Article 2 State Air Pollution Control o Article 3 County Air Pollution Control o Article 5 Annual Emissions Inspection of Motor Vehicles o Chapter 4 SOLID WASTE MANAGEMENT o Article 1 General Provisions o Article 4 Regulation of Solid Waste o Article 5 Enforcement Violations and Penalties o Chapter 5 HAZARDOUS WASTE DISPOSAL o Article 1 Hazardous Waste Disposal at State Sites o Article 2 Hazardous Waste Management

" Article 3 Sites for Waste Facilities; Notification 4

El E N E RC0 N ENERC0NRev. UA NRL Decommissioning Environmental Report0 o Article 4 Pollution Prevention o Article 5 Pollution Prevention for State Agencies o Chapter 6 UNDERGROUND STORAGE TANK REGULATION o Article 1 General Provisions o Article 2 Underground Storage Tank Tax o Article 3 Assurance Account o Article 4 Grant Account o Article 5 Certification o Article 6 Underground Storage Tank Informal Appeals and Underground Storage Tank Policy Commission o Chapter 7 LIGHT POLLUTION o Article 1 General Provisions 5

= E N EUA NRL Decommissioning Environmental Report F.' ENERCONRe. - Rev. 0 2.0 FACILITY DESCRIPTION The UARR is in the NRL, which is located on the first floor of the north wing of the Engineering Building. See Figure 2.1 for the location of the Engineering Building. The Engineering Building is made of brick and reinforced-concrete construction, including most floors and ceilings. Four adjacent rooms in the Engineering Building are permanently established as the NRL and are designated a controlled access area. These are: 1) Room 122, the Control Room; 2) Room 124, the Reactor Room; 3) Room 216, and 4)

Room 124A, Equipment Storage and Experiment Setup Room. Room 216 is the room directly above the reactor room, which was originally designed to receive a beam of neutrons from the reactor. A 9 inch diameter hole penetrates the floor of this room directly above the center of the reactor core, and a 30 inch by 36 inch hatch to the roof above is directly over the hole. Little use was made of this beam capability, so during the refurbishment of the reactor in 1972, no provision was made in the new bridge for a hole to accommodate the beam tube. At this time the hole in the floor is capped and locked, and the room is used for storage of reactor supplies and departmental records.

The reactor is located near the bottom of a circular pit approximately 14 feet below ground level. The pit contains a steel tank resting on a 1-foot-thick concrete slab. Eight inches of poured concrete surrounds the outside of the tank, except for a window 4 foot wide by 1 foot 10 inches high, which was left in the concrete to allow for the insertion of a thermal column at a later date, and a 3-inch-diameter circular opening, which was intended to accept a van de Graff generator beam tube. The inside of the steel tank is covered on the sides by a layer of Gunite approximately 2 inches thick and on the bottom by a layer 4 inch thick. The entire inner surface of the Gunite is coated with Amercoat (epoxy-base paint).

The UARR is a TRIGA pool-type reactor designed and constructed by General Atomic Division of General Dynamics Corporation (now GA Technologies of San Diego, California). The reactor was constructed at the University of Arizona in 1958 and went into operation in December of that year. The licensed power was 10 kW thermal with operation at 30 kW possible for short times. The original core loading consisted of 61 aluminum-clad fuel elements. Subsequently, two additional aluminum-clad were obtained and the facility was licensed to allow operations at 100kW. The reactor was extensively updated in 1972.

In May of 1972, a new TRIGA control console, control rod drives, and bridge were installed. Based on a revised Safety Analysis, a license amendment was approved in June 1972 allowing for receipt and possession of additional fuel for a complete change over from aluminum-clad to stainless-steel-clad fuel.

In December of that year, 87 partially used stainless-steel-clad TRIGA fuel elements were obtained, 6

M1_ SE N E RC 0 N UA NRL Decommissioning Environmental Report Rev. 0 permitting operation in the pulsed mode. The original TRIGA console, bridge, control rods, control rod drives and all the aluminum-clad- fuel elements were given to the University of Utah for use in their TRIGA Reactor Facility.

In February of 1973, initial criticality with the stainless-steel-clad fuel was obtained with 71 fuel elements containing approximately 2.4 kilograms of U-235 and graphite reflector elements in non-fuel positions in the F-ring. In June of 1973, a neutron radiography tube was installed in the reactor pool. In December of 1975, a motor-driven reactivity oscillator was first placed in the reactor core, after which a fuel element instrumented with thermocouples was installed in the core in January 1976. In August of 1978, an aluminum-clad graphite thermalizer block was installed in the reactor pool.

In October of 1978, a license amendment increased the maximum reactivity insertion in the pulse mode from $2.10 to $2.50. In January of 1981, a new top grid plate was installed to allow vertical flux mapping and void coefficient measurements in the core.

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0ENERCON UA NRL Decommissioning Environmental Report Rev. 0 Figure 2.1 Location of Engineering Building on the UA Campus 8

SEE-N E R C 0 N UA NRL Decommissioning Environmental Report Rev. 0 3.0 ALTERNATIVES The proposed action is the decommissioning of the UARR. It was determined that there are two alternatives associated with this action. The following are the alternatives:

  • No Action
  • Decommissioning of the Reactor and Facility Reuse Each alternative is discussed in more detail below:

3.1 No Action This action would require that the university maintain current radiological controls, site security, the license, a reactor administrator, and the utilities. The no-action alternative would require that UA apply for and obtain an extension to the current NRC operating license. The no-action alternative is in non-compliance with the 10CFR30.36 (timeliness rule). The purpose of the timeliness rule is to reduce potential risk to the public and the environment.

3.2 Decommissioning of the Reactor and Facility Reuse The University plans to remove all radioactive materials from the UARR facility, dismantle the reactor and its peripheral support systems, release the licensed area for unrestricted use and seek termination of License R-52.

Many of the reactor components and systems that are either activated or contaminated and will need to be segregated from non-radiological components and surfaces so that they disposed of as low level radioactive waste (LLRW). Building materials such as the reactor tank and dry storage pits will need to be evaluated for radiological activity and removed and disposed of according to their radiological status, as necessary.

The following are decommissioning tasks, which are necessary for site release. The sequence in which these tasks occur may vary:

  • Further characterization
  • Remove loose equipment
  • Remove hazardous materials (lead, cadmium) and asbestos
  • Remove the control rod drives, rotary rack drive, and bridge
  • Remove fuel storage rack, holsters, and cooling coils
  • Remove the reactor structure, reflector, and irradiation components 9

E N E RC 0 N UA NRL Decommissioning Environmental ReportRev. 0

  • Remove and disposition pool water
  • Segregate and package materials according radioactivity levels and classification
  • Remove auxiliary systems (rabbit system, water purification, ventilation)
  • Remove Gunite, activated portions of the tank liner, concrete, and affected soils
  • Decontaminate or remove the dry storage pits
  • Decontaminate building surface
  • Ship waste for disposal
  • Perform the Final Status Survey (FSS)

Submit required reports that demonstrates to the NRC that the facility meets the release requirements

  • Request license R-52 termination
  • Restore the facility for future use by the University.

The UARR is expected to shut down operations in May 2010. The on-site decommissioning tasks are expected to start after fuel removal within the following year and are anticipated to last about 4-6 months.

The FSS will be developed by the Decommissioning Contractor using the criteria provided in NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual" (MARSSIM) (NRC 2000). Since it is anticipated that no subsurface foundations or soils are impacted by the operation of UARR, the FSS will only cover the exposed concrete and soil surfaces remaining within the UARR facility after reactor and activated components have been demolished and removed.

3.3 Alternatives Considered but Eliminated The alternative for continued operation of the UARR past 2010 was considered but not evaluated. This report is based on the assumption that the University will decide that the license is to be terminated and that operation past 2010 is not feasible.

3.4 Cumulative Effects The cumulative effects of the implementation of the proposed action will result in short term cumulative impacts as discussed in Section 5.0 of this ER.

3.5 Comparison of the Predicted Environmental Effects The following table provides the predicted environmental effects and impacts of the alternatives that were evaluated for this ER. More detailed information on the expected impacts can be found in Section 5.0 of this ER.

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UA NRL Decommissioning Environmental Report ENE RCON Rev. 0 Affected Environment No Action Proposed Action Land Use No Impacts Possible Impact Transportation No Impacts Possible Impact Geology and Soils No Impacts No Impacts Water Resources No Impacts No Impacts Ecological Resources No Impacts No Impacts Meteorology, Climatology, and Air No Impacts Possible Impact Quality Noise No Impacts Possible Impact Cultural and Historic Resources No Impacts No Impacts Visual/Scenic Resources No Impacts No Impacts Socioeconomic No Impacts No Impacts Environmental Justice No Impacts No Impacts Public and Occupational Health No Impacts Possible Impact Waste Management No Impacts Possible Impact 11

SE N E RC0 NE N R UA NRLC0 Decommissioning NRev. Environmental Report0

4.0 DESCRIPTION

OF THE AFFECTED ENVIRONMENT The following sections describe specific areas of the Environment that may be affected as a result of the Decommissioning activities.

4.1 Land Use The UARR is in the NRL, which is located on the first floor of the north wing of the Engineering Building. The Engineering Building is made of brick and reinforced-concrete construction, including most floors and ceilings. The reactor is located near the bottom of a circular pit approximately 14 feet below ground level. The pit contains a steel tank resting on a 1-foot-thick concrete slab. Approximately 8 inches of poured concrete surrounds the outside of the tank. The inside of the steel tank is covered on the sides by a layer of Gunite approximately 2 inches thick and on the bottom by a layer 4 inches thick. The entire inner surface of the Gunite is coated with Amercoat (epoxy-base paint).

4.2 Transportation The UARR is located in a relatively low traffic area in the center of Tucson, AZ. A recent corridor study for the development of a modem streetcar for this area recommends that the streetcar line be located a few hundred yards to the south (Diehl, 2007). The local streets will be used to carry radioactive waste and construction debris during the decommissioning of the UARR.

4.3 Geology and Soils Tucson is in the Basin and Range Province. The physiography of the area is typical of the province with alternating broad valleys and mountains. Tucson is located in the center of the Santa Cruz River Valley.

This valley appears to be a grabben or down-dropped block between valley bounding normal faults. The valley is filled with about 2,000 feet of upper Tertiary and Quaternary sedimentary deposits composed of alternating sands, silts, clays, and gravels, which are underlaid by Tertiary volcanic rocks. The surface deposits are gravels of composition similar to the bedrocks of the nearby mountains. Tucson is in an area of relatively low seismicity. No major earthquakes have been reported in the area. A search of the U.S.

Geological Survey's earthquake data file indicates that the nearest reported earthquake was a magnitude 4.5, which occurred on March 9, 1972, and had an epicenter more than 44 miles from Tucson. Tucson is reported to have experienced Modified Mercalli intensities of up to IV from distant earthquakes. S. M.

Dubois and others (NUREG/CR-2577) place the site in their Seismic Zone 3, which they define as a zone of sparse seismicity. A geologic map and cross sections can be found in the Safety Analysis Report -

Section II - Site Characteristics.

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F EN E R C 0 N UA NRL Decommissioning Environmental Report Rev. 0 4.4 Water Resources Tucson is located near the center of a valley almost completely surrounded by mountains. The valley gradually rises toward its center, and the University is located near this high point. The licensee provided data, in the submittal dated July 17, 1989, that show that the base of the reactor is above the 100-year flood level of near or distant stream beds. The physical contours of the site and the drainage path near the building will not permit accumulation of water around the building. There are no credible paths for reactor pool water to get into the campus water system or sanitary sewer system. The water table at the university is typically 200 feet below the surface.

4.5 Ecological Resources The NRL is in a well developed area with native plants and wildlife on the outside of the Engineering building.

4.6 Meteorology, Climatology, and Air Quality The climate of Tucson is classified as a west coast desert climate. Tucson's coldest month is January when the average low is 36.4°F and the hottest month is July when temperatures reach an average high of 99.1 F. Tucson is approximately 325 miles from the Pacific coast, and therefore hurricane and tropical depression energy directed toward the city is depleted by the time the disturbance reaches the city.

Typical wind direction is from the southeast in the morning, shifting to a general west-northwest direction in the afternoon. Wind speed is usually between 5 to 10 miles per hour. The average annual rainfall in Tucson is 11.2 inches Tornados in Tucson are rare; sightings occur once in 2 years and one may touch down once every 10 years. On the basis of the meteorological data presented in the licensee's Safety Analysis Report, the NRC staff concluded that the meteorological conditions at the reactor site do not pose a significant risk of damage to the reactor nor render the site otherwise unacceptable for the facility.

(ref. 3) 4.7 Noise The UARR is in an academic setting and noise is typically at a low level. The noise is primarily from maintenance of the grounds and facilities near the Engineering Building.

4.8 Cultural and Historical Resources The oldest portions of the University of Arizona campus were listed on the National Register in 1986 (Giebner et al. 1985). This historic district (see Figure 4.5) is comprised mainly of the original 40 acres on which the University was founded in 1887. Additional areas to the south and north of this area are included in the district, as well as a volcanic stone wall encircling the campus and several areas 13

0 E N E RC O N UA NRL Decommissioning Environmental Report Rev. 0 containing historic landscaping. The Period of Significance for the University of Arizona Historic District is the university's historic growth period, 1885-1938, and the district is characterized by Queen Anne Revival, Classical Revival, and Spanish Romanesque Revival architecture. Brick and locally mined volcanic stone are the prevalent building materials. Historic plantings include mainly cactus and desert-adapted trees, many of which were among the first of their kind to be planted in Tucson. The Engineering building is located within this historic district.

Figure 4.1 Engineering Building Location within the Historic District 14

WW NUA NRL Decommissioning Environmental Report E N E R CON Rev. 0 4.9 Visual/Scenic Resources The UARR is located within the Engineering Building in the center of the UA campus. The visual scenic resources in the area of the UARR consist of building interiors, which include laboratory and office facilities as well as the control room and reactor areas.

4.10 Socioeconomic The population of Tucson's metropolitan area in 1988 was 648,492 and was projected to grow to 943,000 by the year 2000. The nearest residence is Yuma Hall, a student dormitory, located 300 feet west of the NRL. The nearest private residences that are not under University control are approximately 1300 feet west of the reactor laboratory. The nearest private residences in the direction of the prevailing winds (southwest to northwest) are also approximately 1300 feet from the laboratory. There is no heavy industry in the vicinity of the University campus. The nearest airport, Tucson International Airport, is 6.5 miles south of the campus. Interstate 10, a major highway, passes within 1.75 miles from the west of the reactor laboratory. The Southern Pacific Railway and Amtrak pass within 1.1 miles south of the reactor laboratory. The Davis Monthan Air Force Base is the only major military facility in the vicinity of Tucson and is located 5 miles southeast of the campus. In view of the safe operating history of the previous 30 years and the location of nearby industrial, transportation, and military facilities, the NRC staff concluded that these facilities pose no significant risk to the safe operation of the UARR. (ref. 3) There have been no changes that should alter these conclusions.

4.11 Public and Occupational Health Public and Occupation Health activities associated with the current operations of the UARR include the following:

Reactor Sources of radiation directly related to reactor operations include the reactor core, the ion-exchange columns, the cooling water cleanup system, and radioactive gases (primarily argon-41). The fission products are contained within the stainless steel cladding of the TRIGA fuel elements. Radiation exposures from the reactor core are reduced to acceptable levels by water and concrete shielding. The ion-exchange resins are changed routinely before high levels of radioactive materials have accumulated, thus limiting personnel exposure. Personnel exposure to the radiation from chemically inert argon-41 is limited by dilution and prompt removal of this gas from the reactor area and its discharge to the atmosphere, where it is further diluted in the unrestricted area.

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11VENERCO N UA NRL Decommissioning Environmental Report Rev. 0 Extraneous Sources Sources of radiation that may be considered as incidental to normal reactor operation but associated with reactor use include radioactive isotopes produced for research, activated components or experiments, and activated samples or specimens. Four fixed radiation monitors are located in the NRL. A continuous air monitor (CAM) and two remote air monitors (RAMs) are located in the Reactor Room, and a Geiger-Mueller (G-M) monitor is located in the exhaust stack. The CAM is located in the northwest comer of the reactor room and automatically shuts down the window vent and starts the high efficiency particulate air (HEPA) (stack) vent. It has an audible alarm and also a flashing light. The readout is in the reactor room, but it may also be observed through the Control Room window. The two RAMs are located at the south and west windows of the reactor room with audible alarm and readout in the control room. The G-M stack monitor is located downstream from the HEPA filter in the stack exhaust system with readout and audible alarm in the Control Room. In addition to the four fixed radiation monitors, portable survey meters are available for routine use in the laboratories and for checking the radioactivity of samples removed from the core of the reactor. Thin-window G-M tube detectors are used in the laboratory to monitor equipment and people for traces of radioactive contamination.

Routine Monitoring Personnel exposure to radiation from intentionally produced radioactive material as well as from the required manipulation of activated experimental components is controlled by extensively developed and reviewed operating procedures that incorporate the normal protective measures of time, distance, and shielding.

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F ENE R C 0 NENERCONRev. UA NRL Decommissioning Environmental Report0 4.12 Waste Management A Waste Management Plan will be implemented for the disposal of the waste generated during the UARR facility D&D project. The Waste Management Plan will be submitted to the Reactor Laboratory Director for review prior to the start of work. The Waste Management Plan will include detailed guidance for the characterization, sampling, classification, segregation, handling, packaging, manifesting, transporting and disposal of all waste categories.

Uncontaminated wastes will consist primarily of support equipment and building demolition debris.

Waste equipment will come from offices, storage areas, work areas, and the Control Room. These wastes will include desks, chairs, storage shelves and cabinet, and electronic control equipment. These items will be released using radiological surveys and the surface contamination release criteria. These waste streams are suitable for disposal at a local solid waste disposal facility or reuse by the University.

Non-radioactive hazardous waste will be managed through the University's existing hazardous waste disposal system.

Clean construction and demolition waste will be released according to release criteria specified in the Decommissioning Plan. Construction waste will be disposed of at the disposal facility being utilized by the University at the time the material is generated.

Waste generated during the reactor D&D project will be characterized and segregated on site according to separate categories for removal and disposal. These categories may include: uncontaminated waste acceptable for land disposal or reuse, uncontaminated demolition wastes suitable for land disposal or recycle, and Class A LLRW. Additionally, mixed wastes and non-radiological hazardous waste will be segregated from LLRW.

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E N E R C 0C_.ýZJRev. N UA NRL Decommissioning Environmental Report0 5.0 ENVIRONMENTAL IMPACTS The following sections describe the potential environmental impacts that may result from the Decommissioning activities of the UARR.

5.1 Land Use Impacts Land use impacts are expected to be minimal. There will be no construction performed outside of the engineering building and all removed components will be replaced with materials similar to those that currently exist within the main Engineering Building. Following the removal of all radioactive material, the building will become made available for future University academic use. A recommendation will be made to backfill and cap the reactor pool cavity, following license termination.

5.2 Transportation Impacts Various forms and quantities of radioactive waste will be shipped from the UARR facility during the D&D project. The dose consequence from transportation accidents could be higher than the contamination accident scenarios described in Section 5.6 and Section 5.12.2 because high-activity reactor components could be involved. As such, there is a potential for a moderate dose consequence of between 1 and 25 mrem for the public following a transportation accident. However, adherence to NRC and DOT radioactive material packaging and transportation requirements is considered a sufficient control measure for mitigating transportation-related incidents.

5.3 Geology and Soils Impacts It is expected that there will be no Geology and Soils impacts as a result of the Decommissioning of the UARR.

5.4 Water Resource Impacts It is expected that there will be no impact to Water Resources as a result of Decommissioning of the UARR. All water generated as a result of the decommissioning of the UARR will be contained and dispositioned in accordance with all University, federal, state, and local regulations. No water will get introduced to the subsurface environment or into the natural environment outside of the Engineering Building. No water will be discharged to the storm water system, unless it has been sampled to verify it is within regulatory limits.

5.5 Ecological Resource Impacts No Ecological Resource impacts are expected, as all work will be performed within the NRL. Potential lay down areas for equipment will only be placed in developed areas. Decommissioning the reactor would have no impact on amphibians, reptiles, birds, fish, mammals, or threatened species.

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SE N E RC 0 N UA NRL Decommissioning Environmental Report Rev. 0 5.6 Air Quality Impacts An uncontrolled release of airborne radioactivity could occur during cutting and demolition activities involving contaminated or activated materials. Such activities may take place inside temporary containment structures equipped with HEPA filter ventilation systems. The failure of the containment structure could result in the release of airborne radioactive materials into the UARR facility. If the negative pressure is still maintained in the UARR at the time of such an incident, the facility air filter system would prevent release to the environment. If the air flow system in the UARR facility is not operating at the time of such an incident, airborne radioactive material could be released directly to the environment. Alarming continuous air monitors (CAM) will be used in the work areas to warn against the release of airborne radioactivity.

Temporary containment systems with HEPA filter systems will likely vent to the UARR building or tie into existing building ventilation. A failure in the HEPA filter system could result in the uncontrolled release of airborne radioactive materials. CAM will be used to monitor effluent air. If allowable effluent criteria are exceeded, the CAM will alarm and operations inside the containment structure will immediately stop.

While the actual concentrations of airborne radioactive materials are unknown at. this time, the dose consequence of an uncontrolled release is expected to be low (< 1 mrem off-site impact and < 25 mrem to on-site workers). As such, safety management operations (standard engineering and administrative controls) are sufficient for protecting against such accidents.

5.7 Noise Impacts Noise impacts during the decommissioning of the UARR are expected to be those associated with normal construction activities inside of an enclosed building.

5.8 Historic and Cultural Resources Impacts No Historical and Cultural impacts are expected. The only work being performed to decommission the UARR is inside the Engineering Building. The planned decommissioning activities will not affect the outside or historical architecture of the building 19

  • L'j EN E R C 0 N UA NRL Decommissioning Environmental Report Rev. 0 5.9 Visual/Scenic Resource Impacts Visual/Scenic Resource impacts associated with decommissioning are primarily visual and relate to the structures and visual attributes of the decommissioning site. The impact of decommissioning on site aesthetics (e.g., truck traffic, noise) is limited both in terms of land disturbance and duration (i.e., any impacts are temporary and will cease when decommissioning activities are completed).

5.10 Socioeconomic Impacts No Socioeconomic impacts are expected from the decommissioning of the UARR.

5.11 Environmental Justice High and adverse health, economic, or environmental effects to local low-income and minority populations characterize environmental justice. There is no reason to believe that low-income or minority populations would be affected by UARR decommissioning.

5.12 Public and Occupational Health Impacts 5.12.1 Nonradiological Impacts The Nonradiological impacts will be associated with the removal of any asbestos in the decommissioning area. A negative pressure enclosure will be used for the removal of asbestos to prevent the material from causing any impacts.

5.12.2 Radiological Impacts There is a potential for radiological accidents during the UARR facility D&D project resulting from the uncontrolled release of radioactive materials to the work area or the environment. These releases are most likely associated with the management of contaminated liquids in the reactor tank. Uncontrolled releases of airborne contamination could also occur during the demolition of the reactor tank and segmentation of activated and/or contaminated reactor components such as the reactor core components. An uncontrolled release of radioactive material could also occur during a transportation accident.

The accidental dropping of an activated reactor component was also considered as a potential accident.

However, because the more highly activated components are located under water, the surface contamination on these parts would not be sufficiently high to release significant quantities of radioactive materials during such an incident. Such an incident would mostly likely result in additional unplanned external exposures. The airborne release fraction from dropped metal is relatively low.

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E N E R C 0* N UA NRL Decommissioning Environmental Report Rev. 0 A fire is another possible source of an uncontrolled release of radioactive materials. However, the majority of the combustibles that will be present on site will be clean materials. Potentially contaminated combustibles will include dry active waste such as personal protective clothing and rags and towels used for site cleanup and decontamination. The radioactivity contained in these materials would not be high enough to result in a significant release of during such an incident. There will be no fissile materials located on site that could result in a criticality incident because all nuclear fuel will have been removed prior to the commencement of Decommissioning activities.

5.13 Waste Management Impacts The UARR facility D&D project will generate solid LLRW, mixed waste (i.e., contaminated lead and cadmium), hazardous waste (i.e., ACM and oils and fluids drained from equipment), and potentially liquid LLRW (i.e., tank water and decontamination liquids). These wastes will be handled, stored, and disposed of according to applicable state and federal regulations. The DC will coordinate with the waste disposal site(s) regarding the site's waste acceptance criteria and pre-shipment processing requirements.

Waste processing may include volume reduction through compaction or segmentation, neutralization, stabilization, or solidification. Due to the limited size of the facility and work area, concrete rubblization beyond that required for demolition is not expected to occur on site. Complying with written procedures, standard work practices, and operating with the limits of the NRC license will ensure safe waste processing operations. The decisions as to the type and degree of waste processing will primarily be based on economics that weigh the costs of additional handling and processing compared to transferring the material off-site for treatment and/or disposal.

After the characterization surveys and sampling are complete, wastes will be wrapped, bagged, and/or containerized and staged in the appropriate designated area. Items and containers will be properly labeled as Radioactive Material and the label will indicate the external dose rate from the material. Radioactive wastes will be stored in properly secured radioactive materials storage areas. Logs will be maintained for materials placed in disposal and shipping containers.

5.13.1 Radioactive Waste Disposal Prior to disposal, all waste streams will be properly characterized according to the requirements of the disposal facility. This characterization will include qualification of primary radionuclides of concern as well as hard-to-detect radionuclides. Additionally, those radionuclides that have specific limits for Class A waste will be directly quantified or estimated based on ratios to concentrations of other radionuclides.

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SE N E R C 0 N 2,3Rev. UA NRL Decommissioning Environmental Report0 All waste will be shipped to an acceptable waste disposal site in accordance with applicable NRC and DOT regulations regarding waste packaging, labeling, and placarding. Each LLRW shipment will be accompanied by a shipping manifest as specified in Section I of Appendix F to 10 CFR 20, "Requirements for Low-Level Waste Transfer for Disposal at Land Facilities and Manifests." The waste will be manifested consistent with its classification. Only licensed transporters will be used to transport wastes from the UARR facility.

Mixed wastes may be shipped to a licensed processing facility or directly to a licensed land disposal facility depending on the nature of the waste and the treatment options available.

The consequence levels discussed in this section are described in more detail in the U.S. Department of Energy (DOE) Standard DOE-STD-1120-2005, "Integration of Environment, Safety, and Health into Facility Disposition Activities" (DOE 2005) 22

UA NRL Decommissioning Environmental Report EN ENERCON Rev. 0 6.0 MITIGATION MEASURES The following areas may be impacted by the decommissioning of the UARR:

  • Transportation
  • Meteorology, Climatology, and Air Quality
  • Noise
  • Public and Occupational Health
  • Waste Management Mitigation measures that will be used to reduce potential impacts in these areas will include:

Affected Environment Mitigation Measures Transportation Proper loading and shipping of containers and/or materials going off site Meteorology, Climatology, and Air Quality Build negative air pressure tents around work areas so that potential air contaminants are contained within work areas. Using water sprays to minimize the amount of dust that is generated Noise Limit the time of increased noises to daylight hours, with a schedule that takes account of the University's academic calendar Public and Occupational Health Constant radiological monitoring during decommissioning activities will ensure that the public and the occupational workers are safe Waste Management Proper decontamination and segregation of waste will ensure that wastes are disposed of properly.

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1E N E RC 0 NENERCONRev. UA NRL Decommissioning Environmental Report0 7.0 ENVIRONMENTAL MONITORING AND MEASUREMENT PROGRAMS This section describes the environmental monitoring and measurement programs that will be used during the decommissioning of the UARR.

7.1 Radiological Monitoring Frequent radiological monitoring will be performed during the UARR decommissioning activities.

CAMs will be used to monitor the air during selected decommissioning activities. Survey stations will be set-up to monitor personnel and equipment. All waste materials will be surveyed prior to leaving the facility for disposal.

7.2 Physiochemical Monitoring Monitoring for chemical / hazardous constituents such as asbestos will be performed as needed during the UARR decommissioning activities.

7.3 Ecological Monitoring No Ecological monitoring is required during the decommissioning of the UARR.

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  • .J E N E RC 0 NE N R UA NRL C0 Decommissioning NRev. Environmental Report0 8.0 COST BENEFIT ANALYSIS Detailed cost estimates for the completion of the UARR Decommissioning activities are included in the Decommissioning Plan. The following are some of the benefits associated with completion of the decommissioning of the UARR:
  • Increased public health and safety;

" Decreased operating and maintenance costs;

  • Improvement in the Engineering Building Environment from an air quality and waste inventory perspective

" Increased space for other activities within the Engineering Building

" Free release the facility for reuse and termination of the license.

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UA NRL Decommissioning Environmental Report E NERCON Rev. 0 9.0

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES The following is a summary of the environmental consequences related to the implementation of the proposed action:

Affected Environment Environmental Consequences Land Use Short Term Impacts - Construction and remodeling of the Engineering Building Transportation Short Term Impact - Hazardous, Solid, and Radioactive Waste Transportation Geology and Soils No Impacts Water Resources No Impacts Ecological Resources No Impacts Meteorology, Climatology, and Air Quality Short Term Impacts - Possible Air quality issues associated with construction activities Noise Short Term Impact - Noise from construction operations Cultural and Historic Resources No Impacts Visual/Scenic Resources No Impacts Socioeconomic No Impacts Public and Occupational Health Short Term Impact - Possible radiological exposure and dust above background Waste Management Short Term Impact - Disposal of Solid, Hazardous, and Radioactive Waste There will be no adverse or long term environmental impacts as a result of implementation of the proposed action.

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F.I E N E R C 0 N UA NRL Decommissioning Environmental Report Rev. 0

10.0 REFERENCES

The following references were used to develop this Environmental Report;

1. University of Arizona NRC License renewal Environmental Impact Appraisal
2. Safety Analysis Report University of Arizona TRIGA Mark 1 Research Reactor - June 1995
3. Safety Evaluation Report related to the renewal of the operating license for the TRIGA training and research reactor at the University of Arizona Docket No. 50-113 - May 1990
4. EMERGENCY PLAN FOR THE UNIVERSITY OF ARIZONA NUCLEAR REACTOR LABORATORY Facility License R-52 Docket 50-113 Revision 9 May 2003
5. Cultural Resources Assessment for the Modem Streetcar Project, Tucson, Pima County, Arizona; Allison Cohen Diehl; September 25, 2007
6. NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (NRC 2003b).
7. City of Tucson Arizona Urban Planning and Development Web Site for Historical Districts.

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