Text

Worcester Polytechnic Institute Leslie C. Wilbur Nuclear Reactor Facility Decommissioning Plan (W19-1579-003, Rev. 1)
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Issue date:	09/30/2009
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	W19-1579-003, Rev 1
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Document W19-1579-003, W19-1579-003, Rev. 1 S

DECOMMISSIONING DECOMMISSIONING PLAN for the LESLIE C. WILBUR WILBUR NUCLEAR REACTOR REACTOR FACILITY at the WORCESTER WORCESTER POLYTECHNIC POLYTECHNIC INSTITUTE Operating License Operating License No. R-61 Docket No. 50-134 50-134 Prepared Prepared for.

for:

WORCESTER WORCESTER POLYTECHNIC POLYTECHNIC INSTITUTE Preparedby:

Prepared TLG Services, Inc.

TLG Services, Connecticut Bridgewater, Connecticut September 2009 September 2009

Worcester Polytechnic Worcester Polytechnic Institute Institute Document Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning PlanPlan Page Page iii iii of viii

TABLE OF CONTENTS CONTENTS SECTION-PAGE SECTION-PAGE 1.0

SUMMARY

OF PLAN ..................................................................................

SUMMARY

.................................................................................. 1-1 1-1 1.1 In trodu ction ...........................................................................................

Introduction ........................................................................................... 1-1 1.1.1 O verview .....................................................................................

Overview..................................................................................... 1-1 Decommissioning Plan Provisions ..........................................

1.1.2 Decommissioning ........................................... 1-10 1-10 1.2 B ack groun d ........................................................................................

Background ......................................................................................... 1-11 1-11 1.2.1 Site and Facility H istory ..........................................................

History ......................................................... 1-11 1-11 1.2.2 Radiological R adiological Status .................................................................

Status .................................................................. 1-13 1-13 Reactor Facility 1.2.3 Reactor Facility Status ...........................................................

............................................................ 1-14 1-14 Reactor Decommissioning 1.2.4 Reactor Decommissioning Overview Overview .......................................

...................................... 1-15 1-15 1.2.5 Estimated E stim ated Cost .........................................................................

........................................................................ 1-16 1-16 1.2.6 A vailability of Funds ................................................................

Availability ............................................................... 1-16 1-16 1.2.7 Program Quality Assurance Assurance ....................................................

.................................................... 1-16 1-16 2.0 DECOMMISSIONING ACTIVITIES DECOMMISSIONING ACTIVITIES ..........................................................

.......................................................... 2-1 2-1 2.1 Decommissioning Decommissioning Alternative ..............................................................

.............................................................. 2-1 2-1

2.2 2.3 2.3.1 A Facility Operating History 2.2.2 Current Current Radiological Decommissioning ctivities Activities and Tasks Facility Radiological Status ..................................................................

2.2.1 Facility Operating History .........................................................

Radiological Status of the WPI Facility Facility ......................

D ecom m issioning Tasks .......................................................................

................................................................... 2-8 2-1 2-1 2-1 2-1

...................... 2-2 2-2 2-8 2-8 2-8 2 .3.2 Schedule 2.3.2 S ch edu le ....................................................................................

.................................................................................... 2-18 2-18 2.4 Decommissioning Organization Decommissioning Organization and Responsibilities .......................

Responsibilities ....................... 2-19 2-19 W PI Reactor 2.4.1 WPI Reactor Director D irector ...............................................................

............................................................... 2-20 Radiation Safety Officer ..................................................

2.4.2 WPI Radiation .................................................. 2-22 2.4.3 Decommissioning Decommissioning Consultant ..................................................

Consultant .................................................. 2-22 2.4.4 Contractor A ssistance ..............................................................

Contractor Assistance .............................................................. 2-23 2.5 T raining Program Training P rogram ...............................................................................

............................................................................... 2-24 G eneral Site Training ..............................................................

2.5.1 General .............................................................. 2-25 2.5.2 Radiation Worker Training .....................................................

Training ..................................................... 2-25 2.5.3 Respiratory Protection Training ..............................................

.............................................. 2-25 2.6 Decontamination and Decommissioning Decontamination Decommissioning Documents and Guides Guides .... 2-26 2.7 .....................................................................

Facility Release Criteria ..................................................................... 2-26 3.0 OCCUPATIONAL AND PUBLIC HEALTH AND OCCUPATIONAL AND SAFETy SAFETY ...................

................... 3-1 3-1 3.1 R adiation Radiation Protection .............................................................................

............................................................................. 3-1 3-1 3.1.1 Ensuring As Low As Reasonably Achievable Achievable (ALARA)

Radiation Exposures Radiation 3.1.2 Health E xposures ..................................................................

Radioactive Materials 3.1.3 Radioactive H ealth Physics Program ............................................................

Materials Controls Controls ...............................................

3-1 3-1 3-3 3-3 3-12 3-12

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TABLE OF CONTENTS (Continued)

SECTION-PAGE SECTION-PAGE 3.1.4 Dose D ose Estimates E stim ates .........................................................................

........................................................................ 3-13 3-13 3.2 Radioactive Waste Management Radioactive Management ........................................................

....................................................... 3-16 3-16 Radioactive Waste Processing .................................................

3.2.1 Radioactive ................................................ 3-16 3-16 Radioactive Waste Disposal..

3.2.2 Radioactive Disposal ....................................................

................................................... 3-16 3-16 3.3 ..................................................

General Industrial Safety Program ................................................... 3-18 3-18 3.4 Radiological Accident Analyses ..........................................................

......................................................... 3-19 3-19 4.0 PROPOSED FINAL RADIATION SURVEY PLAN .................................

PROPOSED ................................. 4-1 4-1 4.1 Description Description of Final Status Survey Plan .............................................

............................................. 4-1 4.1.1 Review and Approval Approval of Final Status Survey Plan .................. .................. 4-3 4.1.2 Means for Ensuring that all Equipment, Systems, Structures and Site are Included Structures Included in the Survey Plan .............. 4-5 4.1.3 Means for Ensuring that Sufficient Data is Included to Achieve Achieve Statistical G oals ...........................................................

Goals ........................................................... 4-5 4.2 4.2* .................................................................

Background Survey Results ................................................................. 4-5 4.3 Final Release Criteria - Residual Radiation and Contamination Contamination L ev els .....................................................................................................

Levels ..................................................................................................... 44-5 -5 4.4 Measurements for Demonstrating Measurements Demonstrating Compliance Compliance with Release C riteria ..................................................................................................

Criteria .................................................................................................. 44-6 -6 Instrumentation - Type, Specifications 4.4.1 Instrumentation Specifications and Operating C on d ition s ...................................................................................

Conditions ................................................................................... 44-6 -6 4.4.2 Measurement Measurement Methodology Methodology for Conduct Conduct of Surveys ................. ................. 4-7 4.4.3 Scan Surveys Surveys ............................................................................

............................................................................ 4-10 4-10 4.4.4 Soil Sampling Sam pling ...........................................................................

........................................................................... 4-10 4-10 Sam ple A 4.4.5 Sample nalysis .......................................................................

Analysis ....................................................................... 4-10 4-10 4.4.6 Investigation Investigation Levels ...............................

,................................. 4-104-10 4.5 Methods Methods to be Employed for Reviewing, Analyzing, and A u ditin g D Auditing ata ......................................................................................

Data ...................................................................................... 4-11 4-11 4.5.1 Laboratory/Radiological Laboratory/Radiological Measurements Measurements Quality A ssu ran ce .................................................................................

Assurance ................................................................................. 4-11 4-11 4.5.2 Supervisory Supervisory and Management Management Review Review of Results .................. 4-11

.................. 4-11 5.0 TECHNICAL SPECIFICATIONS TECHNICAL ...............................................................

SPECIFICATIONS ............................................................... 5-1 5-1 6.0 PHYSICAL SECURITY PLAN PHYSICAL SECURITY PLAN ....................................................................

.................................................................... 6-1 6-1 7.0 EMERGENCY EMERGENCY PLAN PLAN ....................................................................................

.................................................................................... 7-1 7-1

8.0 ENVIRONMENTAL ENVIRONMENTAL REPORT ....................................................................

REPORT .................................................................... 8-1 8-1

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TABLE TABLE OF CONTENTS (Continued)

CONTENTS SECTION-PAGE SECTION-PAGE 9.0 CHANGES CHANGES TO THE DECOMMISSIONING DECOMMISSIONING PLAN ................................. ................................. 9-1 10.0

10.0 REFERENCES

R EFER EN CES .............................................................................................

............................................................................................. 10-1 10-1 TABLES TABLES 1.1 Profile of the W WPI PI LCWNRF LCW NRF Reactor .............................................................

............................................................. 1-9 1.2 Decommissioning Cost Summary ...........................................

Radiological Decommissioning ........................................... 1-16 1-16 2.1 List of Expected Expected and Potential Radionuclides ................................................

Radionuclides ................................................ 2-8 2-8 2.2 Termination Screening License Termination Screening Values for Building Surface C ontam in ation ...............................................................................................

Contamination ............................................................................................... 2-28 2-28 2.3 Termination Screening License Termination Screening Values for Surface Surface SoiL Soil ..............................

............................ 2-29 2-29 2.4 Decommissioning Worker Decommissioning Worker Training Outline .................................................

Outline ................................................. 2-31 3.1 Typical Typical Health Physics Equipment and Instrumentation .............................

Instrumentation ............................. 3-6 3-6 3.2 Dose Estimate Breakdown Breakdown by Major Tasks and Activities .......................... .......................... 3-15 3-15

3.3 8.1 Estimated Concentrations Concentrations of Radioactivity Control Blade (as of December Summary of Environmental Environmental Impact Radioactivity in the Regulating Decem ber 2008) ............................................................

Impact Assessment FIGURES FIGURES Assessment ...........................................

3-16 3-16 8-3 8-3 1.1 State and Local Maps of the Area Surrounding WPI .................................... .................................... 1-2 1.2 W WPIP I Campus C am pus M Map ap ............................................................................................

............................................................................................ 1-3 1.3 Photographic View of the Reactor Reactor Facility Building Building Exterior ....................... 1-4 Exterior .......................

1.4 Photographic Views Views of the Reactor Reactor FacilityFacility Lower Level. Level ..............................

............................. 1-5 1.5 Photographic Views of the Reactor Reactor Facility Operating Level LeveL........................

...................... 1-7 1.6 Rendering of the Reactor Reactor Pool, Biological Shield and Experimental Experimental F a cilities .............................................................................................................

Facilities ............................................................................................................. 1-8 2.1 Reactor Core Drawing and Photographic Photographic View ..............................................

.............................................. 2-5 2-5 2.2 Reactor Pool and Biological Biological Shield Cross-Section Drawing .......................... .......................... 2-7 2-7 2.3 LCW NRF Decommissioning LCWNRF Decommissioning Schedule Schedule ..........................................................

.......................................................... 2-19 2-19 2.4 WPI-RDP Decommissioning Organization WPI-RDP Decommissioning Organization ...................................................

................................................... 2-21 2-21 APPENDICES A Letter of Financial Financial Com m itment .......................................................................

Commitment ................................................................... A-1

B Revised Technical Specifications for Decommissioning Technical Specifications Decommissioning .................................

................................. B-1B-i

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Rev. No. CRA No.

CRANo. Date REVISION LOG REVISION Item Revised Reason for Revision Revision 0 N/A 03/27/2009 N/A Original Issue 1 N/A 09/22/2009 Sections 1.2.2, Incorporate WPI responses responses to 1.2.7.3, 2.3.1.2, 1.2.7.3,2.3.1.2, NRC RAIs dated June 23, 2.5, 2.7, 3.1.2, additional NRC 2009 and additional 3.1.4 and 4.4.1 comments comments from September 14, 2009 telecom.

telecom .

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APPROVALS APPROVALS Officer Radiation Safety Officer 16-1-07 David Adams Date Reactor Facility Reactor -=

Facility Director 1erle ichae rley ItiiJ Date Radiation, Health

& Safety Committee

& J)~~

\ aQ 1/0-'( /u'1 Messier David Messier Date

Worcester Worcester Polytechnic Institute PolytechnicInstitute Document Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Page vii of Page of viii

ALARA ACRONYMS and ABBREVIATIONS ACRONYMS As low As Is Reasonably Reasonably Achievable Achievable ABBREVIATIONS ANSI American National American National Standards Standards Institute ASME AS ME American Society American Mechanical Engineers Society of Mechanical CDE CDE Committed Committed. Dose Equivalent Equivalent CFR Code of Federal Federal Regulations Regulations cm cm centimeter centimeter COMPASS COMPASS COMPASS Computer Computer Code Version 1.0.0 (development (development sponsored by the NRC) cpm cpm counts counts per minute D&D D&D Decontamination Decommissioning Decontamination and Decommissioning DAC DAC Derived Derived Air Concentration Concentration (see 10 CFR 20)

DCGLw DCGLw Derived Concentration Guideline Levels Derived Concentration Levels DCGLemc Elevated Elevated Measurement Measurement Comparison Comparison DCGL DCGL DECON DECON Decontamination Decommissioning Option Decontamination Decommissioning Option Director Director WPI Reactor Director Director dpm dpm disintegrations disintegrations per minute DQO Data Quality Quality Objective EDE EDE Eye Dose Equivalent (see 10 CFR 20)

ENTOMB ENTOMB Entombment Entombment Decommissioning Option Option FSS Final Status Survey Survey g gram, a unit of mass

GM GST HEPA HP HP LCWNRF LCWNRF MARSSIM MARSSIM Geiger-Mueller Geiger-Mueller General Site Training High Efficiency Health Physics Health Physics Leslie Particulate Air (Filter)

Efficiency Particulate Leslie C. Wilbur Nuclear Reactor Multi-Agency Radiation Radiation (Filter)

Reactor Facility Survey and Site Investigation and Investigation Manual, Manual, NUREG-1575 NUREG-1575 MA MA Massachusetts Massachusetts mR milli-Roentgen, 10. 10-33 Roentgen Roentgen mrem mrem millirem, 10.

10-33 rem rem MSHA MSHA U.S.

U.s. Mine Safety and Health Administration Health Administration mSv mSv milli-Sievert milli-Sievert (unit of dose equivalence, see 10 CFR 20), 10. 10-33 Sievert Sievert MW MW Megawatt Megawatt NIOSH NIOSH National National Institute for Occupational Occupational Safety and Health NQA NQA Nuclear Quality Nuclear Quality Assurance NRC NRC U.S. Nuclear Regulatory Commission Nuclear Regulatory Commission OSHA OSHA Federal Occupational Federal Occupational Safety and Health Acts pCi pCi pico-curie, pico-curie, a unit of radioactivity radioactivity (2.22 disintegrations disintegrations per min.) 10. 12 curie 10-12 POL POL Possession-Only Possession-Only License License ppm parts per million million QA QA Quality Assurance QAPP QAPP Quality Quality Assurance Project Project Plan Plan QC QC Quality Control Control

Worcester Polytechnic Worcester Institute Polytechnic Institute Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Reactor Decommissioning Decommissioning PlanPlan Page viii of viii Page

ACRONYMS and ABBREVIATIONS ACRONYMS ABBREVIATIONS (Continued) rem Roentgen equivalent equivalent man (rem) is a unit of absorbed absorbed radiation dose: 100 rem = 1 Sv RHSC Safety Committee Radiation Health and Safety RSO Radiation Safety Officer Officer RWP Permit Radiation Work Permit SDE Shallow Dose Equivalent (see 10 CFR 20)

Sv Sievert (unit of dose equivalence, equivalence, see 10 10 CFR 20)

TEDE Total Effective Dose Equivalent Equivalent (see 10 CFR 20)

WPI Worcester Worcester Polytechnic Polytechnic Institute WPI-RDP WPI LCWNRF LCWNRF Reactor Decommissioning Project Reactor Decommissioning Project

Worcester Polytechnic Institute Worcester Polytechnic Institute Document Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Page 1 of 1, Page Section 1, of 22

1.1 INTRODUCTION

INTRODUCTION 1.0

SUMMARY

OF PLAN PLAN 1.1.1 Overview 1.1.1 Overview Decommissioning Plan (DP) is for the Leslie C. Wilbur Nuclear Reactor This Decommissioning Reactor Facility Facility (herein referred referred to as "LCWNRF", or "Reactor Facility").

Facility"). The LCWNRF is situated on the Worcester situated Worcester Polytechnic Polytechnic Institute (WPI) campus in Worcester, Worcester, Massachusetts, approximately approximately 40 miles west of Boston. The LCWNRF is housed inin portion of the Washburn a portion Washburn Shops Shops and Stoddard Laboratories Laboratories Building, locatedlocated between West and Boynton Streets. The geographical between geographical location location of WPI campus is shown on Figure 1.1. Figure Figure 1.2 provides an overall overall map of the WPI Campus. An An exterior photograph exterior photograph of the Washburn Shops-Stoddard Laboratories Washburn Shops-Stoddard Laboratories Building, whichwhich houses the reactor facility, is presented in Figure 1.3. Figures 1.4 and 1.5 present present photographic views from the two levels of the LCWNRF. Figure 1.6 presents photographic presents a rendering rendering of the reactor pool, biological biological shield and experimental experimental facilities.

The LCWNRF LCWNRF provided graduate and undergraduate provided graduate undergraduate students reactor students with reactor operating experience operating experience and experimental experimental practice in the fields of nuclear nuclear engineering, metallurgy, chemistry chemistry and physics, as well as irradiation irradiation services services for other other teaching, medical and industrial institutions. WPI discontinued discontinued routine operation operation of the reactor reactor on June 30, 2007 (Ref. 1) and submitted (Ref. 1) submitted an application application to the Nuclear Nuclear Regulatory Regulatory Commission (NRC) for a possession-only possession-only license license (Refs. 2 and 3). On 3). On subsequently granted Amendment No. 11 to Operating August 26, 2008 NRC subsequently Operating License License No. R-61, placing placing the LCWNRF LCWNRF reactor reactor in a Possession-Only Possession-Only License status (Ref. 4). WPI desires to proceed (Ref. proceed with decommissioning decommissioning the LCWNRF LCWNRF and the termination termination of the associated reactor license. license. Accordingly, WPI has filed the appropriate decommissioning amendment appropriate decommissioning amendment requests with NRC along with this DP.

The LCWNRF is contaminated contaminated with limited amounts of radioactive radioactive material, principally principally contained contained in activated metallic core components. Scoping surveys surveys indicate indicate that practices employed practices employed by WPI to minimize the spread spread of contamination contamination were effective contamination was not found outside of the reactor pool.

effective and contamination The goal of the proposed D&D activities is termination termination of WPI's NRC License R-61, Document Document No. 50-134 50-134 and release release of the LCWNRF for "unrestricted use." The term "unrestricted "unrestricted use" use" means that there means that there will be no will be no future future restrictions restrictions on the use of the Washburn Stoddard Laboratories Washburn Shops and Stoddard Laboratories building other than those imposed by the City of Worcester zoning ordinances. WPI holds a separate separate Massachusetts Massachusetts Agreement State byproduct Agreement byproduct material license for possession and use of radioactive materials materials at other campus campus locations:

locations: that license will not be affected by this

decommissioning.

decommissioning.

Worcester Polytechnic Institute Worcester Polytechnic Institute Document W19-1579-003, Document W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Section Page 2 of 22 Section 1, Page

This DP has been prepared NUREG-1537, NUREG-1537, Licensing Rev.

Licensing of Non-Power NUREG-1757, 0,

prepared using the guidance and format recommended Guidelines Guidelines for Reactors (Ref.

Non-Power Reactors NUREG-1757, NMSS Decommissioning Preparing Preparing and (Ref. 5) and incorporates Decommissioning Standard and Reviewing incorporates additional Standard Review Plan (Ref.

profile for the LCWNRF reactor is provided in Tables Tables 1.1 and 1.2.

recommended in Applications Applications additional guidance for guidance from (Ref. 6). A summary in the FIGURE 1.1 FIGURE 1.1 STATE AND LOCAL MAPS OF THE AREA SURROUNDING SURROUNDING WPI Fitchburg (a) State Map (a) State Map

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Worcester Polytechnic Institute Worcester Polytechnic Institute Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Section Section 1, Page 3 of 22 1, Page

FIGURE 1.2 FIGURE CAMPUS MAP WPI CAMPUS MAP 1 Air Air Force andAerospace Force ilnd Aerospace Studies Studies 66 Boynton Hall Boynton Halt 11 Fuller laboratories 11 Fuller Laboratories

-WPI 77 QWPI Campus Map Map Alden Memorial 2 Alden 3 Alhmni Memorial Gym Alumni Gym 4 Atwater Atwater Kent 5 BartlettCenler BartlettCenter Laboratories Kent Laboratories 88 99 10 10 Campus Campus Center Campus COllegiate 20 Center Campus Police Police Religious CollegiateRe TowmbnrgaRoad 20 Trowbridge Road Glf igiowsClr 12 WPllife 12 13 14 14 Goddard GoddardHall GOIdan Sciences and WPILifeSciences Bioengineering Bioengineering Center Hall library GordonLibrary and Cenler

~. 15 Harrington Auditorium Harrington Auditorium 16 HeallhCenter Health Center 17 HigginsHous Higgins House 18 Higgins Laboratories Higgins Laboratories 19 Hughes Hughes House House 20 20 Interatlional House International House 21 21 Jeppson House Jeppson House (One Drury (one Drury Lana)

Lane) 22 22 Kavan Hall Kaven Hal 23 23 OASIS OASIS 24 24 OlinHall Olin Hal 25 25 Plant Services Plant Services 26 26 Power House Power House 27 27 Pro}ectCAt'ller Proect Cantor 28 28 Salisburylaboratories Salisbury Laboaatories 29 29 Skull Tomb SkultTomb 30 Stratton Hall Straiton Hall 31 31 Student Student Development Deselopmentane Cotmsellng CounselingGenter Center 32 WashburnShops and Washburn Stoddard laboratories StoddardLaberatories 33 85 Pres.ott Street Prescott Streel STUDENT RESIDENCES STUDENTAESIDENCES A Daniels Hall A Daniels Hall B 16 Elbbrogo Eibridoe C Elswortlh Ellsworth Apadments Apartments D Founders Founders HallHall E Fuller Fuller Apartennts Apartments F Unlty Unity House House G IllStilule G Institute Hall Hall H Morgan MorQan HallHall IJ Sanford Santora Riley Hall Riley Hall K 22 22 Schussler Snhusslee L Sioddard Complex StoddardComplex M 25 Trowoldge 25TlowbridQe N East East Hal Hall GREEK GAEEK HOUSES HOUSES G1 Alpha 61 AlpnaChiChi Rho Rho G2 Alpha 62 AlphaGamma GammaDella Seloa 63 AlphaTauOme(la G3 A]ps Tau Omega G4 Apnha G4 AJpha XtDella XI Delt!

G5 G5 Lambia Lambda Cho Alpha Chi Alpha G6 66 PhiGamma Phi Gamma Delta Delta G7 G7 Phi Phi Kappa Kappa Theta Thela G8 Phi 68 Phi Sigma Sigma Kappa Kappa G9 69 Phi Phi Sigma Sigma Sigma Sigma 610 Sigma G6O Sigma Alpha AlphaEpsilon Epsilon

- HiIIldl~i.Rlln, G11 Sigma GOt Sigma PhiPhi Epsilon Epsilon

.. HIUIlII~,WllkW;rt G12 G12 Sigma Sigma PI PI G13 Tau G13 TauKappa KappaEpsilon Epsilon G14 TnetaChi G14 ThetaChi G15 G15 Zeta Zela Psi Psi Leslie C. Wilbur Nuclear Nuclear Reactor Facility (Located (Located in the Washburn Washburn Shops and Stoddard Laboratories Building)

Stoddard Laboratories

Worcester Polytechnic Worcester Institute PolytechnicInstitute Document W19-1579-003, Document W19-1579-003, Rev. 1 Reactor Decommissioning Plan ReactorDecommissioning Plan Section 1, Page Page 4 of 22

PHOTOGRAPHIC VIEW PHOTOGRAPHIC FIGURE 1.3 FIGURE VIEW OF THE REACTOR REACTOR FACILITY BUILDING EXTERIOR BUILDING EXTERIOR
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PHOTOGRAPHIC PHOTOGRAPHIC VIEWS FIGURE 1.4 VIEWS OF THE REACTOR REACTOR FACILITY LOWER LEVEL
(a) Thermal Column Column Shield Door Door
(b) Pool Water Treatment & Effluent Treatment System & Tank Effluent Hold-up Tank
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PHOTOGRAPHIC VIEWS PHOTOGRAPHIC FIGURE FIGURE 1.4 (continued)
VIEWS OF THE REACTOR FACILITY LOWER LOWER LEVELLEVEL I- y
.... J (c) Beam Port Access Plug
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PHOTOGRAPHIC FIGURE 1.5 PHOTOGRAPHIC VIEWS OF THE REACTOR FACILITY OPERATING OPERATING LEVEL LEVEL
(a) Operating Operating Floor - East View View
(b) Operating (b) Operating Floor Floor - West West View View
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RENDERING RENDERING OF THE REACTOR FIGURE 1.6 BIOLOGICAL SHIELD AND REACTOR POOL, BIOLOGICAL EXPERIMENTAL FACILITIES EXPERIMENTAL FACILITIES
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PROFILE OF THE WPI LCWNRF PROFILE TABLE 1.1 LCWNRF REACTOR REACTOR REACTORMATEiUAlJS REACTOR MATERIALS Fuel Fuel Uranium aluminum alloy, 19.75% enriched enriched Moderator Moderator High purity light water water Reflector Reflector High purity light water water and graphite Coolant purity light water High IJurity)ight water Control Boral and stainless stainless steel steel Structural Structural material material Aluminum Aluminum Shield Water filled aluminum lined concrete concrete pool pool
, STRUCTURAL STRUCTURAL DIMENSIONS
~ 0" '"
DIMENSIONS Pool 8 feet by 8 feet by 15 feet deep Core (active portion) 15 inches inches by 15 by 24 inches high Grid box 9x6 array of 3-inch modules modules Beam Beam port one, 66 inches diameter diameter Thermal Thermal column One, 40 inches by 40 inches in cross-section cross-section STRATEGIC MATERIALS STRATEGWMATERIALS
. ". . . . :, J.'
Burn-up Burn-up ] Approximately Approximately 1% 1% U-235 THERMAL CHARACTERISTICS THERMAL CHARACTERISTICS(Calculated) (Calculated)
Operating Operating power power 1 kW (maximum 1959-1967) 1959-1967) and 10 kW (maximum 1968-2007) 1968-2007)
Temperature, Temperature, water 130OF 130 0 F (maximum)
Maximum Maximum powerpower peaking peaking factor 2.17 2.17 Maximum Maximum hot channel factor 1.51 1.51 2
Maximum heat flux Maximum 400 Btu/hr-ft Btulhr-ft2 Specific power (clean, cold) Watt/g U-235 2.5 Wattlg U-235 Maximum Maximum gamma heat in core 11 Watt/liter Watt/liter NUCLEAR CHARACTERISTICS (Calculated)
NUCLEA:llCHARACTERISTlCS (Calculated)
Average Average thermal thermal flux 8.3x1010 n/cm22 sec 8.3x1010 Average Average fast flux 11x1010 n/cm 11xlOlO n/cm 22 sec Maximum Maximum operating excess excess reactivity 0.5% delta klkelI k/keff Critical mass 4.0 kg U-235 U-235 Temperature Temperature coefficient -1.63x10-44 delta klkelIPer
-1.63x10* k/keff per degree degree C Void coefficient coefficient -2.4x10-33 delta k/keff
-2.4x10* klkelI per 1% void Prompt Prompt neutron neutron lifetime microseconds 61.2 microseconds Delayed Delayed neutron fraction 0.0077 CONTROL SAFETY ELEMENTS CONTROL ELEMENTS Number 3 vertical vertical blades blades Dimensions Dimensions 10.5 inches wide by 40.5 inches long by 0.375 inches inches thick Material Material Boral Reactivity Reactivity Control 3.5% delta klkelI k/keff each, minimum minimum Total Total worth, 3 blades 12%
12% delta k/keff klkelI Maximum withdrawal rate Maximum withdrawal 7.5 inches/minute (Note: Table 1.1 is continued continued on next page)
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TABLE 1.1 1.1 (continued)
PROFILE OF THE WPI LCWNRF REACTOR PROFILE REACTOR CONTROL CONTROL REGULATING.ELEMENTS REGULATING ELEMENTS Number 1 vertical blade Dimensions Dimensions 10.65 inches inches wide by 40.5 inches long by 0.125 inches thick Material Stainless Stainless steel Reactivity Control Reactivity 0.7% delta k/keff klkelf Maximum withdrawal withdrawal rate 3.8 inches/minute inches/minute STANDARD FUEL FUEL Number of elements 21 + 113 1/3 for minimum critical loading Fuel alloy Uranium-Aluminum Uranium-Aluminum material Clad material Aluminum Fuel enrichment enrichment U-235 19.75% enriched enriched Number of plates per element 18 Plate thickness 0.060 inches inches (1.52mm)
COOLING SYSJ-EM" COOLING SYSTEM' Coolant Coolant Pool water water Type cooling convection Natural convection Temperature Temperature 130OF 130 0 F (maximum)
Purity required required 0.5x10 66 ohm-cm 1 ppm - 0.5x10 ohm-em 1.1.2 Decommissioning Decommissioning Plan Provisions Provisions This DP provides the following information information associatedassociated with the WPI LCWNRF LCWNRF Reactor Decommissioning Reactor Decommissioning Project (WPI-RDP):
(WPI-RDP):
" A description of the present present radiological radiological condition of the LCWNRF and site environs enVIrons
" AA description description of the planned planned approach approach to be employed employed
" Descriptions Descriptions of the methods that will be utilized to ensure protection protection of the health and safety of the workers workers and to protect the environment environment and the public from radiological hazards
" A A description description of of the the physical security and material accountability controls material accountability controls that will be in place place during the various project project phases phases
" AA description description of radioactive radioactive waste management management and disposal
" AA cost cost estimate estimate for decommissioning decommissioning the LCWNRF LCWNRF and a discussion of the source source of funding for these activities activities
*" A A decommissioning decommissioning project schedule
" A A description description of the applicable applicable quality assurance assurance program
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*" AA description
" An description of An Environmental of the trammg training program to be established for personnel performing work in support of the projectproject Environmental Report concerning the expected impact of performing decommissioning activities performing the the
1.2 BACKGROUND
BACKGROUND 1.2.1 Site and Facility History The LCWNRF was made possible by a grant of $150,000 $150,000 from the u.s. U.S. Atomic Energy Commission in June 1958. The LCWNRF reactor was constructed by the the General Electric Company as a standard 1-kW General 1-kW (thermal)
(thermal) open-pool training reactor, and first achieved criticality criticality on December 18, 1959. The reactor license was upgraded to 10-kW (thermal) upgraded (thermal) in 1967, and the LCWNRF reactor first achieved 10-kW operation on January 31, 1968.
The LCWNRF reactor license was renewed in 1982, which extended extended the operating license for 20 years. In 1989, the reactor was converted from HEU fuel (93% U-235) to LEU fuel (19.75% U-235). No modifications modifications were made to the reactor reactor other than itself. In February 1992, a new solid-state-based control panel replaced the fuel itself. replaced the vacuum-tube-based control panel. The control rod drive motors and original vacuum-tube-based position sensors were also upgraded at that time.
The primary use of the LCWNRF reactor reactor was in support of WPI Nuclear Nuclear Engineering-based laboratory Engineering-based laboratory activities activities and student projects. The reactor reactor provided provided undergraduate undergraduate and graduate graduate students, under under close supervision supervision of qualified qualified personnel, with reactor operating experience and experimental experimental practice in the fields of nuclear nuclear engineering, metallurgy, chemistry, and physics.
The LCWNRF LCWNRF is located in the Washburn Washburn Shops and Stoddard Stoddard Laboratories Laboratories Building, an academic academic facility on the WPI campus about one one mile from the center center of of Massachusetts. That building is located Worcester, Massachusetts. located at the top of a small hill, surrounded surrounded by other academic academic buildings. The nearest dormitories dormitories are located more than 500 feet away in various various compass compass directions.
The reactor reactor is a light-water light-water cooled, and moderated, heterogeneous heterogeneous reactor, fueled approximately 4 kg of 19.75%
with approximately enriched U-235. The core is located 19.75% enriched located in the center center of a pool of de-mineralized de-mineralized water eight feet square square by 15 feet deep. There There is a minimum minimum oftenof ten feet of water water above above the top of the the core.
A typical core configuration is based core configuration based onon 21 full elements, elements, plus one-third one-third of anan element, in a rectangular rectangular array. The one-third one-third element element consists of of a removable-removable-plate plate element withwith six plates plates loaded loaded (of the the normal normal 18 plates).
plates). A one-curie one-curie Pu-Be
start-up start-up source blades source occupies occupies one blades and a single, manually one module module adjacent manually actuated adjacent to the active actuated stainless-steel active core.
core. Three Boral stainless-steel regulating regulating blade Boral safety blade control control the
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reactivity. The blades move vertically in two shrouds, extending core.
core. Figure 2.1 depicts the configuration natural convection. The thermal configuration of the reactor extending the length reactor core components.
The core is moderated, reflected, and cooled, by light water that is circulated length of the circulated by thermal column side of the core is also reflected by by by graphite. Core elements contained in a grid box enclosed elements are contained enclosed on four sides to confine the flow of cooling water to the channels channels between between and surrounding surrounding the elements. The grid box and contents, as well as the blade drive mechanisms, are supported by a suspension frame from a reactor bridge. The cold, clean, core with control blades has less than 0.5% excess reactivity. The safety blades, because because of of their location and large large surface area, have a total shutdown reactivity reactivity worth of of approximately 12% delta k/keff.
approximately There is an in-core in-core sample irradiation device, which consists of a sample holder on a track arranged so that the contents track arranged contents of the sample holder may be remotely remotely placed placed adjacent to the core, from the bridge adjacent bridge above. An additional additional area radiation radiation detector detector is located on the reactor bridge approximately approximately one meter above the pool surface.
There are two experimental experimental facilities, external external to the reactor core: the beam beam port, and thermal column, depicted in Figure Figure 2.2. The beam beam port is provided as a means means of access access to fast neutrons. The beam port is an air-filled, six-inch diameter diameter aluminum tube, which extends from the reactor core face and terminating terminating in a flange at the biological shield face. In its now permanent permanent inactive inactive state, it is shielded by a shutter inside the pool and a shield plug in the tube at the biological biological shield. An area radiation detector detector is located near the exterior of the beam port.
Provisions are made for venting gasses generated in the port to the building exhaust exhaust system, and for collecting seepage that may accumulate collecting and draining any seepage between between the port tube and surrounding surrounding biological shield shield concrete.
concrete. Such collecting collecting and draining occurs via tubes embedded embedded in the biological shield.
The thermal column is a graphite-filled, graphite-filled, horizontal penetration through the horizontal penetration biological biological shield that provided a means of access to thermal neutrons. The column column consists of an aluminum case, 40 inches square in cross section, and about six feet feet long. Access Access to the interior of the thermal column is by a dense, 5.5-foot thick, 2.5-concrete shield door at the biological foot square concrete biological shield face. The shield door is mounted on wheels that run on rails set in the concrete floor, and can be moved moved perpendicular perpendicular to the shield face. Provisions Provisions are made for venting venting gasses generated generated in the thermal thermal column to the building exhaust embedded in the exhaust system, via tubes embedded biological biological shield. An area radiation radiation detector is located on the external external pool wall adjacent to the thermal column door.
adjacent
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1.2.2 Radiological 1.2.2 Radiological Status An historical site assessment assessment and radiological radiological surveys were conductedconducted at LCWNRF LCWNRF during the summer of 2008. Documentation Documentation related related to operation operation and use of the reactor was reviewed to determine determine if spills, leaks or equipmentequipment failure have ever or or were likely to have occurred that would have resulted in radioactive radioactive contamination contamination occurring in unexpected unexpected locations, or if unexpected radionuclides could be present unexpected radionuclides present within within the facility's structures, systems and components. Documents reviewed reviewed included reactor operating logs, experiment experiment performance performance logs and periodic radiological survey monitoring results. Additionally, a number number of present and former personnel associated associated with the reactor reactor (i.e., Reactor Directors, Reactor Reactor Reactor Operators, Site RSO, students students (former) and chairman chairman of the RSHC) were questioned questioned as to the likelihood of there being any operational operational events or experiments experiments performed, such as leaks, spills, equipment equipment failures, or monitoring results obtained obtained that would indicate that unusual radionuclides radionuclides were produced contamination was released produced or contamination released to unexpected unexpected locations (i.e., outside of the reactor pool or water purification purification system).
As a result of these reviews and inquiries, there were no indications of any spills, leaks or equipment equipment failures having occurred that would have released released contamination to unexpected contamination unexpected places places (e.g., floors and drains external to the biological
shield, ventilation system, sinks or soil, ground water or outside surfaces on or around the building). Additionally radionuclides activation Additionally there were radionuclides were produced within the facility, except equipment and structures activation of equipment beam port and thermal column.
were no indications structures in close proximity long-lived indications that any long-lived except those produced produced by neutron proximity to the reactor core, the neutron or the Scoping conducted to search for indications Scoping surveys were conducted indications of potential potential hidden hidden contamination. Large-area Large-area scintillation scintillation detectors were used for direct scanning of of gamma, beta and alpha radioactive radioactive surface contamination and to scan surface contamination scan surfaces at at locations where where spills, leaks or tracking of contamination contamination had a potential for for occurring (e.g., on floors and walls around the reactor pool and on and around equipment, drains, gutters, sinks, and lab benches). Additionally, direct gamma gamma radiation scans were performed performed using lx1 lxl and 2x2 inch Nal NaI detectors to search for for contamination deposits within equipment external indications of contamination external to the biological biological shield. Results of the scoping surveys did not reveal evidence evidence of contamination, and confirmed the conclusions conclusions drawn from the historical historical site assessment. In summary, there are no indications indications that radioactive contamination is present outside of the radioactive contamination reactor pool or biological biological shield.
Radioactivity Radioactivity within within the facility is essentially essentially limited to the interior of the reactor reactor pool and the associated associated experimental experimental facilities. The maximum exposure rate encountered was at the geometric encountered geometric center center of the reactor core, predominantly predominantly from the activated stainless-steel regulating activated stainless-steel regulating blade, with an exposure exposure rate of 125 milliRem milliRem
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per hour at 13 cm through water (with a calculated in-air exposure milliRem per hour at one meter).
milliRem Aside from the regulating blade, the radiation and originated originated from otherother activated exposure rate of about 17 radiation exposure rates encountered encountered were low, activated core components, a portion of the beam port port liner near the reactor reactor core and small metallic metallic hardware items within the thermal column, limited to no more than a few milliRem per hour. Actual exposure exposure rates from these other items may be lower, as radiation radiation from the regulating blade and the spent fuel still stored in the pool may have interfered with the radiation have interfered measurements.
Based upon the direct radiation exposure rate measurements, radiation exposure measurements, a radiological radiological inventory was calculated for the activated activated materials. The majority of the residual residual radioactivity at the LCWNRF LCWNRF is contained contained in the activated activated regulating blade, with an estimated estimated 56 mCi of radioactivity; radioactivity; a mixture of Mn-54 (<1%),
<<1%), Fe-55 (68%), Ni-59 Ni-59
(<1%),
<<1 %), Co-60 (27%) and Ni-63 (4.2%). Based on direct radiation measurements, measurements, the the radioactivity in the remaining structures, systems radioactivity components is not expected systems and components expected to exceed a small fraction of that total.
Further radiological radiological characterization characterization of these radioactive items cannot be completed completed until the start of decommissioning, when destructivedestructive sampling techniques techniques can be be
employed.
employed.
Radioactive surface Radioactive contamination was not found on building or structural surface contamination structural surfaces surfaces exterior to the reactor reactor pool's gutters and drains, floor drains, nor reactor pool, the reactor nor was it detected on a limited number of accessible interior surfaces of the ventilation ventilation and reactor water cleanup cleanup systems. Additionally, Additionally, no elevated radioactivity levels elevated radioactivity were observed observed from NaI detector gamma scans made on these items or areas.
1.2.3 Reactor Reactor Facility Facility Status The Reactor is currently currently permanently shut down, with the fuel removed from the core and stored in racks in the reactor pool. By letter dated June 27, 2007 (Ref. (Ref. 1),
WPI certified certified to NRC that it was progressing toward decommissioning decommissioning and that it would defuel and not operateoperate the reactor after June 30, 2007. By letter letter dated dated August 13, 2007 (Ref.(Ref. 2), and subsequent correspondence correspondence (Ref.
(Ref. 3), WPI submitted submitted a request request to NRC for an amendmentamendment to the Facility Facility Operating Operating License No. R-61 R-61 (including Appendix Appendix A, thereto, TechnicalTechnical Specifications Specifications for for the Worcester Polytechnic Institute Reactor),
Polytechnic Institute Reactor), to place the LCWNRF reactor in Possession-Only-License License status. On August 26, 2008 (Ref. (Ref. 4), NRC granted WPI's requested License Amendment Amendment No. 11, for Possession-Only License status. WPI has notified the Possession-Only Department Department of Energy (DOE) of the Institute's desire to return the used reactor reactor fuel to DOE (Ref.
(Ref. 7).
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1.2.4 Reactor 1.2.4 Reactor Decommissioning Decommissioning OverviewOverview implementing the decommissioning Prior to implementing decommissioning actions described herein, WPI will have cleared cleared LCWNRF of extraneous furnishings and materials not directly extraneous associated directly associated with the reactor. In addition, the used nuclear fuel will have been returned to the DOE. The majority of the remediation remediation will focus on components components within the reactor reactor pool, the biological shield surrounding surrounding the reactor, and connected connected support systems systems (e.g., exhaust ventilation system, pool water treatment system and floor drains adjacent to the reactor reactor pool). No structural contamination contamination in other areas of the facility is known or suspected, such that only minor remediationremediation efforts, if any, are anticipated anticipated for the building structures. Additionally, no contamination contamination of soil or or ground water is known or suspected; therefore, decommissioning decommissioning of the LCWNRFLCWNRF can be accomplished accomplished without dismantlement dismantlement or breaching breaching of the building. After After termination termination of the NRC license (thus allowing unrestricted unrestricted use), the affected affected portions portions of the building will be restored for reuse as an educational educational facility. The general activities planned to complete the DP objectives are:
" Remove the activated regulating blade from the reactor core
Remove
" Drain the reactor pool Drain pool
Remove the remaining Remove remaining reactor core components components from within the reactor pool pool
" Remove the
Remove the beam port extension, liner and shuttershutter
" Remove the
Remove graphite blocks and activated the graphite activated portions portions of the aluminum liner liner from the thermal thermal column column
" Remove the activated
Remove activated / contaminated contaminated portion of the aluminum aluminum pool liner, and survey and remove remove any affected underlying biological shield concrete affected underlying concrete
" Remove the reactor
Remove reactor pool water treatment treatment system
Remove Remove the the exhaust exhaust ventilation ventilation ducts associated associated with the beam port and column thermal column
" Survey and remediate the floor drains, if required
Survey required
Perform Perform additional decontamination and dismantlement additional decontamination dismantlement of the structure and equipment in accordance equipment accordance with this DP DP
" Prepare Prepare the decommissioning-generated decommissioning-generated material for free-release free-release or disposal, as appropriate appropriate (i.e., either decontaminate decontaminate and release the material as non-radioactive radioactive waste, or package package the material radioactive waste) material for transport as radioactive
" Ship all radioactive Ship all radioactive waste waste off-site off-site to a licensed waste processor or disposal facility
" Perform Perform and and document a Final Status Survey and submit a request to NRC for termination of the reactor license
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1.2.5 Estimated 1.2.5 Estimated Cost Cost This estimated estimated to cost for the radiological decommissioning of the WPI LCWNRF, radiological decommissioning including a 25% contingency, is $2,594,000. A cost breakdown breakdown is given in Table 1.2. 1.2.
TABLE 1.2 1.2 RADIOLOGICAL RADIOLOGICAL DECOMMISSIONING DECOMMISSIONING COST
SUMMARY
SUMMARY
(2009 dollars*)
LABOR EQUIPMENT, , RADWASTE EQUIPMENT, RADWASTE TOTAL OPERATION PERSON-PERSON- PLUS PLUS CONTRACTS SHIPPING &,,' &. TOTAL L OPERATION CONTRACTS , SHIPPING HOURS TRAVEL TRAVEL & & & SUPPLIES DISPOSAL** COST COST'
& Slj'PPLIES DISPOSAL**
PER DIEM Mobilization Mobilization 400 $64,000 *** *** $64,000 Decontamination Decontamination and 9,060 9,060 $1,317,000
$1,317,000 $316,000
$316,000 $131,000
$131,000 $1,764,000
$1,764,000 Dismantling Dismantling Demobilization Demobilization *** *** *** *** ***
License License Termination Termination 1,440 $247,000 *** *** $247,000 Activities Activities Totals Totals 10,900 10,900 $1,628,000
$1,628,000 $316,000
$316,000 $131,000
$131,000 $2,075,000
$2,075,000 Contingency 25% Contingency $519,000 GRAND TOTAL GRAND TOTAL $2594000
$2,594,000 Costs have
Costs have been been rounded rounded to to the nearestthousand; the nearest person-hourshave thousand; person-hours have been rounded to been rounded to the the nearest ten.
nearest ten.
The estimate
'O'O estimate for for low-level radioactive waste disposal radioactive waste is based disposal is based upon the assumption assumption that that the radioactive radioactive waste waste will be buried at the EnergySolutions, buried at disposalsite (formerly EnergySolutions, LLC disposal (formerly the Envirocare Envirocare of Utah Utah site).
site).
Included in
Included
'O'O'O in Decontamination Decontamination and and Dismantling operations.
Dismantlingoperations.
1.2.6 Availability Availability of Funds WPI is committed to providing the funding for decommissioning decommissioning of the WPI LCWNRF as evidenced evidenced by the letter of financial commitment commitment shown in Appendix A.
1.2.7 Program Quality Quality Assurance A quality assurance assurance program program will be implemented implemented throughout throughout the decommissioning decommissioning effort to assure that work is performed as intended in a controlled controlled manner and does does not endanger endanger public safety, and to assure the safety of the decommissioning staff. staff.
A Quality Assurance Assurance Project Project Plan (QAPP) will be developed incorporate the developed to incorporate applicable applicable portions of Code of Federal regulationsregulations (CFR) 10 CFR 50, Appendix Appendix B (Ref. 8) and 10 CFR 71, Subpart H (Ref.
(Ref. (Ref. 9). In addition, the QAPP will utilize a graded graded approach that bases the level of controls on the intended intended use of the results and the degree of confidence confidence needed needed in their quality. ANSIIASQC ANSI/ASQC E4-1994 (ASQC 1995, Ref. Ref. 10) and NUREG-1575, NUREG-1575, Appendix K (MARSSIM, Ref. Ref. 11)
11) will be used to provide guidance provide guidance in quality-related quality-related activities, including including the development development of a QAPP QAPP and the collection collection and evaluation evaluation of environmental environmental data.
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Quality Assurance following:
Assurance (QA) efforts
" Performing efforts during the decommissioning Performing QA functions for procurement
" Qualifying Qualifying suppliers decommissioning period will include procurement include the
" Auditing project activities project activities
" Monitoring worker performance Monitoring performance for compliance compliance with work procedures procedures
" Verifying compliance of radioactive radioactive shipments shipments with appropriate appropriate procedures procedures and regulations regulations
" Performing Performing dimensional, visual, nondestructive nondestructive examinations examinations or other other required inspection services required inspection compliance with work plans services to assure compliance
" Maintaining Maintaining auditable auditable files The QAPP will be prepared and implemented implemented by a Decommissioning Decommissioning Consultant Consultant contractors, and will be approved and/or contractors, approved and overseen by WPI's management. The program will be implemented by written procedures throughout the program will be implemented by written procedures throughout the decommissioning project.
decommissioning management staff of those organizations The management organizations participating in the QAPP shall regularly review participating review the status and adequacy of that that part of the QAPP that they are implementing. All changes changes to the QAPP shall be governed by measures commensurate with those applied to the original issue. The measures commensurate QAPP incorporate the items discussed QAPP will incorporate discussed in the following subsections.
1.2.7.1 Quality Assurance 1.2.7.1 Responsibilities Assurance Responsibilities WPI, its Decommissioning Consultant and contractors Decommissioning Consultant contractors shall have the responsibility, organizational freedom to:
authority and organizational
Identify Identify quality problems problems
" Take action to stop unsatisfactory unsatisfactory or unsafe work and control further installation or use of nonconforming processing, delivery, installation nonconforming items
" recommend or Initiate, recommend
Initiate, provide solutions or provide to correct solutions to correct quality issues, unsafe quality Issues, unsafe practices practices or non-conformances non-conformances
Verify Verify implementation implementation of solutions 1.2.7.2 Quality Requirements 1.2.7.2 Instrumentation Calibration Requirements for Instrumentation Calibration instruments and associated Field instruments calibrated on a semi-annual associated detectors shall be calibrated semi-annual basis using National Institute of Standards Standards and Technology Technology (NIST) traceable traceable sources. Calibration equipment equipment and laboratory instruments instruments shall be calibrated calibrated on on performed by a qualified vendor.
Equipment calibrations will be performed an annual basis. Equipment
~. Calibration Calibration labels showing instrument calibration due date shall be attached calibration date and identification number, calibration instrument identification laboratory instrumentation.
attached to all field and laboratory
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Response Response Testing All instrumentation instrumentation will be inspected and source-checked source-checked daily prior to use to verify calibration calibration status and proper operation. Control checks and/or source-check source-check criteria criteria will be established established prior to the initial use of the instruments.
Maintenance Maintenance Limited maintenance, changing Mylar maintenance, such as changing high-voltage cables, etc.,
Mylar windows, high-voltage may be performed performed on-site by qualified personnel. Following Following any limited maintenance, calibration maintenance, calibration checkschecks may be performed performed on site by qualified personnel.
Major repairs re-calibrations will be performed repairs and ensuing re-calibrations performed by a qualified vendor.
Record Keeping Record Keeping Calibration maintenance records, or copies of these records, shall be Calibration and maintenance be maintained maintained on site where they will be available for review. The results of the daily instrument functional checks will be recorded on separate separate log sheets sheets for each each instrument and maintained on site.
Sampling and Analysis 1.2.7.3 Sampling Analysis Quality Quality Control Sample CollectionCollection Direct surface beta measurements, removable removable contamination contamination measurements, gamma gamma exposure exposure rates, soil sampling sampling and any specialized specialized measurements measurements will be be performed to provide performed provide data required to meet the regulatory regulatory guidance provided in:
guidance provided
" Title Title 10, Code of Federal 10, Code Federal Regulations, Part 20, Section 1402 (10 CFR 20.1402), Radiological Criteriafor Radiological Criteria Unrestricted Use (Ref.
for Unrestricted (Ref. 12)
NUREG-1575, Multi-Agency Radiation NUREG-1575, Multi-Agency Radiation Survey and and Site Investigation Manual Investigation Manual (MARSSIM) (Ref. (Ref. 11)
" NUREG-1757, NUREG-I757, vol. vol. 1,1, Consolidated Decommissioning Guidance, Consolidated NMSS Decommissioning Guidance, DecommissioningProcess Decommissioning Processfor MaterialsLicensees for Materials Licensees (Ref.
(Ref. 20)
" NUREG-1757, NUREG-I757, vol. vol. 2, Consolidated NMSS Decommissioning 2, Consolidated Decommissioning Guidance Guidance --
Characterization, Characterization, Survey, and Determination Determination of Radiological Criteria Radiological Criteria (Ref.(Ref.
29)
Sample QC Sample Quality Control (CQ) samples will be obtained obtained for minimum minimum of 10% of all samples samples collected for radionuclide-specific collected radionuclide-specific analysis. The QC samples will be a combination combination of split, duplicate, blank, and/or and/or spiked samples. Independent Independent replicate replicate QCQC measurements for direct measurements measurements measurements will be provided for a minimum of 5% 5% of the measurements measurements associated associated with the FSSFSS..
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Sample Identification Direct Identification Direct surface surface beta measurements, removableremovable contamination contamination samples, exposure rates, and any specialized measurements will be identified specialized measurements identified as to location, type of of measurement, measurement, specific instrument instrument and probe used, sample time and date (as appropriate) and name of the person collecting collecting the data.
Volumetric samples (e.g., concrete, soil, etc.) will be identified Volumetric identified with a unique sample number, sample location, depth of sample, sample time and date as appropriate, appropriate, and the name of the person collecting collecting the sample.
Sample Chain-of-Custody Chain-of-Custody chain-of-custody shall be initiated for those samples Sample chain-of-custody samples being sent off site forfor analysis or transferred transferred to another organization for analysis. A sample Chain-of-another organization Custody Record will be generated generated which will document document the sample sample identification identification and sample transfer and will accompany accompany the samplesample during shipping to the new custodian custodian of the sample.
Sample Analysis Sample Analysis Vendor laboratories laboratories shall be on a QA Approved Suppliers contractors contractors for responsibility the type of analytical services being Suppliers List for WPI or its provided. WPI has the ultimate responsibility for ensuring that decommissioning sample analysis specifications laboratory laboratory capabilities capabilities meet data quality requirements.
specifications and Sample Documentation Sample Documentation identification information, sample Chain-of-Custody Sample identification Chain-of- Custody Records, sample analysis analysis results, vendor laboratory qualification laboratory qualification records, or copies of these records, shall be maintained maintained on site where they will be available available for review.
1.2.7.4 Record 1.2.7.4 Keeping Record Keeping Measures Measures shall be established to control the issuance of documents and changes to prescribe activities affecting documents that prescribe affecting quality, such as procedures, drawings and specifications.
specifications. These measures shall ensure that documents and changes changes to documents documents are reviewed reviewed for adequacy, approved personnel approved for release by authorized personnel and distributed distributed to and implemented implemented at the location where the prescribed prescribed activity is performed.
Procedure Control Procedure
Procedures Procedures shall be controlled personnel personnel performing controlled to ensure that current copies are provided the prescribed prescribed activities. Procedures shall be provided to independently independently
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reviewed by a qualified person and shall be approved the organization responsible procedures Radioactive responsible for the prescribed procedures shall be reviewed and approved Radioactive Shipment Package Package Documents Documents approved by a management management member of prescribed activity. Significant Significant changes changes to approved in the same manner as the original.
of All documents documents related to a specific shipping package package for radioactive material shall be controlled by appropriate appropriate procedures. significant changes procedures. All significant changes to such documents documents shall be similarly controlled.
Final Survey Documents Documents All documents documents related related to the FSS shall be controlled appropriate procedures. All controlled by appropriate significant changes to such documents significant documents shall be similarly controlled. This documentation documentation would normally include a Survey Survey Plan, Survey Packages, SurveySurvey Results and Survey Survey Report.
Handling. Storage 1.2.7.5 Handling, Storage and Shipping Approved Approved procedures procedures shall be utilized to control control the handling, storage and shipping of radioactive radioactive materials.
Radioactive Radioactive Material Areas Material Storage Areas shall be provided in the Reactor ensure physical protection Reactor facility for storage of radioactive radioactive material and shipment of radioactive requirements:
radioactive material material shall be controlled through material to protection and control of the stored material. The handling, storage through the following
" Procedures shall be provided Procedures shall provided for handling, storage storage and shipping operations.
operations.
" Established Established safety concerning the handling, storage and safety requirements concerning shipping of packages packages for radioactive radioactive material material shall be followed.
" Shipments shall not be made unless all tests, certifications, acceptances Shipments shall acceptances and final inspections inspections have have been completed.
Shipping and Packaging Packaging Shipping and packaging documents Shipping documents for radioactive radioactive material material shall be consistent with with pertinent regulatory regulatory requirements.
1.2.7.6 Quality 1.2.7.6 Quality Assurance Assurance Records Records Sufficient records shall be maintained to furnish evidence of activities Sufficient activities important to decommissioning as required by code, standard, and specification safe decommissioning specification or project project procedures. Records Records shall be identifiable, identifiable, available available and retrievable. The records shall be reviewed reviewed to ensure their completeness completeness and ability to serve intended serve their intended function. Requirements shall be established concerning Requirements concerning record collection, collection,
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safekeeping, retention, maintenance, administration administration and assigned maintenance, updating, location, storage, preservation, assigned responsibility. Requirements Requirements shall be consistent consistent with applicable regulations and the potential for impact on quality and radiation applicable exposure exposure to the workers and the public. Typical records would include:
with radiation
" Decommissioning Decommissioning Plan
Procedures Procedures
" Reports
Reports
" Personnel qualification
Personnel qualification records
" Radiological Radiological and environmental environmental site characterization characterization records, material material free-release records and FSS records records
" Dismantlement Dismantlement records
" Inspection, surveillance, audit and assessment records records Health and Safety Related Activities Activities Records that have a potential Records potential for impact on quality and radiation exposure to the workers and the public include the following:
" Work Permits Procedures Work Procedures Contamination Survey Reports Contamination Radiation Radiation Survey Reports
" Airborne Survey Airborne Survey Reports Reports
" Counting data or air samples and gamma gamma spectrum analysis
" Instrument Instrument calibrations calibrations
" Source inventory inventory and storage
" Radioactive Radioactive material inventory inventory and storage
Shipment records
" Incidents accidents Incidents and accidents
" Confined space entry permits
" Monitoring Monitoring records for oxygen deficient and explosive explosive atmospheres atmospheres Personal Records Records Typical records containing containing personal personal information that may impact quality and radiation exposure to the workers and the public are as follows:
radiation exposure
*M Dosimetry Records Dosimetry Records
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*" Bioassay Bioassay analysis analysis
" Respiratory Respiratory protection protection qualifications (medical/clearance and fit tests, if qualifications (medical/clearance if required)
" Training Training records records
" Visitor logs and exposure information Visitor information 1.2.7.7 Audits Audits shall be implemented implemented to verify compliance compliance with appropriate appropriate requirements of of the Quality Assurance Project Plan and to determine determine the effectiveness effectiveness of the plan.
The audits shall be performed in accordance accordance with written procedures or checklists by trained trained and qualified personnel personnel not having direct responsibility in the areas being audited.
Audit Reports Reports Reports of the results of each audit shall be prepared. These reports shall include a description description of the area area audited, identification identification of the individual responsible responsible for for implementation implementation of the audited provisions and for performance performance of the audit, and identification identification of discrepant areas. The audit report shall be distributed distributed to the appropriate appropriate level of management management and to those individuals individuals responsible for for
implementation implementation of audited provisions.
Audit Corrective Corrective Action Action Measures shall be established to ensure that discrepancies discrepancies identified identified by audits are resolved. These measures measures shall include notification of the manager responsible for for the discrepancy discrepancy and verification verification of satisfactory satisfactory resolution. Discrepancies Discrepancies shall be resolved by the manager manager responsible for the discrepancy. Higher Higher levels of of management management shall resolve resolve disputed discrepancies.
discrepancies. Follow-up Follow-up action, including re-audit of deficient areas, shall be taken as indicated.
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The decommissioning DECOMMISSIONING ACTIVITIES 2.0 DECOMMISSIONING decommissioning alternative ACTIVITIES alternative selected for the WPI Reactor Reactor is the removal facility from service and reduction of the residual radioactivity removal of the radioactivity to a level that will unrestricted termination permit unrestricted termination of the reactor reactor license and beneficial beneficial reuse of thethe affected affected rooms within the building. The facility will be surveyed surveyed and left in place.
2.1 DECOMMISSIONING DECOMMISSIONING ALTERNATIVE ALTERNATIVE The objective of the decommissioning decommissioning is the regulatory regulatory release of the Reactor Reactor facility located within the Washburn located Laboratories building, allowing Washburn Shops and Stoddard Laboratories for their unrestricted unrestricted use. On this basis the safe storage (SAFSTOR) and entombment (ENTOMB) decommissioning options were considered entombment considered inappropriate inappropriate to WPI's future plans, and DECON is the decommissioning decommissioning alternative selected selected by WPI.
SAFSTOR poses essentially SAFSTOR essentially the same potential risks and environmental environmental impacts as the proposed project, but for a much greatergreater period of time. This alternative alternative would necessitate surveillance and maintenance necessitate continued surveillance maintenance of the Reactor facility over a substantial substantial time period period during which the radiological radiological risks would continue to exist.
ENTOMB would necessitate necessitate continued surveillance surveillance and maintenance maintenance of the Reactor facility over a substantial substantial time period. During this period, the radiological radiological risks would continue continue to exist.
DECON is the decommissioning decommissioning option chosen by WPI. To the extent possible, decontamination of facility equipment and structural components decontamination components will be conducted conducted so as to minimize radioactive radioactive waste. Structural Structural portions of the building found to be radiologically radiologically contaminated contaminated and/or activated shall be dismantled and/or and/or decontaminated, decontaminated, as necessary. This would be followed by an extensive and comprehensive final radiation comprehensive radiation and contamination contamination survey survey demonstrating demonstrating that the LCWNRF LCWNRF meets NRC criteria criteria for release unrestricted use. The results of this release to unrestricted final survey will be documented in a report to be submitted submitted to NRC in support of a request that the site be releasedreleased for unrestricted use and the reactor license terminated.
2.2 FACILITY FACILITY RADIOLOGICAL RADIOLOGICAL STATUS STATUS 2.2.1 Facility Facility Operating Operating History
" Initial Initial reactor criticality: December reactor criticality: 1959 December 12, 1959
" Reactor operation (at lKW):
Reactor operation 1KW): 1959 1959 to 1967 1967
*" Conversion Conversion from 1 KW to 10KW: 1968
0 Reactor Reactor operation (at (at 10 KW): 1968 1968 1968 to 2007 2007
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*" Typical reactor Typical operation: ~
reactor operation: - 100 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months hours per year
" Conversion from Conversion from HEU to LEU LEU fuel: 1989
" Certification of Certification of permanent reactor shut-down:
shut-down: 2007
" Possession-only License Possession-only License Amendment: August 26,2008 26, 2008
" Request Request return return of reactor fuel to DOE: September 2008
" Return Return of of reactor reactor fuel to DOE: To Be Determined Determined The LCWNRF was constructed constructed at WPI to provide graduate and undergraduate students with reactor operatingoperating experience experience and experimental practice in the fields of nuclear engineering, metallurgy, chemistry and physics, as well as irradiation irradiation services for other teaching, medical and industrial institutions. The integrated power generated during operation of the WPI Reactor Reactor is estimated at approximately 41 MW-hours.
2.2.2 Current Radiological Radiological Status of the WPI Facility 2.2.2.1 General Routine radiological radiological surveys show that the radiation radiation levels and contamination contamination measured at the LCWNRF LCWNRF have consistently levels measured consistently been low and limited in extent.
Radiological measurements performed in the summer of 2008, confirmed Radiological measurements confirmed that only minor quantities of residual radioactivity residual radioactivity or radioactive contamination radioactive contamination are present.
The information information indicates indicates that the radioactive radioactive portions of the facility are primarily confined confined to the reactor reactor internals and reactor pool. The majority of the residual radioactivity radioactivity at the facility contained in structures, systems systems and components, is found in a single item, an activated stainless-steel stainless-steel regulating regulating blade blade (as discussed in in section section 1.2.2. Other than the exposure rate emanating from the regulating regulating blade (125 mR/hr at 13 cm, through water) radiation radiation exposure rates at the reactor facility were found to be very low and limited to portions of the reactor core core box and grid, the reactor corecore end of the beam beam port and the reactor side of the graphite graphite thermal column column interior, that were slightly slightly neutron neutron activated. MaximumMaximum radiation radiation levels on on these non-regulating non-regulating blade components components were found to be in the range range of one to three mrem mrem per hour on contact. Radiation Radiation and radioactive radioactive contamination contamination was not not detected detected outside of the reactor reactor pool or experimental experimental facilities in the biological shield.
Estimates Estimates of the radioactivity radioactivity inventory inventory can can be determined determined by considering the constituent elements constituent elements of the material material in question and calculating the duration of and calculating of exposure exposure to the the neutron neutron flux and the energies energies ofof the incident incident neutrons. However, However, in in the case of of the WPI Reactor, with with its low and and intermittent intermittent usage, direct direct measurements measurements are are generally generally more more reliable reliable and and will be used to guide guide the actual actual removal removal and/or and/or dismantlement dismantlement of components. Characterization of components. Characterization of radionuclide radionuclide
mixtures dismantlement, and concentrations mixtures and concentrations will dismantlement, as this requires destructive components components that are currently be performed performed at destructive sampling needed currently needed to the time of actual sampling of structures, systems support support safe storage storage of the used removal the time of actual removal and systems and used fuel, and
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would not be permitted specifying permitted by the possession only license. This information will be obtained during the process specifying the necessary process of decommissioning necessary safety decommissioning and will further define the basis for safety measures and procedures dismantling, removal, decontamination, and waste packaging operations so that exposure operations exposure to personnel is maintained procedures for the varIOUS packaging AIARA.
maintained ALARA.
and be for various storage 2.2.2.2 Principal 2.2.2.2 Principal Radioactive Radioactive Components Components This listing is based measurements.
based upon process knowledge and direct radiation measurements.
radioactive components The most radioactive components to be handled and processedprocessed during the WPI WPI LCWNRF Reactor Decommissioning Decommissioning Project (WPI-RDP) are those that have become become neutron activated.
The reactor core structure was principally constructed constructed of Aluminum, with a small amount of stainless-steel stainless-steel (i.e., the single regulating blade and small fasteners, such such as bolts and pins). Based upon the elemental elemental constituents of these materials, only the stainless steel items should show a significant significant amount of neutron neutron activation. InIn the case of the biological experimental facilities, there are elemental biological shield and experimental elemental constituents within the concrete, concrete, steel rebar and graphite that can become become activated; however however due to their distance from the reactor core, and the low power power level and low usage of the reactor, there should not be a significant amount amount of of activation. This pattern pattern of neutron activation confirmed by the gamma activation was confirmed gamma exposure rates measured measured in and around the reactor core and pool structures.
A summary summary of the most significant radiologicalradiological characteristics characteristics found at the LCWNRF are as follows (see Figures 2.1 and 2.2 for location and configurationconfiguration of of these items):
The gamma
The gamma exposure exposure rate rate at the geometric geometric center of the reactor core, between the three Boral Boral Control Blades and one stainless-steel stainless-steel Regulating measured at 125 mR/hr (at 13 cm),
Blade was measured em), through water). The Regulating Blade Regulating Blade is believed believed to be the principal principal the source, and based on its composition and geometry, an in air exposure rate of 17 mR/hr at 1 meter is estimated. That 6.9 Kg (884 cubic centimeter) blade blade is estimated to contain contain 56 mCi of radioactivity; radioactivity; Mn-54 (<1%), Fe-55 (68%), Ni-59 (<1%),
Mn-54 <<1%), <<1%), Co-60 (27%)
and Ni-63 (4.2%).
" Ion Chambers
Ion Chambers andand lower Suspension Suspension Posts, located above the top corners of of the active core region were found to have contact gamma exposure exposure rates of of about 2 mR/hr (under water).
" Gamma exposure
Gamma exposure rates from the ReactorReactor Core Box, at mid-core plane elevation, on the exposed exposed West, South and North sides, were found to be 4, 7 and 15 mR/hr, respectively, respectively, measured measured through 30 cm of water. Based on the configuration and the radiation core configuration radiation level pattern these radiation levels levels are influenced by the activated stainless likely influenced stainless steel regulating control control blade and the spent fuel that is currently currently stored in racks on the North and South pool walls, and not due to significant significant activation of the Aluminum Core Box.
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*" Gamma Gamma radiation Beam Beam radiation levels were measured, in air, inside the six-inch diameter Tube Extension, with O.4mR/hr 0.4mR/hr where the tube penetrates wall and 4 mR/hr where the extension tube terminates at the reactor core face.
diameter penetrates the pool pool
" Activated Activated stainless steel Hell-Coil Heli-Coil hardware embedded embedded in thermal column thermal column graphite blocks were found with gamma exposure exposure rates of 200 microR/hr on on contact.
" Gamma Gamma exposure exposure rate measured measured on contact with select Thermal Thermal Column Column graphite blocks, ranged from background-to-10 background-to-10 microR/hr microR/hr above background.
As expected, the graphite graphite blocks closest to the reactor core were those found with the detectable radiation radiation levels.
Radionuclides 2.2.2.3 Radionuclides The radionuclides radionuclides expected to be present, or that may possibly be present, in the WPI Reactor Reactor at the time of decommissioning, are listed in Table 2.1. This list of of radionuclides radionuclides is principally principally based on the assumption assumption that reactor operation resulted resulted in neutron activation of reactor core components and other other integral integral hardware hardware oror structural structural members members situated adjacent to, or in close proximity to, the reactor core.
Specific materials materials that are considered to have been exposed to neutron neutron activation activation include principally principally aluminum, and small amounts of stainless steel, graphite and concrete.
concrete. Co-60 and Fe-55 are the principal radionuclides expected to be present in radionuclides expected in detectable detectable quantities at the WPI LCWNRF. Table Table 2.1 also contains other other radionuclides radionuclides that generically generically can be present present at a research research reactor, but are not not expected detectable quantities expected in detectable quantities at the LCWNRF, such as fission products products from the fuel and Europium radioisotopes from activated activated graphite and concrete. The determination determination of actual radionuclides radionuclides and concentrations concentrations present as residual residual structures surrounding activity in structures surrounding the reactor, and there content content in waste materials will be based upon direct measurements measurements and sampling performed performed during the decommissioning process.
decommissioning
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Rev. 11 Reactor Decommissioning Reactor Decommissioning PlanPlan Section Section 2, Page Page 5 of of35 35
REACTOR REACTOR CORE CORE DRAWING FIGURE FIGURE 2.12.1 DRAWING AND PHOTOGRAPHIC PHOTOGRAPHIC VIEW VIEW U
I I CONTROL
~---4M+~~CONTROL ROD ROD I
~TART-UP I COUNTER~'--~+-----~
I CONTROL BLADE ION CHAMBER CHAMBER
-SHROUD SHROUD FUEL
'~'LEMENT -SOURCE OUReE GRI 0 --""<:----""~i (a)
(a) Reactor Reactor Core Core -- Artist Artist Rendering Rendering
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REACTOR FIGURE 2.1 (continued)
REACTOR CORE DRAWING AND PHOTOGRAPHICPHOTOGRAPHIC VIEW VIEW
(a) Reactor View Reactor Core Photo - Overall View
(b) Reactor Core Photo - Close-up Close-up View View
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REACTOR POOL AND BIOLOGICAL FIGURE 2.2 SHIELD FIGURE 2.2CROSS-SECTION DRAWING REACTOR POOL AND BIOLOGICAL SHIELD CROSS-SECTION DRAWING I~
I
~10/
As'C/t~fYt'rn L~ev'-7Y $'Ort.
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2.3 DECOMMISSIONING TASKS DECOMMISSIONING 2.3.1 Activities and Tasks WPI Reactor Reactor facility decommissioning activities activities will be conducted conducted in four phases, as as follows:
" Phase Phase One: Pre-Decommissioning Pre -Decommissioning Activities Activities
" Phase Two: Decommissioning Phase Decommissioning Mobilization Activities Mobilization Activities
Phase Three:
Phase Decontamination and Dismantling Three: Decontamination Dismantling Activities Activities
Phase Phase Four:
Four: Site Restoration Activities Restoration Activities TABLE 2.1 2.1 LIST OF EXPECTED AND POTENTIAL POTENTIAL RADIONUCLIDES RADIONUCLIDES NUCLIDE HALF:'LIFE*
HALF-LIFE* MEANS OF MEANS OF NUCLIDE (years) PRODUCTION (years) PRODUCTION 3H 3H 12.28 Activation 12.28 Activation 14C 5,730 5,730 Activation Activation 54 54MnMn 0.856 0.856 Activation Activation 55 Fe 55Fe 2.73 Activation Activation 6°Co 60CO 5.27 5.27 Activation Activation 59Ni 76,000 Activation Activation 63 63NiNi 100 100 Activation Activation 63 63ZZn n 0.67 Activation Activation 90 90S Srr 29.1 Fission Fission 94Nb 94Nb 20,000 20,000 Activation Activation 99 Tc 99Tc 213,000 Fission Fission 2
1 5Sb 125Sb 2.76 2.76 Fission Fission 129 12911 15,700,000 15,700,000 Fission Fission 134Cs 134CS 2.07 2.07 Activation Activation 137 137CSCs 30.17 30.17 Fission Fission 152Eu 152Eu 13.48 13.48 Activation Activation 1 54 154EuEu 8.8 8.8 Activation Activation 155Eu 155Eu 4.96 4.96 Activation Activation RadionuclideHalf-Life
Radionuclide Half-Life values values are are from "The Health from "The Physics and Health Physics and Radiological HealthHandbook" Radiological Health Handbook" (Ref. 13).
(Ref. 13).
Phase One and Phase Four activities are considered outside outside of the scope of this DP:
however, they are described briefly below below to provide an overall context context to this DP.
Phase Phase One One Phase One activities are those tasks performed performed to prepare prepare the facility for future decommissioning decommissioning activities. This work will be performed performed under the authority of the existing possession-only possession-only license license and may be performed performed before NRC approval to decommission decommission is granted. This work will include include general cleanup of the facility,
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such as removal removal of non-contaminated procedures. This would generally equipment and materials non-contaminated equipment related) situated throughout the WPI LCWNRF: such materials will surveyed, and appropriately dispositioned in accordance appropriately dispositioned generally include removal laboratory and office supplies. Non-radiologically laboratory materials (non-reactor contaminated ceiling Non-radiologically contaminated (non-reactor be collected, accordance with established established removal of no-longer needed furniture, floor ceiling and floor tiles and insulation, which may contain asbestos, may be removed during this phase to facilitate future decommissioning decommissioning activities. At no time during Phase One will any of the reactor's reactor's structures, systems or components components be dismantled dismantled or or expected that the used nuclear fuel would be returned to decontaminated. It is also expected decontaminated.
DOE during this phase.
Four Phase Four performed after the facility's NRC license Phase Four activities are those tasks performed Phase license has been terminated, allowing allowing for unrestricted unrestricted use. During this phase, the facility will be restored and remodeled remodeled for educational classroom or office educational use, such as classroom office space.
detailed plans have not yet been devised, it is expected that the remaining While detailed portions of the biological biological shield, the decontaminated decontaminated reactor bridge and control console will be demolished, and disturbed structural surfaces structural surfaces repaired.
Phases Two and ThreeThree activities encompass the radiological decommissioning activities encompass decommissioning tasks accordance with the provisions of this plan, as described that will be performed in accordance described herein. WPI anticipates that this work will be performed experienced and performed by experienced qualified contractors, qualified contractors, managed overseen by Decommissioning Consultant, and overseen managed by a Decommissioning by the RHSC (see Sections 2.4.3 Decommissioning Consultant and 2.4.4 Contractor Decommissioning Consultant Contractor Assistance).
2.3.1.1 2.3.1.1 Phase Two: Decommissioning Decommissioning Mobilization Activities Mobilization Activities Phase Phase Two will commence Decommissioning Order has been granted commence after a Decommissioning granted by NRC removed from the reactor pool. The tasks in this and the used nuclear fuel has been removed phase will include include preparatory needed to fulfill the administrative preparatory work needed administrative and requirements of this DP, prior to the conduct physical requirements conduct of Phase Three decontamination decontamination and decommissioning decommissioning (D&D) activities. WPI anticipates that sub-phases; off-site and on-site implemented in two sub-phases; Phase Two will be implemented on-site mobilization.
Off-site mobilization Off-site include detailed project planning activities will include mobilization activities planning and preparation of detailed operating procedures, and procurement engineering, preparation procurement of of specialty specialty equipment, supplies and subcontractors.
subcontractors.
On-site mobilization On-site qualification of workers and physical mobilization will include training and qualification physical decommissioning activities. Training and preparation of the facility for phase three decommissioning preparation workers will be performed as described in Section qualification of workers qualification Section 2.5 Training Training
Program.
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Systems and components electric components to be dismantled will be de-energized time in order to assure the safety safety of the de-energized and isolated at this decommissioning decommissioning workers. Temporary electric power, lighting and other utilities will be installed as needed. Material-handling handling equipment, such as ramps, gantry cranes, etc.,
required required to support support the decommissioning decommissioning work.
Temporary etc., will be installed as radiological controls will be installed to support the decommissioning General radiological decommissioning work.
Contamination control boundaries Contamination boundaries and protective barriers, personnel contamination personnel contamination frisking stations and step-off pads will be setup to isolate the active work areas from the un-involved un-involved portions of the facility. Facilities Facilities for workers workers to change change into protective protective clothing will be set up. Portable air samplers, continuouscontinuous air monitors, area radiation radiation monitors, containment containment tents and High-Efficiency High-Efficiency Particulate Particulate Air Air (HEPA) filtered ventilation (HEPA) ventilation units will be setup as required required to support the the decommissioning decommissioning work. A Health Physics (HP) counting counting room will be set up for for sample analysis to support radiation radiation protection, waste management management and final site survey (FSS) work. A secure radioactive material storage storage area will be setup, where waste material can be accumulated, packaged packaged and prepared prepared for shipment shipment to the disposal facility. Additionally, a low-background low-background area will be set up for conducting conducting free-release free-release surveys and secure storage of materials materials prior to release.
During this phase, characterization characterization of structures, systems and components components will be performed on those areas that could not be performed performed performed prior to receipt receipt of the decommissioning decommissioning order (e.g., destructive destructive sampling activated reactor sampling of activated reactor core and biological biological shield materials).
2.3.1.2 Three: Decontamination Phase Three: Decontamination and Dismantling Dismantling Activities Activities Phase Phase Three activities activities will be comprised of ten discrete discrete tasks involving the physical dismantling dismantling of contaminated contaminated and activated equipment and removal or equipment or decontamination of structures, plus three additional tasks associated decontamination associated with:
" The preparation, packaging The preparation, packaging and transportation transportation of radioactive radioactive waste for for disposal (see Section Section 3.2 Waste Management)
" Demobilization Demobilization and preparation preparation of the building for final surveys
" Performance Performance of of a FSS to verify compliance compliance with facility release release criteria criteria (see Sections 2.7 Release Criteria and 4.0 Proposed Final Radiation Survey Plan)
The general philosophy concerning concerning the dismantling dismantling and removal of contaminated contaminated or or activated activated equipment will be to use non-destructive non-destructive disassembly techniques, such as un-bolting, wherever wherever possible. Such techniques techniques eliminate eliminate creation creation of contaminated contaminated particles and debris that can create create airborne and contamination contamination migrations risks. IfIf un-bolting un-bolting can not be performed performed (e.g., if frozen bolts are encountered) only mechanical segmentation techniques mechanical segmentation techniques will be employed in order order to minimize minimize the creation creation of airborne airborne dusts, mists or fumes: examples of such mechanical segmentation segmentation techniques include include sawing and shearing.
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In addition, whenever minimize exposure minimize whenever possible, equipment exposure times and creation removed as whole items to equipment will be removed contamination. The thirteen main creation of loose contamination.
D&D tasks are discussed in the following pages.
main Task 1: Remove Reactor Core Structure Task removal of the reactor core objective of this first task will be the removal The objective support core support structure from the pool. The major items include the following:
structure
"
Reactor Core Box and Grid
" Control Blade
Control Blade Drive Shafts and Drive Mechanisms Mechanisms
Regulating Regulating Blade
Safety Blades Blades
" Ion Chambers and associated associated instrumentation instrumentation hardware
Start-up Counter Assembly Assembly and Guide Tube Assembly
" Sample Irradiation
Sample Irradiation
" Reactor Reactor Suspension Posts
The reactor core structure attached structure is suspended by a four-post aluminum aluminum suspension frame, attached to the bridge spanning the top of the pool. Activation levels and the resulting radiation exposure rates emanating from the core structure are low - in the range of a few mrem/hr. Because disassembly of the structure Because of the low radiation levels, remote underwater structure will not be required. Additionally, because underwater because the core in structure structure is small, it will not need to be segmented segmented to fit into waste containers.
containers.
The first items to be removed from the core will be the regulating blade, which which radioactivity and are the largest contain the bulk of the reactor's radioactivity largest contributor to radiation exposure rates. The four safety safety I/ control blade drive mechanisms mechanisms and decoupled at the reactor drive shafts will be decoupled control drive shafts reactor bridge. The control shafts and the attached blades will be lifted out of the core box by workers workers latching onto the blades with long-handled tools. The blades and shafts will be raised to the surface blades of the pool and decoupled. The control blades, one of which is the regulating blade which has the highest estimated radiation levels of 17 mR/hr at one meter, will be container boxes. The control blade drive shafts manually placed into steel waste container will be manually cut by mechanical means (saws or shears), and sized to fit into the waste waste boxes.
sufficiently low as to safely remaining pool items will be sufficiently Exposure rates from the remaining disassembly of the reactor core. The pool allow draining of the pool prior to further disassembly
will be drained drained in a controlled existing liquid effluent manner using the existing controlled manner effluent discharge protocols. Pool water will be drained to temporary batch tanks, sampled, analyzed released to the sanitary and treated (if necessary) and then released sanitary sewer analyzed sewer system. Radiation Radiation
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levels above the pool water will be monitored as the water level is lowered to assure that no un-expectedly un-expectedly higher sources of radiation If significant assure sources of radiation are exposed. Loose surface contamination levels on the exposed surfaces will be checked contamination drained, to assure that no potential potential airborne checked as the pool water is contamination are exposed.
contamination contamination is indicated, the exposed surfaces will be washed significant loose contamination washed down with water water sprays and the loose contamination contamination will be collected collected along with the drained drained pool water.
After After the pool has been drained, the reactor core box will be removed. The core box consists of the core box sides, grid plate, control control blade shrouds, and other small, miscellaneous hardware miscellaneous hardware items. The entire reactor core box structure structure is small in size (about 36 inches high by 21 inches wide by 28 inches long) and will be removed removed whole, without the need for segmentation.
segmentation.
After removal of the core box structure, radiation radiation levels should be low enough to allow manned manned entry into the pool. The reactor core structure structure will be unbolted from from suspension posts and floor locating the suspension locating lugs using hand tools, and slid laterally to clear the suspension suspension frame assembly. A gantry crane will be set up to span the top of the reactor reactor pool and will be used to hoist the core box out of the pool. Once hoisted out of the pool, the core box will be placed directly into a waste container waste container staged nearby.
After After removal of the corecore box, workers workers will then remove remove the suspension suspension frame, ion ion chambers and start-up start-up counter I/ guide assembly. These These items form one integral structure, with the ion chambers being located inside of three of the four hollow corner posts that comprise comprise the lower portion of the suspension frame assembly.
While the suspension suspension assembly assembly is hanging hanging from the reactor bridge above the pool, workers will manually segment the assembly assembly into manageable-sized manageable-sized pieces pieces using saws or shears. Segments Segments will be hoisted out of the pool using the previously installed gantry crane, and placed into waste containers containers staged nearby.
Task 2: Remove Remove Contents of Thermal Column Column This task removes the contents contents of the thermal thermal column. The thermalthermal column, a aluminum-lined penetration horizontal, aluminum-lined penetration through through the biological shield, is filled with graphite graphite blocks. The individual individual graphite blocks blocks have an approximately approximately four-inch square cross-section, and vary in length up to about three feet long. The graphite blocks are stacked in alternating alternating perpendicular perpendicular rows; some of the blocks contain contain embedded stainless Helicoils to facilitate their removal using a threaded T-bar.
embedded During scoping surveys, radiation radiation exposure exposure rates emanating emanating from the graphite and Helicoils Helicoils were found to be very low - 0.01 and 0.2 mR/hr on contact, respectively.
Smear Smear samples taken on the graphite did not reveal loose graphite graphite dust or or radioactive surface contamination. The graphite blocks will be manually radioactive manually un-stacked stacked and placed intointo waste containers containers staged nearby.
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Equipment Task 3: Remove Reactor Pool Equipment The objective of this task will be to remove the remaining activated equipment from the reactor pool. The equipment is expected to exhibit very low radiation levels, generally less than one mR/hr. Much of pool equipment is either attached to the generally the aluminum pool liner or embedded into the underlying concrete structure. Reactor Reactor pool equipment includes the following items:
" Beam Beam portport extension
" Beam port Beam port shutter shutter and shutter housing
" Core box Core box locating rails
" Spent Spent fuel fuel racks The beam port extension is a six-inch diameter aluminum tube that extends between between the interior face of the biological biological shield and the reactor core box. It will be be unbolted from the beam port shutter assembly for removal from the pool. The beam port shutter is a movable shield inside the beam port shutter shutter housing: the beam port shutter and its attached lifting rod will be removed from the housing. The beam port extension and the beam port shutter (and lifting rod) will then be hoisted out of the pool using a gantry crane and placed into a waste container staged gantry crane staged
nearby.
nearby.
The remaining remaining items will require destructivedestructive removal techniques techniques that have a potential potential for creating creating loose debris. Accordingly, engineering controls Accordingly, engineering controls will be used as required to contain contain and collect any potentially contaminated debris. Such controls potentially contaminated may include enclosing the top of the pool with tarpaulins and using HEPA-filtered HEPA-filtered ventilation ventilation to maintain inward air flow and the use of HEPA vacuums for collection collection of debris. The sequence sequence of equipment equipment removal will be determined by an ALARA evaluation, with the items with the highest exposure exposure rates beingbeing removed removed first.
The beam port port shutter shutter housing is an aluminum aluminum box welded to the aluminum pool pool liner and partially embedded embedded in the biological shield shield concrete. The aluminum liner aluminum liner surrounding the housing will be cut surrounding cut and removed by sawing, drilling or chisel chisel cutting. Jack hammering hammering and concrete concrete drilling will be used to break away surrounding concrete surrounding concrete to free the housing. The housing will then be saw-cut saw-cut from from the remaining remaining beam port tube still embedded embedded in the biological biological shield.
The The core core box locating locating rails are two aluminum aluminum T-channels T-channels attached attached to the pool linerliner floor that that provided support for the reactor core core box. The rails will will be detached detached from the the pool liner liner by sawing, drilling or chisel cutting. The two spent fuel racks are are also attached attached to the liner the liner on the pool floor, and will also be detached be detached from the pool liner liner
by sawing, drilling drilling or or chisel chisel cutting.
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Task 4: Remove Reactor Pool Water Treatment System System The objective of this task will be the disassembly and removal removal of piping and equipment equipment comprising the pool water treatment treatment system. This system is external to the reactor pool, and is comprised of the following items:
" Ion Ion exchange exchange column column
" Filter Filter housing
" Pump Pump
" Hold-up Hold-up tank
" Piping Piping (metal and plastic, all less than two-inch diameter)
Radiological conducted in 2008 Radiological surveys conducted 200S did not reveal reveal any radiation radiation exposure rates rates above background background from this equipment, and internal contaminationcontamination levels are expected expected to be low, if at all detectable.
detectable. These are small items, the largest of which which is the ion-exchange ion-exchange column, approximately approximately 7.5 feet long by 1.5 feet in diameter.
The equipment equipment will be drained (and will have been previously de-energized during previously de-energized initial decommissioning decommissioning set-up activities). Generally, the equipment equipment will not need to be segmented to fit into waste Connecting piping and anchor waste containers. Connecting anchor bolts
will be saw-cut, sheared or un-threaded. Catch basins, drop cloths and HEPA vacuums will be used to control and capture Task Task 5: Remove Liners and Embedments The objective capture any potentially Embedments from Biological contaminated debris.
potentially contaminated Biological Shield objective of this task will be the removal of contaminated contaminated or activated activated portions of the liner from within the pool, thermal column, beam port and gutter drains; and removal removal of contaminated embedded within the biological shield. The exact contaminated piping embedded exact amount and location of liner that will need to be removed cannot be determined determined at at this time. Characterization Characterization will take place place after the pool has been draineddrained and activated equipment removed, at which time direct radiation radiation and contamination contamination measurements measurements can be made to direct the work activities.
At the time of construction, the liners were pre-fabricated from ~-inch were pre-fabricated '-inch thick sheets of aluminum, and used as the interior form for casting-in-place casting-in-place the concrete biological biological shield. Removal will entail pre-cutting the liner in place and prying the entail pre-cutting pieces free from the underlying mechanically underlying concrete. The aluminum liner will be mechanically cut (e.g., sawing, drilling or chisel cutting). The manageable-sized manageable-sized pieces will be be mechanically mechanically pried free using pry bars, jack hammers hammers or hydraulic spreaders.
The beam port liner embedded embedded in the biological biological shield shield (and potentially activated potentially activated concrete concrete surrounding surrounding it) will be removed by over coring around around the beam port liner,
at a diameter concrete diameter of approximately concrete cutting core containing containing the liner 16-to-18 approximately 16-to-IS inches. A contractor specializing contractor specializing in cutting and coring will be utilized for this operation. Once over cored, the liner will be withdrawn from the biological biological shield using chain chain in
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falls and aa portable gantry crane. The resulting core, approximately 5.5 feet in length, may be cross-cut into smaller, more manageable will then be placed into waste containers.
manageable segments. The segments Concrete coring and cross cutting will necessitate the use of water for cooling and in lubrication, and to prevent the generation of any potential airborne dust. The resulting slurry will be controlled, collected and captured as a waste material.
Berms, catch basins and plastic drapes, as well as wet / dry HEPA vacuums will be used to capture and collect the slurry. The resulting slurry will be allowed to congeal and further dried by mixing with cement, if required, and placed into waste containers.
contaminated embedded Potentially contaminated embedded pipes within the biological shield include the thermal column and beam port vents and drains, the inlet and outlet pipes for the pool water treatment treatment system, gutter drain lines and the beam port shutter lifting non-system-related embedments present (such as rod sleeve. There may be other, non-system-related electrical conduits). Such pipes (or conduits) mayor electrical may or may not be contaminated. WPI conservatively planning to remove non-embedded is conservatively non-embedded or embedded pipe within the the concrete concrete biological shield that has been or potentially has been exposed to pool pool water or neutron irradiation, and dispose of it as radioactive radioactive waste. If these items are embedded in concrete, they will either be over cored or the surrounding surrounding concrete
jack hammered hammered to expose the items for removal.
If portions of embedded embedded pipes or conduits cannot be removed removed due to safety or or structural concerns, and need to remain at license termination, they will be building structural evaluated using "License Termination evaluated Screening Values for Building Surface Termination Screening Surface Contamination" given in Table 2.2. In order to apply the screening screening values, the interior of the embedded embedded items will be checked for both loose and fixed fixed contamination contamination at accessible openings. It It is not foreseeable foreseeable that there will be any embedded embedded items left in place place that could be more than a few feet in length, or or without access from both open open ends. As such, if an item needs needs to be left in place, place, the interior surfaces interior surfaces will be characterized characterized for residual radioactivity radioactivity by inserting inserting small-diameter diameter NaI or GM detectors detectors to quantify quantify contamination contamination levels. Loose Loose contamination contamination will be checked checked to verify verify it does not exceed 10% of the screening screening values. Such looseloose contamination contamination will be checked by snaking and obtaining swab swab or or smear samples smear samples throughoutthroughout the interior interior of a pipe, vent or conduit. If If loose contamination contamination is determined to exceed exceed 10% of the screening screening values, those interior interior surfaces surfaces will be decontaminated decontaminated by scrubbing scrubbing and flushing.
Task 6: Decontaminate Decontaminate ConcreteConcrete Biological Biological Shield The objective objective of this task will be to determine determine if activated activated or contaminated contaminated biological biological shield concrete is present, and if found removed shield concrete removed to meet meet release release criteria.
criteria. By the start start of Task Task 6, all contaminated contaminated and activated activated items will have been been removed from from the biological biological shield. The remainingremaining concrete concrete will be surveyed surveyed and sampled sampled for for
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activation and surface will be given near the beam activation contamination beam port, thermal attention for characterizing surface contamination. Added attention thermal column reactor's low power level and limited use, extensive Due to the reactor's activation is unlikely, if at all present. Added attention contamination will be given if signs of water attention for characterizing activation characterizing activation column and floor beneath the core box.
extensive and deep neutron neutron characterizing surface water leakage are observed, and near near probabilities of leakage, such as liner seams and locations having higher probabilities penetrations.
While activated activated or contaminated contaminated concrete is not expected, if it is found above release mechanical means, such as surface criteria, it will be removed by mechanical surface chipping, jack hammering hammering or hydraulic splitting. This process process would be iterative, where material would be removed, resulting surfacessurfaces characterized, and the procedure procedure repeated achievement of release criteria.
until achievement These removal techniques have a potential potential for creating airborne dust.
creating loose or airborne engineering controls will be used as required Accordingly, engineering to control, contain and contain collect any potentially potentially contaminated contaminated dust and debris. Such controls may include enclosing the top of the pool and other openings, use of HEPA-filtered enclosing HEPA-filtered ventilation collection of debris, and water misting.
for inward air flow, HEPA vacuum collection Remove Liquid Effluent Discharge Task 7: Remove Equipment Discharge Equipment
The objective effluent objective of this task will be to gain access to the interior of the liquid effluent equipment for the purpose of radiological discharge equipment discharge characterization, to determine if radiological characterization, remediation removing them as radioactive remediation is required, and if necessary removing radioactive waste.
effluent discharge equipment The liquid effluent small-bore piping, equipment consists of a few feet of small-bore which connects the hold-up tank (removed in Task 4) and reactor pool water water discharge pipe to a locked valve, which in-turn connects to a pipe that discharges to discharge sanitary sewer system. The piping is partially embedded the sanitary embedded in the concrete of concrete floor of the building's building's lower level, with the valve located in a floor pit.
interior of this piping and valve is not known at radiological condition of the interior The radiological this time. However, based on historical site assessmentassessment information and scoping survey results, these items may not be radiologically radiologically contaminated.
Non-embedded pipes and the valve will be mechanically Non-embedded segmented and removed as mechanically segmented radioactive waste. This removal will provide access assumed radioactive access to interior pipepipe surfaces surfaces for characterization embedded portions of the pipe. The interior of characterization of any embedded of evaluated for residual checked and evaluated the pipe will be checked contamination at accessible residual contamination openings (as previously previously described in Task 5 for embedded pipes, vents and conduits conduits Biological Shield). If the embedded that might need to remain within the Biological embedded portion of of screening values in Table the pipe exceeds the screening Table 2.2 and the items require removal, they will either either over cored or the surrounding concrete jack hammered to expose the surrounding concrete contamination is found within the radioactive contamination items for removal. Additionally, if radioactive
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pipe, the first sewer manhole reCelvmg checked checked for radioactive receiving discharges radioactive contamination discharges from this piping will also be contamination and decontaminated Task 8: Remove Exhaust Ventilation decontaminated or removed as required.
Ventilation Equipment Equipment be The objective objective of this task is the removal of ventilation ventilation ducts that could possibly containing containing internal contamination, and the evaluation of down-stream down-stream building ventilation ventilation equipment additional remediation is warranted.
equipment to determine if additional The exhaust exhaust ventilation equipment consists of about 50 linear feet of small-ventilation equipment diameter <<
diameter (< 4-inch), light-gauge light-gauge metal metal duct work, with two inline electric boosterbooster fans, that are connected connected to the beam port and thermal column column vent pipes embedded embedded in the biological biological shield. During reactor operation the ducts drew a vacuum reactor operation vacuum on the beam port and thermal thermal column column such that any gasses generated (e.g., Ar-41, half-life 1.8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) would be routed to the building's building's main exhaust ventilation ventilation system.
The ventilation ventilation duct will be segmented segmented and removed removed using mechanical mechanical methods, such as saws or shears, and placed into waste containers. The duct will be removed removed back to the point where it enters the building's building's main exhaust exhaust ventilation ventilation system.
The interior of the building's main ventilation ventilation system will be checked checked for fixed and contamination at accessible loose contamination accessible openings. While not expected, if contamination contamination is detected detected above the screening values in Table 2.2 (with no more than 10% being loose), the surfaces will be decontaminated decontaminated by simple wiping or vacuuming. If the system's interior interior surfaces surfaces can not be adequately decontaminated or accessed or adequately decontaminated or contamination levels contamination levels properly quantified, the ventilation system will be assumed assumed to be contaminated contaminated and will be removed as radioactive radioactive waste. Otherwise, Otherwise, it will be left in-place.
in-place. If radioactive contamination is found in the ventilation radioactive contamination ventilation ducts, the discharge discharge stack on the roof (and surrounding surrounding roofs) surfaces surfaces will also be checked checked for for radioactive radioactive contamination contamination and decontaminated decontaminated or removed as required.
Task 9: Remove Remaining Equipment Equipment The objective of this task is to survey, evaluate and/or remove remove any fixtures or or equipment remaining equipment remaining within the WPI LCWNRF, where surface contamination could contamination could have been missed or hidden in, under or behind equipment equipment or fixtures. Such Such remaining items may include sinks, old tools, work benches, etc.
remaining Task 10: Decontaminate Decontaminate Building Interior Surfaces Interior Surfaces The objective objective of this task is to provide assurance that the facility is ready for provide added assurance for conducting the FSS.
conducting This task will principally principally involve taking radiological radiological measurements measurements to identify any contamination contamination within the facility that may have been been missed during prior tasks. If any remaining remaining surface contamination contamination is identified it
will be remediated remediated at this time. Based upon the results of the historical site
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assessment and scoping surveys, any additional expected to be minimal.
Task 11: Prepare Waste Waste Packages additional structural Packages for Transportation structural decontamination decontamination is Disposal Transportation and Disposal The objective objective of this task will be the final disposition disposition of the radioactive radioactive wastes wastes generated generated during the decommissioning. Due to the relatively relatively small amount of of waste expected to be generated (less than 600 cubic feet), only one truck shipment shipment should be required. As such, containers of waste materials will be staged staged and prepared for shipment prepared shipment at the conclusion conclusion of the D&D activities. Section Section 3.2 describes describes the waste management performed during this task.
management activities to be performed Demobilize and Prepare Task 12: Demobilize Prepare Reactor Rooms for Final Status SurveySurvey During this task, the WPI facility will be prepared for the FSS. Contractors' Contractors' tools and equipment equipment used during the decommissioning will be surveyed, decontaminated decontaminated (if necessary), and removed from the facility. Final housekeeping housekeeping will be performed performed to remove remove debris, dust or protruding protruding objects from surfaces, which would otherwise interfere with the final survey. Ladders, scaffolding and equipment equipment to be used for for the final survey will be staged.
Termination Activities Task 13: Perform License Termination Activities
During this task, the FSS Plan will be prepared, implemented and the final report prepared and submitted 2.3.2 Schedule Schedule submitted to NRC with a request for termination report termination of the R-61 license.
Section 4.0, Proposed Final Radiation Survey Plan, describes describes these activities.
The decommissioning decommissioning project project schedule schedule is presented presented as Figure Figure 2.3. The January 2010 start date shown on the schedule schedule was chosen for illustration purposes only, with the actual start date based based on the timing of NRC approval approval of this DP and the DOE removal of the fuel. Due to the facility's small size, the tasks listed above will essentially essentially be performed performed in series, by a single work crew. Some task work may be be performed in parallel performed parallel to level work loads, where radiation and industrial safety interferences interferences do not exist. The duration of actual D&D work is expected expected to be less than 12 months. However, due to WPI being an active educational educational institution, some gaps in the work may need to be scheduled so as to avoid disruption of WPI's WPI's normal normal activities. Additionally, changes to the schedule schedule may be made at WPI's WPI's discretion discretion as a result of resource resource allocation, availability availability of a radioactive radioactive waste burial site, ALARA optimization and force majeure considerations.
ALARA optimization considerations. Notwithstanding Notwithstanding the foregoing, WPI does intend to complete the decommissioning decommissioning project as soon as possible. Based on the information in this Decommissioning Decommissioning Plan (DP), WPI anticipates anticipates that a formal request for termination termination of Facility License License No. R-61 will be submitted submitted to NRC within 24 months after the approval approval of the DP is received received from NRC.
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LCWNRF DECOMMISSIONING LCWNRF FIGURE 2.3 DECOMMISSIONING SCHEDULE 2.3 SCHEDULE Task Nilre
__ _ _ -Dec
_ Dec JenFeb MarAr a JunAJ Aug SepOctI Nov: ke JMFeb LhMAs I e.Dec issioonig ActMies 1.1.Phase 1:1:PPI e.Oecollvlussiollillg ActM Oes IIelfoil piol IPafofllled NRC PI ior to NRC DP Appoval)
OP Appr oval) 2 2.
2 Phase 2:eommisso g katioo n AcvWies 2: OecOIlVlussiolwlljJ Mobiizdtion ActMIies 3 2.1 Off-.se 1.1 OO*S<<e Motizion Mobiiz.-ion
4 21 Or~s~e Mobiizalion 12 Ok-sileMo iioo 5 Ptldse 3: Oecor.ami~lIion NMI
1. PIhas 3:D*m' Oislll<VtillO Ades WlisnWttnw ActMies 6 3.1 3.1 Task Rem R*a*t Core TaslI 1:1:RemweReoctor Sfhucie Cote Stlllchae 7 3.2 3.1 Task TaslI 2: Reome CodW 0Then RemtWe Cortefts Cok*
of T1leImalCohlnlll 8 3.3 3.1 Task Ta~ 3:IRemo1e0Re*01PoolE*110e RenKNe Reactor Pool ~,~nlel.
9 ,.4 3.4 Task TaslI 4::Remo Poo Walet TreIOAN RellKNe PooIWalet Tre.1lment System 110 0 3.5 Task :Reom Reacts 3.5 TaslI 5: RetlKNe Re,lCtor PoolliletsPool Limes A EnteddedDDr .1ilS and mId En~kled ad Pipe Pipe 1 I 3.6 Task 6: Dec 1!1 (eonft C eeBioIo!jC.ll Oecor'fllllillate COIlClete iological Shietd Shiekl 112 2 3.7 3.7 TAT7: TaslI 7: Remom Liqud EtfIuett RetlKNe Liquid Effh1limDischm chalMgeeEquipmem Eqpipieli 113 3 38 1.8 Task t: Rom . VetloiSs "em 8: RenKNe ExllillSl Vet411iol1 Systetn 1414 3.9 3.9 Task tto Remow Re Remwe Re!l1aili~ q ment Equipmem
1I5 3.10 Task 10:
116 17 6 .111 1818 ,.13 1919 4.4 PtldSe 10: [*tIecoite OecOf' Task11:WasteMa anWlie B 3.11 Task 11: Waste MiKlJgeOleft 17 3.12 TAQ2DemobizeandmPepael*idi laen BI"~ Muk8efi TaslI 12: Delllobiize !lxl Prep(lellujdi~for 3.13 TA13:PeloimlkeseTerin*
Phase 4: Se Restoiaion lPost Lt.
tsre RestOldtion IPost Lk. Tetlll)
SMaces kttetiol Surtaces WActWles TaslI 13: PertOfmLicetlSe Termili1liollActMties NeVrn fooFSS FSS 2.4 DECOMMISSIONING DECOMMISSIONING ORGANIZATION ORGANIZATION AND AND RESPONSIBILITIES RESPONSIBILITIES WPI is committed to, and retains ultimate responsibility for, full compliance compliance with the Institute's existing NRC reactor licenses licenses and applicable regulatory requirements during decommissioning. WPI's policies and goals will be followed to requirements ensure high standards standards of performance performance in accomplishing accomplishing the decommissioning decommissioning tasks.
WPI intends to utilize experienced experienced and qualified qualified consultants contractors to consultants and contractors perform perform the physical decommissioning decommissioning work. WPI will select the contractors contractors afterafter NRC's approval of the DP. The Reactor Director (from the Office of the Vice Vice President President for Finance and Operations) and the WPI Radiation Safety Officer (RSO),
with assistance of the Radiation Health and Safety Committee (RHSC) will monitor monitor performance performance of the consultants and contractors contractors to ensure that the decommissioning decommissioning work is being performed performed safely and according according to federal, state and local regulatory requirements (NRC, EPA, DOT, etc.).
requirements
Consistent with WPI policy, the RHSC has certain responsibilities to review and certain responsibilities approve policies, policies, procedures, procedures, programs and facilities pursuant pursuant to the safe use of of
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radiological radiological materials and radiation-producing will extend radiological radiation-producing equipment. The RHSC's jurisdiction extend to all decommissioning decommissioning activities radiological controls. The RSO and the RHSC will approve contractor contractor plans, policies described described in this DP.
policies and procedures jurisdiction radioactive material and activities dealing with radioactive approve consultant and procedures used during the decommissioning decommissioning as The planned organization organization for the WPI LCWNRF LCWNRF Reactor Decommissioning Project Project (WPI-RDP) is shown in Figure 2.4. Individuals Individuals performing performing the functions may vary over the project duration; however, the specified functions will be maintained.
contractors and subcontractors Consultants, contractors subcontractors performing performing work under this DP will be required required to comply comply with applicable applicable WPI policies, procedures and regulatory commitments.
2.4.1 WPI Reactor Director Director The WPI Reactor Reactor Director functions include:
Controlling Controlling and maintaining safety during decommissioning activities and protecting of the environment protecting environment
" Reporting Reporting of performance
" Approving Approving minor minor changes to the DP and procedures procedures (which do not change change the
original intent and do not involve an un-reviewed
" Oversight Oversight and consultants
" Ensuring Ensuring that that the un-reviewed safety question) coordination of WPI functional groups, and contractors and coordination conduct of decommissioning the conduct contractors and decommissioning activities complies with with applicable regulations applicable regulations and is in accordance accordance with WPI licenses licenses The minimum qualifications for the WPI Reactor minimum qualifications Reactor Director Director are:
" Currently Currently holds holds (or previously previously held) position of Reactor Director Director
" Ten years of management Ten years management experience experience in the field of regulatory compliance
" Familiarity Familiarity with with the WPI LCWNRF LCWNRF
" Appropriate Appropriate training training in radiation protection, nuclear safety, hazard communication, environmental protection and industrial safety communication, environmental
Worcester Polytechnic Institute WorcesterPolytechnic Institute Document Document W19-1579-003,WI9-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Section Section 2, Page 21 of 2, Page of3535
WPI-RDP DECOMMISSIONING FIGURE 2.4 FIGURE DECOMMISSIONING ORGANIZATION 2.4 ORGANIZATION WORCESTER POLYTECHNIC WORCESTER POLYTECHNIC INSTITUTE INSTITUTE Board Board of Trustees Trustees PRESIDENT PROVOST I Rakxiato H.1i~ &
RadjHboo, Hltallh Safeguards Director I Cornnittee Canrritlee I
I I
LCWNRF Reac-.or I
I Facility I I Radiation Radlalion Safety Officer Officer I (RSO)
(RSO)
I WPI WPI I I
CONTRACTOR(S)
CONTRACTOR(S) I PrOj9Ct Manager I I
IDecomlT1l5S1OOing CoItsullart)
I I
I I
I I
I I
Sil8 Supennlendem Radoo at Protection Radiological Protection TTechrictar's echnioans Radiological Erginew Radiological El19ir_
DecommIssioning Engn_
Deconaiihssonwig Engreer Adrninstrative Assistant Mministrntive Laborers Electricians Electricians Coring It Cutting Concrete Coring Conctete Waste Waste Disposal Transportalion Transportalion Laboratory Services laboratory Se<vices LEGEND:
LEGEND:
Line of Respornsility Line Responsiblity Line of of Coftiniocalion Communlcalion
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2.4.2 WPI Radiation Safety Officer The WPI Radiation Safety radiological support Officer Safety Officer (RSO) shall be responsible for providing decommissioning of the WPI LCWNRF. This function support in the decommissioning ensures that the activities involving involving potential potential radiological radiological exposure conducted exposure are conducted in compliance compliance with the applicable applicable licenses, federal and state regulations, and WPI operating procedures.
standard operating procedures. The position includes includes responsibility responsibility for maintaining the surveillance surveillance and monitoring monitoring program program and for HP radiological radiological protection protection procedures.
procedures.
The RSO will have oversight oversight of all D&D operations.
operations. The scope of his oversight will include all D&D operations operations that involve work with systems or materials that have a radiological component. The minimum qualifications qualifications for this position are:
"* An An advanced advanced degree in health physics or a related field
"* Ten years Ten years operational experience experience related to radiation radiation safety
"* Currently Currently holds (or previously previously held) position position of RSO The RSO is responsible responsible for ensuring that:
[* Radiological Radiological controls are in place prlOrprior to and during any work involving radiation radiation
Applicable Applicable license conditions are satisfied
Applicable satisfied Applicable state and federal regulations are met met The RSO has the authority to:
" Implement any actions necessary to ensure that radiological
Implement radiological controls controls are implemented implemented and followed followed
" Immediately stop or modify radiological Immediately stop radiological work determined to be unsafe unsafe 2.4.3 Decommissioning Decommissioning Consultant Consultant WPI may elect to use a decommissioning consultant to assist WPI with the decommissioning consultant management management of the decommissioning.
The consultant would provide provide project management management and day-to-day oversight of the contractors, as well as providing providing WPI with technical expertise expertise needed needed for the project. While more than one individual may provide provide assistance to WPI, the minimum qualifications for the lead consultant are:
minimum qualifications
An advanced degree in health radiological engineering health physics, radiological engineering or a related field
*0 10 years supervisory experience related supervisory experience related to radiation radiation safety
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10 years operational including decommissioning decommissioning project Contractor Assistance 2.4.4 Contractor experience related to radiological operational experience including completion project radiological decommissioning, completion of a minimum of one NRC-licensed NRC-licensed research reactor reactor Decommissioning Consultant, will select WPI management, with assistance from its Decommissioning select qualified contractors contractors to perform the physical decommissioning decommissioning of the LCWNRF. In In addition to planning and implementing the physical decommissioning activities, the contractors contractors (which may include the Decommissioning Consultant's organization)
Decommissioning Consultant's will provide required HP support, radiation radiation surveys, and waste packaging, processing, and shipping.
Contractors will be selected after WPI's receipt from NRC of the license Contractors license amendment amendment authorizing authorizing decommissioning. The selection selection process will be based on defined a defined selection criteria for contractor scope of work and selection experience, and contractor qualifications, experience, required contractor qualifications reputation. The required experience shall include the qualifications and experience following:
a. Demonstration Demonstration of experience experience in the performance performance of the following tasks, as applicable to their roles and responsibilities:
applicable
" Integration Integration of decommissioning, dismantlement dismantlement and demolition demolition plans
" Waste management management and other other methods used to minimize final waste disposal costs
" Radiological decontamination and remediation Radiological decontamination remediation of facilities and equipment equipment
" Use of survey equipment and protocols protocols suitable suitable for compliance with current NRC or MARSSIM survey criteria
" Development Development and executionexecution of radiation protection, environmental protection and industrial safety programs that will be used during the D&D D&D
" Selection, design and/or procurement of appropriate and/or procurement appropriate containers containers and packaging packaging for radioactive radioactive and hazardous waste, and transportation to transportation approved treatment and disposal approved treatment disposal facilities
" Performing termination surveys on a project of similar size and Performing license termination scope scope
" Waste management management (packaging, manifesting and transportation) of of radioactive radioactive waste
b. The contractor contractor selected management must be able to provide a QA selected for waste management QA requirements under Code of federal Regulations program that meets the requirements Regulations
(CFR) 10 CFR 71, Packaging (CFR)
Subpart H, Quality Quality Assurance.
Assurance.
Radioactive Material, Packaging and Transportation of Radioactive
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c. The contractors will be required to provide qualified personnel and programs, including but not limited to the following areas of expertise, as applicable their roles and responsibilities:
applicable to
" Project Project management management
" Health Physics Health
" Radiological engineering Radiological engineering with MARSSIM survey experienceexperience
" Radioactive Radioactive waste management management
" Industrial Industrial and occupational safety
" Civil Civil and and mechanical mechanical engineering engineering
" Quality Quality assurance assurance
" Construction Construction supervision supervision
" Project controls Project controls
" Decontamination and waste handling Decontamination
" Radiological Radiological safety engineering
" Worker Worker training training and qualification qualification 2.5 TRAINING PROGRAM TRAINING Individuals (employees, contractors contractors and visitors) who require access to the work areas or a radiologically radiologically restricted restricted area will receive training training commensurate commensurate with the potential potential hazards to which they may be exposed.
Radiation protection protection training will be provided provided to personnel who will be performing remediation work in radiological areas or handling radioactive radioactive materials. The training will ensure that decommissioning decommissioning project personnel personnel have sufficient sufficient knowledge to perform work activities knowledge activities in accordance accordance with the requirements requirements of the radiation radiation protection protection program and and accomplish ALARAALARA goals and objectives. The principle objective principle objective of the training training program is to ensure personnel personnel understand the responsibilities and the required responsibilities required techniques techniques for safe handling handling of radioactive materials and for minimizing exposure minimizing exposure to radiation. Table Table 2.4 provides a outline outline on on the methods methods for training, evaluating, and certifying certifying staff staff and contractors, contractors, with an an emphasis emphasis on D&D activities.
Training Training records will will be maintained maintained which will include trainee's trainee's names, dates dates of of training, type of training, test results, authorization authorization for protective protective equipment equipment use, and instructor's instructor's name. RadiationRadiation protection protection training training provides the necessary necessary information information for workers workers to implement implement sound radiation radiation protection protection practices.
practices. The following following are examples examples of the training programs applicable training programs applicable to remediation remediation activities.
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2.5.1 General General Site Training WPI will be implement implement a general training program to project personnel program designed designed to provide orientation personnel and meet the requirements of 10 CFR Part 19, Notices, orientation Notices, Instructions and Instructions and Reports to Workers:
Workers: Inspection Inspection andand Investigations Investigations (Ref.
(Ref. 14).
General General Site Training Training (GST) will be required required for all personnel assigned on a regular regular basis to the decommissioning decommissioning project. GST will include:
" Project orientation/access control Project orientation/access control
" Introduction Introduction to radiation protection radiation protection
" Quality Quality assurance
" Industrial Industrial safety
" Emergency procedures Emergency procedures 2.5.2 Radiation Radiation Worker Worker Training All individuals directly associated with the WPI-RDP WPI-RDP will be required to undergo Radiation Radiation Worker Worker Training Training (RWT), which will include include the following topics:
" Fundamentals Fundamentals of radiation radiation Biological Biological effects of radiation External
" Internal ALARA Program radiation External radiation exposure exposure limits and controls Internal radiation limits and controls
" ALARA Program (program, objectives, investigational investigational limits, keeping keeping doses ALARA)
Contamination limits and controls Contamination controls
" Management Management and control of radioactive radioactive waste
" Use of personal protective Use of equipment protective equipment Personnel Personnel who have documented documented equivalent equivalent RWT from another another site may be waived waived from taking taking training except except for training on site specific requirements specific requirements such as, WPI's WPI's administrative administrative limits and emergency emergency response response actions. Personnel Personnel will be required required to pass the written written examination examination and practical exercises.
2.5.3 Respiratory Respiratory Protection Training Generation airborne radioactivity Generation of airborne radioactivity and extensive contamination extensive loose surface contamination during the decommissioning decommissioning activities is not expected, and use of respiratory protective devices is unlikely to be needed. However, if personnel personnel whose work work
assignments do require respiratory require the use of respiratory protection respiratory protection training required to use. The training training program protection devices, they will receive training in the devices and techniques techniques that they will be program will follow the requirements requirements of:
of:
be
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N
10 CFR 10 CFR 20 Internal 20 Subpart Subpart H, Respiratory Internal Exposure
0 Regulatory 16)
Exposure in Restricted Regulatory Guide Respiratory Protection Restricted Areas (Ref.
Protection and Controls (Ref. 15)
Guide 8.15, Acceptable Programs Programs for Controls to Restrict for Respiratory Respiratory Protection Protection (Ref.
(Ref.
N NUREG NUREG 0041, Manual of Respiratory Respiratory Protection Protection Against Airborne Airborne RadioactiveMaterials Radioactive Materials(Ref.
(Ref. 17)
0 29 29 CFR 1910.134, Respiratory Protection 1910.134, Respiratory Protection(Ref.
(Ref. 18)
Training would be provided provided by either the Decommissioning Decommissioning Consultant or a specialty contractor contractor and would consist of a lecture lecture session and a simulated simulated work Personnel who have documented session. Personnel documented equivalent respiratory protection training may be waived from this training. Use of respiratory protective devices will require specific medical evaluation specific evaluation and respiratory respiratory device fit testing.
2.6 DECONTAMINATION DECONTAMINATION AND DECOMMISSIONING DECOMMISSIONING DOCUMENTS DOCUMENTS AND GUIDES Health physics, industrial industrial safety criteria criteria and other standards standards that guide the described in this DP are discussed activities described discussed in the following sections of this DP:
" Section 3.1 Radiation
Section Protection Radiation Protection
" Section 3.2
Section 3.2 Radioactive Radioactive Waste Waste Management Management
" Section 3.3
Section 3.3 General General Industrial Safety Program
" Section 3.4
Section 3.4 Radiological Radiological Accident Analyses Analyses Relevant documents and guides used are noted therein.
2.7 FACILITY FACILITY RELEASE CRITERIA The proposed decommissioning decommissioning alternative alternative that has been presented presented in this DP does not necessitate necessitate the dismantlement dismantlement of the building that houses the WPI reactor. The results of the historical site assessment and radiological radiological surveys indicate that the building structures (exclusive of the reactor pool / biological shield structure) may reactor pool/biological be directly releasable, without without the need for decontamination.
This section section provides the specific criteria for unrestricted unrestricted release of the WPI WPI LCWNRF. The final release survey will use the Derived Concentration Concentration Guideline Levels (DCGL's) developed developed from the current current NRC guidance guidance for license termination termination in 10 CFR Part 20, Subpart E, Radiological Criteria for License Termination, Radiological Criteria Termination, Standards Standards of Protection Protection Against Radiation Radiation (Ref.
(Ref. 19).
19).
10 CFR 20.1402, Subpart allows termination termination Radiological Criteria Subpart E, Radiological of a license and Criteria for release radioactivity that is distinguishable residual radioactivity of a for Unrestricted site distinguishable from background for unrestricted unrestricted (Ref. 12),
Unrestricted Use (Ref.
use background radiation results in a if the
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average member effective dose equivalent to an average total effective member of a critical group that does not exceed 25 millirem (0.25 mSv) per year and the residual radioactivity reduced to levels that are as low as is reasonably reduced The current NRC guidance for acceptable license termination radioactivity has been reasonably achievable (ALARA).
termination screening screening values does been (meeting the 10 CFR 20.1402 20.1402 criteria) for common radionuclides for building common radionuclides surface contamination contamination and surface surface soil contamination contamination are presented in NUREG-Appendix B, Consolidated 1757, Volume 1, Appendix NMSS Decommissioning Consolidated NMSS Decommissioning Guidance, Guidance, Decommissioning Process Decommissioning for Materials Process for Licensees, (Ref.
Materials Licensees, (Ref. 20). As such, an ALARA analysis is not needed. As stated stated in Section 6.3 in Volume Volume 2 of NUREG-1757, NUREG-1757, "Consolidated "Consolidated NMSS Decommissioning Guidance Characterization, Survey, and Decommissioning Guidance - Characterization, Determination of Radiological Determination Radiological Criteria,"
Criteria," (Ref.
(Ref. 29), "in light of the conservatism conservatism in in the building surface and surface screening levels developed by the NRC surface soil generic screening staff, the staff presumes, absent information to the contrary, that licensees staff, licensees or or building surfaces or soil to the generic screening parties that remediate building responsible parties demonstrate that these levels are ALARA."
levels do not need to demonstrate Upon completion of the decontamination remediation activities (e.g., see decontamination and remediation Section Section 2.3 Decommissioning Decommissioning Tasks), WPI will completecomplete a FSS of the WPI reactor reactor facility using the method described in NUREG-1575, NUREG-1575, Multi-Agency Radiation Radiation Survey and Site Investigation Investigation Manual Manual (MARSSIM) (Ref. (Ref. 11). To support the license termination request, the results of the survey(s) will be summarized summarized in a reportreport which will be submitted to NRC, as required by NUREG 1537 (Ref. (Ref. 5).
impractical or not possible If it is impractical satisfy release criteria (or conclusively possible to satisfy demonstrate that they have been met), the location/item demonstrate location/item will be treated as radioactively contaminated radioactively dispositioned as low-level radioactive contaminated and dispositioned radioactive waste.
radiological surveys and historical Based upon radiological historical site assessment, there is no knownknown suspected potential or suspected potential for surface soil contamination criteria for soil will contamination and release criteria will likely not be needed.
Where there is measurable measurable volumetric radioactivity above background, WPI plans volumetric radioactivity radioactive waste. However, if its removal will to require to remove concrete as radioactive extensive demolition extensive demolition of the Biological disturbance of the building's Biological Shield or disturbance structural features, and structural structural concrete with measurable structural concrete measurable volumetric radioactivity needs to remain in place at license termination, the probabilistic radioactivity RESRAD-BUILD 3.0 code RESRAD-BUILD (Ref. 34) will be used for deriving appropriate code (Ref. appropriate DCGLs.
The release sum-of-fractions unity rule, based release criteria will be based upon use of the sum-of-fractions based radionuclides on or in the material concentrations of radionuclides on relative concentrations material and their respective release criteria if more than one radionuclide radionuclide is present. If additional screening additional screening
values are required included in Table 2.2 or Table 2.3, they will be required for nuclides not included be
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calculated using the probabilistic calculated and assessing MARSSIM RESRAD-BUILD 3.0 code (Ref.
probabilistic RESRAD-BUILD MARSSIM site surveys, with default TABLE 2.2 default values.
2.2 (Ref. 34) for planning LICENSE TERMINATION TERMINATION SCREENING SCREENING VALUES VALUES FOR BUILDING SURFACE CONTAMINATIONCONTAMINATION ACCEPTABLE SCREENING SCREENING LEVELS* LEVELS*
RADIONUCLIDE RADIONUCLIDE SYMBOL SYMBOL UNRESTRICTED RELEASE FOR UNRESTRICTED RELEASE (dpni/100 (dpmllOO cm cm 22)**
Hydrogen-3 (Tritium)
Hydrogen-3 (Tritium) 3H 3H 1.2e+08 1.2e+08 Carbon-14 14C 3.7E+6 3.7E+6 22 22Na Sodium-22 Sodium-22 Na 9.5E+03 Sulfur-35 Sulfur-35 35S 35S 1.3E+07 1.3E+07 Chlorine-36 Chlorine-36 36CI 36C1 5.03+05 54 54Mn Manganese-54 Manganese-54 Mn 3.2E+04 55 55Fe Iron-55 Iron-55 Fe 4.5E+06 6
60CO Cobalt-60 0Co 7.1E+03 6
63Ni Nickel-63 Nickel-63 3Ni 1.8E+06 1.8E+06 "Strontium-90 90 Sr 90Sr
'Strontium-90 8.7E+03 Technetium-99 Technetium-99 99Tc 1.3E+06 1.3E+06 Iodine-129 129 lodine-129 12911 3.5E+04 Cesium-137 137CS 137Cs 2.8E+04 192 1921r Iridium-192 Iridium-192 1r 7.4E+04
Screening levels are Screening levels based on are based on the assumption that the assumption that the the fraction fraction ofof removable surface contamination removable surface contamination is is equal equal to to 0.1. For For cases when the fraction fraction of removable contamination is removable contamination is undetermined undetermined or higher higher than than 0.1, users may users may assume, assume, for for screening screening purposes, purposes, that that 100 percent percent of surface contamination of surface contamination is removable, removable, and and therefore therefore the screening screening levels should be decreased decreased by a factor factor of 10. Alternatively, users having Alternatively, users having site-specific data on the site-specific data fraction fraction of removable contamination, based removable contamination, based on site-specific resuspension factors, site-specific resuspension factors, (e.g., within 10 percent percent to 100 percent range) range) may calculate site-specific screening calculate site-specific screening levels using using RESRAD-BUILD Version Version 3.0 (Ref.
(Ref. 34).
2
Units Units are are disintegrations disintegrationsper (dpm) per per minute (dpm) square centimeters per 100 square 2
(dpm/100 cm2).). One dpm is centimeters (dpm/100 is equivalent to 0.0167 0.0167 Becquerel Becquerel (Bq).
(Bq). Therefore, Therefore, to convert to units units of Bqlm2 multiply each value by 1.67.
of Bq/m 1.67. The screening values screening values represent represent surface concentrationsof individual surface concentrations radionuclidesthat would be deemed in individual radionuclides compliance with the in compliance the 0.25 mSv/yr (25 mrem I/ year) mSvlyr year) unrestricted unrestricted release release dose limit limit in CFR 20.1402.
in 10 CFR 20.1402. For For radionuclides radionuclides in in a mixture, mixture, the the "sum of "sum of fractions" rule applies fractions" rule (see Part applies (see Part20, 20, Appendix B, B, Note 4).
4).
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LICENSE TERMINATION TERMINATION SCREENING TABLE 2.32.3 SCREENING VALUES FOR SURFACE SOIL SOIL
.. ' SURFACE ,SOIL SOIL SCREENING RADIONUCLIDE*
RADIONUCLIDE* VALUES** FOR UNRESTRICTED SYMBOL 'VALUES**
. RELEASE (pCilJ()***
(pCi/g)***
3 Hydrogen-3 (Tritium) 3HH 1.1E+02 1.lE+02 Carbon-14 14C 14C 1.2E+1 1.2E+l 22 22Na Sodium-22 Na 4.3E+00 4.3E+OO 35 35S Sulfur-35 S 2.7E+02 Chlorine-36 36CI 36C1 3.6E-01 3.6E-Ol 45 Calcium-45 45CaCa 5.7E+01 5.7E+Ol 46 46S Scandium-46 Scandium-46 ScC 1.5E+01 1.5E+Ol 54 54Mn Manganese-54 Manganese-54 Mn 1.5E+01 1.5E+Ol 55 Iron-55 55FeFe 1.0E+4 1.0E+4 5
Cobalt-57 Cobalt-57 57CO 7Co 1.5E+02 1.5E+02 60 60CO Cobalt-60 Cobalt-60 Co 3.8E+00 3.8E+OO Nickel-59 Nickel-59 59Ni 5.5E+03 63 Nickel-63 63NiNi 2.1E+03 90 90S Strontium-90 Strontium-90 Srr 1.7E+00 1.7E+OO Niobium-94 94Nb 5.8E00 5.8EOO 9
Technetium-99 Technetium-99 99Tc 9Tc 1.9E+01 1.9E+Ol Iodine-129 129 12911 5.OE-01 5.0E-Ol Cesium-134 Cesium-134 134 Cs 134CS 5.7E+00 5.7E+OO Cesium-137 Cesium-137 137CS 137Cs 1.1E+01 1.1E+Ol Europium-152 Europium-152 152Eu 8.7E+00 8.7E+OO 154 Europium- 154 Europium-154 154EuEu 8.OE+00 8.0E+OO 192 192Ir Iridium-192 Iridium-192 1r 4.1E+01 2 10 Lead-210 210PbPb 9.OE-01 9.0E-Ol 226 226Ra Radium-226 Radium-226 Ra 7.OE-01 7.0E-Ol 226 Radium-226+C Radium-226+C 226Ra+C Ra+C 6.OE-01 6.0E-Ol 227 Actinium-227 Actinium-227 227AcAc 5.OE-01 5.0E-Ol 227 Actinium-227+C Actinium-227+C 227Ac+C Ac+C 5.OE-01 5.0E-Ol 22 8 Thorium-228 Thorium-228 228ThTh 4.7E+00 4.7E+OO (Note: Table Table 2.3 is continued continued on next page)
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LICENSE TERMINATION TERMINATION SCREENING TABLE 2.3 (continued)
SCREENING VALUES FOR SURFACE SURFACE SOIL SCREENING SURFACE SOIL SCREENING RADIONUCLIDE*
RADIONUCLIDE* SYMBOL SYMBOL VALUES** UNRESTRICTED VALUES** FOR UNRESTRICTED RELEASE RELEASE (pCi/g)***
Thorium-228+C Thorium-228+C 228Th+C 228~Th+C 4.7E 4.7E+OO Thorium-230 230Th 23OTh 1.8E+00 1.8E+OO Thorium-230+C Thorium-230+C 23OTh+C 23°Th+C 6.OE-01 6.0E-Ol Thorium-232 232TH 232TH 1.1E+00 l.lE+OO 2 2 232TH+C Thorium-232+C Thorium-232+C 3 TH+C 1.1E+00 l.lE+OO 23 231Pa Protactinium-231 Protactinium-23l 'Pa 3.OE-01 3.0E-Ol 2231Pa+C 3
Protactinium-231+C Protactinium-23l +C 'Pa+C 3.OE-01 3.0E-Ol Uranium-234 234U 1.3E+01 1.3E+Ol Uranium-235 Uranium-235 235U 8.OE+00 8.0E+OO 235 Uranium-235+C Uranium-235+C 235U+CU+C 2.9E-01 2.9E-0l 2
238U Uranium-238 Uranium-238 38U 1.4E+01 1.4E+Ol Uranium-238+C Uranium-238+C 238U+C 238U+C 5.OE-01 5.0E-Ol Plutonium-238 Plutonium-238 238Pu 23SPu 2.5E+00 2.5E+OO Plutonium-239 Plutonium-239 239PU 239Pu 2.3E+00 2.3E+OO Plutonium-241 Plutonium-24l 241PU 241Pu 7.2E+01 7.2E+Ol 241 Americium Americium 241Am Am 2.1E+00 2.lE+OO 241 241Cm Curium-242 Curium-242 Cm 1.6E+02 1.6E+02 243 243Cm Curium-243 Curium-243 Cm 3.2E+00 3.2E+OO
Plus Plus Chain Chain (+C) indicates a value for
(+C) indicates radionuclide with its for a radionuclide present in its decay progeny present in equilibrium.
equilibrium. The values care care concentrations concentrations ofof the parent parent radionuclide, account for radionuclide, but account for contributions chain ofprogeny contributions from the complete chain progeny in in equilibrium parent radionuclide equilibriumwith the parent radionuclide (NUREGICR-5512 (NUREGICR-5512Volumes 1, 1, 2, and and 3).
These values represent These represent surface surface soil concentrations concentrations of of individual individual radionuclides radionuclides that that would be deemed in in compliance with the 25 mrem/year compliance mrem/year (0.25 mSv/year) unrestricted release mSvlyear) unrestricted release dose dose limit limit in in 10 CFR CFR 20.1402.
20.1402. For For radionuclides radionuclides in in a mixture, mixture, the "sum "sum of fractions"rule applies (see Part fractions" rule applies Part 20, Appendix B, B, Note 4).
Screening are in Screening values are units of (pCi/g) in units equivalent to 25 mrem/year (pCilg) equivalent mrem/year (0.25 (0.25 mSvlyear). convert from pCilg To convert pCilg to to units of Becquerel units of Becquerel per per kilogram kilogram (Bqlkg)
(Bq/kg) divide divide each each value by 0.027.
0.027. These values values were were derived derived based based on selection selection of the 99(jh of 01h percentile percentile of the output dose dose distribution distribution for each specific radionuclide for each radionuclide (or radionuclide with the (or radionuclide specific decay chain). Behavioral parameters chain). Behavioral parameters were set at at the mean of of the distribution distribution of the assumed assumed critical critical group.
group. The metabolic metabolic parameters parameters were set at "Standard "StandardMan" or at at the mean of the distribution for an distribution for an average average man.
man.
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DECOMMISSIONING WORKER DECOMMISSIONING Radiological Fundamentals
1. Radiological Fundamentals TABLE 2.42.4 WORKER TRAINING TRAINING OUTLINE
a. Atoms and atomic atomic particles particles Radioactivity
b. Radioactivity
c. Half-life
d. Radiation Radiation and contamination contamination
e. Types and properties properties of ionizing radiation radiation i.
I. Alpha Alpha ii. Beta
11. Beta iii.
11I. Gamma Gamma / X-rays X-rays iv. Neutrons IV.
f.f. Units of measurement measurement i.
I. Exposure Exposure and dose ii. Radioactivity
11. Radioactivity and contamination contamination
2. Biological Biological Effects of Radiation Radiation
a. Effects Effects of radiation radiation on cells cells
b. Acute Acute and chronic radiation radiation dose and effects effects
c. Somatic Somatic and genetic effects effects
d. Possible consequences consequences of radiation dose
e. Prenatal Prenatal radiation radiation exposure i.
I. Potential Potential effects to fetus ii. Dose limits and worker
11. responsibilities worker responsibilities f.
f. Comparison of health risks
3. Sources Sources of Radiation Radiation
a. Natural radiation Natural radiation i.
I. Cosmic ii. Terrestrial
11. Terrestrial
b. Human sources of radiation radiation i.
I. Medical Medical ii.
11. Consumer products
11I. Weapons iii. Weapons testing iv. Industrial IV. Industrial
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DECOMMISSIONING TABLE 2.4 (continued)
DECOMMISSIONING WORKER
c. Types and magnitude WORKER TRAINING OUTLINE TRAINING OUTLINE magnitude of background radiation radiation exposure
4. Radiation Exposure Minimization Minimization - ALARA ALARA
a. ALARA ALARA concept - Definition Definition of "Reasonable" exposure and need for for minimization minimization Responsibilities for ALARA
b. Responsibilities
i. Management Management ii. Radiological control personnel Radiological personnel ill.
iii. Individual radiation Individual radiation workers workers
c. External dose reduction practices practices i.
1. Time, distance concept distance and shielding concept ii. Minimization of exposure time 11.
1. Work planning
2. Getting ready before "Entry" "Entry" 3.
3. Mock-up and work practice
4. No loitering / minimization minimization of workers
5. Use of efficient
5. practices efficient work practices
6. Maximizing Maximizing performance performance of work away from radiation radiation sources sources ill.
111. maximizing working distance from radiation Methods for maximizing radiation sources sources
1. Inverse Square Square Law
2. Worker positioning 3.
3. - low dose waiting areas Work delays -low
4. of long-handled tools / remote handling Use oflong-handled iv.
IV. Proper use of shielding
1. Shielding Shielding concept concept and materials materials
2. Facility's permanent shielding Facility's permanent
3. Temporary Temporary shielding
4. Authorization Authorization to move shielding
d. Minimization of Internal Dose i.
1. Loose and airborne contamination control techniques airborne contamination techniques
1. Non-destructive Non-destructive disassembly
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DECOMMISSIONING WORKER DECOMMISSIONING TABLE 2.4 (continued)
WORKER TRAINING TRAINING OUTLINE OUTLINE
2. Prohibition Prohibition of thermal thermal cutting and grinding on RAM
3. Dust collection collection at source
4. Containment Containment enclosures HEPA enclosures / inward air flow / HEP A filtration / protective coverings coverings
5. Control Control zones and movement movement of personnel and materials materials ii.
11. Respiratory Respiratory protection protection 111. PPE iii.
iv.
IV. Personnel Personnel frisking
v. Contamination Contamination monitoring and surveillance surveillance program 5.
5. Dose limits Regulatory limits
a. Regulatory
b. Project administrative administrative control limits
c. Declared pregnant
d. Non- radiation
6. Governing regulations pregnant worker worker radiation workers and visitors regulations and requirements pertaining Decommissioning Decommissioning pertaining to the WPI Reactor Reactor 10CFR19, "Notices, Instructions
a. 10CFR19, Instructions and reports to Workers:
Workers: Inspection Inspection and Investigations"
b. 10CFR20, 10CFR20, "Standards "Standards for Protection Against Radiation" 10CFR50, "Domestic Licensing of Production
c. 10CFR50, Production Utilization Utilization Facilities" 10CFR61, "Licensing
d. 10CFR61, "Licensing Requirements Requirements for Land Disposal of of Radioactive Radioactive Waste"
e. 10CFR71, 10CFR71, "Packaging and Transportation Transportation of Radioactive Radioactive Material" f.f. 29 CFR1926, "OSHA Construction Construction Standard"
g. 49CFR- Subchapter Subchapter C, "Transportation "Transportation Regulations- Hazardous Hazardous Material Regulations"
h. Decommissioning Decommissioning Plan, NRC license and Technical Specifications Specifications
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7.
DECOMMISSIONING
7. Personnel Personnel Monitoring TABLE 2.4 (continued)
DECOMMISSIONING WORKER WORKER TRAINING TRAINING OUTLINE OUTLINE
a. External External Dosimetry
i. TLD badge ii. Self-reading Self-reading pocket dosimeters
b. Proper Proper use of dosimetry
c. Internal Internal monitoring i.
1. Air sampling program ii.
11. DAC and ALI iii. In-vitro bioassay 111.
iv. Whole IV. Whole body counting
d. Access to dose records
e. Worker Worker responsibilities responsibilities regarding dose records
8. Major Sources of Radiation Radiation at the WPI Reactor
a. Activated control blade
b. Activated Activated Reactor
c. Activated Reactor Core Box Activated Thermal Column Box Column Reactor Activated Beam Port
d. Activated
e. Contaminated Contaminated pool equipment equipment Site-specific Radiation Hazards
9. Site-specific Hazards and Controls Overview of decommissioning
a. Overview decommissioning program objectives objectives
b. Overview Overview of decommissioning decommissioning work activities activities (DP Tasks 1-13)
c. Overview Overview of reactor facility radiological radiological conditions and hazards hazards Overview of planned D&D methods, constraints
d. Overview constraints and prohibitions prohibitions
e. Task-specific Task-specific radiological and industrial industrial safety controls i.
1. Radiological Radiological conditions conditions / safety hazards hazards ii.
11. ALARA Plan ill.
111. Allowable / prohibited work methods Allowable iv.
IV. Contamination / dose control Contamination control requirements requirements
v. Safety hazards hazards and required controls controls
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DECOMMISSIONING DECOMMISSIONING WORKER f.
TABLE 2.4 (continued)
WORKER TRAINING OUTLINE Decommissioning Organization
f. Decommissioning OUTLINE Organization Roles, Responsibilities and Authority
i. management staff
1. Project management staff ii.
11. Radiation protection protection staff staff
1. Radiation Safety Officer
1. Officer (RSO)
2. Radiation Control Technician Technician (RCT) iii. Radiation workers 111.
iv.
IV. NRC and State of Massachusetts Massachusetts personnel personnel
g. Project Project work controls
i. Written Written procedure requirements and compliance procedure use requirements compliance ii. Requirements Requirements for Radiation Radiation Work Permits (RWP) iii. RCT coverage
10. Emergencies, Emergencies, Alarms and Responses Responses
a. Radiation Radiation level alarm
b. Continuous airborne monitor alarm
c. Personnel contamination incidents Personnel contamination
d. Fire
e. Injury f.f. Security Security threat threat
g. Personnel Personnel protective equipment equipment failure
h. Failure equipment important Failure of equipment important to radiological and industrial safety
11. Practical Practical Factors Factors Exercises Exercises
a. Facility Facility access access
b. Donning / doffing PPE
c. Reading Reading / interpreting interpreting radiation surveys surveys
d. RWP sign-on sign-on
e. Step-off pad use f.f. Frisking
g. Stop work and hazard recognition recognition
Examinations and Demonstration
12. Written Examinations
a. All of above to be covered Demonstration of Practical Factors covered Factors
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3.1 3.0 OCCUPATIONAL OCCUPATIONAL AND RADIATION RADIATION PROTECTION PROTECTION AND PUBLIC HEALTH AND AND SAFETY 3.1.1 Ensuring As Low As Reasonably Achievable (ALARA) Radiation Exposures Exposures Decommissioning activities at the WPI LCWNRF Decommissioning LCWNRF involving the use and handling of of radioactive materials will be conducted radioactive conducted in a manner such that radiation radiation exposure will be maintained As Low As Reasonably Achievable (ALARA), taking into account account the current state of technology technology and economics improvements in relation economics of improvements relation to the benefits.
ALARA ALARA Program A documented documented ALARA evaluation evaluation will be required for specific work evolutions if it is likely that 5%5% of the applicable applicable dose limits (collective dose) for any of the following may be exceeded:
" Total Total Effective Effective Dose Equivalent (TEDE) (5 rem)
Equivalent (TEDE)
" The sum of The sum of the Deep Dose Equivalent (DDE) and the Committed Committed Dose Equivalent (CDE) to any individual organ organ or tissue other other than the lens of the eye (50 rem)
*" Eye Dose Equivalent Eye Dose Equivalent (EDE) (15 rem)
" Shallow Dose Shallow Dose Equivalent (SDE) to the skin or any extremity (50 rem)
The ultimate ultimate responsibility for assuring radiation radiation protection protection and maintaining decommissioning remain with the WPI Reactor Director exposures ALARA during decommissioning Director and Radiation Radiation Safety Safety Officer (RSO).
Occupational Exposure Methods for Occupational Exposure Reduction Reduction Various Various methods will be utilized during the Decommissioning Decommissioning Project to ensure ensure that that occupational exposure to radioactive occupational radioactive materials materials is kept ALARA. The methods include the use of Radiological Radiological Work Permits (RWPs), use of protective protective equipment, radioactive material handling techniques, and work practices as described in the following subsections.
subsections. Work will be performed performed in accordance accordance with NRC regulations Decommissioning Plan (DP), and implemented and this Decommissioning accordance with implemented in accordance with approved written procedures.
approved procedures.
Radiological Work Permits (RWPs)
Radiological A Radiation Work Permit (RWP) will be used for the administrativeadministrative control of of personnel personnel entering or working in areas that have radiologicalradiological hazards. Work Work techniques will be specified in such a mannermanner that the exposure for all personnel,
individually and collectively, are maintained ALARA. RWPs will not replace procedures, but will supplement supplement procedures. Radiation Radiation work replace work practices practices will 'bebe
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considered when procedures radiologically procedures are developed radiologically controlled area.
developed for work that will take place in a Project RWPs will describe the job to be performed, define protective equipment to be used, and personnel monitoring protective clothing and monitoring requirements. RWPs will also specify any special special instructions or precautions pertinent to radiation precautions pertinent radiation hazards in the area. Such information information will include listing the radiological radiological hazards present, areaarea dose rates and the presence and intensity of hot spots, loose and fixed surface radioactivity, and other hazards as appropriate.
appropriate. The Health Physics (HP) organization will ensure organization ensure that radiation, surface radioactivity radioactivity and airborne surveys surveys are performed performed as required required to define and document the radiological conditions for each work activity.
RWPs for work activities with low dose commitments commitments may be approved by the HP HP technician or HP supervisory supervisory personnel. RWPs for work activities with potentially high dose commitment commitment or significant significant radiological radiological hazards will be approved by the Decommissioning Consultant. Use of RWPs will be governed RSO or Decommissioning governed by written and approved procedure. Examples of topics covered by RWP implementing procedures procedures include:
" Requirements, classifications
Requirements, classifications and scope for RWPs Initiating, preparing and using RWPs Initiating, Extending expiration Extending RWPs expiration dates of an RWP Terminating RWPs
Terminating RWPs RWP Respiratory Protection Respiratory Protection and TEDE ALARA Evaluations Evaluations WPI anticipates that dismantling activities for the more radioactive components components can be performed performed by unbolting or unlatching, without the need for segmentation.
However, if it is required, segmentation activities will be minimized and limited to mechanical cutting (e.g., sawing or shearing) which does not generate airborne dust, mechanical fumes or smoke. If there ever is a potential for generating generating airborne radioactivity, the use of engineering engineering controls will be the first choice with respect to controlling the the hazard. Engineering Engineering controls will be used to mitigate the airborne radiological radiological hazard at the source. Such controls may include contaminant contaminant capture with HEPA-filtered vacuums.
While extremely extremely unlikely, if circumstances circumstances were to exist where engineering engineering controls are not practical or may not be sufficient to prevent airborne concentrations concentrations that constitute an airborne airborne radioactivity radioactivity area, and worker access access is required required to such such equipment will be utilized areas, respiratory protective equipment utilized to limit internal internal exposures.
Any situation wherein workers are allowed access to an airborne radioactivity area, wherein allowed or allowed to perform work that has a high degree of likelihood likelihood to generate airborne radioactivity exceeding a radioactivity exceeding valuevalue of 0.1 Derived Air Concentration Concentration (DAC), the decision decision
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in accordance accordance with appropriate accompanied by the performance to allow access will be accompanied measurements of airborne radioactivity to assess performance of representative assess potential worker intake. The results of DAC-hour tracking and air sample results for intake intake will be documented appropriate regulations and implementing procedures.
Radioactive Materials Control and Storage of Radioactive Materials The WPI-RDP's HP Program will establish radioactive radioactive material controls that ensure:
" Deterrence Deterrence of of inadvertent inadvertent release of licensed radioactive radioactive materials to unrestricted areas
" Confidence Confidence that that personnel personnel are not inadvertently inadvertently exposed to licensed radioactive radioactive materials
" Minimization Minimization of of the the volume of radioactive wastes generatedgenerated during the decommissioning All material leaving the Restricted Restricted Area will be surveyed to ensure that radioactive material is not inadvertently inadvertently released from the WPI LCWNRF. Refer to Section Section 3.1.3 Radioactive Material Controls, for a description of the specific specific survey methods that will be used.
3.1.2 Health General General Health Physics Program WPI will use written, approved approved procedures to control the implementation implementation of work during the WPI-RDP. All procedures procedures will be developed developed and approved in accordance with written written policy and procedure.
The WPI RSO, with the assistance assistance of a Decommissioning Decommissioning Consultant, will have have full authority authority to act in all aspects to ensure protection protection of workers workers and the public from from the effects of radiation. Procedures Procedures for conduct of the decommissioning decommissioning HP program will be will reviewed reviewed and approved approved according according to WPI policy.
Audits, Inspections, Audits. Inspections. and Management Management Review Review Physical Physical decommissioning decommissioning work will be subjectsubject to continuous continuous oversight oversight by WPI's WPI's RSO or Decommissioning Decommissioning Consultant. Additionally, aspects aspects of the project project may bebe evaluated evaluated and reported reported by an applicable contractor's Quality applicable contractor's Quality Assurance Assurance program program through through audits, assessments assessments andand inspections inspections of various various aspects aspects of decommissioning decommissioning performance, performance, including including HP, as described described in Section Section 1.2.5 1.2.5 Program Program Quality Quality Assurance.
Assurance.
Audits Audits of the the requirements decommissioning HP program the decommissioning requirements of Code of Federal program will be conducted Federal Regulations conducted in accordance Regulations (CFR) 10 10 CFR accordance with CFR 20 (Ref.
with (Ref. 15).
15).
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Additional independent Additional independent assessments or management when deemed appropriate Health appropriate by the WPI Reactor management reviews Reactor Equipment and Instrumentation Health Physics Equipment Instrumentation Director.
reVIews may be performed performed equipment and instrumentation Project HP equipment instrumentation will be suitable to permit ready quantification of radiological detection and quantification radiological hazards to workers and the public. They will be chosen chosen so as to ensure the validity of measurements measurements taken during remediation remediation and final release surveys. The selection selection of equipment equipment and instrumentation instrumentation to be utilized will be based upon detailed detailed knowledge of the radiological contaminants, radiological contaminants, and concentrations concentrations that are expected to exist based expected based onon scoping survey measurements or as known from process knowledge survey measurements knowledge of the working history of the WPI LCWNRF. Equipment and instrumentation instrumentation selection also takes into account the working working conditions, contamination contamination levels and source terms that are reasonably reasonably expected expected to be encountered encountered during the performance performance of decommissioning decommissioning work, as presented presented in this DP.
The following sections present examples examples of the typical equipment and instrumentation instrumentation that may be used during the decommissioning. It is anticipated anticipated that the Decommissioning Decommissioning Consultant Consultant and contractors will be supplying equipment equipment for their own use, and while capabilities will remain remain equivalent, specific
manufacturers manufacturers and model designations Criteria for Selecting A sufficient designations may vary from those examples listed herein.
Selecting Survey Survey and Monitoring sufficient inventory and variety facilitate effective effective measurement Monitoring Equipment variety of instrumentation Equipment instrumentation will be maintained measurement of radiological conditions, control worker maintained on site to worker exposure consistent consistent with ALARA, and to evaluate the suitability suitability of materials materials for release release for for unrestricted unrestricted use. Instrumentation Instrumentation and equipment equipment will be capable of measuring the range of dose rates and radioactivity radioactivity concentrations concentrations expected expected to be encountered encountered during the LCWNRF LCWNRF decontamination decontamination and decommissioning decommissioning activities, including implementation implementation of a FSS.
The project HP staff will select instrumentation instrumentation with sensitivities and ranges that that are appropriate appropriate for the particular protection function and D&D task being particular radiation protection performed, to ensure that the full spectrumspectrum of credible credible radiological hazards can be assessed assessed and monitored. (Criteria for selection of instruments for the Final Status Survey is discussed separately in Section discussed separately Section 4 - Proposed Final Radiation Survey Survey Plan.) Consumable Consumable sampling sampling supplies (e.g., smears, air filters, etc.) will conform to manufacturer regulatory recommendations manufacturer and/or regulatory recommendations to ensure ensure that measurements measurements meet desired desired sensitivity and are valid for the intended purpose.
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Storage.
Equipment Calibration. Testing Storage, Calibration, Equipment and Survey instruments Testing and Maintenance Instrumentation Instrumentation Maintenance of Health Physics instruments will be stored in a common location under the control of WPI-RDP HP personnel. A formal program program will be adhered adhered to throughout the project to service inoperable identify and remove from service out-of-calibration instruments inoperable or out-of-calibration instruments or or equipment equipment as described in HP procedures. Survey instruments, counting Survey counting equipment, air samplers, air monitors and personnel personnel contamination contamination monitors will be calibrated calibrated at Technical Technical Specification-required Specification-required intervals, manufacturer-prescribed manufacturer-prescribed intervals (if shorter frequency) or prior to first use. Such equipment will be traceable to National Institute calibrated against standards that are traceable Institute of Standards Technology (NIST), in accordance and Technology approved calibration laboratory accordance with approved procedures, HP procedures, or vendor technical manuals. Survey instruments will be operationally checked daily when in use. Counting equipment operability operationally checked operability will be be verified daily when in use. The personnel contamination monitors or friskers will personnel contamination operationally tested on a daily basis when work is being performed.
be operationally Specific Health Physics Equipment Specific Health Equipment and Instrumentation Instrumentation Use and Capabilities Capabilities instrumentation that is equipment and instrumentation Table 3.1 provides details of typical HP equipment planned for use in the WPI-RDP. This list is not intended all-inclusive or intended to be all-inclusive or
exclusive, and equivalent makes and models may be substituted availability.
Policy. Method.
Policy, Procedures Frequency and Procedures Method, Frequency The existing framework of WPI's current HP Program substituted based on Program will be used as the basis for on for constructing WPI-RDP's HP Program.
constructing the WPI-RDP's WPI's existing program will be be augmented as necessary using plans and procedures augmented procedures provided provided by the Decommissioning Consultant Decommissioning Consultant and contractors.
Airborne Effluent Monitoring Airborne Monitoring - During decommissioning decommissioning activities where a temporary enclosure is in use with a HEPA exhaust system, the ventilation temporary ventilation system exhaust points from the temporary barrier will be sampled continuously downstream of the HEPA downstream HEPA filtration system. Airborne concentrations within the Airborne concentrations uncontrolled areas of the building will be maintained uncontrolled environmental maintained at less than environmental airborne concentration effluent limits.
airborne concentration Radiation Surveys - Radiation, airborne Radiation airborne radioactivity contamination surveys radioactivity and contamination decommissioning will be conducted in accordance during decommissioning approved HP accordance with approved procedures. The purposes of these surveys will be to (1) protect protect the health and safety of workers, (2) protect the health and safety of the general general public, and (3) demonstrate compliance demonstrate applicable license, federal and state requirements, as compliance with applicable as well as DP commitments. HP personnel will verify the validity of posted posted radiological radiological warning signs during the conduct of these surveys. Surveys will be be
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conducted conducted in accordance equipment equipment suitable and instrumentation operationally operationally Routine surveys accordance with procedures tested prior to use procedures utilizing suitable for the nature and range of hazards instrumentation will be properly utilizing survey properly calibrated in accordance surveys will be conducted at a specified frequency to ensure that with survey instrumentation instrumentation and hazards anticipated. Equipment calibrated and, where applicable, procedural procedural Equipment applicable, requirements.
that contamination contamination and radiation levels in unrestricted unrestricted areas do not exceed license, federal, state or site limits. The HP staff will also perform perform surveys during decommissioning decommissioning whenever whenever work activities create a potential potential to impact radiological radiological conditions.
TABLE 3.1 3.1 TYPICAL TYPICAL HEALTH HEALTH PHYSICS EQUIPMENT EQUIPMENT AND INSTRUMENTATION INSTRUMENTATION APPLICATION, ..
DE~ECTOR INSTRUMENT
. INSTRUMENT INSTRUMENT MODEL MODEL DETECTOR INSTRUMENT ApPLICATION
___ '. - .~ ___ ___ __ :TYPE
'TYPE RANGE RANGE.. "
c
," , .l
' ' " I .
Bicron Micro-Rem meter 1"xl" Tissue 1"x1" Tissue Bicron Micro-Rem meter equivalent 0-5000 Micro rem/hr equivalent Low gamma exposure rates rates scintillation Ludlum Ludlum Model 12 count rate meter, 2"x2" Nal NaI scintillation 0- 500Kcpm 0- 500K cpm Low-level gamma gamma scanning Ludlum 44-10 with Ludlum with 44-10 scintilla tio n Ludlum Ludlum Model 12 count rate meter, 1"xl" NaI 1"x1" Low-level gamma gamma scanning interior of of 0-500Kcpm with Ludlum Ludlum 44-2 scintillation 0-500K cpm equipment equipment and pipespipes Ludlum Model 17 Ionization Ionization 0-50 R/hr Gamma and Beta exposure rates Ludlum Model 17 Ludlu 17chamberModl 0-50 R/hr Gamma and Beta exposure rates chamber Alpha Alpha and Bicron labtech dual channel channel scaler / beta beta ratemeter scintillation, 0-1,000K 0-1,000K cpm cpm Measurement of Measurement of surface surface contamination contamination rate meter scintillation, 100cm 22 100cm Ludlum Ludlum Model 300 Portable Portable Area GM tube 0.1-1000 mr/hr Portable area radiation alarm GMtube 0.1-1000 mr/hr Portable area radiation alarm Radiation Radiation Alarm 177 Alarming GMtube, GM tube, Ludlum Ludlum Model 177 Alarming Ratemeter pancake, pancake, 15 0- 500K 500Kcpmcpm Personnel contamination frisking Ratemeter am22 cm2 Lulm20Ratemeter -clr cmhBta050K Beta m 6sc Ludlum Beta Ludlum 2200 ratemeter-scaler, with 2200 ratemeter-scaler, scintillation, 0-500K cpm, 0-500K cpm, 6 sec. Beta-counting smear and air samples Ludlum scintillation, 12 990 min. Beta-counting smear and air samples Ludlum 44-1 44-1 2to to 990 min.
-12 cm 2 2200 ratemeter-scaler, ratemeter-scaler, Alpha Ludlum 44-2 Alpha cpm 66 sec.
Ludlum Lulu 4-2scntlltin,with scintillation, scintillation, 0-500K to cpm, to-990K 990 mpme.
min. Alpha-counting Alpha-counting smearsmear andand air samples air samples Ludlum 44-2 2 cm 2
~-12cm to 990 min.
-12 Ludlum Thin end Ludlum Model 12 count rate rate meter, Thin end Beta-gamma contamination checks, interior Beta-gamma contamination interior windowGM 0-500Kcpm with Ludlum Ludlum 44-7 window GM 0-500K cpm equipment equipment and pipespipes tube tube Hi-Q Environmental Products TFIA TFIA N/A N/A 0-70 CFM High-volume High-volume grab air samplessamples Apex Pro 200 N/A N/A 0.8-4 LPM 0.8-4LPM Personnel Personnel breathing breathing zone air sampler sampler F&J Model LV-14M Gooseneck Gooseneck "Lo- N/A 0.35-3.5 cfm Low volume air sampling for long-term vor' N/A 0.35-3.5 cfm continuous Vol" continuous air sampling GM cpm 10-1033 cpm Local continuous Local continuous particulate particulate airborne Ludlum Model 333-2 air monitor monitor GM 10-10 monitor with alarm capability Personnel Personnel Monitoring Monitoring - Internal Internal and External - External monitoring and External monitoring will be be conducted in accordance conducted accordance with approved approved procedures. Prospective Prospective external exposure evaluations will be performed evaluations performed prior to initiating initiating decommissioning decommissioning activities activities and
whenever changes in conditions warrant. Visitors to the WPI LCWNRF LCWNRF will be
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monitored in accordance accordance with requirements according to the radiological according requirements specified in WPI's HP procedures radiological hazards of areas to be entered.
Internal monitoring will be conducted prospective internal exposure This prospective conducted in accordance accordance with approved evaluation will be performed exposure evaluation procedures and approved procedures.
performed on an annual basis, at a minimum, or whenever significant significant changes changes in planned work evolutions evolutions warrant warrant additional evaluation. A comprehensive air-sampling program will be conducted comprehensive air-sampling conducted during the WPI-RDP to evaluate worker worker exposures exposures regardless regardless of whether or not not internal monitoring is specified. The results of this air-sampling air-sampling program program will be utilized to ensure validity of specifiedspecified internal monitoring monitoring requirements requirements for decommissioning personnel. If hazards are encountered, at any time during the decommissioning decommissioning, that may not be readily detected detected by the preceding preceding measures, appropriate appropriate special measures measures or bioassay will be instituted to ensure the adequate surveillance surveillance of worker internal exposure.
Monitoring will be required required if the prospective prospective dose evaluation shows that an an individual's individual's dose is likely to exceed exceed 10% of the applicable limits, and for individuals entering a high or very high radiation radiation area.
Respiratory Respiratory Protection Protection - If required, the WPI-RDP respiratory protection protection program will include include direction direction for use of National Institute Institute for Occupational Occupational Safety and HealthlMine Health/Mine Safety and Health Administration (NIOSHIMSHA)
Health Administration (NIOSH/MSHA) certified certified equipment. This program program will be reviewed reviewed and approved by the HP staff to ensure adherence adherence to the requirements requirements of 10 CFR 20 (Ref.
(Ref. 15).
15).
NIOSH[MSHA-approved NIOSHIMSHA-approved air purifying respirators respirators include full-face-piece assemblies include full-face-piece assemblies with air purifying elements to provide respiratory respiratory protection against against hazardous vapors, gases, and/or particulate particulate matter to individuals individuals in airborne airborne radioactive materials materials areas. The RSO or Decommissioning Decommissioning Consultant will also ensure ensure that the respiratory respiratory protection protection program program meets the requirements requirements of 10 CFR Part 20, subpart subpart H (Ref.
(Ref. 15).
Maintenance Maintenance - When respiratory respiratory protection equipment requires cleaning, the filter cartridges cartridges will be removed. The respirator will be cleanedcleaned and sanitized sanitized cleaner/sanitizer and then rinsed thoroughly in plain warm after use with a cleaner/sanitizer water in accordance with HP procedures.
Storage - Respiratory Storage Respiratory protective protective equipment will be kept in proper working order. When any respirator respirator shows evidence of excessive excessive wear, distortion or or has otherwise failed inspection, it will be repaired or replaced. Respiratory protective equipment that is not in use will be stored in a clean dry location.
protective equipment
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Contamination ContaminationControlControl - Contamination include, as appropriate,
" Worker Contamination control measures that will be employed appropriate, the following:
Worker training will incorporate radioactive incorporate methods and techniques for the radioactive materials, and proper donning/doffing of proper use and donning/doffing employed control of of protective clothing
" D&D D&D procedures procedures will incorporate incorporate control techniques to minimize spread of spread of contamination contamination during work work
" Radiological surveillance surveys Radiological surveillance conducted by HP surveys conducted
" Containment Containment devices (e.g., designed designed barriers, containers containers and plastic plastic bags, etc.) will be used to prevent the spread of radioactive radioactive material material
" Physical Physical decontamination decontamination of areas or items to mitigate potential potential contamination contamination migration migration
" Physical Physical barriers barriers such as Herculite Herculite sheeting, strippable strippable paint, and tacky tacky mat step-off pads to limit contamination step-off contamination spread
" Posting, Posting, physical area boundaries boundaries and barricades barricades
" Step-off Step-off pads at the exit point from contaminated contaminated areas Personnel Personnel entries into radiological contaminated areas radiological contaminated areas will require the use of of protective clothing. Depending upon the conditions conditions outlined in the RWP, such such clothing may consist of suitable combinations combinations of the following items:
" Cloth Cloth or Tyvek lab coatcoat
" Cloth Cloth or Tyvek coveralls coveralls
" Cloth Cloth or Tyvek hoods or skull caps caps
" Plastic, Plastic, cloth or Tyvek calf-high booties calf-high booties
" Rubber, Rubber, plastic or cloth shoe covers covers
" Plastic or rubber Plastic or rubber gloves, which may require cloth liners
" Additional Additional layers layers of disposable Tyvek coveralls coveralls or plastic rain suits
" Face Face shields, shields, safety glasses, hard hats, safety shoes, ear muffs or other other industrial protective devices industrial protective devices Access Control Control - A Restricted Restricted Area Area will be established established and properly properly posted and monitored monitored to prevent unauthorized access.
prevent unauthorized Engineered Controls - Personnel Engineered Controls Personnel exposure exposure to airborne radioactive radioactive materials materials will be minimized minimized by utilizing engineering engineering controls such as the following:
** Ventilation Ventilation devices - in-place or portable vacuum cleaners cleaners portable HEPA-filtered HEPA-filtered ventilation ventilation units oror
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" Containment bags, tents, and glove-bags
Airborne glove-bags containment barriers, containers, plastic designed containment Airborne source term reduction - application application of fixatives prior to handling, misting of surfaces to minimize dust and resuspension resuspension Airborne Radioactivity Airborne Radioactivity Monitoring Monitoring - Air sampling will be performed performed in areas where radioactivity is present or likely. 10 CFR 20.1502(b) requires where airborne radioactivity requires monitoring for the intake of radioactive radioactive material if the intake during the year is likely to exceed:
" Ten percent
Ten percent of the annual limit on intake (ALI) for an adult worker, or or
" The committed
The committed effective effective dose equivalent 0.1 rem (1.0 (1.0 mSv) for an an occupationally exposed occupationally exposed minor or declared pregnant pregnant woman woman WPI will establish monitoring requirements requirements for the project project based on prospective estimates of worker concentrations. Such estimates worker intakes and air concentrations. consider estimates will consider the following:
" The quantity
The quantity of material(s) based upon its physical form and use
The annual The annual limit on intake for the nuclides of interest interest
The release The release fraction for the radioactive material(s) being handled handled
" Other factors
Other factors that may be applicable HP personnel personnel will use technical technical judgment in determining determining the situations that necessitate necessitate air sampling regardless of results of generalized, prospective evaluations performed evaluations performed for the WPI-RDP.
The purpose of the radiological radiological air sample will be identified prior to specifying specifying a location for an air sampler. The following are a few examples of the variety of of reasons that exist for collecting collecting air samples:
" Estimation Estimation of worker intakes intakes
" Verification of confinement Verification confinement of radioactive radioactive materials materials
" Early Early warning warning of of abnormal airborne concentrations radioactive materials concentrations of radioactive materials
" Determining Determining the existence of criteria criteria for posting an Airborne Airborne Radioactivity Radioactivity Area Area in accordance accordance with 10 CFR 20 20 Smoke Smoke tubes and buoyantbuoyant markers markers (ribbons) may be used to determine determine airflow patterns in the area. Airflow patterns may be reevaluated reevaluated if there are changes changes at the WPI LCWNRF that may impact the validity of the sampling locations. Such Such factors might include the following:
N Changes Changes in the work process process
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Reactor Decommissioning Reactor Decommissioning Plan Plan Section 3, Page Page 10 of 19 19
*" Changes in the ventilation Changes ventilation system
" Use of portable ventilation that might alter earlier earlier assessments After identifying identifying the purpose for the air sample sample and establishing establishing flow patterns, air sample locations sample locations will be chosen as follows:
" For verification verification of confinement confinement of radioactive radioactive materials:
o Locate samplers in the airflow near the actual or potential release Locate point point o More than one sampling point may be appropriateappropriate when there are more than one potential or actual release release points
" For For estimation estimation of a worker's intake:
o Sampler intakes will be located as close as practical to the worker's Sampler worker's breathing zone, without interfering with the work or worker breathing worker workplace air sampler intakes will not be placed in or near ventilation General workplace General ventilation exhaust ducts unless their purpose is to detect leakage during normal detect system leakage operation, and if quantitative quantitative measurements measurements of workplace concentrations are not workplace concentrations not
Locations or number of air samplers will be changed required. Locations modifications to facility structure, changes modifications potential potential sources.
WPI will maintain a sufficient inventory changed when dictated by changes in work processes, or elimination elimination of by calibrated inventory and variety of operable and calibrated of portable and semi-portable portable equipment to allow for effective semi-portable air sampling equipment effective collection, evaluation, and control of airborne radioactive material airborne radioactive material and to provide provide backup capability for inoperable equipment. Air sampling equipment inoperable equipment. calibrated at equipment will be calibrated prescribed intervals or prior to use: calibration will be against certified prescribed certified equipment equipment relationships to nationally recognized having known valid relationships recognized standards. Table 3.1 3.1 provides provides a listing of anticipated air-sampling equipment.
anticipated air-sampling When the work being performed When continuous process, a continuous sample with performed is a continuous with up to a weekly exchangeexchange frequency is appropriate. Longer sample exchange approved by HP management frequencies may be approved frequencies management for situations where airborne radioactive material and nuisance dust are expected radioactive material expected to be relatively relatively low. Grab sampling for continuous processes processes may also be approved approved by HP management management based based upon consideration of variability of the expectedexpected source term for the facility and appropriate means of airborne sampling process. Grab sampling is the appropriate sampling for processes processes conducted conducted intermittently, and for short duration radiological work that involves a potential for airborne release.
potential release .
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Potential Sources Sources of Radiation or Contamination Contamination Exposure Exposure Potential sources sources of radiation or contamination contamination exposure exposure to workers workers and public, as a result of decommissioning decommissioning activities, may be assessedassessed by several methods, including:
" Process and historical knowledge
Process
" Surveys performed during characterization
Surveys characterization
" Pre-work RWP surveys
Pre-work
" Previous and current job coverage
Previous coverage surveys
" Daily, weekly
Daily, weekly and monthly routine surveillance surveillance surveys Classification Classification of potential potential sources may also be identified by radio radionuclide, physical nuclide , physical properties, properties, volatility and radioactivity.
Worker exposure exposure to significant significant external external deep-dose radiation radiation fields is considered considered unlikely during this project, due to the nature and extent extent of the contaminants present present and/or the work precautions precautions and techniques techniques employed. Worker Worker exposure to airborne radioactivity radioactivity is also unlikely to occur occur during most dismantling operations/work evolutions operations/work evolutions unless they involve use of abrasive abrasive or thermal thermal cutting
methods on activated activated materials:
Exposure of the public to external such cutting external or internal methods methods can internal radiation volatilize or create create loose dispersible contamination. WPI does not plan to use those types of cutting methods on activated materials.
radiation from the WPI-RDP is not not considered considered credible because because of the limited levels and extent extent of radioactivity present radioactivity present and the confinement confinement provided by the facility.
Control of potential potential sources of radiation radiation exposure to workers and public, as a result result decommissioning activities, will be achieved of decommissioning achieved through, but not limited to, the use of administrative, administrative, engineering and physical controls. Administrative Administrative controls consist of, of, but are not limited to:
" Administrative Administrative dose limits that are lower than regulatory regulatory limits
" Training Training
" Radiological surveys
Radiological surveys In general, physical physical barriers barriers (such as lockable lockable doors/gates, and, or other other applicable barriers) may be used in combination combination with radiological postings to preclude inadvertent exposure of the general public to radiation or radioactive inadvertent exposure radioactive materials.
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Environmental Environmental Monitoring Monitoring During the conduct of decommissioning measurements will be made decommissioning activities, measurements made for for radiation radiation and radioactive contamination at locations where radioactive contamination where direct radiation exposure exposure or contaminant contaminant release pathways pathways could exist that could credibly impact impact the environment environment or the generalgeneral public. While releases releases of radioactive radioactive material or or increased increased radiation levels in uncontrolled uncontrolled areas are not expected expected during decommissioning activities, monitoring will be performed to verify that expectation.
decommissioning environmental monitoring Generally, environmental monitoring will entail placement placement of dosimeters at selected selected locations locations to monitor for direct radiation exposure. Such locations will include nearby classrooms, offices or dormitories adjacent adjacent to the LCWNRF frequently occupied occupied by WPI students, staff or visitors. Periodic Periodic measurements measurements will be made for for radioactive contamination at locations radioactive surface contamination locations where radioactive contamination where radioactive contamination could migrate out of the facility (e.g., at the LCWNRF's doorway doorway exits and outward outward air flow paths). Continuous particulateparticulate air sampling sampling will be made at selected selected locations locations representative representative of nearby adjacent adjacent uncontrolled areas.
Health Physics Policies for Non-WPI Non-WPI Personnel Personnel WPI intends to use non-WPI personnel (contractors) to assist in the non-WPI personnel decommissioning. Contractors who will work with licensed licensed radioactive radioactive materials
will be required required
" Attend Attend and to:
satisfactorily complete an appropriate and satisfactorily Provide required Provide Read and Read appropriate radiation exposure history information required exposure sign an applicable and sign information radiation safety course applicable RWP and comply with instructions course
" Follow Follow all special instructions all special instructions given given by by HP HP 3.1.3 Radioactive Materials Controls Controls The WPI-RDP radiationradiation protection protection program program will establish radioactive radioactive material material controls controls that ensure the following:
" Prevention Prevention of of inadvertent inadvertent decommissioning decommissioning radioactive radioactive waste (licensed) material release to uncontrolled areas areas
" Assurance Assurance thatthat personnel personnel are not inadvertently inadvertently exposed to radiation radiation from radioactive decommissioning licensed radioactive decommissioning waste materials materials
" Minimization Minimization of of the amount of radioactive waste material material generated during decommissioning.
Pool water releases will be processed processed using existing pool water treatment treatment equipment equipment and analysis protocols protocols to ensure that discharges discharges to sanitary sanitary sewerage
will meet the requirements requirements of 10 CFR 20.2003 (Ref. (Ref. 22).
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The potentially contaminated below:
" Items contaminated equipment, materials, instrumentation, and tools that are used or encountered encountered during the decommissioning decommissioning will be handled as described Items may be surveyed and released on site as clean if the residual that described radioactivity is less than the values specified specified in Table 1 of NRC Regulatory Guide 1.86, Termination Operating Licenses for Termination of Operating for Nuclear Nuclear Reactors, Reactors, June 1974 (Ref.
(Ref. 23)
" Items Items maymay be shipped shipped directly for disposal as radioactive radioactive waste
" Items Items maymay be shipped to a licensed be shipped radioactive material licensed radioactive material processing facility forfor survey and release, decontamination decontamination followed by survey survey and release, or or shipment for disposal as radioactive radioactive waste
" Items Items may may be be shipped shipped to a licensed licensed facility for holding until they are utilized utilized on another project involving radioactive materials involving radioactive
" Items Items may be transferred transferred to WPI's Agreement-State Agreement-State radioactive radioactive materials license 3.1.4 Dose Estimates Estimates The collective dose estimate decommissioning tasks estimate for the decommissioning involving radiation radiation
exposure exposure individuals individual is Three 0.5 individual basis:
Person-REM Person-REM (rounded individuals will receive radiation exposure laborers were each estimated Three laborers The crew Foreman The crew Foreman was up from 0.448). It is exposure as a result of the estimated to receive estimated estimated to receive 0.032 estimated estimated that five D&D work. On an Person-REM receive 0.128 Person-REM Person-REM Person-REM an
" The The HPHP Technician Technician providing crew coverage was estimated to receive 0.032 crew coverage Person-REM A breakdown breakdown of this dose estimate estimate (collective and individual), by major task and sub-task activities, is provided in Table 3.2; work durations and radiation levels levels used in making making the estimate are also provided. As a general general rule, 40% of the work durations listed on the table are devoted non-exposure-producing activities, such devoted to non-exposure-producing such as work area set-up, pre-work briefings, signing onto RWPs, donning and doffing doffing PPE, etc. The three laborers laborers were conservatively conservatively assumed to be in exposure producing producing locations for 100% of the remaining time. The ForemanForeman and HP HP Technician Technician were assumed assumed to be at exposure-producing exposure-producing locations 25% of the time.
Radiation levels were conservatively conservatively assumed to be the maximum maximum levels likely to be encountered, encountered, without taking credit credit for declining declining radiation levels that would likely occur occur as the overall overall removal process progresses.
This estimate is provided provided for planning planning purposes only. Detailed exposure estimates exposure estimates
and exposure controls shall be developed developed during detailed planning of the decommissioning activities. Area dose rates used for this estimate are based on decommissioning on
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2008 scoping survey data, process knowledge available).
The dose estimate to members is estimated knowledge and current survey maps (where members of the public as a result of decommissioning estimated to be negligible: site perimeter perimeter controls activities decommissioning activities controls will restrict members of the decommissioning activities are taking place.
public from entering the area where decommissioning consistent with the estimate given for the "reference This is consistent "reference research reactor" in in Final Generic NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning Environmental Impact Decommissioning Nuclear Facilities of Nuclear (Ref. 24). In NUREG-0586, the dose to the public during Facilities (Ref.
decommissioning (DECON) and truck transport transportation decommissioning transportation of radioactive waste reference research reactor from the reference 0.1 reactor is estimated to be "negligible (i.e., less than 0.1 person -rem)."
person-rem)."
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DOSE ESTIMATE Phase Activities Activities and ESTIMATE BREAKDOWN and Tasks J/ Sub-Tasks Sub-Tasks BREAKDOWN BY MAJOR Duration Duration days days TABLE 3.2 Estimated Estimated Maximum Rate Exposure Rat.
mremfhr mremlhr 3.2 MAJOR TASKS AND ACTIVITIES Total Crew Exposure Collective Exposure Person-REM Person-REM Individual Worker Radiation Individual Foreman Laborer No. I No.1 Laborer No.
No.22 ACTIVITIES Radiation Exposure, Laborer Exposure. Person-REM Laborer No. 3 No.3 Tech.
Laborer HP Tech.
Phase 1:1: Pre-Oecommloslonlng Pre-Decommissioning Activities Activities Prepare SiteSit. For Decommissioning For Decommissioning Survey and Remove Un-needed materials materials and and supplies supplies (clean) 5.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0oog 0.000 0.000 0.000 Remove Asbestos Asbestos Floor tiles 10.0 10.0 On 0.00 0,000 0.000 O.0 0.000 0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Ceiling Ceiling Tiles Tiles 5.0 0On0 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 equipment and materials Relocate equipment materials (to bebe saved saved by WPI) 5.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Phase 2: Decommissioning Mobilization Activities Decommissioning Mobilization Activities Mobilization Off-site Mobilization 0.000 project documentation Prepare project documentation 20.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Procure equipment equipment and and supplies supplies 10.0 10.0 0n00 0.00 0.000 0,000 0.000 0.000 0.000 0.000 0.000 0.000 Procure specialty specialty subcontractors subcontractors 1t00 10.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 On-site Mobilization Worker Training Wor1c.er Training and qualification qualification 3.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 De-energize selected utilities De*energize 3.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Install General Radiological Install General Radiological Controls Controls 2.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Install Install!/ set-up set*up general construction construction services!
services / Reconfigure Reconfigure Bid. For D&D D&D 5.0 0.00 0.00 0.000 0.000 0,000 0.000 0.000 0.000 0.000 0.000 0.000 Perform Site Characterization Perfonn Characterization 5.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Phase 3: Decontamination Decontamination and and Dismantling Dismantling Activities Activities Task 1: Remove Remove Reactor Core Structure Reactor Core 0.000 Reactor Pool Drain Reactor 5.0 0n00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Disconnect power and I&C Disconnect cables I&C cables 1.0 1.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Control Rod Remove Control Rod Drives Drives 3.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Control Remove Contral blades blades and shafts 3.0 4r00 4.00 0.151f 0.151 0.0f1 0.011 0.043 0.043 0.043 0.043 0.011 0.011 0.003 Remove ion Remove ion chambers and associated associated Instrumentation 2.0 0.50 0.50 0.013 0.001 0.004 0.004 0.004 0.004 0.001 Remove Start*up Start-up counter Assembly Assembly 2.0 0.50 0.50 0.01 3 0.013 0.001 0.004 0.004 0.004 0.004 0.001 Remove Rx Rx Suspention Suspention PostsPosts 5.0 0.50 0.50 0.032 0.032 0.002 0.002 0.009 0.009 0.009 0.009 0.002 0.002 0.000 Remove guideguide tube assembly assembly 1.0 1.0 0.50 0.50 0.006 0.000 0.002 0.002 0.002 0.002 0.000 Remove Core boo Core box 3.0 3.00 3.00 0.t1f3 0.113 0.008 0.032 0.032 0.032 0.032 0.008 0.008 0.000 0.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Contents Task 2: Remove Contents of Thermal Column Thermal Column 0.0S1 Remove Graphite Graphile 3.0 0.02 0.02 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Task 3: Remove Reactor Reactor Pool Equipment Equipment 0.070 Remove Beam Beam Port Extention Extention 2.0 3.00 3.00 0.076 0.013 0.005 0.005 0.022 0.022 0.022 0.022 0.005 0.005 Remove Beam Beam Port Shutter Shutter 2.0 0.50 0.50 0.013 0.001 0.004 0.004 0.004 0.004 0.001 Remove Beam Beam Port Shutter Shutter Housing Housing 5.0 0.05 0.05 0.003 0.003 0.000 0.oof 0.001 S.ool 0.001 0.0Sf 0.001 0.000 0.O00 Remove Core Cow Box Locating Rails 2-0 2.0 0.05 0.05 0.001 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove SpentSpent Fuel Racks Racks 1.0 1.0 0.05 0.05 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Task 4: Remove Pool Water Treatment Treatment System System 0.000 Remove IX IX Column Column 1-0 1.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Filter Fitter 0.3 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove pump pump 0.3 0.00 0.00 0.000 0.007 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove piping piping 0.3 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Hold-up Tank Hold.up Tank 1.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Task 6: Remove Task 5: Remove Reactor Reactor PoolPool Liners Liners andand Embedded Embedded Drains and Drains and Pipe 0.001 Remove TC liner 500 50 0.02 0.02 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Beam Beam PodPort liner 5.0 0.00 0.00 0.000 0,010 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Aluminum Aluminum Pool Pool Liner Liner 15.0 15.0 0.10 0.10 0.019 0.000 0.001 0.005 0.005 0.005 0.005 0.001 Remove Gutter Gutter drains and and piping piping 10.0 10.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove piping Remove piping embedded embedded in in pool pool structure structure 5.0 5.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove adjacent Floor Floor Drains Drains andand associated associated embedded embedded 0.000 piping 5.0 5.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Task 0: Decontaminate Biological 6: Decontaminate Biological Shield Concrete Survey Remaning Pool Concrete; Concrete; Scabble II Spall Concrete (if Concrete (if required) 10.0 10.0 0.01 0.01 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Decontaminate Reactor Bridge Decontaminate 3.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Liquid Task 7: Remove Liquid Effluent Equipment Effluent Discharge EqUipment Remove floor embedded embedded piping piping and and valve valve back to demin.
demin. 1.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Evaluate remaining piping (vault to manhole) manhole) and and abandon in abandon in place 1.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Evaluate manhole interiorsurfaces interior surfaces 1.0 1.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 8: Removo Task 6: Remove Exhaust Ventillatlon System Exhaust Vontillation Remove local Remove local exhaust ducts (Beam exhaust ducts Pod &
(Beam Port &Thevm.
Thenn. Col.Vents)
Col.Vents) 3.0 3.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Remove Filters, Filters, Survey Survey and Clean Clean Plenums 2.0 2.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 stream components Evaluate up stream components 2.0 2.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Task Remove Remaining 9: Removo Equipment Ramalnlng Equipment Evaluate contamination Evaluate contamination 2.0 2.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 remaining contaminated Remove remaining contaminated equipment equipment 4.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Task 10: Decontaminate Building Interior Surfaces Building Interior Surfaces Evaluate surfaces for contamination contamination 5.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Decontaminate ifif required Decontaminate required 5.0 5.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Task 11: Waste Management Waste Management Package and Prepare Prepare Wastes 5.0 5.0 0.05 0.05 0.003 0.000 0.001 0.001 0.001 0.001 0.000 Load waste Load waste for Transport 3.0 3.0 0.05 0.05 0.002 0.000 0.001 0.001 0.001 0.001 0.000 Task Task 12: Demobilize 12: Demobilize and Prepare Building Building for FSSFSS Remove work area Remove area controls and equipment controls and eqUipment 3.0 3.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Return rental equipment 3.0 3.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Pack and shipship tools andand equipment 2.0 2.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 General area General area cleanup cleanup 3.0 3.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Task License Termination 13: Perform L1canse Activities Termination Activities Prepare FSS P ln 20.0 0.00 0.000 FSS Plan 20.0 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Implement FSS Implement FSS 20.0 20.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Prepare FSS Prepare Report and FSS Report LT submittal and LT submittal 30.0 30.0 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 TOTAL PERSON-REM PERSON-REM 0.448 0.032 0.128 0.128 0.128 0.128 0.128 0.032
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3.2 RADIOACTIVE WASTE MANAGEMENT RADIOACTIVE 3.2.1 Radioactive Waste Processing The processes of decontamination MANAGEMENT decontamination and dismantlement dismantlement of the WPI LCWNRF will radioactive waste, consisting principally of activated metals, result in solid low-level radioactive and a small amount of contaminated metals and concrete debris. No mixed or or hazardous waste is expected to be generated. Lead paint coatings and asbestos-hazardous containing materials are likely to be present in the facility, but are not anticipated containing anticipated to be significantly significantly present on materials likely to become radioactive waste. No soil remediation is anticipated which would result in solid radioactive remediation radioactive waste. Solid,low-Solid, low-level radioactive radioactive waste will be handled (processed and packaged), stored and disposed of in accordance with applicable sections of the Code of Federal Regulations Regulations (CFR), disposal site Waste Acceptance Acceptance Criteria, Massachusetts Massachusetts Department Department of Environmental Environmental Quality requirements, WPI Licenses and Permits, and the applicable implementing plans and procedures. Radioactive waste Radioactive processing includes waste minimization or volume reduction, radioactive radioactive and hazardous characterization, neutralization, stabilization, hazardous waste segregation, waste characterization, solidification and packaging.
3.2.2 Radioactive Radioactive Waste Disposal
Low-level Low-level radioactive licensed radioactive waste will be processed low-level licensed low-level waste processed and packaged of Utah) site. The volume of low-level radioactive decontamination are estimated packaged for disposal at a site such as the EnergySolutions, LLC (formerly Envirocare radioactive waste is estimated at 600 cubic feet (packaged volume). All wastes resulting from and dismantling and decontamination estimated to have concentrations concentrations of radioactive radioactive materials materials well below 10 CFR 61 Class A waste limits. The most highly radioactive radioactive item of waste arising arising from the decontamination decontamination and dismantling dismantling of structures, systems systems and components components will be the activated activated regulating control control blade. The blade is estimated estimated to contain contain a total of 56 mCi, representing representing the majority of the waste radioactivity radioactivity to be be generated generated during the decommissioning decommissioning program. Table 3.3 provides provides the estimated estimated concentrations concentrations of radioactivity radioactivity in the regulating control blade.
TABLE 3.3 3.3 ESTIMATED CONCENTRATIONS ESTIMATED CONCENTRATIONS OF RADIOACTIVITYRADIOACTIVITY IN THE THE REGULATING CONTROL REGULATING CONTROL BLADEBLADE (as of December December 2008) 2008)
RADIONUCLIDE RADIONUCLIDE CONCENTRATION, CONCENTRATION, Ci/CubicCi/Cubic Meter Meter Mn-54 Mn-54 0.61 Fe-55 43.22 43.22 Ni-59 0.05 0.05 Co-60 Co-60 16.91 16.91 Ni-63 2.69 2.69
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All other wastes materials would exceed materials are expected exceed 10 CFR 61 Class A limits, will either radioactive concentrations expected to have radioactive either be returned manufacturer, or transferred to WPI's agreement state 'license disposal option becomes becomes available.
available.
concentrations a small fraction of those listed for the regulating blade. The one Curie Pu-Be source, which returned to DOE or a source which license until a suitable 10 CFR 61, Licensing Licensing Requirements Requirements for Land Disposal Disposal of Radioactive Waste, Radioactive Waste, Subpart D - Technical Subpart Requirements for Technical Requirements for Land Disposal Disposal Facilities Facilities (Ref.
(Ref. 25),
establishes establishes minimum minimum radioactive characterization and labeling radioactive waste classification, characterization requirements. adherence to those requirements requirements. WPI's adherence requirements will be ensured ensured through the implementation of implementation project project packaging and characterization procedures, characterization procedures, Disposal Site Waste Waste Acceptance CriteriaCriteria for the selected disposal disposal site(s) and the Project-Specific Project-Specific Quality Assurance Plan. Training/Qualifications Training/Qualifications will be provided provided for project project waste management management personnel to assure conformance conformance to applicable applicable 10 CFR 61 requirements (Ref. 25) as stated in the specific implementing requirements (Ref. implementing procedures procedures and plans.
Audits and surveillances surveillances will be conducted per the Project-Specific Project-Specific Quality Assurance Assurance Plan based on American Society Society of Mechanical Mechanical Engineers Engineers (ASME) NQA-1 (Ref.
(Ref. 26) and the requirements of 10 CFR 71 (Ref. (Ref. 9).
10 CFR 71, Packaging Packaging and and Transportation Radioactive Material, Transportation of Radioactive establishes Material, establishes requirements requirements for packaging, shipment preparation shipment preparation and transportation transportation of licensed licensed material. WPI is licensed licensed by the NRC/ StateState of Massachusetts Massachusetts to receive,receive, possess, use and transfer transfer licensed licensed byproduct byproduct and source source materials. 10 CFR 71 requirements requirements will be met through through the implementation implementation of the WPI-RDP approved approved packaging packaging and shipping shipping procedures. Training will be provided to assure conformance conformance to applicable 10 CFR 71 requirements. Quality Assurance for waste packaging Quality Assurance packaging and transportation transportation will conform to 10 CFR 71 Subpart Subpart H (Quality Assurance) requirements requirements through the implementation project-specific quality implementation of a WPI-RDP project-specific assurance plan.
10 CFR 20.2006, Transfer Transfer for Disposal Disposal and and Manifests, Manifests, establishes requirements for for controlling controlling transfers transfers of low-level low-level radioactive radioactive waste intended for disposal disposal at a land disposal facility; establishes establishes a manifest tracking tracking system; supplements requirements requirements concerning concerning transfers and record keeping; and requires generator certification requires generator certification that that transported materials are properly classified, described, packaged, marked transported materials marked and labeled, and are in properproper condition for transport. These requirements requirements will be met met through the implementation implementation of WPI-RDP packaging and shipping procedures procedures with with the oversight of WPI's RHSC and Decommissioning Decommissioning Consultant.
Radiological Radiological wastes will be disposed of at disposal sites per the applicable disposal site's Waste Acceptance Acceptance Criteria. Associated Associated implementing implementing plans and proceduresprocedures will reflect the characterization, characterization, processing, removal of prohibitedprohibited items, packaging
and transportation transportation requirements. Appropriate designated Appropriate documentation documentation will be submitted to designated disposal sites including, as required, certification qualification certification plans, qualification
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statements, assessments, waste stream transportation transportation plans, and waste waste stream analysis, evaluations waste stream volume evaluations and profiles, volume forecasts. Waste characterization, Waste characterization, waste designation, waste traceability, waste segregation, waste packaging, waste minimization, and quality assurance assurance and training disposal sites will be incorporated requirements of the designated training requirements incorporated in implementing implementing procedures designated procedures to assure conformance to disposal site requirements.
conformance requirements.
Generator State (Massachusetts) and Treatment/Storage/Disposal Generator Treatment/Storage/Disposal Facility Facility State (Utah) requirements (Utah) requirements for radioactive radioactive waste management will be incorporated management incorporated into plans plans and procedures procedures to assure conformance conformance with applicable state regulations, licenses and permits. Applicable Applicable state regulations include Massachusetts include Massachusetts Department of Environmental Department Environmental Quality requirements and Utah Department Quality requirements Department of of Environmental Quality rules (R313) for the control Environmental control of ionizing radiation radiation reflected reflected in in Envirocare's Envirocare's Utah Radioactive Material Radioactive Material License, UT 2300249.
Radioactive waste will be staged Radioactive staged in designated controlled areas at the LCWNRF LCWNRF in in accordance with the requirements accordance requirements of 10 CFR Part 19 (Ref. (Ref. 14) and 10 CFR Part 20 20 (Ref.
(Ref. 19). Measures implemented through plans and procedures Measures will be implemented procedures to prevent prevent the spread of contamination, contamination, limit radiation radiation levels, prevent unauthorized prevent unauthorized access, prevent unauthorized material removal, prevent tampering, and prevent prevent unauthorized prevent weather weather damage. The designated designated areas will be controlled by Radiological Radiological Work Permits
(RWP).
(RWP).
Radioactive waste material Radioactive material will be packaged for shipment per 10 CFR 61 (Ref. (Ref. 25)
(Ref. 27), and the designated disposal site's Waste Acceptance and 49 CFR (Ref. Criteria Acceptance Criteria and held in interim storage (staged) until shipped. Due to the relatively small amount of waste to be generated during the WPI-RDP, it is expected that only one truck shipment shipment will be needed. As such, the waste will be staged on-site until all the waste products have been generated. Radioactive Radioactive material material storage storage areas will be contained inside posted posted restricted according to WPI-RDP procedures restricted areas according procedures and consistent with 10 CFR 20.
3.3 GENERAL INDUSTRIAL GENERAL INDUSTRIAL SAFETY PROGRAM WPI, along with its contractors, shall be responsible responsible for ensuring that the WPI-RDP WPI-RDP complies with all applicable occupational applicable occupational health and safety requirements.
requirements. The primary primary functional functional responsibility responsibility is to ensureensure compliance with the Federal Occupational Safety and Health Acts (OSHA) of 1973 (Ref.
Occupational (Ref. 28). Specific responsibilities responsibilities include:
Conducting Conducting an an industrial industrial training program program to instruct employees employees in general general safe work practices practices
" Reviewing decommissioning
Reviewing decommissioning project procedures procedures to verify adequate coverage of adequate coverage of
industrial safety and industrial industrial hygiene concerns requirements concerns and requirements
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Performing periodic
" Performing correct correct
" Providing any periodic inspections unsafe Providing industrial
" Advising inspections of work areas and activities to identify and conditions industrial hygiene Advising Project Management and work practices Management personnel practices hygiene services as required required personnel on industrial safety matters and on on the results of periodic safety inspections inspections All personnel personnel working on the WPI-RDP will receive Health Health and Safety training in training in order order to recognize and understand the potential potential risks involving involving personnel health and safety associated associated with the work at the WPI LCWNRF. The Health and Safety training implemented implemented on the WPI-RDP is to ensure compliance compliance with the requirements of NRC (10 (10 CFR), the EPA (40 CFR), and OSHA (29 CFR). Workers Workers and regular regular visitors will be familiarized familiarized with plans, procedures procedures and operation of of equipment to conduct equipment conduct themselves safely. In addition, each worker worker must be familiar familiar with procedures that provide for good quality control. Section 2.5 Training Program, provides additional additional information.
3.4 RADIOLOGICAL ACCIDENT ANALYSES RADIOLOGICAL ANALYSES The inventory of radioactive radioactive material expected expected to be present at the start of of decommissioning is significantly decommissioning significantly smaller than that postulated for the accidentaccident scenarios applicable for when the reactor was operational. The reactor fuel will have been removed prior to the start of decommissioning, and the majority of the residual residual radioactivity (less than 60 mCi) is in the form of activated radioactivity activated metals which are not not readily dispersible. As such, the existing operational operational accident analysis continues to bound and by far exceeds consequences of any accident exceeds the consequences accident that could credibly credibly occur occur decommissioning period. As such, a new accident analysis is not during the decommissioning not required..
required
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4.0 PROPOSED FINAL RADIATION SURVEY PLAN Based upon the results of an historical site assessment and scoping surveys of the Leslie C. Wilbur Nuclear Reactor Facility (LCWNRF), Worcester Polytechnic Institute (WPI) intends, to the extent practicable, completely remove equipment practicable, to completely equipment and items that had become neutron activated or that contain radioactive contamination. Such removed materials will be disposed as radioactive radioactive waste.
WPI anticipates that most - if not all - of the building structures will be free of of residual radioactivity, and will not require decontamination.
The Final Status Survey (FSS) Plan (and subsequent FSS Report) discussed in this section deals with release of the WPI reactor building structure structure and surrounding environs environs for unrestricted unrestricted use.
4.1 DESCRIPTION
OF FINAL STATUS STATUS SURVEY PLAN The purpose of the FSS is to demonstrate that the radiological radiological condition of the LCWNRF LCWNRF structures is at or below established established release criteria (see Section 2.7). It It anticipated that NRC will then terminate is anticipated terminate the R-61 reactor license, thereby allowing allowing unrestricted use of all areas of the former LCWNRF.
WPI will develop develop its FSS Plan using the guidance provided in NUREG-1757, Volume 2, Consolidated Consolidated Decommissioning Guidance, Characterization, Decommissioning Guidance, Characterization, Survey, and Determination Radiological Criteria, Determination of Radiological Criteria, (Ref.
(Ref. 29) and NUREG-1575, NUREG-1575, Multi-Agency Radiation Radiation Survey and and Site Investigation Manual (MARSSIM, Ref.
Investigation Manual Ref. 11).
11).
A FSS Plan will be developed developed after decommissioning decommissioning contracts contracts are awarded. The basis for the design of the FSS is MARSSIM.
MARSSIM. The overall goal of the FSS design is is to ensure ensure surveys surveys are planned planned and conducted conducted in such a mannermanner that ensures the proper decision is made as to whether whether or not to accept or reject the Null Hypothesis Hypothesis (see further discussion discussion on Null Hypothesis Hypothesis later in this section). The COMPASS COMPASS computer computer code code (Ref.
(Ref. 21) will also be used as partpart of the survey survey planning planning and survey assessment assessment process.
The major inputs inputs into the FSS planning planning process process are:
" The The development development of of Data Data Quality Objectives (DQOs) (see Section 4.1)
Quality Objectives
"* The The designation designation ofof survey survey units units within within each each area classification (see Section area classification Section 4.4.2) 4.4.2)
The The review review ofof contaminants contaminants and establishment establishment of Derived Derived Concentration Concentration Guideline Guideline Levels (DCGL) (see Sections 2.7 2.7 and and 4.3)
The The selection of appropriate selection of survey instrumentation appropriate survey instrumentation (see Section Section 3.1) 3.1)
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The survey plan will serve as the guidance document for development package instructions sectioned instructions used during implementation sectioned into survey units according development of the survey implementation of the FSS. The facility will be according to guidance provided in MARSSIM.
diagrams, and facility layout drawings will be developed MARSSIM. Plots, survey developed to illustrate the classification of the survey units. In addition to a FSS Plan, survey classification be packages survey work packages will be developed for each survey unit. Each survey package package will include include survey-unit-specific instructions, describe the survey unit size, grid spacing, and scan area unit-specific area prescribed, and specify a prescribed number of static measurements measurements (including the location and spacing).
location reevaluation of the survey plan may be necessary As the survey progresses, reevaluation necessary based acquired survey data. If a condition on newly acquired condition is discovered discovered that is not encompassed encompassed by the survey plan, the survey plan may undergo revision to address the condition.
The condition with the revised survey survey plan will be fully disclosed and provided to Decommissioning Consultant and RSO for review and concurrence the Decommissioning concurrence prior to performance of the FSS as it applies to the revised further performance revised information.
To prevent recontamination recontamination of the clean areas, WPI will institute administrative physical access controls of surveyed and physical surveyed areas deemed radiologically radiologically clean.
Administrative control Administrative surveyed areas will be accomplished by written control of surveyed written instruction contained in the final survey plan and by training of project instruction personnel.
Physical control of surveyed areas may be accomplished by placing rope barriers, locking locking doors where possible, etc. and placing signs to notify personnel regarding where possible, the condition of an area.
The FSS Plan will contain the criteria used to assess all final survey survey data including statistical tests performed. The Plan will also state conclusions to be drawn the statistical drawn based upon statistical test results.
The FSS Plan will be developed according to the guidance provided in MARSSIM guidance provided MARSSIM and based upon the following assumptions:
" The The interior interior rooms of the LCWNRF LCWNRF are impacted (determined from the results of operational history, scoping survey survey data and professional professional judgment).
" The screening activity levels for building surfaces The screening surfaces are based on the assumption that the fraction of removable removable surface contamination is equal to contamination 0.1. The fraction of activity that is removableremovable will be verified. If the removable exceeds 0.1 then more decontamination removable fraction exceeds decontamination will be performed performed site-specific DCGL values will need to be applied.
or site-specific
" Decision Decision Errors Errors - there are two types of decision errors applied to analytical results: Type I (a)
(a) and Type II (B) errors. A Type I error, or false positive, is 11 (B) the probability Hypothesis is rejected when it should be accepted.
probability that Null Hypothesis probability of determining that Null A Type II error, or false negative, is the probability
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Hypothesis Hypothesis is accepted accepted when it should be rejected. The probability decision errors can be controlled by adopting an approach testing. The Null Hypothesis defined by MARSSIM defined MARSSIM as:
Hypothesis is treated like a baseline probability of making approach called called hypothesis hypothesis baseline condition and IS is Null Hypothesis (Ho)(H.) = residual residual radioactivity in the survey unit unit exceeds the release criterion.
exceeds This means that the site or survey survey area is assumed contaminated contaminated until proven otherwise.
otherwise. For the purpose of this final survey, Type I or a error will be set at 0.05 (or 5 percent) and Type II or B 8 error error will be set at 0.05 (or 5 percent).
For the LCWNRF For LCWNRF it is likely that WPI will not need to evaluate evaluate survey survey data relative relative to a reference reference background background area. However, if there were a need to evaluate survey evaluate survey data relative to a reference reference background background area, WPI would utilize either the Sign test or the Wilcoxon Wilcoxon Rank Sum (WRS) test to determine if any residual contamination contamination in a survey unit exceeds the DCGL.
The selection selection process for determining determining which test method method to use will be documented.
" Any background count rate information information required for input into the survey planning planning process will be obtained performing the FSS. The standard obtained prior to performing deviation in the background background count rate will be calculated based based on the data obtained. With the COMPASS COMPASS code used to automatically automatically calculates calculates the standard deviation. The backgroundbackground information information is stored as part of the information and not on a survey unit specific general site information specific basic.
" Once Once the the final survey has been performed, survey data will be converted converted to DCGL units and compared compared to the DCGLs. Individual Individual measurements and measurements concentrations will be compared to DCGL levels for evidence sample concentrations evidence of small areas of elevated activity. Data will then be evaluated evaluated using the appropriate statistical statistical test method (i.e., Sign test or WRS test) to determine determine if they exceed exceed the release release criterion.
" If the
If the release criterion has been exceeded (i.e., Null Hypothesis proven Hypothesis is proven true) WPI management, with assistance assistance from the Decommissioning Decommissioning Consultant, will determine appropriate appropriate further actions. If If all data points are less than the DCGL levels, no statistical test need be performed. performed.
4.1.1 Review and Approval of Final Status Status Survey Plan Plan WPI is utilizing Method Method 1 from NUREG-1757, NUREG-1757, Volume 2, Consolidated Consolidated Decommissioning Guidance, Decommissioning Guidance, Characterization, Characterization, Survey, and DeterminationDetermination of of Radiological Criteria (Ref.
Radiological Criteria (Ref. 29), to submit information information to NRC on facility radiation radiation surveys. WPI has submitted submitted information information to NRC on release release criteria, characterization surveys, and operational characterization operational surveys surveys as part of this DP. In addition, WPI has committed to using the MARSSIM MARSSIM approach in developing developing the final
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radiological survey. Once the design of the final radiological survey for the site has radiological been completed, WPI will submit information to NRC on FSS Design.
information to allow NRC to determine The FSS Plan will include sufficient information the FSS Design is adequate adequate to demonstrate demonstrate compliance with the radiological determine that radiological criteria for license termination. The information information will include:
" AA brief overview overview describing the FSS Design.
" AA description description and map or drawing drawing of impacted areasareas of the site, area, or or radioactivity levels (Class 1, Class 2, or Class building classified by residual radioactivity explanation of the basis for division
3) and divided into survey units, with an explanation division into survey units. Maps will indicate indicate compass compass orientation.
" AA description description of the background background reference reference areas and materials, if they will be used, and a justification for their selection.
" AA summary summary of the statistical statistical tests that will be used to evaluate evaluate the survey survey results, including measurement comparison, if Class 1 survey including the elevated measurement survey units are present, a justification methods not included justification for any test methods included inin MARSSIM, and the values for the decision errors (and) with a justification for for values greater than 0.05.
" AA description description of scanning scanning instruments, methods, calibration, operational operational
checks, coverage, and sensitivity sensitivity for each media and radionuclide.
radionuclide.
" For For in-situ in-situ sample measurements measurements made by field instruments, a description of of the instruments, calibration, operational checks, sensitivity, and sampling calibration, operational demonstration that the instruments, and methods, have methods, with a demonstration adequate sensitivity.
adequate
" AA description description of of the the analytical instruments for measuring samples in the including the calibration, sensitivity, and methodology for laboratory, including for demonstration that the instruments and methods have evaluation, with a demonstration adequate sensitivity.
adequate
" AA description description of how the samples to be analyzed in the laboratory laboratory will be be collected, controlled, and handled.
" AA description description of the FSS investigation investigation levels and how they were determined.
" AA summary summary of any significant significant additional radioactivity that was not additional residual radioactivity not accounted characterization.
accounted for during site characterization.
" AA summary summary of direct measurement measurement results and/or concentration concentration levels in in units that are comparable comparable to the DCGL and, if data is used to estimate or or update update the survey unit.
" AA summary summary of of the the direct direct measurements measurements or sample data used to both evaluate
remediation and to estimate the survey unit variance.
the success of remediation
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LCWNRF into three classes (as suggested adequate survey MARSSIM) to ensure adequate termination request and subsequent coverage in support of a license termination coverage release of the subsequent release property for unrestricted property unrestricted use.
Sufficient Data is Included to Achieve Means for Ensuring that Sufficient 4.1.3 Means Statistical Goals Goals WPI will develop the WPI-RDP FSS Plan using the guidance presented in guidance presented in NUREG-1757, Volume Consolidated Decommissioning Volume 2, Rev. 1, Consolidated Guidance, Characterization, Decommissioning Guidance, Characterization,
Survey, and Determination Determination of Radiological RadiationSurvey and Multi-Agency Radiation Using such regulatory regulatory guidance goals are satisfied.
Radiological Criteria and Site Investigation guidance will ensure (Ref. 29) and NUREG-1575, Criteria (Ref.
Investigation Manual Manual (MARSSIM, Ref.
ensure that NRC-recommended Ref. 11).
NRC-recommended statistical 11).
4.2 BACKGROUND
SURVEY RESULTS BACKGROUND RESULTS Guideline values for residual activity are taken to be levels above the The FSS Guideline naturally occurring background radiation.
occurring background However, if the FSS results are significantly release guideline levels, the regulations allow the licensee significantly below the release licensee to background background subtraction. WPI has opted to not subtract background opt not to use background for direct surface contamination measurements due to naturally occurring contamination measurements occurring radioactive materials that may be present radioactive construction materials. However, WPI present in construction background when gamma exposure will account for background measurements are made.
exposure rate measurements 4.3 FINAL RELEASE CRITERIA - RESIDUAL RELEASE CRITERIA RADIATION AND RESIDUAL RADIATION AND CONTAMINATION LEVELS CONTAMINATION LEVELS criteria for release of the LCWNRF The criteria unrestricted use, after completion LCWNRF for unrestricted completion of the decommissioning activities described in this DP, are presented in Section 2.7. In In summary, they are:
a. The generic values provided in Tables H.1 generic screening values H.l and H.2 of Volume 2 in in
NUREG 1757 (Ref. 29), and
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b.
4.4 Use (Ref.
specified in 10 CFR 20.1402, Radiological A limit specified (Ref. 12)
MEASUREMENTS FOR DEMONSTRATING MEASUREMENTS WITH RELEASE CRITERIA Radiological Criteria DEMONSTRATING COMPLIANCE COMPLIANCE for Unrestricted Criteria for Unrestricted 4.4.1 Instrumentation Specifications and Operating Instrumentation -- Type, Specifications Operating Conditions Conditions Instrumentation Instrumentation utilized during the Final Release Survey Survey (and equipment equipment and materials selected based upon the need to ensure that site residual materials survey) will be selected radiation radiation will not exceed the release criteria. In order order to achieve this goal, WPI will select instrumentation instrumentation that is sensitive to the isotopes of concern and that is capable of measuring measuring levels below the guideline guideline values for those isotopes.
Instrumentation available for the FSS and its respective detection range capability Instrumentation capability is presented presented in Table 3.1 of this DP. Instrumentation Instrumentation sensitivities sensitivities will be be determined determined following the guidance of NUREG-1575, MARSSIM NUREG-1575, MARSSIM (Ref. (Ref. 11) using nominal literature literature values for background, response and site conditions.
Refinements Refinements to these detection sensitivity estimates will be made, as necessary, on on the basis of actual instrument instrument response response and background data gathered gathered during site survey activities. Minimum Detectable Concentrations Minimum Detectable Concentrations for direct integrated integrated measurements measurements and scanning will be determined determined as follows:
Where:
Detectable Concentrations Minimum Detectable MDC = C Concentrations (Direct Integrated Measurement):
(3 +
C*-(3 (B)1/ 2)
+ 4.65 *. (B)II2) (eq. 6-7, Ref.
Ref. 11) 11)
C conversation factor from counts to concentration conversation concentration B = number of background background counts expected to occur while performing performing the measurement measurement Minimum Detectable Detectable Concentrations Concentrations (Scanning):
MDCR MDCR Scan MDC =
ScanMDC =_(eq. Ref. 11)
(eq. 6-10, Ref. 11)
Probe area area (P)
(P)l2 . i . Cs" 112 -Ci" s . _ _---,.,_
100 cm2-100 cm2 Where:
MDCR = minimum detectable count rate Ci i = instrument efficiency instrument efficiency Cs s surface efficiency efficiency P = efficiency surveyor efficiency
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Instrumentation used in the surveys will be calibrated against sources standards that are traceable to National Institute of Standards and Technology representative of the isotopes encountered (NIST), and representative encountered at sources and at the LCWNRF. When used, instruments will be operationally tested daily, or prior to each use, whichever is less frequent. Instruments will not be used in conditions that are not in When whichever manufacturer recommendations.
conformance with manufacturer Measurement Methodology 4.4.2 Measurement Methodology for Conduct of Surveys This DP has been developed under the presumption that the LCWNRF will have been decontaminated decontaminated to the extent practicable prior to the FSS. The WPI-RDP FSS Plan will include several steps to calculate calculate the number of measurements measurements and samples required, according to MARSSIM guidance, to release the site without without restrictions. These steps include:
" Classify Classify survey units
" Specify the Specify the decision error error
Determine the DCGLs Determine
" Calculate the Calculate the relative relative shift (COMPASS, Ref. Ref. 21, may be utilized)
" Obtain the Obtain number of the number of samples samples per survey unit (COMPASS, Ref. Ref. 21, may be
utilized)
" Estimate Estimate the
" Perform the sample sample grid spacing Perform evaluation
" Determine evaluation for small areas with elevated radioactivity Determine if if the number of samples is reasonable the number radioactivity Classify Survey Units The impacted impacted areas of the LCWNRF will be divided divided into three classes of survey survey units. Class Class 1 is an area with the highest potential for contamination.
contamination. Class 2 is an area area that has a low potential potential for delivering delivering a dose above above the release release criteria and has little or no potential for containing containing small areas of elevated elevated activity. Class 3 is an area with the lowest potential potential for contamination.
contamination.
The FSS Plan and survey survey work packages packages for eacheach survey unit will include include a discussion discussion regarding relevantrelevant historical, characterization characterization and in-process in-process survey survey information information and evaluations, to support each each survey survey units' classification.
Specify Specify the Decision Decision Error Error There There are two types of decision decision error error (applied here here to analytical analytical results): Type I (alpha) and Type Type II (beta). A Type I error error is described described as the probability probability ofof determining determining that a result is above above a criterion criterion when when it actually actually is not (false positive).
positive) .
A Type II II error is described described as the probability probability of determining determining that that a result is below below
(. WorcesterPolytechnic Worcester Reactor Polytechnic Institute Reactor Decommissioning Institute Decommissioning Plan Plan Document W19-1579-003, Document a criterion when it actually is above it (false negative). Both types of error set at 0.05 (5%).
W19-1579-003, Rev.
Section 4, Page Section Rev. 1 Page8 of 1111 error will be be Determine Determine the DCGLDCGL MARSSIM defines the derived concentration MARSSIM concentration guideline level (DCGL) as the radionuclide-specific concentration within a survey unit corresponding radionuclide-specific concentration corresponding to the release criterion. The radionuclides radionuclides known or potentially potentially existing at the LCWNRF LCWNRF include 60 Co and 55 60CO Fe, the presumed 55Fe, presumed predominant predominant radionuclides, and possibly traces 3H, 14C, 54 Mn, 63Ni, 152Eu, 154 of 3H, 15 5Eu. The 14C, 54Mn, 63Ni, 152Eu, 154Eu, Eu, and 155Eu. DCGL values are discussed in in Section 2.7.
Section As stated in NUREG-1757 NUREG-1757 (Ref. (Ref. 29), "in light of the conservatism in the building surface surface and surface screening levels developed by the NRC staff, the surface soil generic screening staff presumes, absent information information to the contrary, that licensees or responsible parties that remediate building surfacessurfaces or soil to the generic generic screening levels do not need to demonstrate demonstrate that these levels are ALARA."
Gross activity DCGLs and DCGLEMC DCGLEMC (elevated measurement comparison comparison DCGLs) will be developed during the planning stage for the FSS. Such planning planning will include consideration consideration of "hard-to-detect" radionuclides radionuclides for surfaces. The site-specific
DCGLs will be calculated expected expected plan.
Calculate calculated based on the relative fraction of each radionuclide radionuclide Calculate the Relative Shift mix. Once developed, the values will be radionuclide in the included included in the FSS The relative shift is defined as /1/0 A/u where A /1 is the DCGL - LBGR (Lower Bound of of the Gray Region) and u0 is the standard standard deviation deviation of the contaminant contaminant distribution.
In order order to calculate the relative relative shift, the DCGL must be determined determined and two assumptions assumptions must be made to estimate estimate the LBGR and the standard deviation of the measurement measurement distribution. MARSSIM MARSSIM suggests suggests that the LBGR be set at 50% of the DCGL but can be adjusted later to provide a value for the relative relative shift between the range of 1 to 3. standard deviation may be calculated
3. The standard calculated from preliminary preliminary survey survey data, prior surveys surveys of similar areas and materials or the standard standard deviation deviation of a reference background reference background area.
It should be noted that o0 represents represents the standard standard deviation prior to release after all area decontamination decontamination is thought to be complete. If no reference reference data is available to make a reasonable reasonable estimate estimate of the background background standard deviation, MARSSIM MARSSIM suggests using 30% of the mean survey unit background. background. For the LCWNRF, data from the facility characterization characterization or from post-remediation post-remediation surveys surveys will be used to calculate calculate the standard deviation value for each survey unit. The value for LBGR LBGR is
input into COMPASS, and the relative reported.
relative shift is automatically automatically calculated and
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Obtain Obtain the Number of Samples Samples per Survey Survey Unit Unit Once Once the relative relative shift is determined determined the calculated calculated value, Mo,A/u, will be used to obtain obtain the minimum measurements or samples minimum number of measurements samples necessary necessary to reject the Null Hypothesis Hypothesis based based upon the initial assumptions assumptions and justify that the survey unit unit meets the requirements for release for unrestricted unrestricted use. MARSSIM MARSSIM Table 5-3 5-3 contains contains the number number of samples or measurements measurements necessary necessary for the given decision given decision errors (ct (0 and 8),B), and the calculated calculated relative relative shift (A/u),
(Mo), when dealing with non-radionuclide-specific radionuclide-specific measurements measurements or when the radionuclide is present in the background. The value N/2 from MARSSIM MARSSIM Table 5-3 represents the number of of samples samples or measurements measurements to be collected collected in each survey unit and the reference reference background area. MARSSIM background MARSSIM Table 5-5 provides the number of measurements measurements of of samples samples for the case in which the radionuclide radio nuclide is not in the background.
Estimate Estimate the Sample Grid Spacing The grid spacing for the measurement measurement and samples samples is estimated in two ways, depending depending upon the shape of the grid (i.e., either either triangular rectangular grid). If triangular or rectangular If a triangular triangular grid is used, the grid spacing spacing is estimated estimated as follows:
L = (A/0.866N) 112 1/2 Where:
L = Distance Distance between measurement locations between measurement locations A = Survey unit Area Area Number of measurements N = Number measurements If a square grid is used, the spacing is estimated as follows:
=
L = 1/2 (A/N) 112 (A/N)
Perform Evaluation for Small Areas with Elevated Perform Evaluation Radioactivity Elevated Radioactivity After the grid spacing has been been calculated, the area between between samples samples can also be be calculated. For example, if for a square grid the grid spacing spacing is 10 m, then there could be an undetected (area) of elevated undetected pocket (area) elevated radionuclide radio nuclide concentrations concentrations 100 m M 22 ..
Adjustments to the grid spacing (i.e., additional additional sampling) may be necessary depending depending on the following three factors:
The class of the survey unit
The ability to scan for the radionuclide radio nuclide
The minimum potential potential size of the elevated elevated activity that could produce an an exposure exposure above the dose or risk criterion criterion
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Determine if the Number of SamplesSamples is Reasonable After the number of samples samples per unit has been calculated, it will be evaluated evaluated to determine if the number is reasonable. It is possible, even even if MARSSIM MARSSIM guidance guidance is strictly followed, that there are too few samples to produce produce the desired level of of managers and health physicists will be responsible comfort. The site managers responsible for evaluating whether reasonable. If it is determined whether the number of samples is reasonable. determined that the number number of samples inadequate or excessive, the data quality objectives will be samples is inadequate reevaluated.
4.4.3 Scan Surveys remediation and prior to conducting Following remediation conducting sampling, beta scans for surfaces surfaces and structures and gamma gamma scans for environs environs will be performed performed over 100% of the Class 1 surfaces, 50% of the Class 2 surfaces surfaces and 25% of the Class 3 surfaces. A scanning response scanning response exceeding an action level (based on Section Section 6.8.2 of NUREG-1507) will be investigated/sampled/re-surveyed investigated/sampled/re-surveyed and, if necessary, remediated. If If remediation is performed, performed, scanning shall be repeatedrepeated to demonstrate effectiveness demonstrate effectiveness of the remediation.
4.4.4 Soil Sampling Sampling While soil sampling is not anticipated, if soil samples samples are later determined determined to be necessary, they will be obtained obtained to a depth of 15 cm; samples will be packaged packaged and uniquely uniquely identified in accordance with chain-of-custody chain-of-custody and site-specific site-specific procedures.
4.4.5 Sample Analysis Analysis Samples will be transferred transferred to a radio-analytical radio-analytical laboratory laboratory for analyses in in accordance with documented accordance documented laboratory-specific laboratory-specific standard standard methods. In accordance with MARSSIM, analytical MARSSIM, analytical techniques will provide a minimum detection detection level of of 50% of the individual radio radionuclide nuclide DCGLw (or DCGLEMC)
DCGLEMc) values for all primary contaminants.
contaminants. If analyses indicate exceeding guideline levels, indicate residual activity exceeding further remediation will be performed, as required, and scans and sampling of the remediated remediated area will be repeated.
Investigation Levels 4.4.6 Investigation identified by scans that indicate potential residual Radiation levels identified residual radioactive contamination background will be investigated to identify the source, contamination above background source, level level and extent of such residual activity. Areas that contain residual radioactivity concentrations concentrations of individual radionuclides, or sum-of-ratio sum-of-ratio concentrations concentrations above respective respective guideline values, will be remediated, reclassified (as necessary) and re-surveyed..
surveyed
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4.5 METHODS TO BE EMPLOYED METHODS AND AUDITING AND AUDITING DATA 4.5.1 Laboratory/Radiological EMPLOYED FOR REVIEWING, DATA Laboratory/Radiological Measurements During decommissioning REVIEWING, ANALYZING, Measurements Quality Assurance ANALYZING, decommissioning survey activities, many direct and indirect measurements measurements and sample sample media samples samples will be collected, measured measured and analyzed analyzed for radiological radiological contaminants. The results of these surveys will be utilized to evaluate the suitability of the material material or item for release to unrestricted unrestricted use, or whether whether decontamination of structures, components, and the surrounding decontamination surrounding site have achieved achieved the desired result. Sample collection, analysis, and the associated associated documentation documentation will adhere to written procedures procedures and meet NRC guidance, guidance, as well as comply with with recognized industry recommendations recommendations and good practices. Laboratories Laboratories selected selected to decommissioning samples analyze decommissioning samples will be approved approved by WPI and listed on the contractor's QA Approved contractor's Approved Suppliers List.
contractor will need to implement The selected contractor implement a QA program program that meets the requirements under 10 CFR 71, Packaging Packaging andand Transportation Transportation of Radioactive Radioactive Material, Subpart Subpart H, Quality Quality Assurance Assurance (Ref.
(Ref. 9). In addition, the contractor's contractor's QA QA program program must meet the applicable applicable criteria from 10 CFR 50, Appendix B (Ref. (Ref. 8) and ASME NQA-l NQA-1 (Ref.
(Ref. 26). One of the applicable criteria that must be included included is a QA Approved Approved Suppliers List; the contractor will be required to maintain the QA
either Suppliers List. WPI will assess the effectiveness Approved Suppliers either through through direct audits performed Decommissioning Consultant, or by the acceptance Decommissioning organizations.
organizations.
effectiveness of the QA program performed by WPI's ReactorReactor Director, RSO, or acceptance of audits performed performed by other or other Organizations that perform Organizations radiological monitoring measurements perform radiological measurements recognize recognize the need to establish quality assurance programs to assure that radiological radiological monitoring measurements are valid. Such programs measurements programs are established to:
(1) Readily identify deficiencies deficiencies in the sampling sampling and measurement measurement processes to those individuals responsible responsible for these activities so that prompt corrective corrective action can be taken, and (2) Routinely monitor the survey and laboratory laboratory measurement measurement results in order to assure that results and conclusions are valid Supervisory and Management 4.5.2 Supervisory Management Review Review of Results Results Health Physics technicians technicians who are trained trained and qualified will conduct radiological radiological surveys. In addition, senior-level senior-level Health Health Physicists other than the individual that performed performed the survey will review review radiological surveys and sample results. FSS data will also be independently independently reviewed by the Decommissioning Decommissioning Consultant Consultant..
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In August authorization to operate authorization 5.0 TECHNICAL TECHNICAL SPECIFICATIONS August 2008, NRC granted WPI a license operate the reactor (Ref.
amendment to remove its license amendment (Ref. 4). That amendment amendment authorizes authorizes WPI's possession possession only of the reactor and used fuel, and amended amended the Technical Specifications to remove operational Specifications operational requirements requirements not needed for a Possession-Only Possession-Only License License (POL).
After the nuclear fuel is removed from the reactor reactor and shipped shipped off-site and NRC issues the Decommissioning Decommissioning Order, WPI can commence decommissioning decommissioning operations.
operations. At that time, many of the technical specifications specifications for the POL will no longer apply. Proposed Proposed revisions revisions to the Technical Specifications Specifications for the decommissioning decommissioning period are given in Appendix B. B.
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The existing physical security PHYSICAL SECURITY 6.0 PHYSICAL SECURITY PLAN security plan that is approved approved by NRC will continue continue to bebe implemented implemented during the decommissioning decommissioning period. That existing existing plan meets the requirements requirements in NUREG-1537, NUREG-1537, Chapter Chapter 17 (Ref.
(Ref. 5). All radiologically radiologically controlled controlled areas areas are secured from unauthorized unauthorized entry. The LCWNRF is normally locked locked non-working hours, if unattended. WPI maintains routine, periodic during non-working periodic police surveillance surveillance of the reactor site site..
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As required emergencies emergencies at the reactor 7.0 EMERGENCY EMERGENCY PLAN required by NRC, WPI has a Reactor Reactor Facility Emergency reactor facility. The purpose Emergency Plan for responding to purpose of the Emergency Emergency Plan is to minimize minimize the effect of emergency on the public, personnel, reactor any emergency reactor facility and the environment environment surrounding the facility. Removal of spent spent fuel from the site will significantly significantly reduce the potential potential for significant significant release release of radioactive radioactive material offoff site. Any airborne or liquid releases due to decommissioning decommissioning activities would have negligible negligible impact off-site.
off-site. The most likely accident contaminated accident scenario is a contaminated and/or and/or injured individual. This scenario scenario is adequately addressed by the existing emergency emergency plan. Training Training will be provided to key personnel to ensure their their familiarity with the Emergency Emergency Plan and their expected expected responses.
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This section presents 8.0 ENVIRONMENTAL ENVIRONMENTAL REPORT REPORT summary of information relevant presents a summary relevant to the Environmental Environmental Review process, as described in NUREG-1748 Review NUREG-1748 (Ref. (Ref. 32). Based upon the work scope and approach described in this decommissioning decommissioning plan, the potential potential for observing negative impacts to the environment negative decommissioning of the WPI environment during the decommissioning WPI research reactor are small or not applicable. As such, the information presented research presented intentionally limited, in scope, to that necessary for demonstrating herein has been intentionally herein the lack of significant environmental environmental impact. In that context, impacts are defined defined as being effects upon the following environmental environmental resources: land use, aquatic terrestrial ecology, water use and quality, air quality, waste, human health, ecology, terrestrial archeological resources, socioeconomic, transportation, aesthetics, historical and archeological environmental justice.
and environmental justice.
Due to several factors, many many of the potential environmental environmental impacts that would applicable to the decommissioning project are not be applicable normally be associated with a decommissioning decommissioning WPI decommissioning program. Such factors include: the small size of the facility, the limited scope of the planned D&D work, the short duration proposed duration of the proposed radiological inventory work, and the small radiological inventory within this facility.
Decommissioning work at the WPI reactor facility will be limited to the reactor's Decommissioning reactor's structures, systems and components associated components associated with the reactor's biological shield I/
reactor's biological within a classroom area with a 1,200 ft pool, that are housed within ft22 footprint. No changes changes will be made to the building's structure and no soil or ground water contamination building's structure contamination disassembly of small metallic Decommissioning will principally entail disassembly is present. Decommissioning components, with a very limited amount components, destructive removal work. As such, amount of destructive there will be no disruption there or contact contact with the outside environment. This decommissioning work is not expected expected to cause any perceivableperceivable negative environmental impacts. The rational for this conclusion environmental based on the fact that conclusion is based that decommissioning work scope is small and of limited extent, has very low the decommissioning low inherent radiological hazards inherent radiological inventory of radioactive hazards due to a small inventory radioactive materials, and will produce produce a small amount of radioactive radioactive waste materials. These statements statements are supported by the following determinations supported preparation of the determinations obtained during preparation Decommissioning Decommissioning Plan:
Decommissioning Work Scope Nature and Extent of the Decommissioning Nature Scope
" The scope of the decontamination The scope decontamination and dismantling dismantling work is limited to an 8-foot by 8-foot by 15-foot deep reactor pool, within a five-foot thick concrete concrete biological shield.
biological
" Radioactive contamination within the facility is low and limited to the
Radioactive contamination within the facility is low and limited to the
interior of the reactor pool and a small de interior
No No decontamination decontamination is expected to.
mineralizer system.
demineralizer to be required required for the building building structures.
Worcester Polytechnic Institute WorcesterPolytechnic Institute W19-1579-003, Rev. 1 Document W19-1579-003, Reactor Decommissioning Plan Reactor Decommissioning Plan Page 2 of 5 Section 8, Page There will There will be be no radiological radiological work external to the room which houses the reactor and there will be no outdoor radiological Soil and ground water contamination
Soil The majority
The radiological work.
contamination is not present at the facility.
majority of the D&D work will entail disassemblydisassembly of small, slightly activated or contaminated activated components by non-destructive contaminated components non-destructive method (e.g.,
(e.g.,
unbolting or unthreading) and simple saw cutting cutting of slightly contaminated contaminated metals. No thermal cutting or otherwise otherwise airborne-producing cutting airborne-producing techniques will be used or permitted.
" No structural changes No structural changes will be made to the building that houses the reactor reactor room.
" During the
During the course course of the D&D work, no perceivable perceivable impacts (e.g., noise or or staging of materials and equipment) external to the building are expected.
" Radiological D&D
Radiological D&D work is estimated estimated to require require less than 160 work-days work-days of of effort.
" Decommissioning work can be accomplished
Decommissioning accomplished by a very small, hands-on work crew, generally generally 3 oror' 4 individuals, with an estimated estimated 6,800 person-hours person-hours of of work; plus 4,100 person-hours person-hours of associated technical and management associated technical management support.
Facility Radiological Conditions
" The The reactor was of very low power, with limited use (approximately 40 MW-reactor was hours over 40 years) which resulted in the production production of very little residual residual radioactivity by neutron activation.
" The The extent extent ofof radioactivity radioactivity within the facility is limited, with the majority of of the radioactivity radioactivity contained contained within a single, activated stainless stainless steel regulating control blade having a mass of about 7,000 grams, with an an estimated 56 mCi of radioactivity (15 (15 mCi of Co-60). Radiation Radiation levels from the blade blade are estimated to be 17 mrem/hour at one meter (air), based on a measured 125 125 mremlhr mrem/hr at 13 cm (through water).
" All All other radioactive reactor other radioactive core components reactor core components and experimental experimental facilities are estimated to contain significantly significantly lower levels of radioactivity.
No No significant significant activation activation of the concrete concrete biological shield is expected.
" Worker radiation Worker exposure is estimated radiation exposure estimated to total less than 0.5 person-rem.
person-rem.
" Generation of Generation airborne radioactivity of airborne radioactivity is not expected expected nor will it be permitted, and no air effluents containing radioactivity are anticipated.
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Generation and Disposal Radioactive Waste Generation Disposal
" Less Less than than 600 cubic cubic feet of solid radioactive radioactive waste waste are estimated to be be containing less than 60 mCi of radioactivity. The majority of this produced, containing radioactivity radioactivity (56 mCi) is contained in a single 7 Kg stainless steel control control blade, comprised comprised of activated activated metals (Mn-54, <1%; Co-60, 27%; Fe-55, 68%,
Ni-59, <1%; and Ni- 63, 4.2%).
All radioactive wastes are expected to be 10 CFR 61 Class A wastes.
Based upon the precedingpreceding information, WPI has assessed the potential for potential for environmental environmental resources. The results of that assessment environmental impacts on environmental assessment presented in the Table 8-1. The results of this assessment are presented assessment use following definitions as a measure measure of environmental environmental impact:
environmental effects on the resource are not possible or NONE- Not applicable, environmental or credible given the site specific specific conditions.
SMALL- Environmental effects are not detectable or are so minor that they will Environmental effects neither destabilize important attributes of the resource.
sufficient to alter noticeably, but not Environmental effects are sufficient MODERATE- Environmental not
destabilize important attributes of the resource.
destabilize Environmental effects are clearly LARGE- Environmental noticeable and are sufficient to clearly noticeable destabilize destabilize important attributes of the resource.
TABLE 8.1 8.1
SUMMARY
ENVIRONMENTAL IMPACT ASSESSMENT
SUMMARY
OF ENVIRONMENTAL ASSESSMENT ENVIRONMENTAL ENVIR,ONMENTAL IMPACT JUSTIFICATION IMPACT JUSTIFICATION RESOURCE
. RESOURCE '"
Land Use None No outdoor work will be performed. Current use of the property property -- aa university campus -- will university campus will not not change as aa change as result of the decommissioning.
Ecology: Aquatic Aquatic None contact will be No outdoor work will be performed. No contact made with the aquatic environment.
Ecology: Terrestrial Terrestrial None No outdoor work will be performed. No contact contact will be made with the terrestrial terrestrial environment.
(Note: Table 8.1 is continued on next page)
Worcester Polytechnic Worcester Institute PolytechnicInstitute Document W19-1579-003, W19-1579-003, Rev. Rev. 1 Reactor ReactorDecommissioning DecommissioningPlanPlan Section 8, PagePage 4 of 5
SUMMARY
ENVIRONMENTAL ENVIRONMENTAL IMPACT TABLE 8.1 (continued)
SUMMARY
OF ENVIRONMENTAL ENVIRONMENTAL IMPACT ASSESSMENT JUSTIFICATION ASSESSMENT IMPACT JU$TIFICATION RESOURCE RESOURCE Water Use and Quality Quality Small The decommissioning will require disposal disposal of of approximately approximately 7,000 gallons of pool water via the public sewer sewer system. Historically the pool water has not not contained contained any detectable detectable radioactivity. As a precaution, pool water will be filtered, sampled and analyzed analyzed forfor radioactive content, and batch released to assure that 10 radioactive CFR 20 effluent limits are not exceeded.
Air Quality Quality None Radioactive contamination Radioactive contamination levels levels are very low within the facility, with the majority contained contained in solid, activated activated metallic components components that can be dismantled dismantled without the need for segmentation. Dismantling Dismantling techniques that that could produce dust, mists or fumes will be prohibited.
produce dust, prohibited. Air Air quality within within the reactor reactor classroom will be monitored and sampled sampled for airborne airborne radioactivity radioactivity to assure assure and verify that no emissions emissions of radioactivity to the environment environment are possible.
Use of internal combustion powered powered equipment, such as compressors or generators, that would generate compressors generate emissions emissions are not planned.
Waste Small Less than 600 cubic feet of radioactive radioactive waste is estimated estimated to be generated. No hazardous hazardous or mixed wastes are expected to be generated. All waste materials expected materials are estimated to be a small fraction of 10 CFR 60 Class A estimated upper limits. Wastes are planned planned to be disposed disposed of at the EnergySolutions, LLC facility in Clive, Utah.
Human Health Health Small Occupational exposure to five decommissioning Occupational radiation exposure workers is estimated estimated at less than than 0.5 person-rem:
person-rem: to be be incurred over 6,800 person-hours.
person-hours.
No radiation exposure exposure to the general general public is expected expected via direct radiation or air and liquid effluents.
There is a small risk of worker injury injury during performance performance of the decommissioning decommissioning work, similar to that of of construction work. The probability of an injury leading to construction to a fatality is very small. Based upon the frequency of of fatalities for construction construction workers, 10.3 per 100,000 100,000 workers per year, as reported by the Bureau Bureau of Labor Labor Statistics for 2007 (Ref.
(Ref. 33), the probability for a fatality for this decommissioning decommissioning project, with 6,800 person-hours person-hours of construction construction type work, is estimated estimated to be 0.00035.
(Note: Table Table 8.1 is continued continued on next page)
Worcester Polytechnic Institute Worcester Polytechnic Institute Document Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Plan ReactorDecommissioning Plan of5 Page 5 of Section 8, Page
SUMMARY
TABLE 8.1 (continued)
SUMMARY
OF ENVIRONMENTAL ENVIRONMENTAL IMPACT ASSESSMENT ASSESSMENT ENVIRONMENTAL ENVIRONMENTAL IMPACT JUSTIFICATION IMPACT JUSTIFI CATION RESOURCE RESOURCE Socioeconomics Socioeconomics Small No workers will be displaced displaced by shutdown shutdown and decommissioning decommissioning of the reactor. The reactor reactor facility has a minimal part time staff staff (an RSO and an SRO),
who have other duties at WPI. Decommissioning Decommissioning of of the reactor will likely have a positive socioeconomic impact, in that these staff will be available for for increased educational increased educational activities.
Additionally, a small and temporary temporary positive economic impact may be provided economic provided to the local area area employment of decommissioning workers, through employment purchase of materials, supplies and equipment, and purchase spending on living expenses at hotels and spending restaurants.
Transportation Transportation Small Only one truck shipment is anticipated: to transport transport the radioactive waste to the disposal site.
Aesthetics Aesthetics None All decommissioning decommissioning work will be limited limited to the interior of the reactor classroom. There will be no outdoor work performed. No outdoor storage of of material material or equipment equipment is anticipated. No excessively noise producing producing dismantling techniques techniques is anticipated.
Historical Historical and None No structural or appearance appearance changes changes will be made to Archeological Archeological the building. Decommissioning Decommissioning work is limited to one classroom within the building.
Environmental Environmental Justice Justice None decommissioning work will not involve contact The decommissioning contact with, or disruption of, any surrounding surrounding neighborhoods.
Worcester Polytechnic Worcester Polytechnic Institute Institute Document W19-1579-003, Document W19-1579-003, Rev. 1 Reactor Reactor Decommissioning Decommissioning Plan Plan Section Section 9, Page Page 1 of 1
9.0 CHANGES CHANGES TO THE DECOMMISSIONING DECOMMISSIONING PLAN WPI requests that changes to the Decommissioning approval by the Reactor Director Decommissioning Plan (DP) be allowed with local Director and RHSC, and without prior NRC approval, unless an un-reviewed un-reviewed safety question question is involved. An un-reviewed un-reviewed safety question question involves:
1. The increase in probability of occurrence occurrence or the increase increase of consequences consequences of of an accident or malfunction malfunction of equipment compared to equipment important to safety compared that situation previously previously evaluated evaluated in the original Safety Analysis Report Analysis Report (SAR) for the Leslie C. Wilbur Nuclear Reactor Facility, oror
2. The possibility for a type of accident accident or malfunction malfunction differing differing from those previously analyzed in the SAR, or previously or
3. The reduction reduction in margin of safety as defined in the SAR.
Reports and records of changes to the DP, and retention retention of documents, will be in in accordance accordance with the applicable portions of 10 CFR 50.59 (Ref.
(Ref. 31).
Worcester Polytechnic Institute Worcester Polytechnic Institute Document Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Plan Reactor Decommissioning Plan Section 10, Page Section Page 11 or3 of 3
1. WPI discontinued
10.0 REFERENCES
REFERENCES discontinued routine operation operation of the reactor on June 30, 2007.
Certification letter sent to the NRC on 6-27-07 (copied to Alexander Certification Alexander Adams) signed by David Adams, Mike Curley, and Jeffrey Solomon.
2. submitted an application WPI submitted possession-only license.
application to NRC for a possession-only license.
Certification letter sent to the NRC on 8-13-07 (copied to Alexander Certification Alexander Adams) signed by David Adams, Mike Curley, and Jeffrey Solomon.
3. WPI submitted additional additional correspondence correspondence to NRC in support of an an application for a possession-only application Certification letters sent to the NRC possession-only license. Certification on 11-19-07, 4-10-08, and 5-5-08 (copied to Alexander Adams) signed by by David Adams, Mike Curley, and JeffreyJeffrey Solomon.
4. NRC Granted Granted WPI a Possession-Only Possession-Only License Amendment Amendment No. 11 to R-61.
Received at WPI 9-2-08.
5. Nuclear Regulatory Commission (U.S.), "Guidelines for Preparing and Nuclear Reviewing Applications for the Licensing of Non-Power Reviewing Non-Power Reactors, Reactors, NUREG-1537 Rev. 0, February February 1996.
6. Deleted.
7. WPI requests requests DOE take possession possession of the fuel Email from David Adams Adams to Douglas K. Morrell on 6-25-07; verification verification email from Douglas K. Morrell to David Adams 6-25-07.
8. 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Assurance Criteria Nuclear Power Power Plants and Fuel Reprocessing Reprocessing Plants," Code of Federal Federal Regulations.
9. 10 CFR 71, Subpart H, "Packaging and Transportation Transportation of Radioactive Radioactive Material Material- - Quality Assurance," Code of Federal Regulations.
Federal Regulations.
10. ANSI/ASQC "Specifications and Guidelines for Quality Systems for ANSIIASQC E4-1994, "Specifications for Environmental Data Collection and Environmental Environmental Environmental Technology Technology Programs,"
American American Society Society for Quality Control, 1995.
11. Nuclear Nuclear Regulatory Commission (U.S.), "Multi-Agency Radiation Survey Survey and Site Investigation Investigation Manual Manual (MARSSIM),"
(MARSSIM)," NUREG-1575, NUREG-1575, Rev. 1, August August 2000.
Worcester Polytechnic Institute WorcesterPolytechnic Institute Document Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Page 2 of Section 10, Page of33
12.
13.
10 CFR 20.1402, "Radiological Criteria for Unrestricted Regulations.
Unrestricted Use," Code of Federal B. Shleien (editor), "The Health Physics and Radiological Revised Federal Health Handbook, Radiological Health Revised Edition, Scinta, Inc, Silver Spring, MD, 1992.
14. 10 CFR Part 19, "Notices, Instructions Instructions and Reports to Workers:
Workers: Inspection Inspection and Investigations,"
Investigations," Code of Federal Federal Regulations.
Regulations.
15. 10 CFR 20 Subpart Subpart H, "Standards for Protection Protection Against Against Radiation Radiation --
Respiratory Respiratory Protection Protection and Controls to Restrict Internal Exposure Exposure inin Restricted Restricted Areas," Code of Federal Regulations.
16. Nuclear Regulatory Nuclear Regulatory Commission (U.S.), "Acceptable Programs for Respiratory Protection,"
Protection," Regulatory Regulatory Guide 8.15, Rev. 1, October October 1999.
17.
17. Nuclear Regulatory Regulatory Commission (U.S.), "Manual of Respiratory Protection Respiratory Protection Against Airborne Radioactive Radioactive Materials," NUREG-0041, NUREG-0041, Rev. 1, January 2001.
18. "Occupational Safety and Health Standards -
29 CFR 1910.134, Subpart I, "Occupational Personal Equipment - Respiratory Personal Protection Equipment Respiratory Protection," Code of Federal Federal Regulations.
Regulations.
19. 10 CFR 20 Subpart E, "Standards for Protection Against Radiation Radiation --
Radiological Radiological Criteria Criteria for License Termination," Code of Federal Federal Regulations.
Regulations.
20. Nuclear Nuclear Regulatory Regulatory Commission Commission (U.S.), "Consolidated "Consolidated NMSS NMSS Decommissioning Decommissioning Guidance, Decommissioning Process Decommissioning Process for Materials Materials Licensees,"
Licensees," NUREG-1757, NUREG-1757, Volume 1, 1, Rev. 2, September September 2002.
21.
21. COMPASS Code Version Version 1.0.0, Developed by Pacific Northwest Northwest National National Laboratory, Richland, Washington, under the sponsorship of the U.S. NuclearNuclear Regulatory Regulatory Commission for implementation implementation of MARSSIM MARSSIM in support of the decommissioning license termination rule (10 (10 CFR Part 20, Subpart E).
BNWL-1264, BNWL-1264, March 1970.
22. 10 CFR 20.2003, Subpart K, "Standards for Protection Against Radiation -
Disposal by Release into Sanitary Sanitary Sewerage,"
Sewerage," Code of Federal Regulations.
23. Regulatory Guide 1.86, "Termination of Operating Regulatory Operating Licenses for Nuclear Nuclear Directorate of Regulatory Reactors," Directorate Regulatory Standards, U.S. AtomicAtomic Energy
Commission, Washington, D.C., June 1974 1974
WorcesterPolytechnic Worcester Polytechnic Institute Institute Document W19-1579-003, Rev. 1 Document W19-1579-003, Reactor Decommissioning Reactor Decommissioning Plan Plan Section Section 10, Page Page 3 of of33
24.
25.
Nuclear Regulatory Nuclear Impact Regulatory Commission (U.S.), "Final Generic Statement on Decommissioning Impact Statement Decommissioning of Nuclear Office of Nuclear Regulatory 10 CFR Part 61, Subpart Generic Environmental Environmental Nuclear Facilities," NUREG-0586, Regulatory Research, Washington, D.C., 1988 Subpart D, "Licensing Requirements NUREG-0586, Requirements for Land Disposal of of Radioactive Waste - Technical Radioactive Technical Requirements Requirements for Land Disposal Facilities,"
Federal Regulations.
Code of Federal
26. ASME NQA-1-2000, Assurance Requirements NQA-I-2000, "Quality Assurance Requirements for Nuclear Nuclear Facility Applications," American Society of Mechanical Mechanical Engineers, New York, NY, 2001.
27. 49 CFR Parts 100-177, "Research and Special Programs Administration, Department of Transportation," Code of Federal Regulations.
28. Federal Occupational Occupational Safety Safety and Health Health Acts (OSHA) of 1973, Title 29 29 United States Code, Chapter Chapter 15, "Occupational Safety and Health."
"Occupational Safety
29. Nuclear Regulatory Regulatory Commission Commission (U.S.), "Consolidated "Consolidated NMSS NMSS Decommissioning Guidance Decommissioning Guidance - Characterization, Characterization, Survey, and Determination Determination of of Radiological Criteria," NUREG-1757, NUREG-1757, Volume Volume 2, Rev. 1, 2003.
30. Nuclear Regulatory Regulatory Commission Commission (U.S.), "Minimum Detectable Concentrations with Typical Concentrations Radiation Survey Instruments Typical Radiation Instruments for Various Contaminants and Field Conditions," NUREG/CR-1507, Contaminants NUREG/CR-1507, Final, 1997, Washington, D.C.
31. Regulatory Guide 1.187, "Guidance for Implementation Implementation of 10 CFR 50.59, Domestic Licensing of Production and Utilization Facilities - Changes, Tests and Experiments,"
Experiments," U.S. Nuclear Regulatory Commission, Washington, D.C.,
Nuclear Regulatory November 2000.
32. NUREG-1748, "Environmental "Environmental Review GuidanceGuidance for Licensing Actions Associated Associated with NMSS Programs," U.S. Nuclear Nuclear Regulatory Regulatory Commission, August August 2003.
33. "National Census of Fatal Fatal Occupational Occupational Injuries Injuries in 2007," Bureau of Labor Labor Statistics, United States Department Department of Labor.
34. RESRAD-BUILD RESRAD-BUILD code, version 3.0, version 3.0" Argonne Argonne National Laboratory, Environmental Assessment Division Environmental Assessment Division
Worcester Polytechnic Worcester Polytechnic Institute Institute Document W19-1579-003, W19-1579-003, Rev. 1 Reactor ReactorDecommissioning Plan DecommissioningPlan A, Page Appendix A, Page1 of 2
APPENDIX A LETTER OF FINANCIAL LETTER FINANCIAL COMMITMENT COMMITMENT
Worcester Worcester Polytechnic Polytechnic Institute Institute Document W19-1579-003, W19-1579-003, Rev. 1 Reactor ReactorDecommissioning DecommissioningPlan Plan Appendix A, ~ Page Page2 of 2
100 Institute Road Worcester, MA 508-831-5288, Fax MA 01609-2280, USA 508-831-5064 Fax 508-831-5064 I
www.wpi.edu www.wpi.edu of the Executive Office of Executive Vice~dent Vice President March 25, 2009 March U. S. Nuclear Regulatory U. Regulatory Commission, Commission, I,I, Jeffrey Jeffrey S.S. Solomon, Executive Executive Vice President and Treasurer Treasurer of Worcester Worcester Polytechnic Polytechnic Institute (WPI),
which is is located located at 100 100 Institute Institute Road, Road, Worcester, MAMA 01609-2280. This letter is being provided provided to commitment to fund the radiological assure WPI's financial commitment radiological decommissioning decommissioning of the Leslie C. Wilbur Leslie C. Wilbur Nuclear Reactor Facility that is described Nuclear in the Decommissioning described in Decommissioning Plan to which this letter is attached. attached.
As documented documented in WPl's Decommissioning Plan, the radiological decommissioning WPI's Decommissioning decommissioning cost, including including a 25%
2S%
contingency, is estimated to be $2,600,000. These funds are available available and will be obtained obtained from WPI's WPI's unrestricted capital projectproject funds. As Executive Treasurer of WPI, IIcommit to Executive Vice President and Treasurer spending spending these funds to accomplish accomplish the decommissioning.
decommissioning.
As Executive Vice President and and Treasurer Treasurer of WPI, I have the authority to commit and spend spend these funds decommissioning of the Leslie C.
for the decommissioning C. Wilbur Nuclear Nuclear Reactor Facility. II certify the statementsstatements made in this letter are true and made freely under penalty penalty of perjury.
Sinu rely, sr"U~YA(l Jeff.rey Jeffrey ~. Solomon Solomon Executive Executive Vice President and Vice President and Treasurer Treasurer Worcester Worcester Polytechnic Polytechnic Institute
..:. ,. ~.: .. \' .. ~.
Worcester Polytechnic Institute Worcester Polytechnic Institute Document W19-1579-003, Rev. 1 Document W19-1579-003, Reactor Decommissioning Reactor Decommissioning Plan Plan B, Page Appendix B, Page 1 of 14 14
REVISED REVISED TECHNICAL APPENDIXB APPENDIX TECHNICAL SPECIFICATIONS B
DECOMMISSIONING SPECIFICATIONS FOR DECOMMISSIONING (Edited from the 9-2-08 Possession Possession Only License Amendment)
Worcester Polytechnic Worcester Institute PolytechnicInstitute Document W19-1579-003, W19-1579-003, Rev. 1 Reactor ReactorDecommissioning Plan DecommissioningPlan Appendix B, B, Page Page22 of 14 14 APPENDIX A TO LICENSE NO. R-61 TECHNICAL TECHNICAL SPECIFICATIONS SPECIFICATIONS FOR THE
WORCESTER POLYTECHNIC INSTITUTE WORCESTER POLYTECHNIC INSTITUTE REACTOR REACTOR DOCKET DOCKET NO. 50-134 50-134
Worcester Worcester Polytechnic Institute PolytechnicInstitute Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Reactor DecommissioningPlan Plan Appendix B, B, Page Page3 of 14 14
TABLE OF CONTENTSCONTENTS Page 1.0 DEFINITIONS .......................................................................... 1 DEFINITIONS .............................................................................
SAFETY LIMITS AND OPERATING 2.0 SAFETY OPERATING RESTRICTIONS RESTRICTIONS .....................
..................... 3 Safety Limits ...............................................................................
2.1 Safety ............................................................................. 3 SURVEILLANCE REQUIREMENTS 3.0 SURVEILLANCE .............................................. .4 REQUIREMENTS ............................................. 4 3.1 Frequency of Surveillance Surveillance ..........................................................
............................................................. .44 3.2 Action to be Taken ....................................................................
........................................................................ 4 Radiation Detection 3.3 Radiation ...................................................................... 4 Detection ......................................................................
4.0 SITE AND DESIGN FEATURES FEATURES .................................................
.................................................... 5
44.1
.1 4.2 4.3 S ite .............................................................................................
Site ............................................................................................. 5 Restricted Area and Exclusion Area Restricted Reactor Reactor Building Building and Ventilation
................................................. 5 Area .................................................
......................................... 5 Ventilation System .........................................
4.4 Reactor ............................................................................. 5 Reactor Core ................................................................................
5. ADMINISTRATIVE ADMINISTRATIVE AND PROCEDURAL PROCEDURAL REQUIREMENTSREQUIREMENTS .............. ............. 6 5.1 Facility Administrator ...............................................................
.................................................................. 6 5.2 Radiation, Health, and Safeguards ................................. 6 Safeguards Committee .................................
5.3 Radiological Safety Officer .......................................................... 6 Officer .............................................................
............................................................................. 6 Protection .............................................................................
5.4 Fire Protection Procedu res ..................................................................................
5.5 Procedures .................................................................................. 6
.................................................................... 7 5.6 Operating Records ........................................................................
.................................................................................... 7 5.7 Reports .......................................................................................
5.8 Annual Operating ........................................................ 8 Operating Reports ............................................................
Storage ................................................................................ 8 5.9 Fuel Storage .............................................................................
Worcester Polytechnic Institute Worcester Polytechnic Institute Document W19-1579-003, Rev. 1 Document W19-1579-003, Reactor Decommissioning Reactor Decommissioning PlanPlan Appendix B, B, Page Page 44 of 14 14
The actual values of dimensions, measurements, and other numerical values differ from values given in these specifications and manufacturing manufacturing tolerances, or normal accuracy of instrumentation.
accuracy instrumentation.
values may specifications to the extent of normal construction construction 1.0 DEFINITIONS DEFINITIONS Cold, Clean. CFitical Cold, Clean, Critical Condition: Since xenon and samaFium Condition: Sincc samarium cffects aFC negligible for effects are foF this FeactoF r in its normal
-actor nOFmal operations, opcFations, the term teFm cold, clean, lean, cFitical critical shall refer FefeF to the thc condition of the rcactor-condition FcactoF co Fe when core whcn it is at the nOFmal normal ambicnt ambient watcF tempcFatuFc of water temperature of 7-0 70 to 75'F 75°F and free fFee of experiments that could affect reactivity-.
of any expeFiments Fe activity.
Critical Reactor OpeFation:
CFitical ReactoF Operation:! CFiticalFeactoF Critical reactor opeFation operation shall refer FefeF to any situation situation when moire mOFe than 12 fuel elements elements arc aFe loaded in thethe core COFe and any eentroel contFol blade blade is withdrawn more
'.vithdFa'l/n mOFe than 6 in.
Experimenti:
ExpeFiment: An expeFiment experiment shall mean any apparatus, appaFatus, device, device, OFor material mateFial installed installed in the core COFe orineter-nal OF in extcFnal experimental expeFimental facilities thatthat is not a normal nOFmal part paFt of of thos-e those facilities ..
Movable Exper*iment:
Movable or manipulated OF ExpeFiment: A movable expe.riment ipulated while while the reacter Operable: An instrument Operable:
expeFiment is one that may FeactoF is critical.
operational once it is energized.
will be operational cFitical.
instrument or channel is operable energized.
operable when may be inserted, when the instrument inseFted, removed, Femoved, instrument or channel channel Operational: An instrument or channel Operational: channel is operational operational when that instrument instrument or or channel is installed, energized, channel energized, and in all other other respects performing performing the monitoring monitoring and safety functions for which it was intended.
Reactor Op~er-ation:
ReaetoF OpeFation: .Reactor operation shall be any condition ReactoF opeFation condition wherein wheFein either-eitheF the reactor key is inserted FeaetoF inseFted into the console console lock or OF the reactor-FeactoF is not in a shutdown shutdown eenditien-.
condition.
Reactor ReactoF Safety System: The reactor Safety System: FeactoF safety safety system is that combination control combination of contFol channels associated circuitry channels and assciated CiFcuitFY that forms foFms the automatic automatic protective pFotective system system fort foF the ireactor or-FeactoF OF provides pFovides infor-mation infoFmation that requie manal protective FequiFes manual pFotective action action to-be to be initiated.
Reactor ReactoF Scram:
SCFam: Reactor ReactoF scr-am SCFam shall be the rapid Fapid insertion inseFtion of of the three thFee control contFol blades into the COFe by eitheF of the following methods:
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(1)
(1) Relay (slo Relay interruption of Interruption (2) Electronic
..v) scram: Reaetor (slow).s.ram:
the relay scram circuits whieh of this current relay scram React. r relay CUffent shall de energize Electronic (fast) scram: scram: -Reactor scram (slow scram) shall be instigated which control current CUffent inputs for the energize the scramn Reactor electronic electronic scram scram magnes magnets.
instigated by the trip amplifir amplifier.
scram (fast scram) shall be caused by caused by fuy the applncation application of suincient sufficient negative bias negative 19ias in the tne trip amplifier ampiiiier to terminate ter-minate current CUffent to the scram scram magnets.
magnets.
Readily Available on Call: Readily available on call shall mean Readily available mean an individual on on duty within a reasonable reasonable driving time (1/2 hr) from the reactor (112 hr) reactor building, that can be contacted contacted to fulfill duties as specified specified in the implementing implementing plans and procedures.
Reportable Occurrence: A reportable Reportable Occurrence: occurrence is any of the following conditions:
reportable occurrence (1) a safety system system setting less conservative conservative than the limiting setting established established in the Technical Technical Specifications; (2) operation operation in violation of a limiting condition for operation established in the Technical Technical Specifications;
(3) a safety safety system malfunction incapable performing QA4)
(4) release release of system component malfunction its intended intended of fission products from malfunction or other component malfunction that during operation could, or threatens incapable of performing safety functions; fFom a failed fuel element; component or system threatens to, make the safety system element; (5) uncontrolled or unplanned release of radioactive an uncontrolled radioactive material from the the restricted restricted area of the facility; (6) uncontrolled or unplanned release an uncontrolled release of radioactive radioactive material material that results in concentrations of radioactive concentrations radioactive materials within the restricted restricted area in excess of the limits specified specified in Appendix B, Table 1 of 10 CFR Part 20;
-- ~11 1 1 1 (7) an uncontroud uncontrolled or unanuticipatca unanticipated enange change in in reactivity reactivity in in excess excess of 0.5% Ak/k; (8) conditions conditions arising from natural natural or man-made man-made events that affect or threaten to affect affect the safe operation operation of the facility; and (9) inadequacy in an observed inadequacy in the implementation administrative or implementation of administrative or procedural procedural controls such that the inadequacy inadequacy causes or threatens threatens to cause the existence existence or development of an unsafe condition in connection condition connection with the operation operation ofof the facility.
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Shutdown Condition:
ShutdoYfn reato1r shall bc The I'eactol' regulating blade I'egulating be deemed than 12 fuel clements deemed to be in the shutdown condition if no contl'ol blade is withdl'awn withdrawn from from its fully insel'ted insert Ad position OF gr-id plate.
elements loaded on the gl'id control OF or if the o
Fe al'e there are less
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2.0 2.1 SAFETY LIMITS AND OPERATING RESTRICTIONS Safety Limits RESTRICTIONS Radiation Alarms: Upon indication of radiation levels in excess of 50 mrems/hr mrems/hr fiW (20 mrem./hr fur mrems/hr for fuel storage) area monitors shall actuate audible evacuation evacuation alarms in the reactor room and in the second and third floor areas above the reactor pool.
Radiation Levels: The maximum radiation radiation levels 1 m above the pool surface and at at the surface surface of the concrete shield, when the beam port and thermal column are closed, shall be less than 50 mrems/hr.
Water Level: The minimu.m minimum depth of of water above the top of the end. box. box of the..
the fuel clements elements in the rcaetor reactor pool shall be 10 10 ft. When
',Xlhen fuel is not in the pool, t~he-ae pool, the water level shall be maintained maintained to keep radiation radiation levels as low as reasonably reasonably achievablc achievable (ALAR-A).
...Lf...Ru.A...). The pool (i\ pool water level detector detector and alarm alarm will
'llill be operational, with the
alarm set point being a waterF level level dctcctor operator detector and alarm operator present is present in
'.vater drop of alarm may be by the facility.
faeility.
of less than or equal to 1 foot.
by passed passed provided provided a liecnscd fuot. The pool licensed senior pool water water senior r-eaetor-reactor Water Purity: Corrective action shall be taken promptly if the fullowing limits fur the pool watc-r \vater a-re are not not met.
(1)
(1) pH4 pH less than 8.0 8.0 and greater greater than 6.0 6.0 (2) resistivity resistivity greater-greater than 5 x" 1O*-ehm-em 10-i} ohm cm (3) pool 4 -u+ihnl pool water-water activity activity less than 10,510-i} uCilml W~ater-
'Hater Tcmierature:
Temperature: The The maximum maximum bulk bulk water-water temperature temperature of of the reaetor-reactor pool pool a a shall be 110'F 110 F and the minimum minimum shallshall be 40*F, 40 F, when fuelfuel is in the pool.
pool.
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3.0 SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS 3.1 Frequency of Surveillance Frequency Quarterly: monitoring systems and the pool Quarterly: The area radiation monitoring .wit.h pool water level wateF level s'.viteh shall be checked ensured to be operational checked and ensured operational quarterly.
Semiannually:. At Semiannually: ..'\t least during possession of least semiannually, dUFing of the facility, a reaetor FeaetoF inspection inspection shall be performed eonsisting peFfoFmed consisting of (1) Pool wateF pH shall be measuFed and conductivity and pH devices shall be ealibrate4-ealibFated.
3.2 Action to be TakenTaken If maintenance maintenance or recalibration required for any of the items, it shall be recalibration is required be performed instrument shall be rechecked performed and the instrument rechecked before being placed back in in service.
serVlCe.
3.3 Radiation Detection Radiation Detection Area Monitors: Area radiation sensors Area gamma radiation in the sensors capable of detecting gamma range of 0.1 to 100 mrems/hr mrems/hr shall be installed near the beam beam port, de demineralizer, mineralizer, thermal column door, fuel storage aFea, and less than 1 m above the core pool stoFage area, pool surface, until these items have been removed surface, indication removed or decontaminated. Upon indication of radiation levels in excess of 50 mrems/hr (20 mFems/hF mrem./hr for storage) these fOF fuel stoFage) monitors shall actuate audibleaudible alarms in the reactor room and in the second second and third floor areas above the reactor pool. Area monitors monitors shall be calibrated calibrated on a semi-annual semi-annual basis.
Portable Portable area monitors capable capable of detecting radiation in the range of 0.10 to detecting gamma radiation
50 mrems/hr mrems/hr may temporarily temporarily replace alarms are operational.
required alarms that the required fixed operational.
area area monitors described above provided provided
Worcester Polytechnic Institute Worcester Polytechnic Institute Document Document W19-1579-003, W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Appendix B, Appendix B, Page Page9 of 14 14
Portable Portable Monitors: During fuel handling or other operations involving involving sources sources of radiation, operable portable available to the reactor operator operations involving involving or potentially instruments shall be readily portable survey instruments operator for measuring measuring beta-gamma exposure rates in the beta-gamma exposure range 1.0 mrems/hr to 50 rems/hr, and fast plus th..mal thermal neutron neutron dose rates from...
from.
0.04 to 1,000 1,000 mrems/hr.
mrcmslhr. One or more portable survey survey instruments instruments for measuring beta-gamma exposure rates in the range 10 mrems/hr to 50 rems/hr will be kept beta-gamma exposure kept available to the reactor staff in an external external location (normally the security office) to facilitate facilitate obtaining radiation radiation readings if a reactor radiation alarm should be activated.
Worcester Worcester Polytechnic Polytechnic Institute Institute Document W19-1579-003, W19-1579-003, Rev. 1 Reactor ReactorDecommissioning DecommissioningPlanPlan Appendix B,B, Page Page 10 of of 14 14
4.0 4.1 SITE AND DESIGN Site DESIGN FEATURES FEATURES associated equipment The reactor and associated equipment is housed in the Washburn Laboratories Washburn Laboratories located between between West Street Street and Boynton Worcester Boynton Street on the campus of Worcester Polytechnic Institute in Worcester, Massachusetts.
Massachusetts.
4.2 Restricted Restricted Area Area and Exclusion Exclusion Area Area The reactor reactor room shall constitute constitute a restricted area as defined in 10 CFR Part 20 and shall be controlled controlled by partitions and normally normally locked locked doors. In addition, two small areas, one each each on the second second and third floors of Washburn Washburn Laboratories, Laboratories, directly above the reactor reactor control drives, shall become restricted restricted areas whenever whenever the radiation levels in any of the rooms exceed those specified in 10 CFR 20.1301. 20.1301. The exclusion areas, as defined defined in 10 CFR Part 100, shall consist of the reactor reactor room and the areas above the reactor.
4.3 Reactor Building and Ventilation Ventilation System The reactor reactor shall be housed in a closed room that is designed designed to restrict leakage.
The ventilation ventilation system system shall provide at least two changes changes of air per hour in the
reactor reactor room whenever 4.4 whenever the reactor Reactor Core Fuel Elements:
reactor is operating.
Standard fuel elements Elements: Standard elements shall be flat plate type consisting eonsisting of of uranium aluminum alley alloy elad with v:ith aluminum.
aluminum. The width and and depth of cach each fuel fuel el*ment shall be 38 in. x 8 element 3 in. Ea.h element shall Each element shall have an an a-tiv-active length ofof 24 in.
There shall be a maximum Th*rc shall maximum of of 10 g of of U 285 each 235 in ca. h fuel plate and not more than 170 170 g of of U 235 285 in any fuel element. TheThe fuel shall be cnriched enriched to less than 200%
20% U 235.
285.
Standard fuel elements Standard elements have 18 18 fuel plates, plates, cach each plate 1.52mm 1.52mm thiek thick with a clad elad thickness of of 0.38 0.88 1 mm on caeh each side. NoNo fuel elements elements may be installed installed in the core.
core.
Worcester Polytechnic Institute Worcester Polytechnic Institute Document W19-1579-003, Document W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Appendix B, Page Page 11 of 14
5.0 ADMINISTRATIVE AND PROCEDURAL ADMINISTRATIVE PROCEDURAL REQUIREMENTS REQUIREMENTS 5.1 Administrator Facility Administrator The Director of the Nuclear Nuclear Reactor Reactor Facilities shall have have full responsibility for for maintaining maintaining the facility in a safe configuration.
configuration. The Director shall report to the Provost and shall be responsible to the Radiation, Health, and Safeguards Safeguards Committee for conformance conformance to the facility license provisions and all local and NRC safety regulations. The Director also shall be responsible for proper maintenance maintenance of of such records records and operating operating practices as the Committee may deem necessary for the safe storage of the facility.
5.2 Radiation, Health, and Safeguards Safeguards Committee Committee A Radiation, Health, and Safeguards Safeguards Committee Committee (RHSC) shall review, approve approve and document all proposed modifications proposed modifications affecting reactor safety safety and procedures, committee also shall conduct, at least quarterly, pursuant to 10 CFR 50.59. This committee reviews of operations, operations, equipment performance, records, and procedures. The equipment performance,
Committee shall establish establish written procedures regarding written procedures regarding review review methods, quorums, and subcommittees, and it shall maintain written records of its activities. The members members of the Committee shall be appointed by the Provost of Worcester Worcester Polytechnic Polytechnic Institute (WPI) and a majority shall be WPI faculty members.
5.3 Radiological Officer Radiological Safety Officer A Radiological Radiological Safety Officer Officer shall be appointed to serve on the Radiation, Health, and Safeguards Safeguards Committee and to review and approve all proposed procedures fl:ftd proposed procedures a-a e.perime*t concerning radiological experiments concerning radiological safety. The Radiological Radiological Safety Officer shall advise advise the Director Director of the Nuclear Nuclear Reactor Facilities of rules, regulations, and procedures relating to radiological procedures radiological safety and shall routinely conduct radiation surveys.
5.4 Protection Fire Protection The licensee shall provide provide heat or ionization-type ionization-type smoke smoke detectors, which will alarm when there is a fire in the reactor reactor room. At least least two such detectors shall be operable operable at all times.
Worcester Polytechnic Worcester Institute PolytechnicInstitute Document W19-1579-003, Document W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Appendix B, Page Page 12 of 14 14
5.5 Procedures Procedures Detailed Detailed written procedures operations operations of radiation radiation of*the protection, procedures shall be provided the reae*te, FeactoF, operation exper*iments, expeFiments, and provided for all normal decommissioning operation of supporting supporting facilities, maintenance emergency emergency plans maintenance operations, and operations. These procedures procedures shall be approved by the Radiation, Health, and Safeguards Safeguards Committee before they are implemented.
before Temporary procedures that do not change Temporary procedures change the intent of the initial approval approval procedures procedures may be authorized by two members of the facility staff at least one of of whom shall be a licensed senior operator. Such proceduresprocedures shall be subsequently reviewed reviewed by the Radiation, Health, and SafeguardsSafeguards Committee, 5.6 Operating Records Operating Records In addition to records required required elsewhere elsewhere in the license application, the following records records shall be generated generated and kept of:of:
(1) maximum release or discharge; (2) maintcnancc radioactivity released or discharged maximum radioactivity the effective control of the licensee as measured maintenance oper-ations discharged into the air or water beyond measured at or before the point of such opeFations involving substitution substitution er replaecmcnt of OF Feplacement beyond such of r-eaeter FeactoF
.u...
equipment a.t OF or
. components;
.mp .nents; and (3) tests and measurements measurements performed performed pursuant pursuant to the Technical Specifications.
Old records pertaining operation of the reactor, including power levels, pertaining to operation emergency emergency shutdowns, inadvertent inadvertent scrams, experiments, and in core irradiations, shall be kept for purposes purposes of decommissioning.
5.7 Reports Reports In addition to reports reports otherwise otherwise required required under this license and applicable regulations-regulations-(1) The licensee licensee shall inform the Commission of any incident or condition condition relating to the safe storage of the facility that prevented prevented or could have prevented prevented a safety system safety system from performing performing its safety function as described described in the Technical Technical
Specifications.
Specifications. For each such occurrence, occurrence, WPI shall promptly promptly notify, by telephone or telegraph, the Administrator of the appropriate NRC Regional Appendix U of 10 CFR Part 20 and shall submit within Regional Office Office Listed in within 10 days a report in writing in
Worcester Polytechnic Institute Worcester Polytechnic Institute Document W19-1579-003, Document W19-1579-003, Rev. 1 Reactor Decommissioning Reactor Decommissioning Plan Plan Appendix B, Page Page 13 of 14 14
to the Director, Division of Waste Management (DWME.P), with a copy to the Regional (2) The licensee any observed Regional Office.
Office.
Environmental Protection Management and Environmental Protection licensee shall report to the Director, DWMEP, in writing within 30 days, observed occurrence occurrence of substantial variance variance of conditions conditions from performance performance specifications contained in the Safety Analysis Report or the Technical specifications contained Technical Specifications.
(3) The licensee licensee shall report to the Director, DWMEP, in writing within 30 days, any occurrence occurrence of significant significant changes changes in transient or accident accident analysis as described described in the SAR.
5.8 Annual Annual Operating Reports Operating Reports A report covering covering the previous previous year shall be submitted submitted to the Administrator of the appropriate March31 of each year. It shall include:
Regional Office not later than March31 (1) Operations Summary: a summary Operations summary of issues having safety significance
occurring occurring during the reporting period, including:
(a) changes in facility design (b) performance design characteristics (e.g., equipment performance characteristics (c) changes changes in operating procedures equipment and fuel performance) performance) procedures that relate to the safety of facility operations (d) any abnormal abnormal results of surveillance inspections required surveillance tests and inspections required byby Technical Specifications these Technical Specifications (e) a brief summary of those changes, tests, and experiments experiments that did notnot authorization from the Commission require authorization Commission pursuant to 10 CFR 50.59 50.59 (d)(2)
(f) changes in the plant staff serving in the positions positions of Reactor Reactor Facility Director, SRO, RSO, ARSO, or Radiation, Health, and Safety Committee members; Maintenance: a discussion of corrective maintenance (2) Maintenance: maintenance (excluding preventative maintenance) performed performed during the reporting reporting period period on safety safety related systems and components; (3)
(3) Changes, Tests, and Experiments:
Experiments: a brief description description and a summary of the evaluation for those changes, tests, and experiments safety evaluation experiments that were carried out carried out without prior prior Commission approval, pursuant to the requirements requirements of 10 CFR 50.59 50.59
(d)(2); and
Worcester Polytechnic Institute Worcester Polytechnic Institute Document W19-1579-003, Rev. 1 Document W19-1579-003, Reactor Decommissioning Reactor Decommissioning PlanPlan Appendix B, Appendix B, Page Page 14 of 14 14
(4) Radioactive effluents released 5.9 released from the plant.
Fuel Storage statement of the quantities of radioactive Radioactive Effluents Releases: a statement radioactive Two fuel storage racks arc loeated raeks are lecatcd on opposite sides of of the rcacter-reactor pool. Eaeh Eaeh rack rack shall be designed to eontain not more than 18 fuel elements. When the rcactor reactor contains contains a critical critieal mass, all additional additional fuel elements elements not in the corc core shall be locked loekcd in plaec place cxccpt except as authorized authorized by the licensed liecnscd senior operator operator- in charge.
ehargc.
A l ... fuel element shall not be stored storcd outside ofof the reactor rcaeter pool pool unless it prod~uees produces radiation radiation dose levels of mrcems/hr- at the storage container of less than 100 mrems/hr container surfaee.
surface.
Storage Storage containcrs containers of fuel elements shall be lockcd locked elosed closed when unattended.
unattcndcd All fuel element transfers shall be conducted
All conducted by a staff of not less thanl than thc three pcrccns, w-hich persons, which shall includc include a liconsed licensed senior senior opcr-ator operator in chargc charge and and a RSO. StafStaff members members will eontinuously menitor
'Nill continuously monitor the operations operations ucn3prpriate using appropriate radiation radiation monitoring monitoring and corc core nuclcar nuclear instrumentation.
instrumentation.

ML092880231

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10.0 REFERENCES

1.1 INTRODUCTION

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1.2 BACKGROUND

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4.1 DESCRIPTION

4.2 BACKGROUND

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10.0 REFERENCES

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