ML100610445

University of Florida Training Reactor (Uftr) License Renewal

ML100610445
Person / Time
Site:	05000083
Issue date:	02/26/2010
From:	Haghighat A Univ of Florida
To:	Duane Hardesty Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1586
Download: ML100610445 (72)

Text

U FI UNIVERSITY FLORIDA of College of Engineering 202 Nuclear Science Bldg.

Department of Nuclear & Radiological Engineering PO Box 118300 University of Florida Training Reactor Gainesville, FL 32611-8300 352-392-1401 x306 352-392-3380 Fax haghighat@ufl.edu February 26, 2010 Document Control Desk U.S, Nuclear Regulatory Commission Washington, DC 20555 Attn: Mr. Duane Hardesty

Subject:

University of Florida Training Reactor (UFTR) License Renewal (TAC NO. ME 1586),

DOCKET NO. 50-83 Enclosed document and associated attachments include our responses to the USNRC's RAIs on our application for renewal of Facility Operating License No. R-56 for the University of Florida Training Reactor (UFTR), which was received on February 3, 2010.

If you need further information, please do not hesitate to contact me at haghighatgufl.edu or (352) 392-1401 x306.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on Feb. 26, 2010

• :oLisa L. Purvis a Commission # DD608673 4,. Expires November 3, 2010 Bonded TroyFain - Insuannce.

Inc. 800-385-7019

~A Alireza Haghighat, PhD FP&L Endowed Chair Professor Director of UFTR Cc Jack Donohue, NRC Gabriel Ghita, UF David Hintenlang, Interim Chair Brian Shea, UFTR Manager Glenn Sjoden, RSRS Chair UFTR - NRC file The FoundationforThe GatorNation An Equal Opportunity Institution

Responses to NRC's RAIs Regarding License Renewal for the UFTR This document includes our responses to the USNRC's RAIs on our applicationfor renewal of Facility OperatingLicense No. R-56for the University of FloridaTraining Reactor (UFTR), which was received on February3, 2010.

Q1. Safety Analysis Report (SAR), Section 1.6, Compliance with the Nuclear Waste Policy Act of 1982. Pleaseprovide the contract number ofyour agreement with the Departmentof Energyfor return of spentfuel and/orhigh level waste.

Resl. We have a Subcontract, No. 00074551, with Battle Energy Alliance, LLC.

This Subcontractis issued under Prime ContractNo. DE-ACO7-051D14517 between the DepartmentEnergy and BEA. For further information see Attachment

1. 1.

Q2. SAR, Section 2.3.1.2.2, Tornadoes. The probabilityof a tornadostriking the University of FloridaTrainingReactor (UFTR) site is given as 1.9 x 10-3 per year.

Please explain how this value was determined.

Res2. The probabilityis evaluated using Eq. 2.1 (SAR Section 2.3.1) based on the historicalweather data from 1950 to 2000. The evaluated probabilityshould be considered as a conservative estimation, not an exact value. Tornadoes remain very rare on the UFTR site. It's highly unlikely that Tornadoes could cause serious damage to the reactorbuilding, and even more unlikely to affect the reactoritself.

Q3. SAR, Section 5.3, Secondary CoolantSystem. In your response to Requestfor Additional Information (RAI) 2.b. dated November 26, 2008, you use the Title 10 Code of FederalRegulations (10 CFR) Part20, Appendix B, Table 3 value of 5 E-4 IuCi/ml as the monthly average concentration release limit. However, this value is applicable to release to the sanitarysewer while it appears that dischargefrom the secondary side of the heat exchanger goes to the storm sewer. Pleaseexplain.

Res3. We have corrected the limit and performed the necessary changes to the previous submittal. Attachment #2 demonstrates that for a realisticlevel of contamination and loss rate, activation is well below the limitation of the 10 CFR Part 20 App. B.

Q4. SAR, Section 7.2.3.4.2, Secondary CoolantSystem. The SAR indicatesthat scram upon loss of secondary coolantflow when using city water is immediate. However, Technical Specification (TS) 5.6.2 discusses a 10 second delay uponfirst reaching 1 kW.

Please clarify.

Res4. The City Water System will no longerbe used as a means of secondary reactorcooling. The system will remain a source of makeup water to various systems at the UFTR. To prevent city water from being used for secondary cooling, the piping will be isolated using two manual valves on either side of the electrically operated valve (used to initiate city water flow), which will have its

power permanently disconnected. The scram logic will remain in Well Water Mode and be maintainedas such via existing procedures. The reason for this measure is discussed in the revised UFTR Technical Specifications.

Q5. SAR, Section 9, Auxiliary Systems. The RAI 9-3 response, dated November 26, 2008, stated that the area monitor system alarm set point is 10 mR/hr. However, TS Table 3-4 states monitor set point is 25 mR/hr. Please state ifyou are meeting compliance with 10 CFR 70.24 using 70.24 (a)(1) or (a)(2) andprovide details as to how you are meeting the regulation.

Res5. We believe we meet the requirements of 10 CFR 70.24 a(2) as discussed below:

The three arearadiationmonitors (ARMs) are located in the reactorcell in strategiclocations for providing full monitoring of the reactorcell.

The size of the reactorcell is 60 feet long, 30 feet wide, and 29 feet high. This means that the maximum diagonaldistance of the cell is - 73 feet; thereby, indicatingthat all the monitors are within the 120 feet limit. The three ARMs collectively cover all areas surroundingthe reactor.UFTR has been operating with a setpoint of 10 mrem/hr. Note that 10 CFR 70.24 a(2) requires the setpoint should range from 5 to 20 mrem/hr Tech Spec will be updated. If the radiationlevel were to reach 300 rem/hr within 1 foot of the reactor,the radiationlevel at 73 feet away, 1

considering(-) dispersion, is estimated by:

Dose = 3 0 0 rem 4r _2 =5 6 mrem

-hr'4,z.* 73' hr This is conservatively higher than the upper setpoint of 20 mrem/hr; hence, the UFTR meets the requirementof 10 CFR 70.24 a(2).

Q6. In Appendix E of the UFTR responses to RAIs 11-1 and 11-2, dated November 6, 2008, the undiluted activity ofAr-41from the reactor at 100 kW is given as C = 8.147E-4 Ci/m3, the total stackflow ratefor Ar-41from the core vent and dilutionfan isf= 7.444 m3/s, and the dilutionfactor is DF = 0. 0152168. The resultingflow-dilutedrelease concentration at the top of the stack prior to atmospheric dischargeis Y/= C x DF =

1.24E-5 Ci/m3. In Section 11.1.1.1, Airborne Radiations Sources of the SAR, UFTR applied a stack dilutionfactor of 0.0281 (i.e., 1/35.6) and C = 6. 7E-4 Ci/m3forfull power operation to arrive at a stack concentrationprior to dischargeof Y/= C x DF =

1.88E-5 Ci/m 3. Section 11.1.1.1 of the UFTR SAR also provided the activity at the stack discharge as directly measured to be q/ = 2.48E-5 Ci/m3. What is the explanationfor the differences between these calculatedand measured values?

Res6. Since there are uncertaintiesin the flow rates of dilution fan and core vent, and the activation level of Ar-41, the dilution factor varies; consequently, the informationprovided in the SAR should be substitutedby more recent data.

Q7. Forthe calculationspresented in Table 9 of Appendix E of the UFTR responses to RAIs 11-1 and 11-2, datedNovember 6, 2008, our understandingis that the parameters for the Table 9 calculations are continuousAr-41 release rate of 9.228E-5 Ci/s, stability class A, standardterrain, effective release height of 12.3 m, wind speed at the point of discharge of 3.99 m/s, and the downstream receptorat 0 m on the plume centerline.

Using the input parameterswith EPI code 7.0, we calculatedthe Ar-41 activity concentrationsand radiationdoses as shown in Table ] below which show some inconsistency. Pleaseconfirm the use of the parameters above. If incorrect,please provide correct values. Please describe how a wind velocity of 3.99 m/s was obtained at the stack discharge.

Res7. We believe that the results shown in Table 9 are rathersimilar, and the observed relatively small differences should be attributedto the different methodologies employed in the two software used. Attachment 3 exlpains how the wind speed is determined.

Q8. SAR Section 11.2.2.1 Gaseous Waste Management and Table 11-4, indicatesthat the limit on operationsof 235 hour0.00272 days <br />0.0653 hours <br />3.885582e-4 weeks <br />8.94175e-5 months <br />s/month is intended to satisfy the 10 CFR 20.1302 dose limit of 50 mrem/yr. Provisionsin 10 CFR 20.11 01(d) require that a total effective dose equivalent to the maximally-exposed member of the public should not exceed 10 mrem/yr for purposes ofAs Low As Reasonably Achievable (ALARA); if this dose constraint is exceeded, the licensee shall report this to NRC and take appropriatecorrective action to ensure againstrecurrence.How does UFTR ensure compliance with the provisions of radiationprotection programs of 10 CFR 20.1101?

Res8. As far as the limit on the operationshour, we believe the number of hours of operationsis inappropriate,because several variablessuch as reactor operations(kw-hr), flow rate of core vent, flow rate of dilution fan, and environmentalconditions impact the release concentrationof Ar-41. Moreover, our reporteddata correspondingto highly conservative conditions,which are not realistic;e.g., we have consideredthe directionof flow directly toward the residentialarea (dorm), which is highly unrealistic.As discussed in the attachment#3, considering annual averagedconditions, the concentrationat the residentialreduces to a value significantly lower than the background that is not measurable. This result is in agreement with the measurements conducted by the University's radiationsafety office.

Further,we have provided results of calculationof the number of hours of operationsfor the maximum of amount of concentration,which occurs at the Weil Hall.According to these calculations,reactorcan operate at full power for -228 hours/month resulting in monthly averageddose of 50 mrem/hr, or -47 hr/month of operationsfor maintainingthe 10 mrem/hr limit for achieving ALARA. However, again, we believe it is not appropriateto put a limit on the number of hours of operations,rather,it is necessary to continuously monitor the amount of release radioactivity,and maintain the monthly averagedconcentrationsufficiently low so that we can meet the 10 mrem/hr limit for achieving the ALARA.

Q9. SAR Section 11.2.2.1, Gaseous Waste Management (p.11-2 3), it is indicatedthat if the activity level in the reactorvent dischargesystem exceeds 4000 cps, a monitor will

actuate a warning light and an audible alarm in the reactorcontrol room. The relationshipbetween this count rate alarm and the allowed activity discharge limit is unclear.

a) Explain the relationshipbetween the 4000 cps measurement by the stack monitoringsystem and the stack-diluted dischargeconcentration.Assuming 235 effective full-power hours of operationper month, would this maximum Ar-41 concentration and radiationdoses for members of the public be below 1.OOE-8 Ci/ml3 (Appendix B to 10 CFR Part20) and 50 mremlyr (10 CFR 20.1302)?

b) Is there a relationshipbetween Ar-41 activity and the 4000 cps measurement that ensures that the highest dose to the public is limited to 10 mrem/yr (10 CFR 20.1101)?

Res9. The limit on the count at the reactorvent dischargehas no relation with the Ar-41, because Ar-41 concentrationis monitored on a biannualbasis. The measured count rate during operationskeeps the operatorinformed of any significantchange in the radiationlevel on a relative basis. This count rate includes all sources of activity, and simply is a trending data for the reactor operator.

QlO. The EnvironmentalDosimetry resultsfor the UFTR (referencefacility annual reportfor 2005-2006, 2006-2007 and 2007-2008)fordosimeters 3, 4, 6, 8, 9, 10 and 11 document the same results in each of these years for allfour categoriesand dosimeters 5 and 12 only differ on one. In contrast, the reports ofprevious years indicate the max environmental result was in single-digit millirem, while these later reports document readings in the 100's of millirem with the stack at 1700+ mrem. Please validate the high level of agreementfor the readings in the annual reportsfor 2005-2006, 2006-2007 and 2007-2008 and explain the significant change in later reports.

Res10. By mistake a cumulative data was used; this information is corrected in all reports, and attachments#4, #5, and #6 provide the corrected annual reports for 2005-06, 2006-07, and 2007-08.

QJ 1. In a supplement to the applicationdated October 13, 2009, University of Florida (UF) indicatedthat the costfor decommissioning the UFTR was $2.7 million in 2009 dollars, with the cost being adjustedfor inflation using the ConsumerPrice Index (CPI)

(CPIforall urban consumers, US city average, all items (Base 1982)) and the Low Level Waste DisposalAdjustment Factor.In orderfor the NRC staff to complete its review of the UFTR decommissioning cost estimate, pleaseprovide the following additional information:

a) Documentation supportingthe basisfor the Waste BurialAdjustment Factor(FB) for the Adjusting Base from 1986 to 1982 as was documented in the October 13, 2009 supplement to the application.

b) The specific line items on Table II of the October 13, 2009 supplement to the application identifying the $118, 000 Radioactive Waste disposalcost.

Clarify whether a 25 percentcontingencyfactor is included in the updated 2009 decommissioning cost estimate provided in the October 13, 2009 supplement to the application.

Res 11. Since, we discovered errors in our previous decommission document, we are submitting attachment #7, which includes the details of the CPI and waste disposaladjustment and the full decommission report. Table II in this document lists the total waste management costs is $113,000, which is based on a price quote from radioactivewaste disposalcompany. The specific line items of the quote will be provided after further communication with the company.

The new estimateddecommission cost as of December 2009 is $3.28 million, including the 25% contingency overhead,as indicatedin Table II of the decommission report.

Q12. The July 18, 2002 application, and the October 13, 2009 supplement to the application, includes a statement of intent (SO1) as the method to provide decommissioningfunding assurancefor the UFTR as providedfor by 10 CFR 50.75(e)(1)(iv). Where UF intends to use a SOI, the NRC staff mustfind that the applicant "is a Federal,State, or local government licensee. "The applicationindicates that the applicant is a State government organizationand that the decommissioning funding obligationsof the applicant are backed by the State government. However, corroboratingdocumentation must also be provided. Further,the applicantmust provide documentation verifying that the signatorof the SO1 is authorizedto execute said document that binds the University. This document may be a governing body resolution, management directives, or otherform thatprovides an equivalent level of assurance.As the application does not provide all of the above information,please submit the following:

a) An updated SO1 which includes the current (2010 dollars) cost estimatefor decommissioning, a statement thatfunds for decommissioningwill be obtained when necessary, and the signator's oath or affirmation attestingto the information. (Refer to Section 16.4 ofAppendix A of NUREG-175 7, Vol. 3, " ConsolidatedNMSS Decommissioning Guidance.')

Res 12. We will submit a new commitment letter from our CFO to reflect on corrected cost of decommissioning of $3.2 M ratherthan $2.7 M. Corroborating documentation to the SOl is also being prepared.We will try to include these documents in a separate submittalas soon as possible.

Q13. Pleaseprovide an update to SAR Section 5 and other sections of the SAR as applicable with the description of the replacementprimarypiping and any changes to instrumentation types or sensing locations.

Res13. We will provide this document in a separate submittalby March 8, 2010.

Copy.of Subcontract, No. 00074551, for return of spent fuel

STANDARD RESEARCH Battelle Energy Alliance, LLC (BEA)

SUBCONTRACT NO. 00074551 2525 Fremont Avenue P. 0. Box 1625 Idaho Falls, ID 83415-3890 "REACTOR FUEL ASSISTANCE AND FUEL ELEMENTS" Subcontractor: Contractor's Procurement Representative University of Florida Office of Engineering Research Lynda Keller, 339 Wcil Hall Subcontract Administrator Gainesville, FL 32611 208-526-5597 To: Roslyn S. Heath 208-526-5780 PI: W. Vcntelson Lynda.Keller@inl.gov Period of Performance: Award Amount:

June 1, 2008 - $0.0 December 31, 2012 Introduction This is a standard research subcontract for unclassified research and development work, not related to nuclear, chemical, biological, or radioklgical weapons of mass destruction or the production of special nuclear material for use in weapons of mass destruction. This Subcontract is between Battelle Energy Alliance, LLC (BEA) (Contractor) and University of Florida (Subcontractor). The Subcontract is issued under Prime Contract No. DE-AC07-05ID014517 between the Contractor. and the United States'Department of Energy (DOE) for the management and operation of the Idaho National Laboratory (INL),

Agreement The patties agree to perform their respecti.ve obligations in accordance with the terms and.conditions of the Schedule, General Provisions and other documents attached or incorporatedby r.fcrcncc, whiciftogether constitute the entire Subcontract and supersedes all prior discussions, negotiations, representations, and agreements.

BATTELLE ENERGY ALLIANCE, LLC UNIVERSITY OF FLORIDA (riEA)

By: t.r-p(-. 1CA..- By:

Name: Lynda Keller Name: Roslyn SDect h Title:. Syb=00 AdWnistor Title: Assistant Director for Research Date: i. 1/ilg,*" Date:

I '1J [ V4

3atielle Energy Alliance, LLC Standard Rescarch Subcontract No. UUU745 I Pag 2 of 1.2 SCHEDULE OF ARTICLES

1. Statement of Work The Subcontractor shall furnish the following services, in accordance with the requirements, terms and conditions specified or referenced'in this Subcontract:

Provide for utilization of the rcactor owned by the Subcontractor in a program of education and training-of students in nuclear science and engineering, and for faculty and student research. The Subcontract provides for the:continued possession and use of Department of

-Energy (DOE.)-owned nuclear materials, including enriched uranium, in reactor fuel without incremental charge of use, bum-up, and reprocessing while used for research, education and training purposes.

The DOE-owned nuclear materials were originally provided to Subcontractor under Subcontract No. C88-101864-001, reissued as K97-176844-003, and again reissued as 00000071-002. The nuclear materials will now reside with this Subcontract No. 00074551.

The Subcontractor's Principal Investigator assigned to this work is W. Vernetson. The-Principal Investigator shall not be replaced or rcassigned without the advance written approval of the Contractor's Subcontract Administrator.

2. Reports and Data Requirements

a. Proarcss Reorts

1. Distribution of the DOE/NRC Form 741, Nuclear Material Transaction Report, shall -include JSG/IMM. Copies of DOE/NRC Forms 742, Material Balance Report, and 742C, Physical Inventory Listing, shall be sent to the Contractor point-of-contact for nuclear material management and accountability.

2. Annually, in conjunction withlsubmittal of the Material Balance Report and Physical Inventory Listing reports, the Subcontractor is required to submit information listed below so that the Contractor can mcct DOE requirements for annual reporting contained in DOE Order 5660. 1B, Management of Nuclear Materials. The Subcontractor isrequired to notify the Contractor of.the following-,

2.]. Fuel usage in grams Uranium 235 and number of fuel clcments.

2.2. Current inventory ofunirradiated fuel elements in storage.

-2.3. Current inventory of fluc elemcnts in core.

2.4. Current inventory of useable irradiated fuel elements outside of core.

2.5. Current inventory of spent fuel elements awaiting shipment.

2.6. Projected fuel needs for the next five years.

2.7. Current inventory of all other nuclear material items under Idaho Field Office (DOE-ID) assigncd.project identification number, i.e., those project numbers beginning with the character "I".

2.8. Current Subcontractor point-of-contact tbr nuclear material accountability.

Battelle Energy Alliance, LLC Standari Rcscurch Subcontacr No. 00074551 Page3of 12

b. Final Report:

The Subcontractor shall fumish within 6 months afitr the shipment of all remaining material under this Subcontract, a report indicating the amount ofrmaterial returned and whether additional material requests are planned.

3. Period of Performance The work described in the Statement of Work is cffcctivc Juno 1,2008, and shall be completed on or before December 31, 2012.

4. Reactor Fuel Special Provisions

a. Title to all special nuclear materials loaned to the Subcontractor under this Subcontract shall at all times be and remain the United States Government.

b. The Contractor will not charge theSubcontractor for materials (I) consumed in the operation of the facility until expiration of this Subcontract, and (2) not recovered in reprocessing subsequent to the ultimate return of the special nuclearmaturial.

c. As a Nuclcar Regulatory Commission (NRC) Licensee, the Subcontractor shall, in addition to complying with I0CFR 73.37 and 73.72, be responsible for performing (or contracting others to pcrtorrn) the actions necessary for compliance with the Order for Safeguards and Security Compensatory Measures on the Transportation of Spent Nuclear Fuel greater than 100 grams, as modificd by the NRC from time to time. If required, arrangcrmcns for anncd escorts arc tho responsibility of the Subcontractor.

d. If the Subcontractor desires to return material provided under this Subcontract, the Subcontractor shall submit a request to the Contractor, preferably within 18 months, but no later than 6 months, from the time which the.Subcontractor desires to return the materials to the DOE, indicating thecharacteristic and amount of material the Subcontractor desires to return. The Contractor will provide: requirements for documcntation and instrunctiona for returning the material. At the Contrautor's option, the Contractor will promvde a shipping container and provide funds directly to a Carrier, or under a Separate Purchase Order (subject to negotiated cost limitations),

the Contractor will reimburse the Subcontractor for commercial shipping container rental, use of a Canicr, and other costs for activities incident to the shipment of the material. Tl'he Subcontractor has no rsponsibility for receipt at a DOE facility, storftgc nor processing of such material. The Subcontractor's obligation is to return matcrial in the form defined, as affected by the activities listed above in Article 1.

e. Except as otherwise provided herein, the Subcontractor is responsible for and will pay the Contractor any charges imposed by the Contractor.for material delivered to the Subcontractor and not ultimately returned to the Contractor.

g. Notwithstanding any other provision of this Subcontract, the Contractor or the Government shall not be responsible for or have any obligation to the Subcontractor for decontamination or decommissioning (D&D) of any of the Subcontractor's facilities.

h. The Subcontractor is responsible for the management, accountability and control of DOE-owned nuclear material in its possession. Nuclear material supplied under this Subcontract by the DOE shall comply With the following requirements:

Battcllc Energy Allianm, LLC Standard Rcseach Subcontract No. 00074551 Page4 or 12 I. Nuclear material is accounted for with a 10-digit alphanumeric, budget and reporting project identification number, which is assigned and controlled by Idaho Operations (NE-[D). The Subcontractor is not allowed to make changes to this number.

2. The project identification number must be recorded in the Project Number field on the DOE/NRC Form 74 1,"Nuclear Material Transaction Report", involving any activity, e.g., receipts, removal and adjustments (Reference NUREG BR-0006, "Instructions for Completing Nuclear Material Transaction Reports");

and DOE/NRC Form 742C, "Physical Inventory Listing" (Reference NUREG BR-0007, "Instructions for the Preparation and Distribution of Material Status Reports").

I. In the event the terms and conditions of this Subcontract arc not in agreement with NRC rules and regulations, thu NRC requirements will take precedence.

5. Subcontract Administration

a. The Contractor's Subcontract Administrator for this Subcontract is Lynda Keller. The Subcontract Administrator is the only person authorized to make changes in the rcquirements of this Subcoutoact. or make modifications to this Subcontract, including changes or modifications to the Statement of Work and the Schedule. The Subcontractor shall direct all notices and requests for approval required by this Subcontract to the Subcontract Administrator.

Any notices and approvals required by this Subcontract from the Contractor to the Subcontractor shall be issued by the Subcontract Adninistrator.

b. The Contractor's Technical Reprcsentative for this Subcontract is D. Morrell. The Technical Representative is the person designated to monitor the Subcontract work and to interpret and clarify the-technical requiremaents of the Statement of Work. The Technical.

Representative, is not authorized to make changes to the work or modify this Subcontract.

c. The Contractor's Materials Management and Accountability rcpresentative for this Subcontract is M. Wilkinson. Progress reports as specified in Section 2.a. shall be provided to the representative according to:the timeliness established by DOE and NRC directives.

d. The Subcontractor's Subcontract Administrator for this Subcontract is R. Heath.

6. Supplier Performance Evaluation Systemn(SPES)

Contractor evaluates subcontractor performance in accordance with the SPES. The'Subcontractor shall be formally evaluated no less than quarterly as applicable, and upon completion of the work. A minimum score of 80 points out of 100 is required to maintain approved status. Information concerning the SPES is available for reiew at: httt:/llwww.inl.uo-v/procurement/forms.shtnL. Seleut INL Supplier Management Program.

7. Lower-tier Subcontractors Subcontractor shall not subcontract performance of any portion of the work being performed at the INL without the advanced written approval of Contractor, (excluding material doliverics). Lower-tier subcontracts and purchase orders must include provisionsto secure all rights and remedies of

Battelle Encrgy Allianu, LLC Standard Rcseardi Subcontract Ne. 00074551 Page 5 f 12 Contractor and the Government provided under this Subcontract, and must impose upon the lower-tier subcontractor all of the general duties and obligations required to fulfil! this Subcontract.

Subcontractor is responsible for the performance and oversight of all lower-tier subcontractors

8. Order of Precedence In the event of any inconsistency between provisions of this Subcontract, the inconsistency shall be resolved by giving precedence as follows: (a) Subcontract Change documents, if any, (b)

Subcontract, (c) Specifications or Statement of Work, (d) General Provisions,. and (e) other provisions of this Subcontract, whether incorporated by reference or otherwise. However, Subcontractor shall notify Contractor ptior to performing work-based on resolution of any inconsistency by he.order of precedence set forth hercin.

9. Applicable Documents The following.documents -reapplicable to Subcontrakt:

a. 10 CFR 73.37 and 73.72,

b. Order for Safeguards and Security Compensatory Measurements on the Transportation of Spent Nuclear Fuel.

c. DOE/NRC Form 741, Nuclear Material Transaction Report.

d, DOE-NRC form 742, Material Balance Report.

.c. DOE/NRC Form 742C, Physical inventory Listing.

E. NUREG BR-0006, Instructions for Completing Nuclear Material Transaction reports.

g. NUREG BR-0007, Instructions for the Preparation and Distribution of Material Status Reports.

h. DOE Order 5660.18, Management of Nuclear Materials.

Batelle nergy Alliance, LI.C.

Standard Research SubcomrctfNlti00074551 Page 6 of 12 GENERAL PROVISIONS CLAUSE 1 - PUBLICATIONS A. The Subcontractor shall closely Coordinate with the Contractor's 'Technical. Representative regarding any proposed scientific, technical or. professional publica'tion of the results 'f the work performcd or any data developed under this Subcontract, The Subcontractor shall provide the Contractor an opportunity to review any proposed manuscripts describing,: in whole or inpart, the results of thework performed or any data developed under,*his Subcontract at, least forty-fi&ve (45) days, prior to their submission for publication. The Contractor will review the proposed publication and provide comments. A response shall be provided to the Subcontractor within forty-five (45) days; otherwise, 4the iSubcontractor may assume that the Contractor has no comments. Subject to the requirements of Clause 9, the Subcontractor agrees to address aiiy concerns or issue- identified by the Contractor prior to submission for publication.

B. Subcontractor may acknowledge the Contractor and Govcrnment sponsorship of the work as appropriate.

CLAUSE2-NOTICES A. The Subcontractor shall immediately notify the Contractor's Subcontract Administrator lin writing of: (I) any action, including anyprocceding before an administrative agency, filed against the Subcontractor arising. out of the perfornance of this Subcontract; and (2) any claim against the Subcontractor, the cost and expense of which is allowable under the terms of this Subcontract.

B. .If, at any time during the performance of this Subcontract, the'Subcontractor becomes aware of any citcumstances which may jeopardize its performance ofall or any portion of the Subcontract, it shall immediately hotifý the Contractor's Subcontract Administrator in writing of such circumstances, and the Subcontractor shall take, whatevr !action is necessary to cure such dcfect within thc shortest possible time.

CLAUSE-3 -ASSIGNMENTS The Contractor may assign this Subcontract to the Government or its designee(s). Except as to assignment of*payment due, the Subcontractorý. shall haveý no right to assign or mortgage this Subcontract or, any part of it without the prior written approval of the Contractor's Subcontract Administrator, except for subcontracts already identified- in the Subcontractor's proposal.

CLAUSE 4- DISPUTIES A.. Informal Resolution

• I. The paroties to a. dispute shall attempt to resolve it in good faith, by direct, informal negotiations. All negotiations shall be confidential. Pending resolution of the dispute, the Subcontractor shall proceed' diligently with the performance of this Subcontract, in accordance with its terms and conditions.

2. The parties, upon mutual agreement, may seek the assistance of a neutral third party.at any time, but they must seek such assistance no later than 120 days after the date of the Contractor's receipt of, a claim. The requirement to seek the assistance ofaaneutral third.

party may be waived or modified only with thebconsent of all parties;. The parties may

Battclhe Energy Alliance. LLC Standud Research Subcontract No. 00074551 Poge 7 of 12 request the assistance of an established Ombudsman Program, where available, or hire a mutually agreeable mediator, or ask the DOE Office of Dispute Resolution to assist Lhem in selecting a mutually agrecable mediator. The cost of mediation shall bc shared equally by both parties, If requested 'by both partiesl, the neutral dtird party wlay offTr a uon-binding opinion as to a possible settlement. All discussions with the neutral third party shall bc confidential.

3. In the event the parties arc unable to resolve the dispute by using a neutral third party or waive the requirement to seek such assistance, the Contractor will issue a written decision on the claim.

B. Formal Resolution I. If a dispute has not been. resolved by informal resolution, it may.be submitted to binding arbitration upon agreement, of both parties, by and in accordance with the Commercial Arbitration, Rules of the American Arbitration Association (AAA). Ifarbitrafion is agecd to by both parties, such decision is irrevocable and the outcome of the arbitration shall be binding on all parties.

2. Each party to the. arbitration shall pay its pro rata share of the arbitration fees, not including counsel fees or witness fees or other expenses incurred by the party for its own benefit.

3. Judgment on the award rendered by the arbitrator may be entered in any court having jurisdiction.

C. Litigation If arbitration is declined fbr such dispules, the parties may pursue litigation in any court of compccnt jurisdiction.

D. Governing Law-This Subcontract shall be interpreted and governed in accordance with all applicable' federal and state laws and all applicable federal rules and regulations.

CLAUSE 5 - RESPONSIBILITY FOR TECHNOLOGY EXPORT CONTROL The parties understand that materials and. information resulting from the performance of this Subcontract may be subject .to export control laws and that each party is responsibler for its own

.compliance with such laws.

CLAUSE 6- COSTAACCOUNTING STANDARDS (CAS) LIABILITY lApplicable to Subcontracts exceeding $500,0001.

'Clause 10 below incorporates into these GENERAL PROVISIONS clauses entitled, "COST ACCOUN2TNG STANDARDS" and "ADMINISMRATION OF COSTACCOUNTING STANDARDS."

Notwithstanding the provisions of these clauses, or of any other provision oftthe Subcontract, the Subcontractor shall be liable to the Government for any increased costs, or interest thereon, resulting from any failure of the Subcontractor, with respect to activities carried on at the site of the work, or of a subcontractor, to comply with applicable cost accounting standards or to follow any practices disclosed pursuant to the requirements of such clause.

Rattele Eni.ey Alliance, LtC Standard Research Subcontract No. 00074551 PagcE of 12 CLAUSE 7 - DISCLOSURE AND USE RESTRICTIONS FOR LIMITED RIGHTS DATA Generally, delivery of Limited Rights Data (or Restricted Computer Software) should not be necessary. However, only if Limited Rights Data will be used in meeting the delivcrty requiroments of the subcontract, the following disclosure and use restrictions shall apply to and shall be inserted in, any FAR 52.227-14 Limited Rights Notice on anyLimited Rights Data furnished or delivered by the Subcontractor or a lower-ticr subcontractor:

A. These "Limited Rights Data" may be disclosed for evaluation purposes under the restriction that the "Limited Rights Data" be rctained in confidence and not be furthcr disclosed;-

B. These "Limited Rights Data" may be disclosed to other contractors participating in the Govcinment's program of which this Subcontract is a part for information or use in connection with the work performed under their contracts and under the restriction that the "Limited Rights Data" bc retained in confidncre and not be furtherdisclosed; and C. These "Limited Rights Data" may bc used by the Government or others on its behalf for emergency repair or overhaul work under the restriction that the "Limited Rights Data" be retained in confidence and notbe further disclosed.

CLAUSE 8 - ORDER OF BRECEDENCE Any inconsistencies in the documents comprising this Subcontract shall be resolved by giving precedence in the following order: (a) the SCHEDULE OF ARTICLES and this Subcontract Signature Page; (b) these GENERAL PROVISIONS; (c) other referenced documents, exhibits, and attachments; and (d) any referenced specification or Statement of Work.

'CLAUSE 9 - SECURITY REQUIRRMENTS A. This Subcontract is ýintended for unclassified, publicly releasable research or dcvelopment work.

The Contractor does not expect that results of the research project will involve classified information or Unclassified Controlled'Nuclear Information (UCNI) (See 10 CFR part,1017).

However, the Contractor may review the research work generated under this. Subcontract at any time to determine if it requires classitication or control as UCNLI.

B. If, subsequent to the date of this Subcontract,ýa review of thi information reveals that classified, information or UCNI is being generated under this Subcontract, then the security requirements of this Subcontract must be changed. Ifsuch changes cause an increase or decrease in costs or otherwise affect any other term or condition of this Subcontract, the Subcontract shall be subject to an equitable adjustment as if the.changes were directed under the Changes clause of this Subcontract.

C. If the security requirements are changed, the Subcontractor shall exert every reasonable effort compatible with its established policies to continue the performance of work under the Subcontract in compliance with the change in the security requirements. If the Subcontractor determines that continuation of the work under this Subcontract is not practicable because of the change in security requirements, the Subcontractor shall notify the Contractor's Procurement Representative in writing. Until the Contractor's Procurcment Reprcscntative provides direction, the Subcontractor shall protect the material as directed by the Contractor.

Th'telle Enery Alliance, LLC StanduA Rcsiarch SubconatmetNo. 00074551 Page 9.of 12 D. After receiving the written notification, thc Contractor's ProcurementRepresentative shall explore the circumstances surrounding the proposed change in security requirements and shall endeavor to work out a mutually satisfactory method to allow the Subcnttraotor to continue performance of work under this Subcontract.

E, Within 15 days ofreceivingtlie written. notification of the Subcontractor's stated inability to proceed, the Contractor's Procurement. Representative must determine whether (1) these security requirements do not apply to this contract or (2) a mutually satisfactory method for continuing performance of.work under this Subcontract can be agreed upon. If this determination is not made, the Subcontractor may request the Contractor's Procurement Representative to terminate the Subcontract in whole or in part. The Contractor's Procuremcn Representative shall terminate thc Subcontract. in whole or in part, as may be appropriate, and the termination shall be deemed a termination under the terms of the Tcmination for the Convenience of the Government clause.

CLAUSE, 10 - CLAUSES INCORPORATED BY REFERENCE The FEDERAL ACQUISITION REGULATION (FAR) and the U.S. DEPARTMENT OF ENERGY ACQUISITION REGULATION (DEAR) clauses listed below, which are located in Chapters I and 9, respectively, of Title 48 of the Code of Federal Regulations, are incorporated by this reference as a part of these GENERAL PROVISIONS with the same force and effect as if they were given in full text, as prescribed below.

The full text of the clauses may be accesscd electronically at ht www~aneuv/far/ (FAR) and httn:Lfp*ressionals.prdde.pogv/ma5t\A-5Wchnsfpracurinieigt/Acauisitinn+Regulation (DEAR).

As used in the clauses, the term "contract" shall mean this Subcontract; the term "Contractor" shall mean the Subcontractor; the term "subcontractor" shall mean the Subcontractor's subcontractor, and the termsý "Government" and "Contracting Officer" shall mean the Contractor, except in FAR clause 52.227-14, and DEAR clauses 970.5227-4, 952.227-11, 970.5232 and 52.245-5 Alternate I, in which clauses "Government" shall mean the United States Government and "Contracting Officer" shall mean the DOE/NNSA Contracting Officer for Prime Contract DE-AC07-05ID14517 with the Contractor. As used in DEAR clauses 952.204-72 and 952.227-9, the term "DOE" shall mean DOE/NNSA or the Contractor.

The modifications of these clause terms are intended to appropriately identify the parties and establish their contractual and administrative reporting relationship, and shall not apply to the extent they would affect the U.S. Government's rights. The Subcontractor shall include the listed clauses in its subcontracts at any tier, to the extent applicable.

APPLICABLE TO ALL SUBCONTRACTS UNLESS OTHERWISE INDICATED BELOW:

DEAR 952.204-71 SENSITIVE FOREIGN NATIONS CONTROLS (APR 1994). Applies if the Subcontract is for unclassified research involving nuclear technology.

FAR 52.216-7 ALLOWABLE COST AND PAYMENT (DEC 2002). Substitute 31.3 in subcontracts with educational institutions and 31.7 in subcontracts with nonprofit organizations for 31.2 in paragraph (a).

FAR 52.216-15 PREDETERMINED INDIRECT COSTS RATES APR 1998).

FAR 52.222-21 PROHIBITION OF SEGREGATED FACILITIES (FEB 1999).

FAR 52.222-26 EQUAL OPPORTUNITY (APR 2002).

Battell Energy Alliance, LLC Standard Rcesarch Subcontract No. 00074551 Page lOf 12 FAR 52.223-3 HAZARDOUS MATERIAL IDENTIFICATION AND MATERIAL SAFETY DATA SHEETS (JAN 1997) AND ALTERNATE 1.Applies only if Subcontract involves delivery of hazardous materials.

FAR 52.225-13 RESTRICTIONS ON CERTAIN FOREIGN PURCHASES (DEC 2003).

DEAR 970.5227-4 AUTHORIZATION AND CONSENT (AUG 2002), Paragraph (a).

DEAR 952.227-9 REFUND OF ROYALTIES (FEB 1995). Applies if "royalties" of more than $250 are paid by a subcontractor at any tier.

DEAR 952.227-11 PATENT RIGHTS - RETENTION BY THE CONTRACTOR (SHORT FORM) (FEB 1995). (Applies only if Subcontractor is a nonprofit organization as set forth in 48 CFR 27.301. If Subcontractor does not qualify in accordance with 48 CFR 27.301, it may request a patent waivcr pursuant to 10 CFR 784.)

FAR 52.227-14 [Check provision below that applies OR include only applicable provision].

RIGHTS [N DATA-GENERAL (JUN 1987) with ALTERNATE V and DEAR 927.409 Paragraphs (a) and (d)(3). Applies if the Subcontract is for development work, or for basic and applied research where computer softwaro is specified as a Doliverable in the Statement of Work or other special circumstances apply as specified in the agreement.

X RIGHTS IN DATA-GENERAL (JUN 1987) with ALTERNATE IV, subparagraph (c)(i) and DEAR 927.409, subparagraph (a) Definitions.

Applies if the Subcontract is for basic or applied research and computer software is not specified as a Deliverable in the Statement of Work, andno other special circumstances apply per DEAR 927.409.

FAR. 52.227-23' RIGHTS TO PROPOSAL.DATA (TECHNICAL) (JUNE 1987). Applies if the Subcontract is based upon a technical proposal.

FAR 52.229-10 STATE OF NEW MEXICO GROSS RECEIPTS AND COMPENSATING TAX (APR 2003). Applies if any part of this Subcontract is to be performed in the Staterof New Mexico.

FAR 52.232-20 LIMITATION OF COST (APR 1984). Applies if the Subcontract is fully funded.

FAR 52.232-22 LIMITATION OF FUNDS (APR 1984). Applies if the Subcontract is incrementally funded.

FAR 52.242-1S STOP-WORK ORDER (AUG 1989) with ALTERNATE I (APR 1984).

FAR 52.243-2 CHANGES - COST-REIM BURSEMENT (AUG 1987), WITH ALTERNATE V FAR 52.244-2 SOBCONTRAC'rS (AUG 1998). Insert in Paragraph (c): "Any subcontract or purchase order for other than "commercial items" exceeding the simplified acquisition threshold. ("Commcreial item"' has the meaning contained in FAR 52.202-1, Definitions.)"

DEAR 970.5245-1' PROPERTY (DEC2000),

FAR 52.246-9 INSPECTION OF RESEARCH AND DEVELOPMENT (SHORT FORM)

(APR 1984).

Biuttlle Energy Allianjce, LI.C Stwandad RA4sarh Subeonimc: No. 00074551 Page IIof 12 FAR 52.247-63 PREFERENCE FOR U. S. FLAG AIR CARRIERS (JUNE 2003). Applies if the Subcontract involves international air transportation.

PAR 52.247-64 PREFERENCE FOR PRIVATELY OWNED U.S.-FLAG COMMERCIAL VESSELS (APR 2003).

DEAR 952.247-70 FOREIGN TRAVEL (DEC 2000).

FAR 52,249-5 TERMINATION FOR CONVENIENCE OF THE GOVERNMENT (EDUCATIONAL AND OTHER NONPROFIT INSTITUTIONS) (SEP 1996).

DEAR 952.217-70 ACQUISITION OF REAL PROPERTY (APR 1984). Applies if the Subcontract involves leased space that isrcimnbursed.

DEAR 970.5232-3 ACCOUNTS, RECORDS, AND INSPECTION (DEC 2000%

APPLICABLE IF THE SUBCONTRACT IS FOR $10,000 OR MORE:

FAR 52.222-3 5 EQUAL OPPORTUNITY FOR SPECIAL DISABLED VETERANS, VETERANS OF THE VIETNAM ERA AND OTHER ELIGIBLE VETERANS (DEC 2001).

FAR 52.222-36 AFFIRMATIVE ACTION FOR WORKERS WITH DISABILITIES (JUNE 1998).

FAR 52.222-37 EMPLOYMENT REPORTS ON SPECIAL DISABLED VETERANS, VETERANS OFTHE VIETNAM ERA AND OTHER ELIGIBLE VETERANS (DEC 200 1).

APPLICABLE IF THE SUBCONTRACT EXCEEDS S100,000:

FAR 52,203-5 COVENANT AGAINST CONTINGENT FEES (APR 1984)

FAR 52.203-6 RESTRICTIONS ON SUBCONTRACTOR SALES TO THE GOVERNMENT (JULY 1995).

FAR 52.203-7 ANTI-KICKBACK PROCEDURES (JULY 1995), excluding Paragraph (cXI).

FAR 52.203-10 PRICE OR FEE ADJUSTMENT FOR ILLEGAL OR IMPROPER ACTIVITY (JAN 1997).

FAR 52.203-12 LIMITATION ON PAYMENTS TO INFLUENCE CERTAIN FEDERAL TRANSACTIONS (JUNE"2003).

FAR 52.219-8 UTILIZATION OF SMALL BUSINESS CONCERNS (MAY 2004).

FAR 52.222-04 CONTRACT WORK HOURS AND SAFETY STANDARDS ACT -

OVERTIME COMPENSATION (SEP 2000).

DEAR 970.5227-5 NOTICE AND ASSISTANCE REGARDING PATENT AND COPYRIGHT INFRINGEMENT (AUG 2002).

APPLICABLE IF THE SUBCONTRACT EXCEEDS $500,000:

FAR 52.215-10 PRICE REDUCTION FOR DEFECTIVE COST OR PRICING DATA (OCT 1997) if subcontract exceeds $550,000.

I Haitelle Encergy Alliance, LLC Standard Rescarcb Subcontraico No. 0(174551 Pag>e12 of 12 FAR 52.215-11 PRICE REDUCTION FOR DEF.ECTIVE COST OR PRICING DATA-MODIFICATIONS (OCT 1997) not used when 52.-215-10 is included. in subcontracts greater than S550,000.

FAR 52.2 t5-12 SUBCONTRACTOR COST OR PRICING DATA (OCT 1997). Applies if 52.215-10 applies.

FAR 52.215-13 SUBCONTRACTOR COST OR PRICING DATA-MODIFICATIONS (OCT 1997). Applies if 52;215-I1 applies.

FAR 52.219-9 SMALL BUSINESS SUBCONTRACTING PLAN (JAN 2002). Applies unless there are no subcontracting possibilities.

FAR 52.227-46 ADDITIONAL DATA REQUIREMENTS (JUNE 1987).

FAR 52.230-2 COST ACCOUNTING STANDARDS (APR 1998), excluding parangaph (b). Applies to nonprofit organizations if they are subject to full CAS coverage as set forth in 48 CFR Chapter 99, Subpart 9903.201-2 (FAR Appendix B).

FAR 52.230-3 DISCLOSURE AND CONSISTENCY OF COST ACCOUNTING PRACTICES (APR 1998), excluding paragraph (b). Applies to nonprofit organizations if they-are subject to modified CAS coverage as set forth in 48 CFR Chapter 99, Subpart 9903.201-2 (FAR Appendix B).

FAR 52.230-5 COST ACCOUNTING STANDARDS - EDUCATIONAL INSTITUTION (APR 1998), excluding paragraph (b).

FAR 52.230-6 ADMINISTRATION OF COST ACCOUNTING STANDARDS (NOV 1999).

(END OF GENERAL PROVISIONS)

Response to RAI (Oct. 2009 submittal)

Responses to REQUEST FOR ADDITIONAL INFORMATION UNIVERSITY OF FLORIDA TRAINING REACTOR DOCKET NO. 50-83 by Alireza Haghighat, Director of UFTR Ce Yi, Research Scientist, UFTR Matthew Berglund, SRO. UFTR Brian Shea, Manager, UFTR Nuclear & Rdiological Engineering Department University of Florida 202 Nuclear Sciences Building Gainesville, Florida 32611 (352) 392-1401 (November 26, 2008)

(October 2009, updated on release limit)

Responses to REQUEST FOR ADDITIONAL INFORMATION UNIVERSITY OF FLORIDA TRAINING REACTOR DOCKET NO. 50-83 Question 1: Your letter dated April 7, 2008, states that the normal operatingpressure for the secondary side is not monitored, but that secondaryflow rate is about 4 times higher than the primaryflow rate so the dynamic pressure of the secondary system is expected to be higher than the primary system pressure. Therefore, if a sign ficant leak is developed on the primary/secondaryboundary, the resistivity of the primary water is expected to change, which is constantly monitored and controlled. The technical specifications (TSs) limits on primaryflow rate are greaterthan 36 gpm or 41 gpm depending on fuel coolant channel spacing tolerance, and the TSs limits on secondaryflow rate are greaterthan 60 gpm when using a well system and 8 gpm when using city water.

Is the assumption that a significant leak would be detected in the primary water resistivity valid if the reactoris operatingat the TS limit of 36 gpm or 41 gpm primaryflow rate (or normalprimaryflow rate if it is in excess of the allowed TS limit) and 60 gpm or 8 gpm secondaryflow rate? In your response, address how the primary andsecondary pressuresare affected by the flow characteristicsin the heat exchanger.

Response 1:

The resistivity ofprimary water is monitored.If some fission products leak into the primary coolant due tofuelfailure, this will cause resistivity change in the primary water regardlessof the flow rates.

The shell-tube type heat exchanger is one of the Type AHTR series, manufactured by AMETEK (Type 316 Stainless Steel, U-tube configuration),with one pass on the shell side for the secondary coolant, and two-pass on the tube sidefor the primary coolant.

Here we use the Kern method (Refs. 1 and 2) to estimate the shell-side and tube-side pressure drop.

The shell-sidepressure drop can be estimated by the following equation.

1 LApS = f. G.N~. DS ZpDets Where

= exp (0.576 - 0.19 s ln(Re,)) is Fanningfrictionfactor on shell side (Note the factor also takes entrance and exit pressure losses into account)

D, = shell innerdiameter 2

G 2-- is the shell side mass velocity m,= the shell side massflow rate A, - D.,CR is the shell side crossflow area P1.

C = the distance between tubes (see Figure 1)

PT = tube pitch size (see Figure 1)

Tc PT Figure 1 - Trianglepitch size parameters (Res = GsDe l's shell-side Reynolds number (Eq. I is validfor 400 < Re < 1 X 10')

O=4xfroo flow area 4X " 4- a

[De ott lowriea = d( -] = Equivalent diameter of the shell side wetted perimeter 7ido/2Eqf for triangularpitch.

do= Tube outer diameter p = shell side water density Ls = shell side length B = baffle spacing Ns= number of times the shell side waterpasses across the tube bundle (Ns=Ls/B) ps= the shell side water viscosity at shell side water temperature

/= the shell side water viscosity at tube wall temperature The tube side pressure drop is calculatedby the following equation

= (4f, X!R A, di + 4NP)-y (2)

Where, 2

[ft = (1.S8ln (Re) - 3.28)- ] = the frictionfactor on the tube side Np = the number ofpasses on the tube side L = tube length.

di = tube inner diameter V, = the averageflow speed (m/s)

The first part of Eq. 2 accountsfor the pressure drop due to friction, and the second part accountsfor pressure drop due to the change of direction of U-tubes.

3

In orderto use Eqs 1 and 2, parametersgiven in Table 1 are considered.

Table 1 - Parametersused to evaluatepressure drop in the heat exchanger.

Parameters value tube inner diameter 5.35E-02 m tube outer diameter 6.35E-03 m shell inner diameter 2. 06E-O1 m shell length 1. IOE+O0 m tube length 1.OOE+O0 m number of baffle 10 pitch size (Pt) 1.27E-02 m tube distance (C) 6.35E-03 m number ofpasses (tube side) 2 number of tubes 126 Average Primary Coolant Temp. 86.5 'F Average Secondary Coolant Temp. 75.3 'F For reference, we use primaryflow rate at 40 gpm, and secondaryflow rate at 200 gpm (well water). The effects of differentflow rates will be discussed later. In Table 2, the temperatures are the average measured values, and they are used to look up the viscosity values.

4

Table 2 - Pressuredrop in the heat exchangerfor the reference case (primaryflow rate 40 gpm, secondaryflow rate = 200 gpm)

Flow rate (gpm) PressureDrop (psi)

Shell-side (Secondary) 200 2.18 Tube-Side (Primary) 40 4.42 Above table indicates that the pressure drops in the primary and secondary sides are relatively small, and moreover the primary drop is largerthan the secondary side.

The heat exchangershell-side and tube-side inlet/outletpressures are not monitored in UFTR. However, we can estimate the pressures based on the piping layout andpump characteristics.Figure 5-5 in UFTR SAR shows the schematic of UFR secondary coolant system. The figure is also attached in this document (Appendix A). A simplified version of Figure 5-5 in SAR is used here to estimate the primary outlet and secondary inlet pressures as shown in Figure 2 A

To fuel box top

~15 ft

-12 ft inlet Primary OLlet Secondarf V

Heat 126 ft exchanger well ii Water level pump Figure 2 schematic of UFTR secondary coolant system usedfor determination of heat exchanger inlet/outletpressures.

The well pump, model 150HlO is manufactured by Goulds Pumps, ITT Industry. The specifications of the pump are given in Appendix B. According to the data given in the Appendix, the pump at 10 hp, for 200 gpm, has a dynamic head of 163 ft. In Figure 3, the 5

height difference between the pump and heat exchanger is -I I lft (126ft minus 15ft).

Assuming no significantpressure loss in the pipes, the secondary inlet pressureis about 50ft (163 ft minus illft) water above the atmospherepressure. While on the primary side, the heightfrom the heat exchanger to the top offuel box (where -thepressure is atmosphere) is -12ft. The primary outlet pressure is about 12ft water above the atmospherepressure. Consideringi psi is equal to 2.306ft water, then the inlet pressure for the secondary is -36.4 psi, and the outlet pressurefor the primary is -19.9 psi.

Consideringthe expected pressure drop in the heat exchangergive in Table 2, the secondary outlet pressure is -34.2 psi, which is -72% higher than the primary outlet pressure. This difference increasesas the secondaryflow rate decreases, e.g., at 100 gpm with a dynamic head of 238ft, the pressure difference is -251%. This means that there is always a negative pressure which prevents any leak from the primary loop to the secondary loop.

Figures3 and 4 show the pressure drop as afunction offlow ratefor the primary and secondarysides, respectively.

5.5 6

.*5 4 -------------

-- -- -- -- - - -- -

2.5*

30 32 34 36 38 40 42 44 46 Primary flow rate (gpm)

Figure3 - Primarypressure drop in the heat exchangerfor differentflow rates 6

2.5 0.5-0

1. so10IS 0 Secondary flow rate (gpm)

Figure 4 - Secondary pressuredrop in the heat exchangerfor differentflow rates Abovefigures show that the primarypressure drop rangesfrom 2.61 psi to 5.72 psi for a flow ratefrom 30-gpm to 46 gpm. While the secondarypressuredrop is below 2.18 psi for aflow rate up to 200 gpm.

In conclusion, the secondarypressureremains higher than the primarypressure in the heat exchanger when operatingon the well water. For city water, the primarypressure drop is still largerthan the secondarypressure drop. The primary heat exchanger inlet pressure is likely higher than the secondary inlet pressure. So it is not valid to assume that the secondarypressure is always higher than the primarypressure. However, the activity release is limited even if there is leakage in the heat exchanger (See analysis in Question 2).

Question 2: Your letter dated April 7, 2008, states that "with conservative assumptions on sodium in the primary coolantsystem, irradiationtime, neutronflux level, cross section,primary-to-secondaryleakage and secondary dilutingflow, the following values are determinedfor a 1 liter/hrundetected leak rate continuing for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with 1 ppm sodium assumed in the primary coolant system. Activation for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> yields -54 mCi Na-24 in the primary coolant tank at a concentration of -0.0895 tCi/ml before dilution by the secondaryflow. For a 1 liter/hourleak rate undetectedfor an hour, the concentrationassuming 140 gpm well waterflow (minimum based on well waterflow withoutflow warninglight), the concentrationbecomes -2.8E-06 pCi/mI. Public release is allowed at 5E-3 uaCi/mIso we conclude that this unlikely event would not be a problem in this regard."

Question 2a: What is the basisfor the 'assumptionsof ] ppm sodium in the primary coolant, activationfor 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, and 1 liter/hour leak ratefor 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />?

7

Response 2a:

The activity release is calculatedby thefollowing equation.

LR AR = ( - e--AC) X P--N3)

FR (3)

Where, AR = Activity release in the unit ofuCi/ml

= 2.0 X 1012 neutronsfcmn2sec is the core total (fast + thermal)flux at 100 kW Microscopic absorption cross sectionfor Na-23 N = Number of Na atoms in 1 mlprimary coolant (Sodium concentration)

= Decay coefficient of Na-24 (T11 2 =15.02 hrs) t = Activation time LR = Primaryto secondary leakage rate FR = Secondaryflow rate A. Estimation of activity for different operation times and Na-23 concentration The reasonfor considering a sodium concentrationof ]ppm sodium is based on the measurement results by UF Extension Soil Testing Library. (See attachment). Two water samples arefilteredprimary coolant and the unfiltered city water (before entering the primary system). Results show that the primary coolant sodium concentration is 0. 7 ppm.

The current operation time of the UFTR by the Technical Specifications is 6 hrs. We will further examine the effects of operation time and sodium concentration.

Here, in order to examine the effect of higherNa concentrationand longer operation times, we evaluate the activity releasefor concentrationsin a range of 1-10 ppm for operation hours of 2 to 10 hrs. Figure 1 compares the activity releasefor different hours of operation as afunction of Na concentration in the primary coolant. Note that these calculations are based on 1 liter/hr leakage rate, and 200 gpm secondaryflow rate.

8

6.OE-05 5.0E-05 41

- 4.0E-05 -_-__

" *t=2 hr 3.0E-05 -U-- t=6 hr 2t=8 hr t=10 hr

.0E-05 *- limit 0.OE+O0 0 2 4 6 8 10 12 Na-23 concentration (ppm)

Figure] - Comparison of the activity releasefor different operationtime as afunction of sodium concentration (100 kW, 1 liter/hr, 200 gpm)

Above figure indicates that the activity is less than the release limit (5e-5 uCi/ml) if sodium concentration is less 10 ppm for a case of 8 hrs of operation. Only the case with a Na-23 concentration of 10 ppm and an operation time of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> exceeds the limit.

B. Estimation of activity release for different leakage rates and Na-23 concentration Figure 2 compares the activity releasefor different coolant Leakage Rate (LR) as a function of the Na-23 concentration in the primary coolantfor 6 hrs operationtime and 200 gpm secondaryflow rate, at 100 kW 9

7.OE-05 6.OE-05

• - .OE-05 E

o 4.OEO5 -- LR=1 3.OE-05

• LR=3 3,2OE-05 2.OE 1,OE-05 00-,lmi 0 1 2 3 4 5 Na-23 concentration (ppm)

Figure 2 - Comparisonof the activity releasefor different primary to secondary leakage rate as afunction of sodium concentration (100 kW, operation time of 6 hrs, and 200 gpm secondaryflow rate)

As expected, Fig. 2 shows that activity leakage increases linearly as the primary coolant leakage rate increases.For the case with LR=3 andNa-23 concentration 4 ppm, the activity release is still below the limit.

C. Estimation of activity release for different secondary flow rates and Na-23 Concentration Well water is the only supply for UFTR secondarysystem now. Based on the current UFTR Technical Specifications, the nominal well waterflow rate is -200 gpm. A warning is triggeredifflow drops to 140 gpm or less, and the reactoris tripped if the flow rate drops to 60 gpm or less. Figure 3 compares the activity releasefor differentflow rates as afunction of Na-23 concentrations,for an operation time of 6 hrs and leakage rate (primaryto secondary) of I liter/hr at 100 kW 10

6.OE-05 5.0E-05 -

_*4.0E-05 4.QE-0-4--60 gpm U3 120 gpm 3.OE-05 160 gpm 2.OE-05 ,'- 200 gpr limit 1.0E-0S1 0 1 2 3 4 5 Na-23 concentration (ppm)

Figure 3 - Comparisonof the activity releasefor different secondaryflow rate as a function of Na-23 concentrationfor 1 liter/hr leakage (operationtime of 6 hrs, 100 kW).

Figure 3 shows that the only case exceeding the release limit is the case with 4 ppm Na-23 concentrationand a secondaryflow rate of 60 gpm.

Question 2b: How is the public release limit (5E-3 !iCi/mI) derived? Appendix B to 10 CFR Part20, Table 2, Column 2, lists an average yearly concentration release limit of 5E-5 ,Ci/mifor water effluents, and Table 3 list a monthly average concentration release limit to sewers as 5E-4 uCi/ml.

Response 2b:

The release limit has been updated to the limit 5E-5 ,Ci/ml Question 2c. As discussedpreviously, the TS limit on secondaryflow rate is 60 gpm when using well water and 8 gpm using city water. Therefore, provide an estimated effluent concentrationassuming the allowed TS limits for secondaryflow.

Response 2c:

The analysis on the secondaryflow rate is discussed in Section D in the answer to question 2.a Question 2d: What is the basisfor your conclusion that a primary to secondary leak is unlikely?

Response 2d:

The statement is based on the analysis (See the answers to Question 1) of the pressure drop in the heat exchangerfor the primary and secondary sides.

11

References

1. Kern, D.Q., ProcessHeat Transfer,McGraw-Hill,New York 1950.

2. Kakac, Sadik andLiu, Hongtan,Heat Exchanger Selection, Rating and Thermal Design, CRC Press, Boca Raton, Florida,2002 12

Appendix A - Schematic of UFTR secondary coolant system (FromSAR Figure5-5) t Dtasket Check Total Relief Flowmeter Valve Strainer Valve Flow Valve City Water and Flow3""

Switch

-laokflow Preventer Throttle To Well and Pump Vacuum Prom CST Sample Connection Sample Connection Drain To Storm Sower

Appendix B - UFTR Secondary CoolantPump (well pump) Specifications MGOULDS PUMPS Model 150H METERS FEET 800 i. . - t 80 RECOMMENDED RANGE . - RPM 3450 50-240GPM .. 60 Hz 700 - ---- -... . . . . I. 70 200 ¶1501-25-10 1 60

.. _2. I

[OD.H208 4 150 50 40 Z 400 ~1--H - -6i

-J 0 100 30 ... */._;t' F-. U-I-- 30 200

... ...

....................

.' "......". "

20 50 200 _____..

'1 5 OH O5 ' 2 ' ...........................

.110 0 0 0 10 20 30 40 50 60 m3/hr CAPACITY Curve Reference SU 507 DIMENSIONS AND WEIGHTS DISCHARGE 3' NPT W.E. Motor 1 W.E. Motor Motor Motor W.E. Wt.

HP Stages Order Order PH Motor Motor WE. LOA Wt- HP Stages Order Order PH Volts Lgth. Lgth. LOA (Ibs)

No. No. I Volts Lgth. Lgth, (lbs.) No. No.

S10940 1 230 28.2 18.0 46.2 95 S13970 1 230 33.1 39.3 72.4 255 - ~~5.82" Effecctive S10978 200 S13978 200 diam eter S 2 150H052 S1097,0 230 15 6 150H156 513971 230 with cable 510975 3 460 22.2 18.0 40.2 95 513972 3 460 28.0 39.3 67.3 229 9 uard S10979 575 "S13979 575 S11970 1 230 28.0 24.3 52.3 185 S14978 200 7S1978 200 S14971 230 7.5 3 150107 3 S11971 230 20 8 150H208 514972 3 460 30.6 49.3 79.9 274 511972 3 460 24.2 24.3 48.5 160 S$14979 575 /"

3TR.)

511979 575 S15978 200 (4" M S15971 230 512970 1 230 30.6 29.3 59.9 215 25 10 150H2510 515972 3 460 33.2 59.3 92.5 316 5%"

S12978 200 S'515979 575 MOTOR (6"MITR.)

10 4 150H10 4 512971 230 512972 3 460 25.5 29.3 54.8 185

-12979 575 (All dimensions are in inches and weights in lbs. Do not use for construction purposes.)

"Non-stock motors have a six (6) week lead time.

Water end and motor must be ordered separately and are packaged separately.

MGOULDS PUMPS Model 150H SELECTION CHART Horsepower Range 5 - 25, Recommended Range 240 GPM, 60 Hz, 3450 RPM Pump Depth to Water in Feet/Ratings in GPM (Gallons per Minute)

Model HP PSI 25 50 75 100 125 150 175 200- 250 300 350 400 450 500 600 0 254 230 200 164 102 20 206 172 120 ItSOH0 2 5 30 174 122 2 Stages 40 126 60 0 250 234 215 192 164 126 20 237 220 194 170 130 78 150H07 3 7,5 30 220 197 174 134 78 3 Stages 40 200 174 140 84 _

50 176 142 90 205 18 6 163 92 60 144 100 251 2 8 23 0

20 253 240 225 210- 190 168 140 104 150H10 4 10 30 240 226 210 190 170 140 104 j 4 Stages 40 228 212 193 172 146 108 50 213 193 172 147 111 21 6 19 2 1 64 12 2 1_ _ 60 194 176 148 116 55 24 6 23 6 22 6 02 20 257 248 238 228 218 206 194 167 128 _

15OH15 6 30 258 248 238 228 218 206 194 181 150 100 6 Stages 40 248 240 230 220 208 196 184 170 154 168 107 130 1 220 209 196 184 -

so 240 230

- 0 234 220 210 198 185 172 154 136 788 0 259 252 2 37 221 204 183 16 13 9 20 260 253 246 238 230 223 206 187 166 138 100 150H20 8 20 30 260 253 246 239 231 223 214 197 -177 154 120 8Stages 40 254 247 240 232 224 216 208 .188 168 140 102 50 255 247 240 232 224 216 208 199 180 156 125 80 60 247 240 232 225 216 209 199 190 170 142 106 0 258 252 240 226 212 198 182 165 113 20 259 253 247 240 227 213 199 183 166 144 78 150H25 10 25 30 260 253 247 240 234 220 207 192 175 I 156 132 100 10 Stages 40 260 254 247 241 234 228 214 200 184 168 146 118 50 260 254 248 242 235 229 222 208 193 177 158 134 104 60 260 254 248 242 235 230 222 216 201 186 169 1481 120 84 5

Appendix C - UFTR Coolant Sample Test Results Sample number.* CWJ - unfiltered (city water)

Sample number : DI1 -filtered (primarycoolant)

UF/IFAS Analytical Services Laboratories F[ff UNIVERSITY Of FLRIDA Extension Soil Testing Laboratory WASk Wallace Building 631 PO Box 110740 Gainesville, FL 32611-0740 Email: soilslab(hmail.ifas.ufl.edu Web: soilslab.ifas.ufl.edu Phone #:352-392-1950 Water Test To: Nuclear Engineering/Berglund, Matt For further information contact:

PO Box 118300 Sanders, Cynthia B. & Wilber, Wendy Gainesville, FL 32611 Alachua County Coop Extn Service Tel: 352-392-1429 x318 2800 NE 39th Ave Gainesville, FL 32609-2658 Set: 1852 Tel: 352-955-2402 Report Date: 18-Nov-08 Email: sandersl@ufl.edu Parts per million (ppm or rng/L) Electrical Lab Sample Conductivity Total No Identification pH in carbonates Calcium Magnesium Hardness Iron Manganese Sodium Chloride Suspended mmho/om in Ca Mg Fe Mn Na Cl Solids or dS/m meq/liter 22987 CW 1 30.1 21.5 163.4 0.00 0.00 10.5 27.6 0.0 7.60 0.35 0.80 22988 DI 1 0.0 0.0 0.0 0.00 0.00 0.7 -0.3 0.0 5.70 0.00 N/A REPORT OF WATER TEST RESULTS The following table will assist in classification of water hardness:

Interpretation . Hardness The reported values have different meanings depending upon the ........................ pp....grains.....per...gallon...

planned uses of the water. The following interpretations are divided ppmn grains per gallon into Household Uses and Irrigation sections. Please read the applicable section to better understand these water test results. soft 0 to 17 0to I relatively soft 17 to 50 1 to 3 moderately hard 50 to 120 3 to 7 HOUSEHOLD USES INTERPRETATIONS hard 120 to 170 7to 10 The physical and chemical determinations made by the Extension vary hard > 170 >10

.............................................................................

Soil Testing Laboratory can be effectively used to diagnose potential problems in water. However the lab does not test a water's suitability Iron and Mn can impart a metallic taste to water as well as for human consumption. Bacteriological tests may be available from stain clothes and plumbing fixtures. Staining can be caused by the County Health Department or from selected commercial as little as 0.3 ppm Fe or Mn.

laboratories.

Hardness is calculated according to the following equation: Electrical Conductivity of water is related to the amount of Hardness = (ppm Ca x 2.5) + (pptn Mg x 4. 1) dissolved salts in the water. Higher salinity results in higher (parts per million, ppmn) electrical conductivity. Increases in electrical conductivity with time may mean that the aquifer is turning brackish or that salt water intrusion is occuring.

This data report has been issued on the authority of Dr. Rao Mylavarapu, Laboratory Director, and Mr. Pete Straub, QA Officer, in support of Florida Cooperative Extension Services.

Page I of 2 Print Date: 11/18/08

Sodium and Chloride levels are used to define the type of salts pH is a measurement which denninnes made the level of the acidity or contributing to the electrical conductivity of the water. Electrical alkalinity of the water. Much of the Florida's well waters are alkaline conductivity measures the presence of all dissolved salts. If the (pH 7.6 to 6.5). The high pH results from the calcium carbonate aquifer electrical conductivity reading is elevated, the presence of sodium in which the water has been in contact. Use of such water in effect and chloride indicatethat the water source is a brackish or that causes liming of the crop. Some crops, blueberry or pine seedings will saltwater may have intruded into the water source. grow poorly if exposed to water containing appreciable amounts of lime.

Surface waters are usually lower in pH.

ptl is a measurement which determines the level of acidity of the water. The pH of water can change rapidly for a number of Total Carbonates and Bicarbonates are a direct measure of the liming reasons. If the reading is lower than 6.5, treatement of water may potential of the water. For many crops, use of water with an appreciable be necessary to preclude damage to metallic plumbing. liming potential is not ofconcerm and may lower the need for agricultural lime additions. However, as noted above, some crops will be Additional information on interpretation of these results can be adversely affected. Neutralization of the liming potential can be found in IFAS Circular 703, "Home Water Quality and Safety." economically accomplished in some situations by treatement of water with acid. Refer to Notes in Soil Science No. 18, "Neutralizing excess IRRIGATION AND MICROIRRIGATION bicarbonates from irrigation water" and Notes in Soil Science No. 25, INTERPRETATIONS Quick-test method for pH and bicarbonates in water."

Interpretation of water quality for irrigation purposes must be Ca and Mg are used to calculate Hardness described in the Hosehold crop specific. Crops respond differently to the quality of water Uses described above.

with wlich they are irrigated. Use the following information as a guideline to determine ifa possible problem exists. If there is a Na and Cl can be used to determine the type of salts present and to possible problem indicated, consult with your county extension diagnose the possibility of saltwater intrusion.

agent and/or refer to the additional publications cited in the following text. Fe and Mn can cause plant tissue staining. Overhead irrigation with water containing levels above 0.3 ppm may cause staining to foliage.

Electrical conductivity of water is related to the amount of Additionally such levels indicate that the water should be treated to dissolved salts in the water. Higher salinity results in higher prevent microirrigation plugging due to enhanced microbial growth or electrical conductivity. As the electrical conductivity increases, iron encrustations.

the plant must expend more energy to take in nutrients dissolved in the water from fertilizer and the soil. Some plants are very Suspended solids are used to predict the amount of undissolved sensitive to salinity, while others can tolerate a wide range. Use material that is in the water. High suspended solids indicate that the following table to make general interpretations. Refer to IFAS plugging problems are likely to occur if the water is used for Circular 817, "Soil, Container Media, and Water Testing microirrigation without adequate filtration.

Interpretations and WAS Standardized Fertilization Recommendations." A reference copy of the circular is Criteria for estimating plugging potential of microirrigation water maintained at your county extension office. sources.

Class of water Electrical conductivity Plugging potential- -

Factor Units Sight Moderate Severe dS/m or mmhos/om* pH 7.0 7.0 to 7.5 7.5 Excellent 0.25 Suspended solids ppm 50 50 to 100 100 Good 0.25 to 0.75 Mn, Fe ppm 0.1 0.1 to 1.5 1.5 Permissible 0.75 to 2.00 Hardness ppm 150 150 to 300 300 Doubtful 2.00 to 3.00 Electrical Unsuitable > 3.00 conductivity dS/m 0.7 0.7 to 2.9 2.9

• Conversion ppmisoluble salts = EC x 700 Adopted from IFAS Bulletin 258, "Causes and prevention of emitter plugging in microirrigation systems" Page 2 o172 Print Date: 11/18/08

Response to RAI on Ar-41 Release

Response to NRC RAI No.7 Prepared by: Glenn Sjoden Reviewed and revised by: Alireza Haghighat The following response is in reference to questions surrounding calculations used to compare EPI code 7.0 with STAC2.1 as outlined in Item #7 of the RAI document.

The parameters used for annual averages as noted in the item were, in general, reasonable averages and best representative estimates, as applicable, collected from various sources as noted. However, with regard to previously cited calculation parameters, these did indeed default to "most conservative" positions that do not necessarily reflect "true", average conditions. Therefore, based on discussions regarding this matter, it is more appropriate to assign across the board average, conditions for ultimate assessment of the environmental burden of Ar-41. To elaborate on this point further, the following apply:

- The velocity of the wind at the stack height is interpolated from the classification of land use based on standard profiles for frictional (drag) effects on wind speed in STAC2.1; these are based on velocity profile fits for "URBAN", "SUBURBAN", or "RURAL" from Smith, M.E.

Recommended Guide for the Predictionof the Dispersionof Airborne Effluents, 3rd ed. New York:

The American Society for Mechanical Engineers, 1979. Use of "URBAN" was used for the discussion in Item #7 (which gives the most conservative (lowest) answer for wind speed at stack discharge of 3.99 m/s at the stack based on a ground speed average of 2.42 m/s measured from a data station located 3.56 m off of the ground). Therefore, the URBAN model yields the lowest wind speed and assumes tall buildings surround the stack; since this is not the case, a better more representative value for the wind profile land use is a "SUBURBAN" terrain category, which is clearly more representative of the University of Florida campus.

- The Pasquill stability class notedin Item #7 is stability class "A", the most conservative value. A more correct value based on seasonally averaged daytime weather data for the University of Florida campus is stability class "B".

- The (computed) "effective height of effluent release" from the stack is directly affected by the exhaust velocity, local temperature, stack effluent temperature, etc, since the effluent acts as a "buoyant plume" at discharge. Again, the effective release height of 12.3 m noted in Item #7 reflects the effective stack height based on the most conservative value; based on average ambient conditions, this value will fluctuate based on exhaust velocity; at this time, with equipment changes, the best estimate for mean stack exhaust speed is 6.4 m/s (equal to 7882.2 cfm).

- If we assume universally average conditions for all parameters, as follows:

o Ground Altitude ZALT: 42. m o Effluent Half Life THALFH: 1.8300E+00 Hrs

o Effluent gmol Weight MOLWT: 4.0960E+01 gmol o Global Center XGLOB: .00m YGLOB: .00m o Stack Location XSTAK: .00 m YSTAK: .00 m o Wind Direction FROM Vector (0 to 360) WINDIR: 167.1 deg o Source Release Strength (Ci/s or g/s) QSC : 9.2280E-05 o Phys Stack Height SHSTAK: 9.0 M o Stack Diameter DISTAK: .860 M o Effluent Exit Velocity VSTAK: 6.4 M/S o Effluent Exit Temperature TSTAK: 29.23 C o Ambient Air Temperature TAMB : 29.23C o Effluent Specific Heat CPEFF : 1.009E+03 J/KG-C o Density of Effluent / Density of Air EDF : 1.40 o Ground Wind Velocity UGND: 2.4 M/S o Height of ground velocity Measurement SMEAS : 3.6 M o Air Density at 29.23 C Est= 1.22 KG/M3 o Mass Flow Rate Out Stack SMDOT: 12.75 KG/S o Heat Emission Out Stack QHEFF: 0.OOOE+00 CAL/S o Terrain is SUBURB - Velocity at Stack USTAK: 4.25 M/S o Effective Stack Height: 12.9 M o Pasquill Condition: B - MODERATELY UNSTABLE; SUNNY AND WARM (2.0 M/S +- 20 deg)

The peak concentration from the universally averaged conditions is 3.157E-08 Ci/M 3 (or 158.6 mrem/yr assuming continuous reactor operation at 100% power) at a range located of 65 m down wind along a 167.1 wind vector. This is in the vicinity of Weil Hall, as shown on the map attached. The nearest occupied dormitory is East Hall, and based on the average conditions, the concentration at that location (at downwind 10 m, -200 m off plume centerline) is << 10 rem/yr, i.e., it is not measurable.

Om lOOn 250m Hall 500mn Figure depicting average wind vector from the UFTR stack along the UFTR campus. Tick marks indicate lOOm intervals.

UFTR Annual Report 2005-2006

Attachment #4 2005-06 Annual Report Introduction As stated in the University of Florida Training Reactor (UFTR) Technical Specifications, Section 6.6.1 OperatingReport, routine annualreports covering the activities of the reactorfacility during the previous calendaryear shall be submitted to the Commission within nine (6) months following the end of each prescribedyear. The prescribedyear ends August 31 for the UFTR. This annual operatingreportincludes 7 sections:

(1) a narrativesummary of reactoroperatingexperience including the energy produced by the reactorand the hours the reactorwas critical; (2) the unscheduled shutdowns including, where applicable,corrective actions taken to preclude recurrence; (3) tabulationof majorpreventive and corrective maintenanceoperations having safety significance; (4) tabulationof major changes in the reactorfacility andprocedures, and a tabulation of new tests or experiments, that are significantly differentfrom those performedpreviously and are not described in the Safety Analysis Report, including conclusions that no unreviewed safety questions were involved, (5) A summary of the nature and amount of radioactiveeffluents releasedor dischargedto the environs beyond the effective control of thefacility operatorsas determined at or before the point of such release or discharge.(The summary shall include to the extent practicablean estimate of individual radionuclidespresent in the effluent. If the estimatedaverage release after dilution or diffusion is less than 25% of the concentrationallowed, a statement to this effect is sufficient.);

(6) A summarized result of environmentalsurveys performed outside thefacility; (7) A summary of exposure received by facility personnel and visitors where such exposures are greaterthan 25% of that allowed.

1

The following discussion on the above seven sections covers the periodfrom September 1, 2005 to August 31, 2006, except as noted otherwise.

1. Summary of Operation Experience In the past reportingyear, UFTR continues to function as a reliable andproductive facility with a broad range of research and educationalutilizations by users within University of Floridaas well as researchers and educators around the State of Florida.

In the summer of 2005, the UFTRfacility has startedthe HEU to LEUfuel conversion project.

The generatedenergy and operationhours in this year are given asfollows:

Energy generated. 6852.360 KWH ReactorRun Time: 168.53 hrs

2. Unscheduled Shutdowns From September 1, 2005 to August 31, 2006 there were 5 unplanned shutdowns, each one summarized in the table below.

Reason Corrective Action 9/6/05: Fuel Box temperature indicated Reset temperature indicatorback to normal above 155 'F, about 921.9 'F (Occurred2 in about 6 minutes. Assured that is was not times, 9/30/05)

• likely to trip again, experimented with limitingpower level to see if it affected trip.

1/27/06: Extended Range indicatorcame on Relays were cleaned and replaced. Verified and loud buzzing camefrom the wide range power supply voltages. Continuedto board array.Extended range light indicated operate at power to monitor switching the extended circuit was energized at an circuit in the indicated noise levels.

incorrectpower level.

2/27/06: Overpower trip caused by ValidatedDCO.Reviewed and approved of overcompensation of AFC in Auto, resulting restartto complete A-2 surveillance by in safety 2 trip. RSRS Executive Committee.

2

4/5/06.- Trip initiated by rising trip set point Valid DCO/Alignment check of HV trip.

on A9 High Volts Bistable card. *

• Note:Filed as an Unscheduled Reactor Trip

3. Safety Related Maintenance Operations

1) 5/06- 8/06: the Safety Channel 1 High Voltage trip is investigated.And it is due to the safety channel 1 high voltage drifts out of the spec. Related electrical components are replacedor repaired.The system has been tested accordingto SOP and it is operational.

4. Major Changes in Reactor Facility, Procedures and Experiments UFTRfacility completes the HEU to LEUfuel conversion. Correspondingchanges on reactorfacility,procedures and experiments can be found in the UFTR HEU to LEUfuel conversion report.

5. Radioactive Effluents Liquid release:

UFTR is equipped with a waste water holdup tank. The tank is released two or three times per year. The radioactivityin the releasedwater is measured. Wastewater shall be sampled and monitoredpriorto tank discharge. No isotopic analysis is required if the estimated average release concentration is less than 25% of the concentration limit allowed in I0CFR20, Appendix B, Table 2. The current limit is 5.OE-9 uCi/mL for releases to the sanitary sewer.

Time period (mm.dd.yyyy) Water released (Gallon) Activity released(uCi/mL) 06.10.2005 - 09.07.2005 895.9 5.48E-010 09.07.2005 - 08.21.2006 929.8 < Lower Limit ofDetection Argon-41 Release:

The Argon-41 release concentrationis measuredabout every six months. The annual Argon-41 release is estimated by the measurement and operation hours. Discharge concentrationsofAr-41 shall not exceed 1.OE-8 uCi/mL per IOCFR20 Appendix B, Table II when averaged over 30 days.

3

UFTR Gaseous Release Data Table Month(s) Releases per Unit Energy Instantaneous Ar-41 Conc. at Generation (uCi/kW-hr) Full Power (uCi/mL)

Sep. 2005 - Dec. 2005 3736.34 9.32E-008 Dec. 2005 - Aug. 2006 3520.06 8. 70E-008 UFTR Gaseous Release Summary Month Release (uCi/month) Monthly Average Concentration (uCi/mL)

September 2005 0.4117x 106 1.4258 x 10/I(

October 2005 0 0 November 2005 0 0 December 2005 2.7740 x 106 9.5224 x 10-'o January2006 7.2 705 x 106 2.4957x 10-9 February2006 5.4143 x 106 1.8586x 10-9 6

March 2006 3.1937x 10 1.0963 x 10-9 April 2006 5.0805 x 106 1.7440 x 10-9 May 2006 0 0 June 2006 0 0 July 2006 0 0 August 2006 0 0 TOTAL ARGON- 41 Releases for the reportingyear: 24.14 Ci 4

YEARL YAVERAGE ARGON- 41 Release Concentration:6.90 78 x 10-'0 uCi/mL

6. Environmental Surveys The firm maintainingradiationrecords for the University of Floridakeeps a year to date record, therefore it is easier to report radiationexposure by the nearestcompleted calendaryear.

The following film badge exposures arefor the periodJanuary 1, 2005 to December 31, 2005.

Thirteen areas (Numberedfrom 1 to 13) were monitoredfor the entire calendaryear. A list of these numbered areas can be found in UFTR SOP. Reactor cell is separately monitored during the same time period. The area radiationexposures are tabulated below. All doses are in unit of mrem.

Area No. TEDE 1 15 2 5 3 3 4 1 5 8 6 1 7 6 8 4 9 2 10 4 11 1 12 2 13 3 Area DDE LDE SDE, WB TEDE Reactor C 8 7 8 8 5

7. Radiation Exposures Note that UFTR Tech Specs requires only a summary of exposure received by facility personnel and visitors where such exposures are greaterthan 25% of that allowed. Since all personnelexposures during this periodare below the limits, we provide an exposure summaryfor the UFTR staff.

The following table illustrates the radiationdosages of 4 workersfor the period January 1, 2005 to December 31, 2005. All the dosages are in mrem.

Individual DDE LDE SDE Berglund, M. 28 29 31 Holman, M. 10 9 7 Vernetson, W. 12 11 16 Yenatskyy, M. 9 9 6 Shea, B 7 5 3 6

UFTR Annual Report 2006-2007

Attachment #5 2006-07 Annual Report Introduction As stated in the University of FloridaTrainingReactor (UFTR) Technical Specifications, Section 6.6.1 OperatingReport, routine annual reports covering the activities of the reactorfacility during the previous calendaryear shall be submitted to the Commission within nine (6) months following the end of each prescribedyear. The prescribedyear ends August 31 for the UFTR. This annual operatingreportincludes 7 sections:

(1) a narrativesummary of reactoroperatingexperience including the energy produced by the reactorand the hours the reactorwas critical; (2) the unscheduled shutdowns including, where applicable,corrective actions taken to preclude recurrence; (3) tabulationof majorpreventive and corrective maintenance operationshaving safety significance; (4) tabulationof major changes in the reactorfacility andprocedures, and a tabulation of new tests or experiments, that are significantly differentfrom those performed previously and are not describedin the Safety Analysis Report, including conclusions that no unreviewed safety questions were involved, (5) A summary of the nature and amount of radioactiveeffluents releasedor discharged to the environs beyond the effective control of the facility operators as determinedat or before the point of such release or discharge.(The summary shall include to the extent practicablean estimate of individualradionuclidespresent in the effluent. If the estimated average release after dilution or diffusion is less than 25% of the concentrationallowed, a statement to this effect is sufficient.);

(6) A summarized result of environmentalsurveys performed outside thefacility; (7) A summary of exposure received by facility personneland visitors where such exposures are greaterthan 25% of that allowed.

1

The following discussion on the above seven sections covers the periodfrom September 1, 2006 to August 31, 2007, except as noted otherwise.

1. Summary of Operation Experience In the past reportingyear, UFTR continues to function as a reliable andproductive facility with a broadrange of research and educationalutilizations by users within University of Floridaas well as researchersand educators aroundthe State of Florida.

And as a milestone year, the UFTRfacility has completed the HEU to LEUfuel conversion project.

The generated energy and operation hours in this year are given as follows:

Energy generated: 4801.040 KWH ReactorRun Time : 202.50 hrs

2. Unscheduled Shutdowns From September 1, 2006 to August 31, 2007 there were 5 unplanned shutdowns, each one summarized in the table below.

Reason Corrective Action 11/21/06: Coolantflow trip, accidental Performed % hour of nitrogenflow without due to nitrogen insertion.* trip indication at shutdown, andperformed daily satisfactory checks.

5/30/07: Sqfety 2 power channel - Troubleshoot, repairedsafety 2 HVsystem.

apparenthigh voltage trip, S2 HV apparent drop below 10% set point (Occurred3 times, 6/8/07 and 7/26/07).

• 8/13/07: NE Fuel box high temperature.* Completed successful daily checks.

• NOTE: Filedas an Unscheduled Reactor Trip

3. Safety Related Maintenance Operations

1) 6/0 7: Dilutionfan motor is replacedand the dilutionfan is cleaned upon observing reduced dilutionfan RPM 2

2) 7/07: Troubleshootand repairSafety 2 High Voltage

4. Major Changes in Reactor Facility, Procedures and Experiments None

5. Radioactive Effluents Liquid release:

UFTR is equipped with a waste water holdup tank. The tank is releasedtwo or three times per year. The radioactivityin the releasedwater is measured. Wastewater shall be sampled and monitoredprior to tank discharge. No isotopic analysis is required if the estimated average release concentration is less than 25% of the concentrationlimit allowed in IOCFR20, Appendix B, Table 2. The current limit is 5.OE-9 uCi/mLfor releases to the sanitarysewer.

Time period (mm.dd.yyyy) Water released(Gallon) Activity released (uCi/mL) 08.21.2006- 05.18.2007 816.2 < Lower Limit of Detection Argon-41 Release:

The Argon-41 release concentration is measuredabout every six months. The annual Argon-41 release is estimated by the measurement and operationhours. Discharge concentrationsofAr-41 shall not exceed 1. OE-8 uCi/mL per IOCFR20Appendix B, Table II when averaged over 30 days.

UFTR Gaseous Release Data Table Month(s) Releases per Unit Energy Instantaneous Ar-41 Conc. at Generation (uCi/kW-hr) Full Power (uCi/mL)

Sep. 2006 - Feb. 2007 3520.06 8. 70E-008 Mar. 2007 -Aug. 2007 3787.94 9.59E-008 3

UFTR Gaseous Release Summary Month Release (uCi/month) Monthly Average Concentration (uCi/mL)

September 2006 0 0 October 2006 0 0 November 2006 0 0 December2006 0. 0002 x 106 5.1958 x 10-14 January2007 0 0 February2007 2.5267x 106 8.6736x 10-1° March 2007 7.3 762 x 106 2.5937x 10-9 April 2007 2.6621 x 106 9.3 601 x 10-10 May 2007 0.0257x 106 9.0519 x 10-12 6 6.5665 x 10-13 June 2007 0.0019X 10 July 2007 0.0033 x 106 1.1441 x 10-12 6

August 2007 5.3977x 10 1.8980 x 10-9 TOTAL ARGON - 41 Releasesfor the reportingyear: 17.99 Ci YEARLYAVERAGE ARGON- 41 Release Concentration:5.2550 x 10-10 uCi/mL

6. Environmental Surveys The firm maintainingradiationrecordsfor the University of Floridakeeps a year to date record, therefore it is easierto report radiationexposure by the nearest completed calendaryear. The followingfilm badge exposures arefor the periodJanuary 1, 2006 to 4

December 31, 2006 Thirteen areas (Numberedfrom I to 13) were monitoredfor the entire calendaryear. A list of these numbered areas can be found in UFTR SOP.

Reactor cell is separatelymonitoredduring the same time period. The area radiation exposures are tabulatedbelow. All doses are in unit of mrem.

Area No. TEDE 1 2 2 6 3 <1 4 <1 5 <1 6 <1 7 1 8 <1 9 <1 10 <1 11 <1 12 <1 13 <1 Area DDE LDE SDE, WB TEDE Reactor C < 1 mrem <1 mrem 2 < 1 mrem

7. Radiation Exposures Note that UFTR TechSpecs requires only a summary of exposure received by facility personnel and visitors where such exposures are greaterthan 25% of that allowed. Since allpersonnel exposures during this periodare below the limits, we provide an exposure summaryfor the UFTR staff The following table illustrates the radiationdosages of 4 workersfor the period January 1, 2006 to December31, 2006.All the dosages are in mrem.

Individual DDE LDE SDE Berglund,M. 75 103 157 Holman, M. < 1 mrem < 1 mrem < 1 mrem Vernetson, W. 70 74 101 Yenatskyy, M < 1 mrem < 1 mrem 4 5

UFTR Annual Report 2007-2008

Attachment #6 2007-08 Annual Report Introduction As stated in the University of FloridaTraining Reactor (UFTR) Technical Specifications, Section 6.6.1 OperatingReport, routine annual reports covering the activities of the reactorfacility during the previous calendaryear shall be submitted to the Commission within nine (6) monthsfollowing the end of each prescribedyear. The prescribedyear ends August 31 for the UFTR. This annual operatingreport includes 7 sections:

(1) a narrativesummary of reactoroperatingexperience including the energy produced by the reactorand the hours the reactorwas critical, (2) the unscheduled shutdowns including, where applicable,corrective actions taken to preclude recurrence; (3) tabulationof majorpreventive and corrective maintenanceoperations having safety significance; (4) tabulationof major changes in the reactorfacility andprocedures,and a tabulation of new tests or experiments, that are significantly differentfrom those performed previously and are not described in the Safety Analysis Report, including conclusions that no unreviewed safety questions were involved, (5) A summary of the nature and amount of radioactiveeffluents releasedor discharged to the environs beyond the effective control of the facility operatorsas determined at or before the point of such release or discharge.(The summary shall include to the extent practicablean estimate of individual radionuclidespresent in the effluent. If the estimated average release after dilution or diffusion is less than 25% of the concentration allowed, a statement to this effect is sufficient.);

(6) A summarized resultof environmentalsurveys performed outside thefacility; (7) A summary of exposure received by facilitypersonnel and visitors where such exposures are greaterthan 25% of that allowed.

The following discussion on the above seven sections covers the periodfrom September 1, 2007 to August 31, 2008, except as noted otherwise.

1

1. Summary of Operation Experience In the past reportingyear, UFTR continues to function as a reliable andproductive facility with a broadrange of research and educationalutilizations by users within University of Floridaas well as researchersand educators aroundthe State of Florida.

The generated energy and operation hours in this year are given asfollows:

Energy generated.&8726.214 KWH ReactorRun Time: 197.63 hrs

2. Unscheduled Shutdowns From September 1, 2007 to August 31, 2008 there were 5 unplanned shutdowns, each one summarized in the table below.

Reason Corrective Action 10/5/07: Coolant level trip, coolantpump Completedform 0. 6A andsuccessful daily trip.* pre-operationalchecks.

11/14/07: Criticalposition on Reg. Blade Provided reliable indicationon S-1.

at 368 versus the expected 300 - 305 Assured applicablesurveillances affected range. by maintenance were completed satisfactorily.

4/29/08: HV indicatorrequiredtrip. Checked SC1 high voltage, andperformed daily operationalcheck.

6/2 7/08: Pit alarm went off andSRO noted Cleaned waterfrom pit (< 300ml).

A/C waste water line came loose and was PerformedDCO- SAT drippingwater on the floor.

8/7/08: Sporadic dilutefan RPM indicator; Postedsign. Performedsatisfactorydaily dropfrom 561 to 553 with momentary drop pre-operationalcheck, and check room at to 484. open and close.

• NOTE: Filedas an UnscheduledReactor Trip

3. Safety Related Maintenance Operations

1) 12/07- 05/08: safety blade 2 is repaired,due to failure to drop during drop test surveillance.

2

4. Major Changes in Reactor Facility, Procedures and Experiments None

5. Radioactive Effluents Liquid release:

UFTR is equipped with a waste water holdup tank. The tank is releasedtwo or three times per year. The radioactivityin the released water is measured. Wastewater shall be sampled and monitoredpriorto tank discharge. No isotopic analysis is requiredif the estimated average release concentration is less than 25% of the concentrationlimit allowed in IOCFR20, Appendix B, Table 2. The current limit is 5. 0E-9 uCi/mL for releases to the sanitarysewer.

Argon-41 Release:

The Argon-41 release concentration is measured about every six months. The annual Argon-41 release is estimated by the measurement and operation hours. Discharge concentrationsofAr-41 shall not exceed 1. OE-8 uCi/mL per I OCFR20Appendix B, Table II when averaged over 30 days.

UFTR Gaseous Release Data Table Month(s) Releases per Unit Energy Instantaneous Ar-41 Conc. at Generation (uCi/kW-hr) Full Power (uCi/mL)

Sep. 2007- Oct. 2007 3787.94 9.59E-008 Nov. 2007 -Apr. 2007 3272.26 620E-008 May 2007 -Aug. 2007 4756.73 9.77E-008 3

UFTR Gaseous Release Summary Month Release (uCi/month) Monthly Average Concentration (uCi/mL)

September 2005 3.9666x 106 1.3948 x 10-9 October 2005 0.9528x 106 3.3 502 x 10-10 November 2005 1.8955 x 106 4.9880 x 10-c' December2005 0 0 January2006 0 0 February2006 0 0 March 2006 0 0 April 2006 6.2525 x 106 1.6454 x 10-9 May 2006 16.6721 x 106 4.7560 x 10-9 June 2006 2.3422 x 106 6.6817x 10-"

July 2006 1.7109 x 106 4.8805 x 10-'° August 2006 2.7611 x 106 7.8767x 10-1° TOTAL ARGON - 41 Releasesfor the reportingyear: 36.55 Ci YEARL YA VERAGE ARGON- 41 Release Concentration:8.8116x 10-J° uCi/mL

6. Environmental Surveys The firm maintainingradiationrecordsfor the University of Floridakeeps a year to date record, therefore it is easierto report radiationexposure by the nearest completed calendaryear. The followingfilm badge exposures arefor the periodJanuary 1, 2007 to December 31, 2007. Thirteen areas (Numberedfrom 1 to 13) were monitoredfor the entire calendaryear. A list of these numbered areas can be found in UFTR SOP.

Reactor cell is separatelymonitored duringthe same time period.The area radiation exposures are tabulated below. All doses are in unit of mrem.

4

Area No. TEDE 1 2 2 <1 3 <1 4 <1 5 <1 6 <1 7 3 8 <1 9 <1 10 <1 11 <1 12 <1 13 <1 Area DDE LDE SDE, WB TEDE Reactor C < 1 mrem < 1 mrem < I mrem < 1 mrem

7. Radiation Exposures Note that UFTR TechSpecs requires only a summary of exposure received by facility personneland visitors where such exposures are greaterthan 25% of that allowed. Since all personnel exposures duringthis period are below the limits, we provide an exposure summaryfor the UFTR staff The following table illustrates the radiationdosages of 3 workersfor the period January 1, 2007 to December 31, 2007. All the dosages are in mrem.

Individual DDE LDE SDE Berglund, M. < 1 mrem < 1 mrem 40 Vernetson, W. < 1 mrem 16 41 Yenatskyy, M. < 1 mrem < 1 mrem 2 5

UFTR Decommission Report

UFUNIVERSITY UFLORIDA of College of Engineering Department of Nuclear & Radiological Engineering UFTR Nuclear Facilities 202 Nuclear Sciences Bldg.

PO Box 118300 Gainesville, FL 32611-8300 352-392-1401 352-392-3380 Fax www.nre.ufl.edu January 4, 2010 MEMORANDUM TO Decommissioning File FROM: Brian Shea, Reactor Manager

SUBJECT:

Annual Estimate of UFTR Decommissioning Cost per 10 CFR 50.75 The estimated cost for the complete decommissioning of the University of Florida Training Reactor (UFTR) as of December 2009 is $3.28 million. To meet the requirements of 10 CFR 30.3 and 50.75 the decommissioning cost estimate is updated to reflect any changes in pertinent new information. No significant facility modifications or unusual occurrences took place from the previous cost update. The cost update was adjusted based on the Consumer Price Index (CPI) and Low Level Waste Disposal Adjustment Factor. The decommissioning cost estimate is being kept on file as the current cost estimate per NRC requirements.

Consumer Price Index Adjustment Factor (Fcpi)

Consumer Price Index historical data can be found from Department of Labor, Bureau of Labor Statistics:

CPIfor all urban consumers, US city average, all items (Base 1982) ftp://ftp.bls.gov/pub/special.requests/cpi/cpiai.txt (See Appendix A at the end of this attachment)

The adjustment factor of Fcpl,,, will be updated annually by finding the ratio of the current year CPI to the above CPI for December 1982. For example, to calculate Fcp 1for year 1986:

SCPI 1105=1.132 CPI/982 97.6 where, x corresponds to the year when the factor being calculated.

Waste Burial Adjustment Factor (FB)

Waste Burial Adjustment is evaluated using the 1986 data as base cost. The 1986 base cost can be found at U.S. Nuclear Regulatory Commission: Report on Waste Burial Charges (NUREG-1307, Rev.13) (Base 1986) http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/ (See Appendix A at the end of this attachment)

First we adjuste the base from 1986 to 1982:

'92 SB1986=

1. 132 0.883 Then the waste burial adjustment factor for a given year can be evaluated by:

F=B,. _ B, 1" B 1982 0. 883 where, x corresponds to the year when the factor being calculated.

Note that BWR values for Bx are used as they are more conservative than PWR values 2009 Decommissioning Cost = FB .(1982 Cost of Radioactive Waste disposal) +

Fci .(1982 Total Cost Estimate - 1982 Cost of Rad Waste Disposal) 1 1. 198 x (199,000) + 210.2 (541,000 -199,000)

= 3.28million 0.883 97.6 Attachments cc: Facility Director (memo only)

RSRS Members (memo only)

Introduction All reactor facilities, licensed by U.S. Nuclear Regulatory Commission, are required to ensure that decommissioning funds will be available when the facility ceases licensed activities. The University of Florida Training Reactor (UFTR) is owned and operated by a public educational institution in the State of Florida and its decommissioning funds are guaranteed through the State of Florida statement of intent to budget the cost.

To meet the requirements in 10CFR50.82 (b)(1)(ii) and (b)(1)(iii), DECON alternative will be adopted. Decommissioning activities will be completed without significant delay unless prevented by factors beyond the licensee's control (NUREG-1537). The UFTR decommissioning goal would be to safely remove licensed and neutron-activated material from the facility and to remove as much residual radioactivity as reasonably achievable, ensuring that residual radioactivity levels would permit the release of the property for unrestricted use, as defined in NUREG 1757 Vol 1. Residual radioactivity, distinguishable from background, would result in a calculated dose from all pathways to the average member of the critical group not in excess of 0.25 mSv/yr (25 mrem/yr).

The decommissioning cost estimate for UFTR is based on actual vendor price quotes (Coughlin, 2009), prior experience with reactor disassembly, NRC Decommissioning Guidance (NUREG-1757, 2006),

and decommissioning experience of other research reactors (Marske & Hertel, 2001). The cost estimate takes no credit for salvage value of any reactor components.

Facility Description Summary NRC License Numbers and Types License No. R-56, Argonaut-type Reactor Types and Quantities of Materials Authorized Under the Licenses Listed Above Authorized to possess up to 5.2kg of contained Uranium-235, 1 curie sealed plutonium-beryllium neutron source, 25-curie antimony-beryllium neutron source, possess but not separate byproduct material and special nuclear materials as may have been produced by the operation of the facility.

University of Florida Training Reactor The University of Florida Training Reactor (UFTR) is located on University of Florida campus at Gainesville, Florida. The UFTR is a modified Argonaut type reactor, a light water and graphite moderated, graphite reflected, light water cooled reactor. The UFTR originally operated from December 1959 at power levels up to the maximum of 10kW. In 1964 the reactor license was amended to allow operation at power levels up to the current 100kW rating. In 2006 the original HEU fuel was replaced by LEU fuel. The reactor core is heterogeneous in design with 19.75% enriched uranium silicide-aluminum (U 3Si 2-AI) fuel contained in aluminum cladding. Water is used as the coolant and also as the moderator.

Graphite blocks surround the boxes containing the fuel plates and water moderator. Graphite serves as a moderator and reflector. An isomeric sketch of the reactor is presented in Figure 1.1 of the UFTR Emergency Plan. The reactor is used for various types of nuclear research (e.g. Nuclear Activation Analysis) and educational programs. The reactor building, which was built in 1958, is a "vault-type" building as defined in 10 CFR 73.2(o). The building is divided into five segments, including the reactor

cell, staff offices, classroom, and two rooms dedicated for Nuclear Activation Analysis. The current floor plan is shown in Figures 1.2 and 1.3 of the UFTR Emergency Plan.

General Description of Rooms Reactor Cell A 2000-square foot reactor cell encompasses the reactor structure and the reactor control room.

The biological shield around the reactor core is made of cast-in-place concrete 1 to 2 meters thick. A three-ton monorail crane traverses the reactor cell from north to south wall. All of the potentially contaminated equipment is stored in the fenced-off low-level storage area within the reactor cell.

Potentially contaminated waste (personal protective clothing and small common items) is kept within the reactor cell boundary in trash bins. Liquid reactor effluents, including primary/secondary coolants as well as the air conditioning condensate, are stored in a tank, which is also located within the reactor cell.

The tank contents are checked for contamination prior to being transferred to an external holdup tank.

The low-level storage area in is the only commonly utilized area in UFTR that is not surveyed weekly for radiological contamination and thus the only area where surface contamination may exist during everyday facility operation.

A qualitative and quantitative analysis of all potentially contaminated (non-SNM) reactor components was performed in February 2009, when the entire reactor was disassembled. The main radionuclides present in the analyzed samples were europium-152, barium-133, cobalt-60 and zinc-65 with half-lives 13.33, 10.51, 5.27, 0.675 years respectively, see Table 1. Specific Activity listed in Table 1 for Rx Graphite Stringers and Rx Concrete is based on gamma emission analysis using a High Purity Germanium Detection system. The analyzed samples were collected from areas that were exposed to the highest neutron flux.

Structural reactor concrete and reactor graphite combined make up 99% of reactor waste. Given the half-lives of main radioisotopes and 50 years of reactor operation, the current radionuclide concentrations in graphite and concrete are near their equilibrium concentrations, and therefore do not need to be adjusted in the future. For the purposes of the decommissioning cost estimate, it was assumed that all concrete from 0.5 meters under the floor to two meters above the floor, as well as all of the reactor graphite, would be contaminated. Based on decommissioning experience of comparable facilities, this estimate is conservative because two-meter thick reactor walls are expected to be contaminated to the depth of fewer than 0.5 meters.

Table I Quantities of Accumulated Materials and Their Levels of Radiological Contamination Contaminated Weight Specific Activity Actual/Shipping Contact Radiation Material/Component (kg) (nCi/g) Volume (M 3 ) Level (mR/hr)

Co-60: <0.95 Rx Graphite Stringers 13000 Eu-152: <0.1 7.1/8.5 <7 Zn-65: <0.85 Rx Steel (I-beams, shafts, 900 Co-60: 550 0.1/5.6 800 fasteners)

RxSand 1900 Co-60:0.30 1/1.5 <10 Eu-152: 4.6 Co-60: <1.3 Rx Concrete 290000 Eu-152: <2.0 90/180 N/A Ba-133: <0.6 Rx Aluminum (shield tank, 805 Zn-65: <80 0.3/10 10 primary piping)

Combustibles 50 N/A 1./2 <2 NuclearActivation Laboratory The Nuclear Activation Analysis Laboratory (NAAL) is used for processing small batches of activated samples. NAAL is the only location at UFTR, other than the reactor cell, where radioactivity is used and stored. The south NAAL room is used for handling and analyzing sealed radioactive samples and sealed commercial radioactive sources. The north room of the NAAL is used for insertion and removal of samples from the reactor via a pneumatic rapid sample transfer (RABBIT) system. The RABBIT system is used for short neutron irradiation of samples. It is mostly used for generating short-lived radioisotopes with half-lives of less than a day. An 8'x8'xlO' hot cave is located within the north room of the NAAL. It is used for storing and remote handling of highly radioactive items such as thermocouples and steel nuts/bolts that were removed from the reactor core. The RABBIT system glove box and the hot cave are not contaminated as indicated by the swipe survey conducted on March 4, 2009.

Table II Manpower requirements, occupational radiation doses and costs for decommissioning UFTR Person days Total 1982 Costs Time H.P. person Person (Thousands Operation or category (days) Supervisor Foreman Craftsman Tech Tech Clerk -days -mrem of $)

Planning & preparation Prepare documentation* 25 10 25 0 0 0 10 45 0 12.2 Perform radiological survey* 5 0 5 0 10 0 0 15 4 4.3 Develop work plan* 30 20 30 0 20 30 30 130 0 33.0 Subtotals: 60 30 60 0 30 30 40 190 4 50 Decommissioning Rx Concrete Slabs** 3 1, 2 3 1 0 0 7 20 2.2 Rx Graphite** 5 5 5 10 5 10 0 35 1500 10.7 Rx piping and shield tank** 5 2 4 5 5 5 0 21 1000 6.3 RxSand** 4 1 3 4 3 4 0 15 1000 4.5 Rx Structure* 50 30 50 100 25 100 30 335 1000 94.9 Rabbit System** 0.4 0.2 0.4 0.1 0.2 0.7 0 1.6 5 0.5 Workbenches* 0.4 0.1 0 0 0.1 0.2 0 0.4 1 0.1 Rx Vent System* 2.6 1.3 1.9 0.9 1.3 3.9 0 9.3 5 2.8 Washing Machine* 0.2 0.1 0 0 0.1 0.2 0 0.4 0 0.1 Filters* 0.4 0.2 0.4 0 0.2 0.8 0 1.6 0 0.5 Ceiling* 2.2 1.1 2.2 0.5 1.1 4.4 0 9.3 1 2.8 Walls* 4.4 2.2 4.4 0 2.2 8.8 0 17.6 2 5.3 Floors* 2.9 1.5 2.9 0 1.5 5.8 0 11.7 10 3.5 Soil and Concrete Analyses* 10 3 0 0 8 10 5 26 5 6.5 Site Restoration 20 10 20 60 10 40 0 140 2 42.5 Documentation and Reports* 25 10 25 0 10 0 25 45 0 16.1 Subtotals: 136 69 121 184 74 194 60 676 4551 199 Power, Equipment and Material Small tools and materials* 4.1 Protective equipment** 2.4 Commercial Vacuum Cleaner* 2.4 Electric Power 3.5 Heavy equipment rent* 48.6 Subtotals: 61.0 Waste management costs Packaging materials* 8.1 Transportation & disposal*** 105.7 Subtotals: 113.8 Final Radiological survey* 8 4 8 16 8 36 0 9.0 Totals 204 103 189 184 120 224 108 902 4555 433 25% Cost contingency 108 Total cost with contingency 541

• Values based on NUREG/CR-6477

• • Values based on reactor disassembly experience

• • • Value based on 3/9/2009 BIONOMICS radioactive waste disposal price quote

The estimated cost for decommissioning the UFTR is $3.28 million (Table II). The decommissioning is expected to take 1-2 years, and require 5 person-rem to complete. The cost estimate assumes most of the decommissioning work will be performed by contractors. The cost estimate for decommissioning the UFTR reactor facility for years 2009 and beyond will be adjusted for inflation by the consumer price index and the waste burial factor. The cost estimate will be annually adjusted to reflect any changes in pertinent new information such as changes in labor, burial, energy and material costs, recent unusual occurrences and facility modifications. If and when a decision to decommission the UFTR is made, the funds needed for decommissioning will be requested from the State of Florida Legislature as per 10 CFR 50.75(e)(2)(iv).

References U.S. Nuclear Regulatory Commission (2006). ConsolidatedDecommissioning Guidance -

DecommissioningProcessfor MaterialsLicensees (NUREG-1757 Vol.1, Rev2). Washington, DC.

U.S. Nuclear Regulatory Commission (1996). Guidelinesfor Preparingand Reviewing Applicationsfor the Licensing of Non-Power Reactors - StandardReview Plan and Acceptance Criteria(NUREG-1537 Vol.1, Rev2). Washington, DC.

U.S. Nuclear Regulatory Commission (2006). ConsolidatedDecommissioning Guidance - Financial Assurance, Recordkeeping,and Timeliness (NUREG-1757 Vol.3). Washington, DC.

Coughlin, W. (bcoughl@ehs.ufl.edu) (9 March 2009). RE: Reactor rad waste disposal quote status. Email to: Yenatskyy, M. (yenmike@ufl.edu).

Marske, S., Hertel, N. (2001). Decommissioning Of The Georgia Tech Research Reactor.

WM'01 Conference, Tucson, AZ

U.S. Department Of Labor Bureau of Labor Statistics Washington, D.C. 20212 Consumer Price Index All Urban Consumers.- (CPI-U)

- U.S. city average All items 1982-84=100 Year Jan. Feb. Mar. Apr. Yay June July Aug. Sep. Oct. Nov. Dec.

97.6, 1982 94.3 94.6 94.5 94.9 95.8 97.0 97.5 97 .7 97.9 98.2 98.0 1983 97.8 97.9 97.9 98. 6 99. 2 99.5 99.9 100 .2 100.7 101.0 101.2 101.3 1984 101.9 102.4 102.6 103.1 103.4 103.7 104.1 104.5 135.0 105.3 105.3 105.3 1985 105.5 106 . 0 106.4 106.9 107.3 107.6 107.8 108 . 0 108.3 108.7 109.0 109.3 04 1986 109.6 109.3 108.8 108.6 108.9 109.5 109.5 109.7 110.2 110.3 110.4 k .1 0 . 5.,

1987 111.2 111.6 112.1 112.7 113.1 113.5 113.8 114.4 115.0 115.3 115.4 115.4 1988 115.7 116.0 116.5 117.1 117.5 118. 0 118.5 119.0 119.8 120.2 120.3 120 .5 1989 121.1 121.6 122.3 123.1 123.8 124 . 1 124.4 124.6 125.0 125.6 125.9 126.1 04 1990 127.4 128.0 128.7 128. 9 129.2 129.9 130.4 131.6 132.7 133.5 133.8 133.8 1991 13 4. 6 i34.8 135.0 135,.2 135.6 136.0 136.2 136.6 137.2 137.4 137.8 137.9 1992 138.1 138.6 139.3 139.5 139.7 140.2 140.5 140.9 141.3 141.8 142.0 141.9 1993 142.6 143.1 143.6 144.0 144.2 144.4 144. 4 144.8 145.1 145.7 145.8 145.8 04 1994 146.2 146.7 147.2 147.4 147.5 148.0 148.4 149.0 149.4 149.5 149.7 149.7

-H a 1995 150.3 150.9 151.4 151.9 152.2 152.5 152.5 152.9 153.2 153.7 153.6 153.5 1996 154.4 154.9 155.7 156.3 156.6 156.7 157.0 157.3 157.8 158.3 158.6 158.6 1997 159.1 159.6 160.0 160.2 160.1 160.3 160.5 160.8 161.2 161.6 161.5 161.3 N 1998 161.6 161.9 162.2 162.5 162-.8 163.0 163.2 163.4 163.6 164.0 164.0 163.9 1999 164.3 164.5 165.0 166.2 166.2 166.2 166.7 167. 1 167.9 168.2 168.3 168.3 C 2000 168.8 169.8 171.2 171.3 171.5 172.4 172.8 172.8 173.7 174. 0 174.1 174.0 ox 2001 175.1 1"!75. 8 176.2 176.9 1 17.7. 178 . 0 177 .5 177.5 178.3 177. 7 177.4 176.7 2002 177.1 177.8 178.8 179.8 179.8 179.9 180. 1 180.7 181.0 181.3 181.3 180.9 S 2003 181.7 183.1 184.2 183.8 183.5 183.7 183.9 184. 6 185.2 185.0 184.5 184.3 2004 185.2 186.2 187.4 188.0 189.1 189.7 189.4 189.5 189.9 190.9 191.0 190.3 2005 190.7 191.8 193.3 194.6 194.4 194 .5 195.4 196.4 198.8 199.2 197.6 196.8 2006 198.3 198.7 199.8 201.5 202.5 202.9 203.5 203.9 202.9 201. 8 201.5 201.8 200"7 202.416 203.499 205.352 206. 686 207. 949 208. 352 208. 299 207. 917 208 490 208. 936 210. 177 210,036 2008 211.080 211.693 213.528 214,823 216.632 219. 815 219 964 219.086 218.783 216.573 212.425 ..2-1-0.228 2009 215.949 211. 143 212. 193 212.709 213.240 213. 856 215.693 215. 351 215,834 215.969 216. 177 216.330

Attachment 7-Appendix B Waste Burial Adjustment Data 2 Summary The elements of decommissioning cost, per 10 CFR B. is evaluated by recalculating the costs of 50.75(c)(2), are assigned to three categories: those that are burial/disposition of the radioactive wastes from the refer-proportional to labor costs, L,; those that are proportional ence PWR (Ref. I) and the reference BWR (Ref. 2) based to energy costs, F,; and those that are proportional to on the price schedules provided by the available burial burial costs, B,. The adjustment of the total sites/waste vendors for the year of interest. The results of decommissioning cost estimate can be expressed by these recalculations are presented in Table 2.1, by site and by year. Effective July 1, 2000, different price schedules Estimated Cost (Year X) at the South Carolina burial site applied for states within

= [1986 $ Cost] [A L - B E, t-C BJ] and outside the newly created Atlantic Compact, comprised of South Carolina, Connecticut, and New where A, 8, and C are the fractions of the total 1986 Jersey (see footnote (c) in Table 2. 1). Effective July 1, dollar costs that are attributable to labor (0.65), energy 2008, waste from states that are not members of the (0.13), and burial (0.22), respectively, and sum to 1.0. Atlantic Compact will not be accepted at the South The factors L,, E,, and B, are defined by Carolina disposal site. Licensees not located in either the Northwest or Atlantic Compacts should use the B, values L, = labor cost adjustment, January of 1986 to January for the Generic LLW Disposal Site. Issues of this report of Year X. prior to 1998 considered direct disposal of LLW at an available LLW disposal site as the only LLW disposition E, = energy cost adjustment, January of 1986 to option. This report includes the additional LLW January of Year X, and disposition option of turning over the majority of the LLW generated during decommissioning to waste B,= LLW burial/disposition cost adjustment, January of vendors for disposition. The B, values for this option are 1986 to January of Year X (i.e., burial/disposition also provided in Table 2.1 for the years 1998 through cost in January of Year X divided by burial cost in 2008 (see footnote (d) in Table 2.1). It is left to the January of 1986). licensees to determine whether direct disposal or disposition using waste vendors best represents their Licensees are to evaluate L. and F, for the years particular situation.

subsequent to 1986 based on the national producer price indexes, national consumer price indexes, and local conditions for a given site (see Chapter 3).

Table 2.1 Values of B, as a Function of LLW Burial Site, Waste Vendor, and Vear(a)

B, Values for Washington Site' 13,Values Ior South Carolina Site H\ Values for Generic LILW Disposal Atlantic Compact"' Non-Atlantic CompactO: Site'&'

Direct Disposal Direct Disposal Iircct Disposal Direct Disposal Direct Disposal Direct Disposal Direct Disposal s Ihn Direct Disposal with Vendors-Year PWR BWR PWR BWR PWR LtVR 1\VR PWR BWR P1WR 13WR PWR BWR PWR BWkR 2008 8.283 23 185 5 153 20.889 25.231 22.504 9.872 11.1P8 NA NA NA NA 25.231 22.504 9.872 11.198 2006 6.829 11.702 3.855 9.008 22.9333 20.451 8.600 . 23.030 20.813 8.683, 10,206 NA NA NA NA 2004 57374 13.157 200 3.8t6 11,755 19.500 17.389 7.790 8.347 21.937c

... 7.970 16.705 7,9-34 79.467 8.8i3 83 NA N N NAA NA 2002 3.634 14.549 5748 15571 17.922 15.988 9.273 8.626 18732 16.705 9.467 8.860 NA NA NA NA 2000 2.223 3.375 4.060 4.-7') 17.922 15.987 7878 7.943 18,120 16.244 8,052 8.189 NA NA NA NA 1998 1 65 14.403 4.538 15.203 15.886 1.948 7 173 6.968 NA NA NA NA NA NA NA NA (a) The values shown in this table are developed in Appendix B, with all values nonnalized to the 1986 Washington PWRI/BWR values by dividing the calculated burial costs for each site and year by the Washington site burial costs calculated Ior the year 1986.

(b) Effective I/1"93. the Washington site is not accepting waste from outside the Northwest and Rocky Moutntain Compacts.

(c) Effective 7/1/2000. rates are based on whether a waste generator is or is not a member of the Atlantic Compact.

(d) Effective 7/1/2008. the South Carolina site is not accepting waste from outside the Atlantic Compact.

(e) B. values for the Generic site are assumed to be the same at that provided for the Atlantic Compact. fo~rlack of'a better alternative at this time.

(1) Effective with NUREG-1307, Rev. 8 (Ref. 3). turning over the majority of LLW to waste vendors for disposition is considered a possibilit.

(g) Calculated using the "flat rate" cost method. See Sections B.2 and B.3.