ML20076E106

Requests Termination of License R-58 Before GL Blackshaw Departure on 830630.Facility Dismantled Per Approved Procedures Following Receipt of 800122 Authorization

ML20076E106
Person / Time
Site:	05000129
Issue date:	05/23/1983
From:	Collins W WEST VIRGINIA UNIV., MORGANTOWN, WV
To:	Thomas C Office of Nuclear Reactor Regulation
References
NUDOCS 8305260308
Download: ML20076E106 (28)

Text

g West Virginia University geg;*;ig,"jg, Academic Affairs & Research N Morgantown, West Virginia 26506 May 23, 1983 Mr. Cecil 0. Thomas, Chief Standardization and Special Projects Branch Division of Licensing Mail Stop 340 United States Nuclear Regulatory Commission Washington, DC 20555 RE: License R-58, Docket No. 50-129

Dear Mr. Thomas:

This is to officially request termination of NRC License R-58, Docket No.

50-129 which is currently held by West Virginia University in conjunction with its formerly owned AGN-211P Nuclear Reactor (Serial No. 103). Following receipt of the NRC's January 22, 1980 letter authorizing West Virginia Univer-sity to dismantle the reactor, the facility was disassembled according to approved procedure.i..

The reactor fuel elements, all control / safety rods, electromechanical rod drive mechanisms, and some peripheral hardware have been sent to the University of Oklahoma. The remaining parts of the reactor (control console, superstructure, etc.) were junked. Prior to shipment and/or disposal of reactor components, radiation surveys and wipe tests were conducted to ensure that no radioactive contamination existed as a result of reactor operations. Also, Rooms B-30 and B-31 in Hodges Hall, which were the site of the AGN-211 P Reactor Facility, were surveyed and certified to be free of radioactive contamination by the University's Radiation Safety Office. At present, these rooms are being utilized as a physics research laboratory.

We are simultaneously requesting an NRC site inspection visit from the Region II Administrator, Mr. John T. Collins for purposes of license termination. Also enclosed are copies of the letter to Mr. Collins, the results of radiation surveys and wipe tests of reactor components and at the facility site, and other corres-pondence and paperwork which document the decommissioning efforts to date.

West Virginia University would like to obtain closure on the R-58 reactor license termination process prior to Dr. G. L. Blackshaw's departure from the University on June 30, 1983. He has been Acting Reactor Director for nearly ten years and is familiar with many facets of the reactor facility. He has recently been talking with Ms. Pat Anderson of the NRC concerning steps to be taken to effect license termination. Please direct any questions you might have to either:

Dr. G. L. Blachhaw Acting Reactor Director College of Engineering J

West Virginia University /

Morgantown, West Virginia 26506 Phone: (304) 293-4821 8305260308 830523 PDR ADOCK 05000129 W PDR

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i Mr. Cecil 0. Thomas, Chief - RE: License R-58, Docket No. 50-129 Page 2 May 23, 1983 or, Dr. Steven T. Slack University Radiation Safety Officer Room G-210 University Hospital West Virginia University Morgantown, West Virginia 26506 Phone: (304) 293-341 Thank you.

Sincerely.

f.

illiam E. Collins Vice President Academic Affairs and Research WEC:bam cc: G. L. Blackshaw S. T. Slack John T. Collins - NRC Region II Administrator This SI day of 77ae/ , 1983, William E. Collins, a person known to me personally, appeared.;before me, a Notary Public, swore that he is the person named herein and affixed his signature to this letter.

My commission expires hbM/ . 87 h.s ,w suY - e x c e.c Notary Public in and for Monoht;alia County, West Virginia

W West Virginia University e gge;ifo,"jg,^c demic ^rr.ir, a Reseirch b Morgantown, West Virginia 26506 May 23, 1983 Mr. John T. Collins Regional Administrator - Region II United States Nuclear Regulatory Commission

• 101 Marietta Street Atlanta, Georgia 30303 Re: License R-58, Docket No. 50-129

Dear Mr. Collins:

This is to officially request an NRC cite inspection visit for the purpose of terminating NRC License R-58, Docket No. 50-129 which is currently held by West Virginia University in conjunction with its formerly owned AGN-211P Nuclear Reactor (Serial No. 103). The attached letter to Mr. Cecil 0. Thomas of the NRC should clarify our actions with respect to this request and be considered an official addendum to this request. Also are enclosed are copies of all material being sent to Mr. Thomas. As noted in the letter to Mr. Thomas, you should contact either Dr. Blackshaw or Dr. Slack concerning special details related to the reactor facility and/or your site visit.

. Thank you.

Sincerely, William E. Collins Vice President -

Academic Affairs and Research WEC:bam cc: G. L. Blackshaw S. T. Slack Cecil O. Thomas, NRC Chief This day of , 1983, William E. Collins, a person known to me personally, a'ppeared before me, a Notary Public, swore that .

he is the person named herein and affixed his signature to this letter.

1 l My commission expires .

1 Notary Public in and for Monongalia County, West Virginia 1

O e

• t W OSt hirginia, MEDICAL CENTER TJniversity MoRGANToWN. WEST VIRGINGA 28508 Schoolof Medicine Department of Radiology

• Division of Medical Physics and Radiation Safety Telephone: 304-293-3413 May 20 1983 TO: G. Lansing Blackshaw FROM: Donald C. Turner, 0"N b %

Radiation Health Technician RE: Contamination levels in the vault I have reviewed the wipe test records on the Hodges Hall Vault (Room 132 Hodges) and conclude that the room is mildly contaminated, (See Attachments). It is certain that the contamination predates the storage of the. reactor components in the room. The reactor components were individually wipe tested before and af ter storage, and no contaminatior. was found. See Memos (01 April 1980, 10 August 1982, and 18 November 1982). There is some tritium contamination on the shelves, floor and walls of the room and there is a little higher energycontamination. The overall contamination level is less than 1 x 10 microcuries per hundred square centimeters. The vault was the University storage area for radionuclides for a number of years and -

it is not surprising that there is some contamination.present.

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Division of Medical Physics and Radiation Safety Telephone: 304 293 3413 May 19 / 1983 TO; G,L, Blackshaw FROM: Donald C. Turner, D - '

AW $ "i Radiation Health Technician REs Summarized Data on Wipe Tests Performe.d at Old Reactor Site.

Between 11 June 1980 and 07 February 1983 eleven wipe tests were performed in the old reactor site room. Only area H (See Attached Floor Plan) shows any significant counts that cannot be attributed to variations in the calibration of the Liquid Scintillation Counter over the years. Area H is the Hood where Dr. Montano has been doing radionuclide work since May 1980.

I conclude ~ that there is no contamination present.that is traceable to the reactor nor has there ever been any.

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WeEst Virginia, MEDICAL CENTER ,

UniVQ7$1ty MORGANTOWN. WCST V1RGlN8A 28508 School of Medicine Department of Radiology '

Division of Medical Physics and Radiation Safety Telephone: 304 293 3413 Noverter 18, 1982 M: G. 1.ansing Blackshaw FRN: Donaid C. Turner MuwIl C. @t.m RE: Results of R,eactor Fuel and shipping barrel leak test.

Enclosed are two copies of the leak test performed on the reactor fuel elements and the shipping container. I certify that the -

leakage is less than the .005 micorcuries required for shipnent of the elements. I also certify that the shipping container is free of contamination. ,

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Report on Leak Tests of Reactor Rods The fuel elements of the reactor were wiped on 14 November 1980 when they were packed in the barrel for shipment to the University of Oklahoma. All of the elements were wiped on the outside of the plastic which covers them. No alpha contamination

-was detected on any of these elements. On one element (;B-3) on which the paint had slaughed off I took a wipe on_th uranium. I detected an alpha activity of 2.03' x 10-g uCi. bare This is not enough to be considered nignificant leakage. The drum that the elements were removed (? rom was checked for contamination and no leakage was found in it either. (See attached copy)

I conclude that there is no significant leakage and that the elements may be se.fely shipped.

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WOSt Virginia M EDIC At. CENTER Un1MerSity " o a o a " ' o " "- "c5' v ' o ' " ' a **505 School of Medicine Department of Radiology ~

Division of Medical Physics and Radiation Safety Telephone: 304-293-34,13

. -10 August 1982 TO: G. Lansing Blackshaw

' ~ ~ ~ TROM: 'D6dald"C. Tu'rner Radiation Health Technician .

'ReTdlEs of Neactor fuel and shipping barrel leak test.

RE: ,

Enclosed are two copies of the leak -tests performed on the

-reactor fuel " rods" and the shipping container. There is no

.. detectable leakage. I certify that the leakage is less than the

.005 microcuries required for shipment of the fuel. I certify that the shipping container is fre.e of significant contamination (i.e.

. Its just like any other normal barrel).

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West hirgillia MEDICAL CENTER University e MORCANTOWN. WE$T VIRGINIA 26506 Schoolof Medicine Department of Radiology '

-Division of Medical Physics and Radiation Safety Telephone: 304-293-3413 April 1, 1980 TO: Lance Blackshaw FROM: Donald C. Turner Radiation Safety Technician

. RE: Results of Wipe tests of reactor room and- '

reactor components taken'.during~~the dis- .

mantlement period All wipe' tests were taken using Q tips. A 100 sq cm area of each component was wiped and an identi-fication number was placed on each component as it was removed from the room. In addition varying volumes

-of sludge and rust and dirt were collected and analyzed as the opportunity presented itself..

All samples were counted for 100 minutes each in a Nuclear Chicago Automatic Gamma Well Counter with the following settings; Gain =8, Attenuator=25, Base =

50 key, Window = Integral (Energy range 50 key through 2000 key),

, The purpose of using an integral window was .to -

i determine if there was any discernable radiation above background. If.so othar methods were to be used to'de-termine the specific gamma ray energy and the radionuclide identity. As it turned out only two samples showed any significant activity above background these will be discussed in more detail below.

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sAnalysi.s of. an anomaly found in the dirt taken from location 2 of the reactor room. floor.

At the time of the removal of the last of the core components of the reactor, -the floor of the room was swept. An gamma ana-lysis of this dirt showed a net CPM of 20 CPM above background.

This sample weighed 4 grams and we calculated a 4 CPM gram above background. ,

We then placed this sample in front of a Germanium Lithium Crystal Multi-channel analyzer [Tracor Northern TN-] 705 (2000 volts positive, coarse gain 50, fine gain ]2.0, LLD 47, ULD 1000)]. We took sample readings and background readings for

'50,000 seconds. . ,

The net difference in the integrated total for all channels

.for sample and background was 35,596 counts. Indicating that cthere was a detectable gamma activity in the sample.

'We then compared the results-of the counts for various regions

~

~ of the spectrum. The sample was: found to.have ,a. higher activity 1

'in all regions of the spectrum. There is no area of the spectrum which seems to be safely responsible-for the difference. We

, -thus conclude that this sample of dirt contains no unusual

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radionuclide contaminants, but that it is merely a variation in 1

uthe background. A check of the literature indicates that it is not unusual to find variations of an order of magnitude in

. -background samples.

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I Summary:

r l The only results which varied by more than three

standard deviations from the background were the air sample V 18 page 2, the Reactor Floor dirt Glass tube f i 30 page 2, Reactor Floor Dirt #4 Page 3; and Concrete Rubble taken from the floor in the front of the room l

location 9 of the map Page 3 #12. -

The air sample ran for 7 cycles and pulled 350,000 liters of air through the filter. This works out to a net activity of 6.3 x 10-13 uCi liter. It can be. ignored.

The other samples are just dirt and rubble and the variations just reflect variations in the background radionuclide level. There is no evidence of any contamination by fission by products' (see. analysis of Reactor floor dirt) . I conclude that there is no reason why the room could not be turned over to Dr. Montano to use as a part of his laboratory,

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/ We St Virginia ll MEDICAL CENTER ,

! University MORGANTOWN. WCST VIRGINIA 2650G l

1 Schoolof Medicine Department of Radiology ,

Division of Medical Physics and Radiation Safety .

Telephone: 304 293-3413 February 6, 1980 TO: Lance Blackshaw FROM: Donald C. Turner Radiation Safety Technician RE: Results of Reactor Water Analysis taken on 30 Jan 1980.

.Water samples from.the reactor were counted in alpha, .

, .C7 :

-- - .- d.bM.;'td .'a'n6%aum@ .coun t!Er' sib 6ETdEir-if. @.5T.in Jand 01- Teb 'O 86. ' "'7d'S.25 O

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- . .' .I. ,All samples were counted fod '10 -minutes each in a ~

i

- Huclear Chicago Automatic Gamma Uell Counter with tne following settings: Gain = 8, Attenuator = 25, Base =

50 key Window = Integral (Energy Range 50 key through 2000 kev) l II. A Beckman LS. 9000 Liquid Scintillation Counter with automa tic quench correction

• and H numbers to assure quality control. Lower limit 0 upperlimit 655 program'

1. -

III. Alpna Counter:

An Eberline Laboratory Counting System LCS-1 at 1700V 0-2kv.

I _. A t tachmen t .

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jb ~ . ,

Gross _ cpm _ _ Ne t cpm I. -Ba'ckground 78.0 0

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Reactor Saraple 71.9 0 137 Cesium Standard 31158.2 31086.3 Counter Efficiency = 9. 69.

Minimum Detectable Activity 8.37 cpm 137Cs Standard .luci April 1971 II. .

Background 28,00 0 Reactor Water 29.0 1.

.s III. Background 1.0 0

. Reactor Water 1.0 . 0 226. Radium Stand. 2527.6 2526.6 226 Ra = .0063 uCi Since these tests show that as far as radionuclide

^

\

-contamination is concerned the reactor water is the l

same as Monongahelia County tap water, I conclude that l

it would .be safe to discard the wa ter.

l l

! College of En0incering . Morgantown, West Virginia u". 304 293-4821 26506 November 29, 1982 W

w .

' WestVirginia ,

-University Mr. Dennis M. Crutchfield, Chief Ope' rating Reactors Branch No. 5 .

-United States Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Crutchfield:

RE: License R-58, Docket No. 50-129 On November 19, 1982 West Virginia University (WVUO sent the.last of the fuel elements for its AGN-211 Reactor (Serial No.103) to the

. University of Oklahoma., This was permissible under NRC's dismantling

< -order for the reactor dated January 22, 1980. At this time disposal of all reactor components has been completed with the exception of the

-Ra-Be start-up source.

- % University of Oklahoma, which had been authorized to possess the WVU reactor fuel under an amendment to its R-53 license, received 235 U), reflector

-from WVU all the' reactor fuel (12 elements - 800.12 g elements, all control / safety rods, plus electromechanical rod drive mechanisms and some peripheral hardware. WVU junked the remaining parts of the reactor (control console,- superstructure, etc.) following radiation surveys and wipe tests to ensure that no radioactive con-tamination existed.

h now plans to conduct a radiation survey of the former reactor

-and fuel storage sites in preparation for what I assume will be a final NRC inspection visit. The single remaining loose end is the fate of the Ra-Be start-up source (believed to be about 100 millicuries in strength) .

Although not specifically mentioned in the reactor license, it should probably be incorporated into an existing NRC license at WVU to provide a short-term solution for termination of the reactor license.

This letter is primarily for information purposes; however, if you would wish to make suggestions regarding License No. R-58 termination procedures, please do so. By the way, Peter Erickson has been most

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., 3 J ,

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(, - fN Equal Opportunity / Affirmative Action institution -

.,,.~ .

Mr. Dennis M. Crutchfield Page 2

- November 29, 1982 .

helpful throughout the entire duration of the reactor dismantling /

• disposal procedure. Without his expert guidance, we would not have

.been able to accomplish what we have done to date.

Sincerely,

.  ::^ g G. Lansing Blackshaw Associate Dean - Academic Affairs Acting Reactor Director GLB:bam cca Peter Erickson - NRC Dr. Steve Slack - WVU Radiation Safety Officer Dr. Curtis J. Tompkins - Dean of Engineering Dr. William E. Collins - Vice President for Academic Affairs and Chairman of WVU Radiation Safety Committee e

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UNITED STATES 8 i s. s., ( , ' o NUCLEAR REGULATORY COMMISSION

'f* , -. (g, . I WASHINGTON, D. C. 20555

%,U [/e January 22, 1980 Docket No. 50-129

~

'Dr. G. Lansing 31ackshaw J College of Engineering -

West Virginia University  ;

Morgantown, West Virginia 26506

Dear Dr. Blackshaw:

The Comission has issued the enclosed Order that authorizes you to dismantle the AGN-211P Reacter in accordance with your application dated September 27, 1979, as supplemented November 30, 1979. The  !

dismantling plan replaces the Technical Specifications in their l

entirety.

The related Safety Evaluation, Environmental Impact Appraisal, and Negative Declaration are also enclosed.

l

--A copy of the Order and Negative Declaration are being filed with l the Office of the Federal Register for publication.

Sincerely,

' ~t- $' -

Robert W. Reid, Chief Operating Reactors Branch #4 -

- Division of Operating Reactors

Enclosures:

1. Order Authorizing Dismantling

2. . Safety Evaluation

-3. Environmental Impact Appraisal

4. Negative Declaration ec: w/ enclosures See next page

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West Virginia University cc: -w/ enclosure (s)

--Office of the Governor State of West Virginia

. Charleston, West Virginia 25305 estVirginiaUniversityfbs'  ;;q[

Department of Political Scihnce --

ATTN: Committee of State Officials on Suggested State Legislation antown, West Virginia 26505

~

cc: w/ enclosure (s) & incoming dtd.:

9/27/79 and 11/30/79 State Department of Health ATTN: State Director of Health State Office Building No.1

-1800 Washington Street, East .

Charleston, West Virginia 25305 i

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- UNITED STATES .J590-01 f f

'WUCLEAR REGULATORY COMMISSION

{ s, .s., f ; g wasHowcrow, c.c.zosss t a

.  %[ * # -WEST VIRGINIA UNIVERSITY _

' DOCKET NO. 50-129

- . ORDER AUTHORIZING DISMANTLING OF FACILITY AND DISPOSITION OF COMPONENT PARTS By application dated September 27, 1979, as supplemented November 30, l

1979, the West Virginia University (the licensee) requested authorization to dismantle the AGN-211P Reactor (Serial No.103) (the facilityy, a .

-research reactor located in Morgantown, West Virginia, and to dispose of the component parts, in accordance with the plan submitted as part of the application. A " Notice of Proposed Issuance of Orders Authorizing Dis-mantling of Facility, Disposition of Component Parts, and Termination of Facility License" was published in the Federal Reaister on October 29, 1979 (44 FR 62087). No request for a hearing or petition for leave to intervene was filed following notice of the proposed action.

. The Nuclear Regulatory Comission (the Comission) has reviewed the application in accordance-with the provisions of the _Comission's rules and regulations and has found that the dismantling and disposal of com-

--ponent parts in accordance with the licensee's dismantling plan will be in accordance with the regulations in 10 CFR Chapter I, and will not be inimical to the comon defense and security or to the health and safety of the public. The basis for the findings is set forth in the concurrently

~ ~

~ issued Safety Evaluation by the Office of Nuclear Reactor Regulation.

"The Comission has prepared an -environmentalimpact appraisal for

~

this action. Based on that appraisal, the Commission has detemined that

~

this action will not result in any significant environmental impact and that an environmental impact statement need not be prepared.

Ir^'

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. ; . K-

- 2- 7590-01

. \

. l Accordingly, West Virginia University is hereby authorized to j dismantle the AGN-211P Reactor (Serial No.103)-covered by Facility

. 1.icense No. R-58, as amended, and dispose of the component parts in

. :accordance with their dismantling plan and the Comission's rules and

-regulations.

After completion of the dismantling' and decontamination, the submission of a report on the radiation survey to confim that radia- ,

- tion levels in the facility area meet the values defined in the dis- g j mantling plan and inspection by representatives of the Comission, consideration will be given to whether a further order should be issued terminating Facility License No. R-58. .

For futher details with respect to this action see (1) the application for authorization to dismantle facility and dispose nf component parts dated September 27,'1979, as supplemented November 30, 1979, (2) the Comission's related Safety Evaluation, (3) the Cosmission's Environmental Impact Appraisal, and (4) the Comission's Negative -

Declaration dated 01/22/80 (which is also being published in the Federal Recister). All of these items are available for public inspection at the Comission's Public Document Room,1717 H Street, N.W., Washington, D. C. A copy of items (2) and (3) may be obtained upon request addressed to the United States Nuclear Regulatory Comission, Washington, D. C. 20555,

~~~

Attentioni " Dire ~ctor, Division of'Uperatinglea~ctors.

~

l Dated at Bethesda, Maryland, this 22nd day of-January,1980. ,

' ~

FOR THE NUCLEAR REGULATORY COMMISSION l

William . Gamill, Acting Assistant

~

Director for Operating Reactor Projects Division of Operating Reactors ,

. i

- - , - - - - - - - - - - , - , - - , - - - - - - - - - - _ _ _ _ _ - . - - - - - - -e- -, e e-ews a - - - - - - - - -

i

1. o g ,

uni [ED STATES

! n NUCLEAR REGULATORY COMMISSION

-WASHINGTON, D. C. 20555 h  ;

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

......o SUPPORTING ORDER AUTHORIZING DISMANTLING 0F FACILITi AND DISPOSITION OF COMPONENT PARTS

-WEST VIRGINIA UNIVERSITY AGN-211P REACTOR DOCKET NO. 50-129 Introduction

By application dated September 27, 1979, as supplemented November 30, 1979, the West Virginia University (the licensee) requested authorization to dis-mantle the AGN-211P (Serial No.103)~ Reactor and dispose of its component parts in accordance with its dismantling plan.

Discussion The AGN-211P Reactor is a small research reactor designed to operate at a maximum power of 75 watts. The reactor core consists of a matrix array of ,

12 fuel elements that are surrounded by 30 graphite reflector elements.

The fuel and graphite elements are held vertically in a steel grid plate.

-The entire core is situated at the bottom of a ten-foot deep water-filled tank. The fuel elements consist of 20% enriched UO2 pellets fused in a polyethylene moderator. The total fuel lor. ding is 800 grams of U235.

All fuel has been removed from the reactor and is now stored onsite in the

! locked shielded " Isotopes Storage Vault" in three separate steel containers.

The Ra-Be neutron startup source is stored in the Isotopes Storage Vault in a water-filled drum. The fuel assemblies were surveyed when removed from l thg core. Surface contamination was determined to be less than 1000 dpm/100 cm' (removable) and activation of 4 MR/hr or less at 1 cm. The startup source will be transferred to a Department of Transportation (DOT) approved 5hlpping container and remain in the Isotopes Storage Vault until shipped offsite.

l Pool water measurements show activity levels consistent with tap water with no

- detectable _ activity _ associated with reactor operations. Control rods, safety rods, guide tubes and other components removed from the reactor structure show no detectabib activation or contamination. ,

Evaluation The licensee proposes to transfer reactor pool water (not radioactive) to the stonn drains, to disassemble the reactor components and to remove those components, the ' reactor tank and concrete shield blocks from the reactor room.

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Usable components, which may be transferred to another university, will be

-decontaminated, if necessary, and stored-in the Isotopes Storage Vault. Non-usable components will be decontaminated, if necessary, and disposed of as scrap.

Disposable components are the graphite themal column, steel water tank and concrete shield blocks. ,

4

. Radioactive contamination and activation of reactor components are expected to be at or near background because' fuel elements exhibited very low con-

.tamination and the stainless steel control rod blades and other components that were removed exhibited no detectable contamination or activation. All work will be accomplished under the supervision of the Univeristy Radiation l

Safety Office. Releasing the pool water to the stom drains is acceptable since the pool water has been shown to be free from radioactive contamination.

- The licensee proposes to store the fuel, the startup source and usable reactor hardware in the Isotopes Storage Vault:until they are shipped to another authorize'd licensee. If the fuel, startup source and reactor components are not shipped to another licensee, the fuel and startup source will be shipped to the Oak Ridge National Laboratory. Other reactor components would be either used at the University for non-nuclear related activities or scrapped if not sent to another licensee for reuse in a reactor. Components that,are put to use in non-reactor operations will be surveyed for contamination and activation.

The licensee will, assure that contamination of all components put to other use or disposed of as scrap is less than values given in Regulatory Guide 1.86 and l that activation is not above natural background.

The physical security plan will remain in effect until the fuel is shipped offsite.

Following completion of the dismantling activities, the NRC will inspect the

-facility to confirm that it has been dismantled in accordance with the dis-

~ mantling plan.

Conclusion We have concluded, based on the considerations discussed above, that dis-

mantling the AGN-211P Reactor and disposing of component parts. as described l - --in the-dismantling-plan will-not -be inimical-to the. common defense and l security or to the health and safety of the public.

~ 1 ated: 'Jenuary 22, 1980 I

l l

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1. o g UNITED STATES 8 g NUCLEAR REGULATORY COMMISSION g j WASHINGTON, D. C. 20555 l

'+, . . . . . .o! ENVIRONMENTAL IMPACT APPRAISAL BY THE .

OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING ORDER AUTHORIZING DISMANTLING OF FACILITY AND DISPOSITION OF COMPONENT PARTS

. WEST VIRGINIA UNIVERSITY

~

AGN-211P REACTOR DOCKET NO. 50-129 Introduction The West Virginia University (the licensee) AGN-211P Reactor operated at a maximum of 75 watts and was used primarily for research and the teach-ing and training of students in various fields of nuclear technolo~g y. The l licensee estimates' that the reactor operated for about 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> each year at 75 watts over a 12-year period. The reactor has not operated since i February 1971, and the University has no need for it now. Therefore, the reactor will be dismantled and compone'nt parts reused at another facility )

l l

l or disposed of. l All fuel and the radioactive startup source have been removed from the reactor and are stored onsite in the University's Isotopes Storage i Vault. The fuel and startup source will be shipped to the Department of 1

Energy (DOE) Oak Ridge facility or to another licensee for reuse. All reactor components remaining are expected to be near background levels of radiation (activation and contamination) because of the low power and short operating history of the reactor. Checks of some of the internal reactor components confirm this assumption.

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Facility No changes to the structure of the building, electrical services, water lines or sewer lines are required in the dismantling of the reactor. ,

Environmental Effects of Disassembly and Disposal .

The reactor components are near background levels in radioactive contamination and activation-because of the low power, short operation history of the reactor. If contamination is found, it will be reduced to acceptable levels (less than values specified in-Regulatory Guide 1.86) by decontamination. The reactor components will be transferred to another licensee for reuse in another reactor or will be used by the University for non-reactor related activities. The unusable reactor components will ,

l be scrapped. The fuel and startup source will be transferred to another licensee or to the DOE Oak Ridge facility.

A description of the disassembly operation is provided in the licensee's l

September 27, 1979 submittal. There will be no significant exposure to

( personnel or the generation of radioactive wastes <iuring the dismantling 1

operation because all components are at very low levels of radioactivity.

The fuel and startup source will be packaged in accordance with U. S.

Department of Transportation (DOT) requirements prior to shipment offsite.

Other components will be decontaminated prior to shipment, if necessary, and would therefore require no-special,-DOT approved, shipping containers. ,

= Alternatives to. Dismantling-of--the Reactor-and Disposa14f-Components The reactor has not been used for some time and is of no present or future value to the University. It occupies space which can be used by the University for other purposes.

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Long Term Effects of Dismantling and Disposal of the Reactor Components Upon removal of the reactor components, the West Virginia University reactor facilkty rooms will be used for other purposes. The reactor .

fuel will be used by another licensee or reprocessed at the DOE Oak

-Ridge facility. The reactor components will be put to use by another licensee or used in non-reactor related projects at the West Virginia University.

Costs and Benefits of Facility Dismantlina and Alternatives The costs of dismantling and transfer of reactor components to another

' licensee are estimated to be less than $20,000. There'is no reasonable alternative to the proposed dismantling and disposal of the reactor.

Conclusion .

We conclude that there will be no significant environmental impact

- associated with the dismantling of the facility and the disposal of its component parts, and that no environmental impact statement is required to be written for the order authorizing dismantling of the AGN-211P Reactor and disposal of the component parts.

l Dated: January 22, 1980 f

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1. '*****% 7590-01 a 4' \ UNITED STATES l

E 3. ia NUCLEAR REGULATORY COMMISSION wAsMNGTON. D. C. 20555 NEGATIVE DECLARATION FOR THE WES~f!RGINIA UNIVERSITY RESEARCH REACTOR l DOCKET NO. 50-129 The U. 5. Nuclear Regulatory Commission (the Connission) has considered t%e order authorizing dismantling of facility and dis-position of ec=ponent parts for the West Virginia University (the l . licensee) AEL-211P Reactor operated under Facility License No. R-58.

l i The order au23rizes the licensee to disassemble the rcactor which emerated at ;2ceer levels up to 75 watts (thermal), and to dispose j cf the car:2cieer parts.

The U.1. helear Regulatory Commission, Office of Nu: lear Reactor Regalatiets, has prepared an environmental impact appraisal for th.s research reactsr. On the basis of this appraisal, we have concluded that an erniremmntal impact statement for this particular action is

- not warrartted because there will be no significant environmental impact l

attributable :s the scoposed actior The environmental impact appraisal is avattiable fsr puslic inspection at the Commission's Public Document h at UU im Street, N.W. , Washington, D. C.

Cated at Bethesda, Maryland this 22nd day of January,1980.

FOR THE NUCLEAR REGULATORY COMMISSION Robert W'. Reid, Chief

- Operating Reactors Branch #4 Division of Operating Reactors f

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CoNege G21sngineering aq. ,

• -* 26506 j September 27, 1979

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.WestVirginia Mr. William cammill University Acting Assistant Director for Operating Reactor Projects Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, DC 20555 Re: License R-58, Docket No. 50-129

Dear Mr. Gammill:

. In conformance with 10CFR50.82 and Regulatory Guide 1.86, West Virginia University requests the following: ...

1. 'That NRC authorize the University to dismantle the AGN-211P (Serial No.103) Reactor according to the Distantling Plan presented below.

2. That NRC authorize the University to temporarily store the reactor fuel and graphite reflector elements, control and safety rods, rod drive assembly, air monitor, water demineralizer, ion chamber and BF3 * *" #8' 8'** **

and rod drive assembly structural supports including the core grid plate, and the control console at the reactor site,

3. That NRC authorize the University to dispose of all reactor hardware other than that cited in Item 2. without further restriction. This would primarily include the graphite thermal column, steel water tank, and concrete shielding blocks.

4. That NRC authorize removal of any and all restrictions on future University uses for disposition of the reactor high-bay area room.

5. That prior to expiration of the current Possession Only license on June 19, 1980, NRC authorize one of the following: ,

i

a. . Shipment of all components cited in Item 2. La a suitably licensed party.

b. Shipment of fuel to Oak Ridge and disposal of all other components in Item 2. without further restriction.

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~-6. ~That the -referenced NRC license be terminated upon complu-

' ' tion of Items 1. through 5. .

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Justification

/ The'AGN-211P reactor at West Virginia University has not been operated esince' February 1971. In early 1972, it was decided to apply for a Possession Only type license from the Atomic Energy Commission with the ultimate objective being disposal and transfer of the reactor to an interested and suitably licensed party. A Possession Only license was granted via Amendment No. 6 to the referenced license on June 13, 1973. Through the years, the University has attempted without success to effect transfer of the reactor to Northwestern University, the

' University of Missouri, and North Texas State University. At this time, only North Texas State University remains a viable client; however, they have yet to secure the necessary permits to possess and construct the reactor.-

West Virginia University now has a rapidly expanding fossil fuel based

~

- energy research program funded by numerous Federal and State supported c

research grants and contracts. Space for research facilities is at a l< premium, and the AGN-211P Reactor high-bay area is desperately needed to accommodate research activities. We are at the stage where certain research activities may-have to be reduced in scope or even cancelled if proper laboratory facilities cannot be developed. In this context, c

the University requests that reactor dismantling, disposal, and

license tersination be. approved in two major steps

1. Immediate NRC authorization and approval be granted for Items 1. through 4. This would free the reactor room (high-bay area) for construction of urgently needed energy research facilities. Rationales and procedures to accom-j plish this will be noted below.

I ~ 1.--1Jpontompletion of -Items-1.-through-4. wither-Item Sa. or 5b. be carried out prior to the June 19, 1980 license

-expiration date (Amendment No. 7 to referenced license),

and that Item 6. be effected, i.e. license' termination.

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'DelifisToncerninfeach of fhe requested items ~rioW" follow:

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Item 1. - Dismantling Plan The AGN-231P Reactor (Serial No.103) in its original operating configuration consisted of a matrix array of 12 fuel elements and 30 graphite reficctor elements standing vertica31y in a steel grid plate.

j This core matrix was situated at the bottom of a 10' deep water-filled rectangular steel tank, having 5' x 5' cross-sectional l

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I dimensions and walls approximately 5/8" thick. Four control-safety

-rod boral-stainless steel blades were vertically inserted into spaces' '

t, between fuel elements in the core. These rods were electromag-

- netically coupled to rod drive mechanisms, and were spring loaded to permit greater than "1g" acceleration into the core under scram

• conditions. A 1" diameter " glory hole" tube also penetrated the

. center of the core to permit access of various foil and sample materials to the re8 on i of maximum neutron flux. When operating, the reactor had a maximum licensed power of 75 watts.

Surrounding and abutting the steel tank is a 4' thick concrete block biological shield. The tank and shield blocks rest on a reinforced floor level concrete pad. There is an opening through one side of this shield to permit placement of a 5' thick graphite thermal column (approximately 170 ft 3 of graphite in all). This thernal i

- colu n is in turn shielded on its outer face by an 18" thick move-able' sliding concrete shield.

The reactor facility proper'is located in Rooms B-31 and G-31 in the basement of Hodges Hall on the Downtown Campus of West Virginia University. This room combination, constituting the reactor high-bay area, has a floor dimension of 25' x 20' and a height of 24'.

There are three access doors to the high-bay area. Two of the doors which lead to hallways in Hodges Hall cannot be unlocked from the outside. Entrance can only be attained by entering Room B-30 (formerly the location of the reactor control console which is now

stored in B-31)and then proceeding through a locked internal access door from Room B-30 to Roon B-31. Access to the high-bay area is .

controlled by the University Radiation Safety Office, administered by Dr. Stephen T. Slack, University Radiation Safety Officer.

For reference purposes, an " overhead" view of the fuel-reflector f element matrix configuration is presented in Figure 1., and a sketch l

of a typical reactor fuel element is shown in Figure 2. The fueled I

portion of the fuel element consists of a solid homogeneous mixture

• of 20% enriched UO2 pellets fused in a polyethylene moderator.

~ ~ Total ~ 235g loading for the ~12 ' fuel elements-in the core-is -800 l grams. Each fuel element has 2 7/8" x 3" cross-sectional dimensions and an overall length of 301/4".

The history of activities at the AGN-211P Reactor site since the l

cessation of reactor op6 rations"Iri'Febrdiry7971 is as follows. -In

~-

February 1972, electrical power to safety and control rod drive motors was disconnected. A Possession Only license for the reactor l

was issued to West Virginia University on June 13,fl973 via Amend-ment No. 6 to License R-58, Docket No. 50-129 - with an expiration date of June 19, 1979. On April 25, 1974, Mr. Don Burke (AEC-Atlanta) arrived unannounced at the University for an AGN-211P Reactor facility inspection. Through a lack of satis-j factory communication channels at the University, we were unaware l

L l

4

@ Ion. Chamber .

A B C D E F ,

R R R R R R 2 F = Fuel Element

,R F )F F f F R 3 R = Reflector Element S = Reflector Element R F F 0F F S 4 containins Ra-Be start-up source R F F F F R 5 = Control and Safety Rod Channels R R R R R R 6 0 = Clory Hole R R R R R R 7 Ion Chamber Q Fission Chamber Figure 1. Overhead View of AGN-211P Reactor Fuel and Reflector Element Matrix Showing Location of Neutron-Power Level Detectors Lead Handle Shadow Base Plate

' b .4 Shield M T i (into Poly- 207. Enriched UO Poly-3" ethylene Polyethylene Fueled I G d Post e) v Seement p 4, s, u, + s '

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• 10" 5" 5 3/4" I2 1/ 8 " 2" 5"

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3/8" Figure 2. Side View of AGN-211P Reactor Fuel Element

s 5

that the Possession Only license had been granted; and, in fact.

were cited for several items of non-compliance. The foremost item of non-compliance was that-steps-to absolutely gua'rantee sub-criticality and inoperability of the reactor had not been taken.

1 Basically, we had not been aware that official permission had been given under the Possession Only license to remove fuel and/or .

reflector elements to put the core in a suberitical configuration.

.On April 25, 1975, fuel elements D-6 and E-4 were removed from the

-core in Mr. Burke's presence (Refer to Figure 1. for element identi-fication). These were wipe tested and survey monitored. At-sur-

. face survey ceter readings on the fuel elements were 4.0 mR/hr.* .

.and wipe tests showed surface contamination to be less than 1000dpm/100 cm 2 . Fuel elements D-4 and E-4 were doubly-wrapped.and

> sealed in 4 mil thick polyethylene sheet and stored in a locked 1/4" thich steel box located in the high-bay area next to the concrete

. block shield. (Access to the storage box is controlled by the Univer-sity Ra,diation Safety Office.) In addition to removing the fuel elements, all mechanical linkages between the rod drive motors and l

the control and safety rods were removed. Calculations assured us that the reactor was less than 0.25% Ak/k subcritical with the fuel

. elements removed. In fact, 'the removal of one fuel element- was l

sufficient to assure suberiticality with all rods out of the core.

On July 19, 1978, element F-4, which'is a-graphite reflector element L containing the neation start-up neutron source, was removed from l

the reactor. It was vertically braced in the center of a 55 gallon

! covered plastic drum'which was filled with water, and stored in Room 132 of Hodges Hall. Calculations, indicated and neutron survey meter readings verified that the maximum neutron. dose rate at the outer perimeter of the drum was'10 mrem /hr. Room 132 was formerly a radioisotopes storage vault utilized by the Departntent of Physics.

Its inner floor dimensions are 8' x 10' with a ceiling height of l

l 10'. The walls are 2', thick high density concrete. Access to'the i vault, again controlled solely by the Radiation Safety Office, is through a 2 1/8" thick solid oak door with a 1/4" thick lead plate running through its middle. The door is key locked, and can also be

^~boit locked and' secured using a' heavy

• duty 11 aster lock or its equivalent. It should be noted that the is.,otopes vault.is not pre-sently being used for radioactive materials storage, other than the

-neutron start-up source which:is presently located in it.

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'Although it is difficult as' ess s accurately, a conservative estimate would be that the reactor spcradically operated at 75 watts power for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year over a 12-year' period. Translating this to a continuous-operation of the order of o.ne vatt per year l

I for 12 years, followed by a shutdown period of 8.5 years, gives a present 235U activity of 55pci/gm. This is approxinately 20 times higher than the natural radioactivity of 235g, ,

l l

l

. 6 On July 25 and 27, 1979 the remaining ten fuel elements were removed from the core, wipe tested, and stored in two 55 gallon sealed steel drums in the reactor high-bay area. We interpreted this to be permissible under Conditions 2.C.(3) and 2.C.(4) of -

Amendment No. 6 of the referenced license which read:

Condition 2.C.(3) "The reactor shall be changed by removal of fuel element (s) and, if required, graphite reficctors such that the reactor is at least 0.25% dk/k suberitical with all control rods fully withdrawn from the core."

Condition 2.C. (4) " Fuel element (s). removed from the core shall be stored in a locked enclosure within the facility and the key for this enclosure shall be under the control of the person responsible for administration of the reactor."

Removal of two fuel elements had guaranteed 0.25% dk/k sub-criticality with all rods removed. Removal of all fuel elements resulted in c keff = 0 core. There appeared to be no prohibition of this if the elements were stored at the reactor site. .

Fuel elements G-3, C-5, D-5, E-3, and E-5 were labeled and stored in one drum; and fuel elements B-3, B-4, B-5, C-4, and D-3 were labeled and stored in the other. Each element was wipe tested, doubly wrapped in 4 mil polyethylene sheet (which was sealed with reinforced tape), and vertically placed in a 3/4" plywood matrix structure especis11y built to properly space and support the elements in the drums. The drum lids were bodified so that they could be secured with steal bands and locked with heavy duty Yale padlocks.

Keys to these locks are possessed by Dr. G. Lansing.Blackshaw, Acting Reactor Director and Dr. StephenSlack, University Radiation Safety Officer. Wipe tests of all removed fuel elements indicated removeable contamination of well under 1000dpm/100 cm2 . Radiation

-surveys at the outside strface of the drums presently show maximum readings of 2mR/hr.

In order to remove fuel elements B-3, B-5, E-3, and E-5, it was l

! -necessary to remove the control rods from the core. The control rod blades slide in channels attached to these elements and removal of these elements was not possible without taking out the control rods.

j -'--Six- fuel ~ elements-had already been extracted when the first of these elements, E-3, was removed--so the possibility of criticality mwas non-existent. The control blades and rod couplings to the rod

. drive mechanism housing were wipe tested and showed no evidence of radioactive contamination. In conjunction with removal of the control rods, the rod drive mechanism housing also had to be

-decoupled from the steel superstructure. At present the control blades and rod couplings are stored in the high-bay areas, whereas t

the rod drive mechanism housing is covered for dust protection l purposes and stored in the radioisotopes storage vault. We have interpreted the storage vault (Room 132) and the high-bay area i

L.

7 (Rooms B-31 and C-31) in flodges 11all to be included in the defini-tion of the " reactor site." .

To summarize, the present status of the AGN-211P Reactor is this:

All fuel has been removed and is in on-site locked storage with

• access controlled by the Acting Reactor Director and/or the Univer-sity Radiation Safety Officer. The control rods and rod drive mechanism are also stored at the reactor site, as well as the reflector element containing the neutron start-up source. The remain ~ing 29 graphite elements are still located in the grid, under water, in the steel tank. Wipe tests have demonstrated removeable, contamination of less than 1000dpm/100 cm2 on all fuel elements.

.No other components show any evidence of contamination.

At this stage the University requests that disassembly of the remaining in-place reactor hardware be authorized. Wipe tests of these components (with the exception of the graphite reactor elements),

' radiation surveys, and monthly air and water sampling clearly

' indicate that there is no contamination present. Air samples indicate no measurable activity above background, which ranges from

-8

• 1.0 x 10 pCi/l to 8.0 x 10 Ci/1 for the Morgantown, West

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Virginia area---dependent upon the date the sample was taken.

Water in the reactor tank has consistently shown a lack of detectable extraneous activity during the past five years, measuring the order of 10-5 pCi/cc, again dependent on instrument background. Reactor pool water ceasurements have been totally consistent with tap water sa:ples run as blanks for comparison purposes.

Since there are no fueled components lef t in the reactor, we request that disassembly be permitted in an order which mak,es logistical sense, given the physical environment of Rooms B-31 and C-31. This would be:

a. A sump pump to transfer reactor tank water to Hodges Hall storm drains. Approximately 1500 gallons of water will be discarded.

b. Remove.the graphite reflector elements.

c. Remove the ion-chamber instrumentaticn from the reactor tank.

d. Remove the reactor air monitor and water dcmineralizer.

c. Remove all reactor steel structural supports and braces attached to the reactor tank.

1

f. Remove the moveable concrete thermal column shield.

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g. Remove the thermal column graphite.

h. Remove the steel reactor tank.

1. Remove the concrete shield blocks. ,

All work will be carried out under the combined supervision of the Acting Reactor Director and the Radiation Safety Office. Air monitoring and wipe tests of all components will be performed on a continuous basis. To date, the monitoring of all individuals involved with reactor fuel removal has shown that no personnel radiation exposure occurred; and checks of gloves, rags, etc. used in fuel and components handling has indicated that they are free of radioactive contamination. If evidence of contamination exists (although none is expected), all parts, components, etc. will be decontaminated to acceptable levels before they are transferred to storage or.sent to disposal.

Items 2. and 3. - Storage and Disposal .

In erder to permit research usage of Rooms B-31 and G-31 in Hodges Eall and to allow North Texas State University sufficient time to acquire the necessary permits to possess and reconstruct the AGN-211P Reactor, it is requested that West Virginia University be allowed to store the usable and potentially transferrable components of the reactor in Room 132 Hodges Hall.(the previously noted isotopes storage vault), and dispose of the non-usable components. At pre-sent the usable components are deemed to be the fuel and reflector elements, control and safety rods, rod drive assembly and housing, air monitor, water demineralizer, ion chamber and BF3 detectors, l

the structural steel components, the fuel-reflector element grid I plate, and the control console and cables. Disposable components are the graphite thermal column, steel water tank, and concrete shielding naterials--all of which would be scrapped.

The fuel storage drums contai.ning five'Tuel elements each vill-be placed in opposite corners on the floor of the isotopes storage

-vault. The metal box containing the other two fuel elements will be located in one of the other vault corners. With this

._ arrangement, criticality would:be impossible. Shelves presently

~ ~

exist .in the room to hold the graphite rsfl'ector elements.~ "The l

! door to'the vault will be both key-locked and bolt-locked, with the bolt lock secured with a padlock. Only the Acting Reactor Director

- and the Radiation Safety Of ficer will have keys to the vault.

A radiation hazard warning sign will be posted on the door to the l

storage vault. Appropriate radioactive materials tags will be l

placed on the fuel storage containers and the barrel holding the I neutron start-up source located within the vault. An alarm system will be installed at the vault site to detect unauthorized entry.

9 Output from this system will be directly coupled to West Virginia University Security Police headquarters so that unauthorired intrusion into the vault would be immediately discovered. Authorized entry to Room 132 by either the Acting Director or the Radiation Safety Officer and his staff members would be preceded by a telephone call to -

Security Police headquarters for notification and identification purposes. A quarterly radiation and environmental survey of the vault will be performed, and results logged and reported according IE to the provisions of Section C.3. of Regulatory Guide 1.86.

Item 4. - Unrestricted Use of Room B-31 and G-31 Hodges Hall qg.

(High-Bay Area)

Upon storage and disposal of all reactor hardware, the high-bay area will be thoroughly wipe tested and surveyed for sources of contamination. Responsibility for this will be vested in the University Radition Safety Office, where equipment cxists for this

~

type of nonitoring. Rooms B-31 and G-31 are expected to be free of contamination, as past surveys have indicated. If the final radia-

' tion survey results support this, a report will be sent to NRC as specified in Section 4 of Regulatory Guide 1.86, with a request that Rooms B-31 and G-31 be made immediately available for unrestricted use. It should be noted that the arrangement of all research equipment to be installed will be such that access to the rooms by NRC inspectors will be possible.

Item 5. - Ultimate Disposal of the Usable Reactor Components Two options are noted here. . Item 5.a. provides for the contingency that North Texas State University may still procure the necessary authorization to acquire the reactor. If so,. they or any other bona fide client (in terms of proper NRC authoriza tion) will be sent the i usable components of the AGN-211P Reactor. March 1, 1980 will be l _ the deadline date for this option to-be viable. If 5.a. proves unfeasible, then Item 5.b. provides that the fuel and neutron source bearing graphite reflector element will be shipped to Oak Ridge.

Any reactor components usable for non-nuclear related activities will be retained by the University, and the remainder scrapped. In either 5.a. or 5.b. the fuel will be shipped in containers approved by NRC and DOT, and in accordance with the transportation regulations of these agencies.

Item 6. - Termination of Referenced License Following completion of either of the two options in Item 5. , a final radiation survey will be made of Room 132 Hodges, the radio-isotopes storage vault . If contamination exists, it will he removed to the acceptable levels as noted in Table I of Regulatory Guide

! 1.86; however, none is expected to occur. A report will be cade l

10 to NRC, at which time approval will be sought to terminate License R-58, Docket No. 50-129. This will be donc prior to the license expiration date of June 19, 1980. .

Safety Evaluation of Reactor Dismantling and Disposal Since AGN-211P Reactor fuel has already been removed from the reac-tor system and stored in three separate containers, there is no danger of criticality. No significant radiation hazards other than low-1cvel radiation at the fuel storage container surfaces have

'been detected to date, nor are any anticipated. Dismantling, trans-fer to storage, and disposal of components will be performed under the supervision of qualified, trained individuals--the Acting Reactor Director and the University Radiation Safety Officer. Gloves and film badges will be worn by all personnel participating in the dismantling operations. As noted previously, radiation monitoring procedures will be continuously carried out. All electrical connections and services to the reactor system have long .since been severed, so electrical hazards are non-existent. Normal safety precautions associated with the movement of heavy materisis, c. g.

concrete shielding blocks, will be observed. Ultimately, all nuclear materials associated with the reactor will be removed from

-the University. There is some chance that certain non-contaminated components may be retained for non-nuclear use. These might include control console instrumentation, electrical cables.and connectors, control rod drive motors,. electromagnetic couplers, etc. This would depend upon whether an institution is found that can accept the reactor.

l Environmental Impact Appraisal of Reactor Dismantling and Disposal l

No changes in Hodges Hall building structure, electrical services, water lines, or sewer lines will be associated with dismantling

-_ operations. It has been.noted that adequate reactor fuel and component storage facilities already exist. An alarm system will have.to be installed in the storage vault, Room 132 Hodges Hall.

-Evidence to date indicates that no radioactive contamination of the

-high-bay area, storage vault, or non-fuel components is to be l

---exp ect ed. If hardware contamination does exist, it will be reduced to acceptable levels. Shipment of fuel materials will be in accordance with NRC and DOT regulations. .

- West Virginia University has not had use for the AGN-211P Reactor since early 1971. Future use is out of the question, and the space i

currently occupied by the reactor is urgently needed for energy-related activities. Dismantling and disposal costs will be borne by the University. In the event that usable components, including j

the fuel, can be transferred to another institutions, the costs

11 associated with packaging and shipment will be paid by that institution. .

In brief, no significant environmental impact is anticipated.

We believe that all our activities undertaken with respcet to reactoe fuel and control-safety rod removal have been permissible under-conditions and interpretations of License R-58, Docket No.59-129.

Egeditious NRC approval of Items 1. through 4. in this request vill greatly help the University obtain laboratory facilities space which is immediately needed to properly conduct research work under existing grants and contracts. If further information is required, or you wish to discuss technical or regulatory aspects of this request, please contact Dr. G. Lansing Blackshaw, College of Engineering, West Virginia University, Morgantown, West Virginia 26506: Phone (304) 293-4821.

West Virginia University certifies that this request has been prepared in conformity with Title 10, Code of Federal Regulations, Parts 20, 50, and 70, where applicable, and NRC Regulatory Guide 1.86, where applicable. Tha licensee also solemnly affirms that.all information contained'herein is true and correct to the best of our knowledge

.and belief.

West Virginia University, Licensee Morgantown, West Virginia e M

- G. Lansing Blacksf(aw Assistant Dean of Engineering Acting Reactor Director ,

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^

/Q .+v w Ray Q;bppelman' Vice President - Energy Studies, Graduate Programs, and Research Chairman, University Radiological

! Safety Committee -

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l State of West Virginia

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County of Monongalia Subscribed and sworn to before me this c7 of September, 1979.

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Notary Public

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l' My Conunission expires //!//!8d

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CoNege of Engineering Morgantown. West Virginia 26506 November 30, 1979 43;tf -

sa, v WestVirginia Mr. William Gammill -

Acting Assistant Director for Operating MIWrSity Reactor Projects Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, DC 20555 Re: License R-58, Docket No. 50-129

Dear Mr. Gammill:

Mr. Peter Erickson from your Division recently called me to ask some specific questions regarding West Virginia University's September 27, 1979 request to dismantle and dispose of its AGN-211P (Serial No.103) Reactor. Presumably, these requests for additional information had come from members of your staff. The paraphrased questions and responses follow:

Question: What is your most sensitive radiation survey instrument?

Response: The University Radiation Safety office has informed me that a Model E-520 Eberline portable gamma probe Geiger counter (with readout) is sensitive to detecting radiation levels as low as 0.02 mR/hr. This is capable of discriminating true sources of low-level radiation from background and noise fluctuations.

Question: You did not specifically mention contingencies for

. handling possibly irradiated reactor components (other than fuel elements). What do you plan to do?

l

' Response: We have detected no discernible radiation from any of the components removed from the reactor with the excep-l, tion of the fuel elements, which was noted in the dismantling

-request. In particular, the glory hole guide tube, the control and safety rod blades, and the steel " blade guide channels" attached to four of the fuel elements show absolutely i

no evidence of being radioactive. ,These would.have been -

I located in regions of maximum neutron flux during periods of

. reactor operation. We see only background fluctuations on the E-520 meter. In brief, we expect no irradiated materials problems with which to contend.

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, (, I 0' (Dih jl Equal Opportunity / Affirmative Action Employer

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-Question: What do you intend to do.about the.Ra-Be neutron start-up source in the graphite reflector element which is presently stored in a 55-gallon water-filled plastic drum, -

which in turn is located inside the storage vault?

Response: This is unsatisfactory on a long-term basis. Our initial reaction was to construct a 1" thick rectangular cross section lead " cover sleeve" for the source bearing element to attenuate the soft gammas resulting from Ra decay; and then imbed this sleeve in a SS-gallon steel drum filled with paraffin. We now believe that this approach will be both time consuming and costly in terms of materials procurement and labor, and will still not result in a container which meets DOT and NRC shipping regulations.

We thus intend to immediately proceed to secure a DOT approved shipping container for the neutron source bearing element, and transfer the element from the water-filled drum to the shipping container within the confines of the storage vault. A portable electrically operated overhead crane can be set up in the vault to accomplish this. Maximum radiation exposure to any personnel involved in this element transfer will be 5 mrem.

This will be determined by a combination of pencil dosimeters and area survey monitors. Dr. G. L. Blackshaw will be both in charge of and the most active participant in the operation.

~

Once transfer to the shipping container is accomplishe'd, the container will be stored in the vault until the decision has

-been reached to send the reactor fuel to Oak Ridge or to North Texas State University. (See Item 5 on page 1 and Justification on page 2 of the September 27, 1979 letter.)

Sincerely, C. Lansing Blackshaw Assistant Dean of Engineerf.ng Acting Reactor Director

-Copies to: - D r. --Ray . Koppelman -

.Dr. Steve Slack e

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