ML20090L689
| ML20090L689 | |
| Person / Time | |
|---|---|
| Site: | 05000047 |
| Issue date: | 03/16/1992 |
| From: | Naughton J ARMY, DEPT. OF, MATERIALS TECHNOLOGY LABORATORY |
| To: | Alexander Adams NRC |
| Shared Package | |
| ML20090L695 | List: |
| References | |
| NUDOCS 9203230075 | |
| Download: ML20090L689 (17) | |
Text
m g -- - - -
,+ r, L
q' DEPARTMENT OF THE ARMY u.s. ARMY. LABORATORY COMMAND MATERIALS TECHNOLOGY LABORATORY WATERToWN, MArsSACHUSETTS 02172 0001 p AYe' ens or Base Realignment and Closure Office March 1f;,1992 Docket No. 50-47 Mr. Alexander Adame Nuclear Regulatory Commission OWFN MS: 11820 Washington, D.C. 20555
Dear Mr. Adams:
Responses to the questions you raised in your correspondence of Februaiy 5,1992, regarding the U.S. Army Materials Technology Laboratory Research Reacer are enclosed.
As you know, we are in the design phase of this project and will not proceed to the construction phase until the Decommissioning Order has been received. Under the value engineerhg clause of our design contract, our designer har proposed to give the construction contractor more flexibility during decommissioning in an effort to save time and cost. For example, they suggest ruluiring the contracur to take core samples of the vessel to determine the extent of contamination, if the area is heavily contaminated, the entire containment vessel and platforms would need to be removed as explained currently in the decommissioning application if negligible contamination is
' encountered however, the reactor sessel could be decontamlnated by removing selected concrete surfaces thereby eliminating the need to remove the entire reactor vessel and platforms during decommissioning. This type of flexibility is also reflected in our response to your comments 2 and 19. . Does the Decommissioning Order process leave us value er.gineering flexibility?
For further coordination on this application, contact either Laura Rodman in the Base Realignment and Closure Office on 617 923 5320, or Peter Coinetta in the Hazards Management and Safety Office on 617 923-5225.
Finally, as you requented in accordance with 10 CFR 50.30(b), th!s response is
- executed in a signed original under oath or affirmation. Please note tnat Major Adams has retired End effective March 1,1992, Mr}or James T. Naughton assumed all the former commander's duties. An assumption of comrr .d letter is attached for your
~lnformation.
L l
c 9203230075 920316 7 DR- ALOCK 0D00
n ft %TLI U.S. Arrny Materials Technology Laboratory Docket No. 50-47
[
Sincerely,
'+
t)g]0'd((itu(Sh AMEST.fMUGfq0N
'A4AJ, OD U
~' Deputy Diotector/ Commander
Enclosure:
As Stated CC w/encloswe:
Commander U.S. Army Toxic and Hazardous Materials Agency ATTN: CETHA BC (Mr Natore Torrisi)
Aberdeen Proving Grounu, Maryland 21010-5401 Commander U.S. Army Corps of Engineers, New England Division ATiN: CENED-PD L (Mr. Dennis Waskiewicz) 424 Trapelo Road Waltham. Massachusetts 02254-0149 Headquarters, Department of the Army AYTN: SAILE ESOH (Colonel Chris Conrad)
Washington, D.C. 20310 0110 Mr. Robert M. Hallisey, Director Radiation Control Program Department of Public Health The Commonwealth of Massachusetts 150 Tremont Street Boston, Massachusetts 02111 tA, 4 LLLJ.LLLLf.aLLLlL__'------.- 3 Y%EE JLL.UN Subscribed and sworn to before me this /6 % day of MeLL,,1992.
}
L%.tl.a_ h:bt1ji: Lu_
Notary Public ' O My commission expires Om e 1 t_ n,'-
2LO. ; ^7
Comment 1: Reference to U.S. Nuclear Regulatory' Commission, Guidelines For
- Decontamination of facilities and Equipment Prior To Releast For Unrestricted Use or Termination of Licenses For By product, Source, or Special Nuclear Material, August 1987, will be replaced with the referenced Regulatory Guide lib 6 (R0 1.86), Termination of Operating Licenses For Nuclear Reactors.
-Additionally, the Army will commit to the unrestricted use acceptance criteria 1 of 5 uR/hr above background at one meter from the surface. !
The Army also will comply with the Commonwealth of Massachusetts requirement that the final reactor site shall not sause exposure to any individual who would be continuously present that exceeds an annual dose of 10.0 millirem. This requirement is consistent with the NRC Guidance and Discussion of Requirements ,
For An Application To Terminate A Non-Power Reactor Facility Operating License, Revision 1, September 15, 1984 Furthermore, the Army will also comply with the State Regulation 105 CMR 120. Consistent with 105 CMR 120.460, the ntate Radiation Control Program Manager will be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of any known or-suspected release of radioactive contamination. In addition, the Army will '
notify the State Radiation Control Program Manager 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of any ,
shipment of radioactive materials.
Comment 2: The radiation survey of the US AMTL Research Reactor Facility
- indicates that most of the remaining radioactive materials are inside the
- reactor pool and in the reactor building basement. The metal components inside !
the pool, (e.g. the reactor pedestal, grid plate, steel racks, remaining
- pipes / tubes, primary coolant hold-up rank below the reactor. as well as the
< stainless steel pool liner) and some of the components in the basement are all :
considered radioacitve waste and will be radiologically characterized before being packaged and shipped for land disposal as low-level waste. The information included below contains the type of information that will be in the contractor's radiological program and used to protect workers and the public l during the decommissioning.
< Properly trained technicians, wearing appropriate protective clothing, safety glasses, etc., will characterize radiation fields present at the work site before work commences. They will time the dismantling-tasks and monitor personnel exp'sure -
o in order to keep these exposures within the. limits prescribed in Section 2.1.4 and Table 2-1 of the Decommissioning Plan. Personnel will wear
. pocket. ion chambers egamma dosimeters) inside their protective clothing to periodically monitor whole iody gamma exposure. These dosimeters will be calibrated in accordance w. h the information provided in Section 8.4 of the
-Decommissioning Plan.
High range field. Instruments auch as an Eberline RO-2 ton chamber will be used initially to locate and characterize high radiation fields. A suitab'le check source will be used periodically to ascertain that instruments are
' functioning properly. Staging areas designed to control any spread of
. contamination will be used. Metal structures will be removed as stated in Section 3.4.1 of the Decommissioning Plan. Appropriate respiratory protection .i will be used if contaminated or radioactive materials, are mechanically or torch j cut as indicated in_ Section -3.4.2 of the Decommission 1ag Plan. If l decontamination of any metal parts is feasible and undertaken, liquids will be collected and processed as stated in Section 6.2 of the Decommiseloning Plan. 1 i
^
rt y y sy y,----r-
.#y9- w -
%ggy ,_93- gr --'ya+ rw, v-=-*'-, -
4 1
Af ter the removal and packaging of highly radioactive structures, more sensitive instruments will be used to detect radiation levels in the mR/hr and uR/hr ranges. -Typical lower limits of detection for these instruments are given
-in Comment 26.
All waste generated during the decammissing of the MTL reactor will be surveyed, sampled, and analyzed prior to disposal. The criteria to be used to determine if waste.la to be released to a clean landfill or disposed of as radioactive waste will depend on whether the material is surface contaminated, volume contaminated, activated, or a combination of these. The waste generated during decommissioning of the facility will be generated from three different categories of materials.
The first category includes materials that were subjected to the reactor _
neutron flux, materials and components that were near the reactor core during ,
operations. Examples include the stainless steel pool liner, reactor pedestal, grid plate and parts of the biological shield.
The second category includes materials that were in contact with the reactor
' coolant water (some of the materials are also in the first category). The second category includes the surface of the concrete that makes up the annulus and pool as well as coverete within part of the biological shield. This part of the biological shield is assumed to be contaminated due to coolant water ',
, leakage.
The third category includes materials not in the other two categories. This category includes structural materials that must be removed in order to access other potentially contam*nated materials. Examples are concrete platforms surrounding the reactor pool monolith and the concrete surrounding the N-16 hold-up tank beneath the reactor.
- The-criteria described below will be used to determine if the waste in each of the categories will be released to a clean landfill or disposed of as .
radioactive waste.
(1) Category 1: It is expected-that all category one waste will be disposed of as radioactive waste. The determination will first be based on surface activ!ty measurements. These measurements will be compared'with the levels specified-in IC Circular No. 81-07,' Control of Radioactively Contaminated Materials. _If the measured surface activities exceeds those_ levels _specified in IC Circular 81-07, the material will be disposed of -
radioactive was*3.
However, if the: levels. are below those specified in IC Circular 81-07, volume activity of the potentially activated material will be determined to-provide reasonable assurance that no licensed material will be releaaed for unrestricted-disposal. The determinstion of volume activity of category one material will be accomplished byssampling:the material and performing a gamma spectrum analysis.
The gamma spectrum analysis will be performed using a system that is sensitive
- down-to the environmental lower limit of detection, if man-made radionuclides are detected in the_.potentially activated material, (the release criteria for the concrete is discussed under category two), it will be disposed of as
-radioactive waste, 2
t (2) Category Twot The material in the second category consists of concrete or other porus material;that is contaminated on the surface and/or within the matecial volume. The determination of whether this material is contaminated will first be based on the levels specified in IC Circular No. 81-07. If the surface radioactivity measurements of the coacrete exceed the levels specified in IC Circular 81-07, the concrete will be scrabbled and the measurement repeated. However, when the concrete block that is being surveyed meets the releasable levels specified in IC Circular No. 81-07, the volume activity must l be determined before disposing of the waste. The determination of volume activity will be determined by sampling representative blocks of concrete and l
performing a gamma spectrum analysis using a system that is sensitive down to the environmental lower limit of detection. If a correlation between surface readings and volumetric activities can be established, surface readings will be used insteed of volume activities. These results will-be compared with concentrations of man-made gamma emitting radionuelldes found in background concrete. lf the radionuclide-concentrations exceed background by greater than three standard deviations, the concrete will be disposed of as radioactive waste.- Concentrations of man-made gamma emitting radionuclides in_ background concrete will be determined by collecting and analyzing several concrete samples outside MTL. The background analysis will also be performed by using gamma spectrometer system that is sensitive down to the environmental lower limit of
- detection.
(3) Category Three: The release criteria for. category three materials will
- be_the surface activity levels specified in IC Circular No. 81-07. Since this -
material is only potentially contaminated on the surface, no analysis is required to determine volume activity. j Comment 3: The activation of the other materials in the concrete was not l considered for.three reasons. The first reason is because the materials used in the high_ density concrete were not known. The seconu reason is the presence of unknown amounts of contamination in the biological shield.as a result of the leakage from the pool makes the use of activation calculations of little use.
Thirdly, after twenty years of decay, the specific activity of the remaining activated nuclides-in'the concrete is considerably smaller than that in the stainless _ steel _ beam tube and the carbon steel rebars. This section of the Decommissioning Plan is used to support the estimates of waste and worker radiation exposure.- The Army is aware that activation would have taken place and.will address these activation products during material characterization.
Comment 4: The-NRC comment referred to Eu-159 which was not refered to within the Decommissioning Plan.
There was no verification performed during site surveys to confirm the u- - assumptions;made in the neutron activation analysis. The neutron activation analysis was performed many months after the site surveys, and the activation
- analysis was basel on re monable assumptions with_the limited, known information.-
l 3-i u
_m _
In Section 1.3.2.5, the Plan states that the only gamma-emitting and ,
-long-lived nuclides expected f rom the neutron activat ion of stainless steel and ;
iron are Co and Mn. The detection of the radionuclides europium in the reactor annulus is-not surprising because Eu could be a fission product or an activation product. _However, radionuclides of europium are not expected activation ,
products of-stainless steel or iron.
4 Comment'5 _ The assumption that 50% of the biological sh-leld is contaminated is based on the fact that the reactor pool leaked primary coolant through the biological shield during a long period of time (see Section 1.2.2. in the '
Decommissioning Plan).
The assumption that Cistern 242 is not contaminated is based or. the low-level radioactive liquid contained by Cistern 242. Daring excavation and i removal of the cistern, the concrete will be surveyed using appropriate instrumentation, and if it is found to be contaminated, it will be disposed of ,
as_ radioactive waste. In addition, it is assumed that any contaminntion in Cistern 242 will be surface contamination and can be removed by scabbling the concrete surface.
1 Both assumptions are.the basis for waste volume estimaten. If the assumptions prove-to be invalid, the waste volume estimaten and the waste disposal cost estimates would be either higher or lower than the actual volume.
Comment 6: The Decommissioning Plan states that during decommissioning of the reactor monolith, lead "with fixed contamination . . . will be packaged and given to the' licensee for storage as a mixed waste. If mixed waste is
-determined to be present, the waste will be either kept for less than 90 days or arrangements will be made for longer term storage in coordination with EPA and
~
the Commonwealth of Massachusetts under the requirements 1of RCRA. Any interim storage-area-at MTL will'be an indoor area with' restricted access. The RPO will maintain control of the facility and will monitor the area to determine the doso rate-at unrestricted areas near the storage area to ensure that they are less _
than-_the' administrative l11mits given in Table 2-1 of the Decommissioning Plan.
LEventually, the mixed waste will be shipped from MTL to either-a licensed / permitted long term storage area or a disposal facility.
LComment"7: The tank-located directly beneath the reactor pool was used to allow the decay of = nit rogen _ and other _short lived activation products._The flow of coolant water was through. the fuel elements and down in'.a this nitrogen decay
-primary. coolant hold-up tank._ ,
4
- a _ . _
- _ ._ _. _ . - _ _ _ _ _ _ _ _ - _ _ .__._~___.__.m__-._____._
4
- Comment 8: The MTL Radiation Protection Officer (Rp0)'will be responsibic for ensuring _the application of radiation safety principles to reactor i
- decommissioning operations. He will report any radiation safety violations to ,
the Commanding Of ficer. The MTL Technical Monitor will also be informed.- The i
- RPO will observe on going operations during periodic work site visits and utilizes QAE/HP reporti (verbal & written information) to assure that work is ,
progressing in accordance'with the Decommissioning Plan and NRC order as well as being in compliance with any other NRC regulations. He will provide ,
- recommendations as to how safety natters are handled, and shall have the !
authority to stop work at anytime. Furthermore, the RPO will keep the Radiation ,
Control Committee advised of the status of the effort. (See attached
- organizational Pigure 2-19)
The QAE/HP.will rep)tt_to the MTL RPO at the beginning of each work day. He will-also report to th4 Project Technical Monitor and the Contracting Officer's Representative. Informition regarding daily operations, any violations of the ALARA principle, questionable RC&SO guidance for workers and any non-compliance items will be eported tt the MTL RPS and COR by the QAE/HP. The MTL RPO will follow-up and casure any violations and compliance issues are corrected appropriately.
The RC&SO will provide the immediate on-site radiation sat < , guidance to workers, and will brief '.he RPO whenever necessary, at least on a weekly basis, providing pertinent _informtion regarding daily operations. The Contractor's Project Manager and RC&SO shall have authority to stop work in the event that proper. safety is not employed and/or if a violation is detected or suspected.
Resumes of key contractur personnel will be provided upon contract award. f 5
- Comment 9:- The Radiation Control Committee (RCC) consists of the following personnel:
- a. Chairman: This MfL employee has training.and experience in industrial radiography (X-Ray machines) and is appointed by the Director to 4 Chair the Committee.
- b. ' Alternate Chairman: Radiation Protection Officer c.- Two assistant health physicists to the RPO (one being the military representative)
- d. An Industrial Hygienist
-e.
- The MTL Safety Officer (Technical Monitor)
- f. A physicist-
- g. A division supervisor
- h. : Union representatives (non members) also attend meetings
,The RCC will be involved'in the preparation, review, and approval of-work packages by providing oversight and assistance as requested by MTL management or the RPO. Otherwise, information will be provided to the RCC by the RPO at.
quarterly meetings or on an as necessary basis.
5
. - t Comment 10: Applicable sections of Regulatory Guides 8,31 and 8,29 will be i incorporated into the t raining program. The same information will also be incorporated into the General Employee Training (CET).
Comment 11: Personnel exempt from the CET and Respiratory Protection (RP) training must document the most recent training which meets or exceeds these requirements, Regardless of previous training, all workers will be required to take and pass the CET and RP test before they will be allowed into a radioactive work environment. Workers who do not pass the test will be required to attend the training course until they pass or are determined not qualified to perform the assigned tasks. Training requirements in excess of the CET and RP will be implemented _on a case by case basis as described in Section 2.1 of the
- Decommissioning Plan.
Comment 12: The distinction between radiation and non-radiation workers is intended to be used for both management and safety reasons. The Army realizes
, that all workers, regardless of their job assignments, have the potential to be working in the vicinity of radioactive materials, either known or unknown.
Therefore, the Army has decided that the CET and associated testing shall be required for all workers entering a radiation control area.
Comment-13: The additional training as outlined in Section 2.1.3 of the Decommissioning Plan will be applied for areas at or above 100 mR/ hour.
Additional training will also be required for individuals performing jobs where the total exposure received during that job would be at or above 100 mrem.
Comment 14: A copy of the agreement between AMC and NRC concerning 10 CFR 20 requirements is enclosed. If implementation of this standard is delayed until January 1994, the Army will comply with the new implementation- date.
Comment 15: See response to Comment 2.
1 Comment-16: An agreement concerning the transport and treatment of possibly contaminated, injured personnel f rom MTL to the Massachusetts General Hospital has been negotiated. -The remediation contractor will have prepared, prior to any work, a Site Safety and Health Plan (SSHP) to identify, evaluate and tantrol '
- safety, health and radiological hazards and to provide contingency plans for i emergency response.- The-Response Plan will be written consistent with
- requirements of~29 CFR 1910.120(1). The Plan will respond to all regulations, guides and standards and will consist of the required policies-and procedures
- to_ protect workers, MTL personnel, the general public and the environment. We wi.11 provide the NRC a copy of the Emergency Response Plan when it is completed.
6 i
, .n m ,.~-, .n , ,,----.n -.- , -- ,- .,. - - . . , . - - - - .-. , - - , - -
Comment 1/: Most of the uniteensed matertal/ items, i.e. furniture, cabinets,
. block and brick, were removed f rom t he f acility during January 1992. Personnel working in the reactor were issued radiation dosimetry badges to record possible exposures. They were denied access to areas where ambient radiation fields or
.{6' contamination possibly existed within the reactor building. These areas included the Californium-252 Facility and the access area to the top of the
~
reactor pool. Both of these areas are locked-up unless someone who has access approval is working in the area. Only background levels of radiation er.ist in other areas of the reactor outside to core area. Prior to commencing this work, personnel were instructed as to the location and type of radioactive materials in the reactor and associated hazards.
Prior to the removal of any equipment , or furniture (unlicensed materials) etc. , such it ems were monitored to determine if any contamination aas present.
None is known to be in these areas. Items such as cement or lead shielding bricks were monitored with a Pancake GM prior to being removed from the
-building. Information provided in Regulatory Cuide 1.86 and the May 1987 N.R.C.
document entitled " Guidelines For Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for By-product, Source, or Special Nuclear Fiaterial", was utilized. The removal of property was coordinated with the MTL Logistics Division and the equipment turn in papers were documented 1as to the release of these items as being free of any radioactive contamination.
In the near future, the Californium source (By product Material License Number 20-01010-04) will be returned to the Department of Energy. All associated equipment or materials will be monitored prior to release. No contamination is suspected.
Finally, MTL is waiting for approval of an NRC amendment request to move the Kaman Neutron Generator f rom the reactor experimental floor area to another building for storage prior to transferring to another licensee.
Comment 18: The statement in Section 3.4 of the Decommissioning Plan was meant to apply to the steel containment vessel below grade line. iowever, in response to the question, ventilation will be maintained, air will exit the reactor
. through:llEPA filtration. .The existing reactor building HVAC system may be used to the extent feasible prior co dismantling it.- After it is removed, a temporary ventilation system shall be installed (including exhaust f ans , . llEPA
- filters, monitors ,' and alarms) which will- allow for monitored release f rom -the reactor-building. . Under normal operation, the reactor building doors shall be closed. In the event of a._high-radiation signal, the fan flow will be isolated and.the= reactor building door, if opened, shall be' closed. The air will then be recirculated _through filters and released after the level of radiation has been reduced below acceptable limits. This will allow'for monitored release from the reactor building.
7 i
i t
Containment enclosures shall be erected around dismantling activities likely .
to create airborne contamination. To clean airborne contamination, each enclosure shall be provided with a ventilation system which will permit the recirculation of air thraugh a f an, monitor, alarm, and HEPA filter and will be configured to admit fresh air.- While the reactor building doors are opened to ,
permit removal of contaminated material, the local enclosures will prevent _the ,
dispersal of airborne contamination to the reactor building environment and to the environment through the open reactor building doors. In the event of a high radiation signal the fan flow will be isolated. The air will then be ,
recirculated through filters-and released after the level of radiation has been reduced below the appropriate limits. This will allow for monitored release from the containment enclosure.
Comment 19: Based upon the observations listed below, no structural analysis was judged to have been required to ensure safe disassembly of these structures.
The platform concrete slabs and supporting steel f raming were designed for live e loads of 250 lba/sf. This load is approximately 3.5 times the dead load of the slab which is typically 6 inches deep (7 inches adjoining the pool). As the concrete slabs are cut, the continuity over the steel support beams will be disrupted and' in the worst case, the slab will be spanning as a simply supported one way beam strip. In this case, the slab will be supporting its self weight and, in the worst case, the personnel and equipment (circular saws, most likely) equivalent to an uniform occupancy load of 25 psf, resulting in total-load of 100 psf. The mid-span moment will be proportional to 100/8. The design basis mid-span moment, based on the slab dead load of 75 psf and 250 psf live load, is proportional to 325/24, or 108/8. Therefore, the loss of cont!nuity will not result in moments in excess of those used in the original design which was based upon the working stress method, (The structure was designed in 1958).
Precautions will be taken by the Contractor to shore the slab sections being l removed. The existing overhead crane has a load capacity of 10 tons and can l support a concrete panel 7 ft wide and 10 ft long (the span of the slab between i the steel beams).
I A.similar assessment ot the operating floor slab results in the following observations. The 2.5 ft thick portion of the slab (dead weight equal to 375 psf) was designed for a live load _of_3000 psf and the 1 ft thick slab (dead weight _ equal to 150 psf) was designed for a live load of 1000 psf. The dismantling operations-which result-in the transformation of a slab section from a continuous structure to one that is simply supported and loaded by its_self weight and nominal occupancy load will not result in an overstressed condition.
The= structural steel has.been-designed for the 250 psf live-loads in addition to the slab dead loads. Precautions will be taken by the Cont ractor to shore the slab sections:being removed.-_These are expected to be of a size no larger than the existing door opening (approximately 7 ft by 7 ft). .
The removal of the coolant equipment enclosure wall will be performed after a portion of the operating floor slab has been removed. The entire enclosure I wall 1will not be removed. -Only a section of the wall where it is attached to the pool. structure will be removed to permit the installation of the scaffolding required'for dismantling the pool. The portions to be removed will not be I supporting the floor slab. The available survey data indic des that the coolant equipment _ enclosure walls are not contaminated.
8
n
- Comment 20 - The security at MTL' consists of a secured site perimeter with a site entrance security _ station and locked reactor building. The provisions for additional security during the decommissioning include the provision of a fence around the construction. site with a locked gate and security watches provided by
. contractor. Access into the construction site will be through a gate which will have_its own security _ station staffed by contractor-security forces. The contractor.will arrange with MTL to provida security passes for the decommissioning work force. At the conclusion of each days work the gate in the construction site fence will be locked and the reactor building doors will be locked.
Comment 21: The second sentence of Chapter 5 is in error. As pointed out in the first sentence, an accident analysis is not required since there is no fuel present at the site.
Comment 22: The technical specifications will be written using the word !
"shall."
l Comment 23: During the characterization of the soll surrounding the reactor ,
facility and its supporting aux 111ary structures, isotopes of Co and Cs were l
- found. These are-the primary man-made isotopes suspected to be present in this area. -If radionuclides are detected in the soil at concentrations that exceed background levels by three standard deviations, an assessment will be performed to determine if additional soil must be removed. This determination will be based on-a pathway exposure analysis to individuals of no greater than 10 mrem
-per year above background due to the detected radionuclides in the soll.
The methodology described above will be applied after the trenches and pits
-have been backfilled and when the surveying, sampling, and analysis described in Secion 8.3 of the DP have been performed. However, the soil aren to be surveyed and sampled as described in Section 8.3 will be expanded to include the entire 42 by_48 meter area around the reactor.
Conment-24: The contact radiation level is expressed in dpm/100 cm for use during surface contamination level measurements following excavation. In zaddition, gamma spectrometry shall be performed for each sample and the results will be expressed in units of pCi/g.
Comment 25: _ Prior to conducting;the grid-square surveys required as part of the reactor building termination survey, a quick scan.of the facility and surrounding area will be conducted. The scan will focus on areas with a potential for the-collection of-contaminated materia'Is. This would include areas potentially contaminated during operation such as concrete expansion joints- or cracks.- Other areas selected for scanning would include items and materials adjacent to areas which had been involved in decontaminution activities.
9
- . - . - - _ - - - _ . . - , , . - - - . . . - . . . _ - - - - - . ~ . _ ,- - - . . -
- Comment 262 : Table 8-l_should note field survey instruments most often used for-detecting-low-level alpha and beta-gamma radioactivity. .A revised Table 8-1 is shown below. _The instruments listed here are only a few of the field g instruments capable of measuring alpha and beta-gamma fixed surface
, radioactivity at reasonable levels above-background.
Instrument Type, Model Detection Nuclides and Manufacturer Levels Gross ZnS(Au) PAC-4F-Eberline 2; 30 dpm Alpha Gas Proportional PAC-40-Eberline . 2; 50 dpm Gross Gieger-Mueller (GM) RM }; 1000 dpm l Beta gamma Eberline Radiation Monitor CM-Model 12-Ludlum 2, 1000 dpm GM-Model 2A-Ludlum- > 1000 dpm Beta-gamma & Ion Chamber-RO-2-Eberline }, .01 mR/hr x-ray I
gamma & x-ray Pressurized Ion Chamber Model 450P- <25 kev x-rays i Victoreen mR/hr
-Beta- Pressurized Ion Chamber Model 450P- <1 MeV &-
Victorcen- <1 uRem/hr Comment 27:- In_the event that decommissioning work extends beyond NRC required:
implementation date, MTL would prefer to continue using the old 10 CFR Part-20 regulations until the work is' completed.- However, a statement requiring the contractor to abide by the regulations that are in effect for the Army at that time will be included in the Scope of Work ,
Comment =28 ' -If access to a commercial-licensed burial facility is lost, the following contingencies are planned:
(1) If the characteristics of.the reactor waste qualify, the waste will be sent to Envirocare of_ Utah, Inc. This commercial company will not be affected by;the compact-legislation closing date.
(2) -The U.S. Army Armament, Munitions and Chemical-Command is in negotiations with the Department of Energy to use their facilities if access to'
-all commercial sites is lost.
4 (3); Waste could be shipped to the Defense Consolidation Facilityfin Snelling, SC, compacted, and returned to;the installation _for storage.until Massachusetts is permitted-t6 dispose of the waste in ecmpliance:with compact legislation.
(4). Package the waste and store on the installation for the specified.
period of time, then' turn the waste oversto the-Commonwealth of Massachusetts-
.IAW compact legislation.
10 t
, ~. - - , . -w. - - -- . . - - . . . , _ . . . - . . - - , - - _ . - - - - . -
_ _.- _- m . = _ - _ _ . _ _ _ -_.__ _ _..~ _ . _ . - _ _ _ . _ ____, _ ._ - . _
1 i
Radiological Program for Characterizing the Demolished Concrete ,
& Metal Wastes )
4 As noted in the Decommiscioning Plan, the radiation survey of the US AMTL Research Reactor facility indicates that most of the remaining radioactive
- materials are inside the reactor pool and-in the reactor building basement.
The metal components inside the pool, (e.g. the reactor pedestal, grid plate, steel racks, remianing pipes / tubes, primary coolant holdup tank below the >
, reactor, as well as the stainless steel pool liner) and some of the components in the basement are all considered readioactive waste and will be radiologically characterized before being packaged and shipped for land disposal as low-level waste.
The information included here contains the type of information that will be in the contractors radiological program, and used to protect workers and the public during the decommissioning.
Properly. trained technicians, wearing appropriate protective clothing, ,
safety glasses, etc., will characterized radiation fields present at the work
- site before work commences. They will time the dismantilng tasks and monitor ,
personnel exposure-in order to keep these exposures within the limits prescribed in Section 2.1.4 and Table 2-1 of the D.C. Plan.
Personnel will wear pocket ion chambers (gamma dosimeters) inside their protective clothing to periodically monitor whole body-gamma exposure. These doslieters will be calibrated in accordance with the information proveded in Section 6.4. .
High range field instruments such as an Eberline R02 ion chamber will be
, used' initially to. locate and characterize high radiation fields.- A suitable check source will be used periodically to ascertain that instruments are functioning properly.
. Staging areas designed to control[ any spread of contamination will be used.
Metal structures- will b'e removed ;as stated _in SectionI 3.4.1. Appropriate respiratory -protection will bez used if contaminated. or radioactive materials etc., are mechanically or torca cut as indicated in Section 3.4.2.
If. decontamination of any metal parts is feasable and undertaken, liquids:
-uill be collected and processed as stated in Section 6.2.
Afterlthe-removal and packaging of highly radioactive structures, more sensitive instruments will be used to detect radiation levn1s in-the mR/hr and-uP/hr ranges. -Typical lower limits of detection for these instruments are given An Comment 26.-
m r-' ..-Le - + " ,-'pg em y
'I The biological shield wall is suspected to be part(ally radioactive and to The n:tivat. ion source would contain both activation and contamination sources.
be limited to the portion near the reactor core elevation, especiallj in the I neighborhood of.the neutron beam penetrations. The activation nuclides ,
considered to be present are Co-60, Eu-154 in the concrete and Co-60, Ni-ba, and Fe-55 in the steel rebar.
. Prior to-breaking up the concrete a determination as to whether there is any .
removable contamination on the surface will be made. Subsequent measurements ,
will be made to detect and characterize radionuclides within the cement.
Any material with radiation levels above background levels will be hat.dled .
and packaged as radioactive waste.
3 i
1 .
1 s
- - - .gr_._,.r. _
p 7 __,7 9._ yy,,. 3
_f,.-
l DEPARTMENT OF THE ARMY l'
U.S. ARMY LA80H AT'91 COtNAAND
?
MATEHIALS TECHNOLOGY LABORATORY 5kI=[/ .
t, w ATsNToWN, M ASSACHUSETTS 02112 0001 !
alftMTrA CP SLCMT D (340) 28 February 1992 ;
MEMORANDUM FOR SEE DISTRIBUTION i
SUBJECT:
Assumption of duties ;.s Deputy Dir : tor / Commander I
- 1. Effective,1 5*. arch 1992, the undersigned assumes command of the U.S. Army l Materials Technology Laboratory (2ilMAA) Watertown, MA 02172-0001 sice Melvin E l Adams, MAJ, AR. I I
- 2. Authority: Paragraph 3-4 and 3-5, AR 600-20. l
- 3. hriod from: 1 March 1992 to an indefinite period.
l
,.. /
l; _ ;( * / ?/l ' jy, JAMES T. NAUGirl'ON lMAJ, OD v' DISTRIBUTION:
1 FT Devens off Rec D
l l
1 l-l
J..
. ' "g' DEPARTMENT OF THE ARMY U.S. ARMY L ABOR ATORY COMM AND
.s-y kf rgf j I MATER! ALS TECHNOLOGY LABOH ATORY WATERTOuvN. M AS$ACHUSE TTS 02177A;01 I
(,* g anyty to arturam er i
l l
SLCMT-DD (340) 2 March 1992 !
I l
MEMORANDUM FOR SEE DISTRIBUTION
SUBJECT:
Signature Block, Deputy Director / Commander As of 2 March 1992 all correspondence for the signature of the )
Deputy Director /Com:ander, MTL will be as follows, i l
l JAMES T. NAUGHTON MAJ, OD Deputy Director / Commander DISTRIBUTION; D
i I
I l
, - w, .s. - .o a-,-. .. . :a:r mm in a n-- ., a .+ , .s - . . a e m -.- s e 2
-u*na + - n --.-..J-.n--u.s s- .e .s- - - , ,...s.,
t
. l
. ., i 5' %
rY ?
- di 4 ag
- 2. 3,s 21 o i .
U %
Ma t, t i vsgE4' e, ff'8 $
t t
/ n.-a_
3 w' N k -.
\
\
\
\
\
+
\
!)
t L%
N^ 2 N
? U ??
a ph a !s n spi n
5 5,
.g. W $
n i i
\ /
/
/
/
PA i
.< t-d 5
' \
mv Y
-@,3- c E n$
- [
7 L
v +t 21 t
a p-y 3 $t T t.
L 4[ Pt r l-EM .'. 7b d'HMEW7 8
/ OF / p,qy