ML20099L164

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Application for Amend to License R-127,authorizing possession-only in Safstor Status
ML20099L164
Person / Time
Site: 05000538
Issue date: 03/14/1985
From: Carpenter T
MEMPHIS STATE UNIV., MEMPHIS, TN
To:
Shared Package
ML20099L159 List:
References
NUDOCS 8503200499
Download: ML20099L164 (37)


Text

O e APPLICATION FOR AMENDMENT NO. 5 to MEMPHIS STATE UNIVERSITY FACILITY OPERATING LICENSE NO. R-127, DOCKET 50-538 Submitted: / I/fluA Thphas M. Carp e/ pter President /

Memphis State University r

STATE OF TENNESSEE COUNTY OF SHELBY Thomas G. Carpenter, being duly sworn, states that he is President of Memphis State University; that he executed this document for the purpose t set fcrlh; that the statements made herein are true to the best of his knowledge , information, and belief; and he is authorized to execute this ,

document on behalf of said university. l Sworn and attested this day before me / ,1985 k

Notary Public v My commission expires dU 8503200499 850315 DR ADOCK 0500

CONTENTS Ti tl e Page a nd Swo rn Stat enen t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Contents.......................................................... ii I GENERAL INFORMATION............................................... 1 A. Introduction B. The Applicant II CURRENT STATUS OF THE FACILITY.................................... 2 III PROPOSED FACILITY MODIFICATIONS................................... 3 A. Reactor Fuel and Neutron Source B. Reactor Components, Shielding, and Controls C. Administrative Controls IV PROPOSED AMENDMENT N0. 5 TO OPERATING LICENSE R-127............... 6 A. Scope of Authorization and Conditions of the License B. Technical Specifications V SAFETY EVALUATION................................................. 23 A. Facility Modifications B. License Amendment C. Environmental Considerations VI REFERENCES........................................................ 25 APPENDICES A. List of Applicant's Directors and Principal Officers B. Existing Facility Arrangement C. Fuel Inventory (SNM)

D. Assessment and Storage Locations of Radioactive Materials and Fission Product Activity ii

I. GENERAL INFORMATION A. Introduction. The Model AGN-201, serial 108 Nuclear Research and Training Reactor has been operated by the Memphis State Univer-sity Center for Nuclear Studies since December 10, 1976. Effec-tive December 31, 1984, the Center was terminated and all prior training commitments were scheduled for completion by selected members of the operating staff no later than March 31, 1985.

Accordingly, and pursuant to the Code of Federal Regulations, Title 10, Chapter 1, Part 50.90, Memphis State University (MSU) <

hereby applies for amendment to its Class 104(c) Facility Operat-ing License R-127, Docket 50-538, to:

1. Change the reactor facility to a SAFSTOR (reference 1) status permitting the licensee to possess but not operate the AGN-201, serial 108 Nuclear Reactor and,
2. Possess, in an approved storage facility, up to 700 grams of contained U-235 normally used in connection with operation of the facilty and,
3. To possess, but not to separate, such byproduct and special materials as may have been produced by operation of the reac- L tor.

Approval of this application will provide assurance that the MU Reactor Facility can be safely maintained for an indefinite  ;

period during which further planning and preparation can be ac- <

complished to either decommission and dismantle the facility or to secure adequate resources for future restoration to an opera-tional status. Maintenance and security of the facility in compliance with license requirements specified for SAFSTOR or '

mothballed status are within the capabilities of existing per- '

manently staffed full-time positions at the university. ,

B. The Applicant. General information required by 10 CFR 50.33 con-cerning the applicant, except as shown below, is contained in the Application for Construction Permit and License to Operate the Model AGN-201, Serial 108 Nuclear Reactor at Memphis State Uni-versity dated April 11, 1975, as amended (see Docket 50-538).

1. The names, addresses and citizenship of its directors and of its principal officers pursuant to 10 CFR 50.33(d)(3)(ii) has been updated and included herein as Appendix A.
2. Earliest date for completion of SAFSTOR: March 31, 1985.
3. Latest date for completion of SAFSTOR:
  • June 30, 1985.

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II. CURRENT STATUS OF THE FACILITY The MSU Research and Training Reactor, Madel AGN-201, is located in -

an annex to the ground floor of Building 113 which is situated in the northwest corner of the MSU South Campus. The reactor is constructed as a sealed system containing a solid, homogeneous core, four control rod assemblies, solid graphite reflector, and lead and water shield-ing in a reactor tank which is 61/2 feet diameter by 91/2 feet high. The reactor is operated at ambient temperatures and requires no auxiliary or liquid cooling systems. The fuel is distributed within nine core discs and four control rod capsules and is composed of U02 in poly-ethylene (approximately 3.3 kg Uranium enriched 19.8% in the isotope U-235). A 10 milligram Radium-Beryllium neutron source and drive assembly is installed in one of the experiment ports of the reactor assembly.

Reactor operations are conducted from a console situated in a separate Reactor Control Room. Electrical cables for neutron monitoring in-struments and rod control systems interconnect the console and reac-tor assembly via a floor-level cable trough passing through the Control Room and Reactor Room. A designated fuel storage area is lo-cated in the basement of Room 147 at the northeast corner of Building 113. The existing facility arrangement is shown in Appendix B.

Detailed descriptions of the reactor assembly, console, and fuel storage area are documented in references 2-6.

The MSU reactor was operated for approximately fifteen years (1957-1972) by Argonne National Laboratory and eight years (1976-1985) by Memphis State University. The reactor had been in storage for about four years prior to restoration at the present site. MSU has con-ducted more than 2,400 startups and accumulated approximately 960 hours0.0111 days <br />0.267 hours <br />0.00159 weeks <br />3.6528e-4 months <br /> of operations at critical since December,1976. The core has never operated at steady-state power levels exceeding.0.1 Watt (thermal ) . The inherent design features of this reactor and the low power at which it is operated preclude the buildup of significant amounts of fission products and the fission product inventory is con-sidered to be negligible (reference 2).

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III. PROPOSED FACILITY MODIFICATIONS A. Reactor Fuel and Neutron Source. All fissionable materials shall be removed from the reactor, core tank, and safety and control rod fuel capsules using the existing, approved MSU AGN-201 Mainten-ance and Storage Manual . This manual contains a specific Reactor Defuel Procedure and Defuel Checklist. The presence of a Senior Operator licensed pursuant to 10 CFR 55 and the MSU Radiation Safety Officer, or his designated representative, is required during all fuel handling evolutions. The Reactor Defuel Procedure was executed and found to be safe and effective during a routine (5 year) fuel inspection conducted by facility operators in December, 1981.

The fuel discs will be placed into the same containers using the same packing scheme consisting of 6J drums, five gallon pails, and vermiculite that was found to be acceptable (reference 2) to  ;

transport and store the fuel during facility construction in '

1976. Not more than 200 grams of U-235 shall be in any one con-tainer. The shipping / storage containers shall then be sealed and placed into secure storage in Room 010 of our facility (Appendix ,

B). The containers, packing scheme, and fuel storage facility 1 are described in detail in Part 3 of Amendment 3 (December,1975) ,

to reference 3. A complete listing and identification of special nuclear material (SNM) for the MSU Reactor is contained in Appen-dix C to this document.

The ten milligram Radium-Beryllium, sealed neutron source will be removed from the reactor, placed into a shielded container, and stored in a sealed D.0.T.-7A type shipping container normally lo-cated in the Reactor Room unless an alternate location is speci-fied by the Radiation Safety Office. The container and room will be properly identified pursuant to 10 CFR 20.203 and 20.204.

B. Reactor Components, Shielding, and Controls. Except for purposes of inspection and maintenance when minor disassembly may be re-quired, the defuelled reactor assembly shall remain assembled as follows: the Thermal Column Tank, Access Port Liner Tubes, Glory Hole Liner Tube, and Rod Drive Area Cover Plate shall be installed and gasketed to maintain the vessel secondary fluid-tight integ-rity. The graphite reflector cylinder, lead shielding, and Access Port Filler Plugs shall remain installed. Neutron detectors with interconnecting instrument cables shall remain installed. The aluminum core tank and safety and control rod assemblies shall not be installed. The doors to the reactor skirt area shall re-main locked at all times that authorized personnel are not pre-sent.

The defuelled aluminum core tank and safety and control rod fuel capsules will be stored with covers and gaskets in place. The core tank, fuel capsules, and all rod drive assemblies will be stored, apart from the reactor assembly, in the Reactor Room.

Prior to the SAFSTOR condition, the reactor vessel interior including the core tank and fuel capsules shall be thoroughly surveyed for residual radioactivity and loose surface contamina-I tion under the supervision of the MSU Radiation Safety Officer.

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Surface contamination in excess of acceptable concentrations (references 1,7) shall be clearly identified and documented for future reference. If warranted, appropriate placards and/or tags shall be affixed to the vessel or specific components listing the radioactivity concentrations.and nuclides that are present.

The Shield Tank and Thermal Column Tank water shall be sampled for radioactivity and drained using existing, approved procedures from the MSU AGN-201 Maintenance and Storage Manual. The Shield Tank and Thermal Column Tank will be blown dry with air and shall remain dry in SAFSTOR status.

Except for purposes of inspection and maintenance when minor dis-assembly may be required, the console shall remain intact with access doors locked. The Rod Control Circuits shall remain de-energi zed. All of the reactor control cabling is routed through a single, multi-conductor cable with a molded 60-pin plug at each end. The control cable plug at the reactor assembly and the con-trol cable plug at the console will be disconnected and wrapped in protective plastic. The power cable connecting 115 VAC to the console Reactor Control Power circuits shall be disconnected and removed. Interconnecting cables for the neutron flux monitors may remain connected.

The Reactor Room and Control Room shall remain locked at all times that authorized personnel are not present.

C. Administrative Controls.

1. Organization. The position of Director, Center for Nuclear Studies, was discontinued af ter December 31, 1984. Staff positions subordinate to the Director which include the Supervisor of Nuclear Operations, Reactor Administrator, Reactor Supervisor, and: Reactor Operators will be discon-

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tinued after removal of fuel from the reactor. Reactor de-fuel is scheduled to be accomplished by March 31, 1985. The Reactor Safety Committee (RSC) will be disbanded only after the license amendment for SAFSTOR has been approved and issued.

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a. The Vice President for Advancement and Continuing Educa-tion shall remain as the Administrative Officer directly responsible to the President.of Memphis State University for maintenance, safety, security, and administration of the reactor facility and fuel storage area. He shall, in this capacity, represent the President in matters per-taining to the facility license and, within limitations  ;

set forth in the license, have final approval authority l and responsibility for decisions, procedures, and events that would affect the facility, the reactor, reactor com-ponents, and reactor fuel. He shall be responsible for l official communications in connection with the reactor f acility including all required reports and retention of !

l records. To assist the Vice President, university service organizations are available and shall provide the person-i 4

nel described in paragraph III.C.1.b to assure long term protective storage of the facility and radioactive mate-rial s . The Vice President may appoint personnel, as necessary, to positions reporting directly to him for purposes of executing routine requirements of the facil-ity license so long as the appropriate personnel qualifi-cations standards are met.

The Vice President for Advancement and Continuing Educa-tion shall be advised by the Radiation Safety Subcommit-tee in all matters concerning risks to personnel health and safety from ionizing radiation and shall be advised by the Director of MSU Security and Safety Services in all matters concerning physical security of the facility and fuel storage area,

b. The MSU Radiation Safety Officer (RS0) fills a full-time position established within the Department of Security and Safety Services and maintains the MSU Radiation Safety '

Office. The RSO, or his designated representative, shall perform such surveillance activities of the reactor fa-cility and fuel storage area as specified in the SAFSTOR amendment. The RSO shall advise the Vice President for Advancement and Continuing Education, in writing, of the results of these activities including any appropriate recommendations.

Maintenance activities necessary to maintain the facility utilities and support systems shall normally be performed by the Department of Physical P.lant and Planning upon request from the Office of Advancement and Continuing Education and in accordance with the existing university policies and procedures.

Physical security shall be maintained by MSU Security Officers in accordance with the approved security plan for the reactor and fuel storage facility.

2. Procedures. The approval of existing written procedures per-taining to startup and operation of the reactor including experiments that would involve the reactor or reactor fuel shall be revoked. Controlled copies of such procedures shall be removed from circulation and shall not be used.

There shall be written procedures, approved by the Vice Pres-ident for Advancement and Continuing Education and as other-wise specified in the SAFSTOR amendment, for the surveillance and testing of support and protection systems necessary to maintain the mothball status of the facility; personel radia-tion protection consistent with 10 CFR 20; and implementation of the approved Security Plan and Emergency Plan.

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IV. PROPOSED AMENDMENT NO. 5 TO OPERATING LICENSE R-127 g ,g i

It is proposed that the existing Operating License be amended to change paragraphs 2.B.(1), 2.B.(3), 2.B.(4), 2.C.(1), 2.C.(2), 2.D, and the Technical Specifications as follows:

Scope of Authorization and Conditions'of' the A. cen .

1. Change paragraph 2.B.(1) to read: "... to possess but not operate the facility at the designated location in Memphis,  ;

Tennessee, in accordance with the procedures and limitations i set forth in this license."

2. Change paragraph 2.B.(3) to read: "... to receive, possess, and store up to 700 grams of contained Uranium-235 enriched  ;

equal to or less than 20% in connection with the facility, and ...".

3. Change paragraph 2.B.(4) to read: " ... such byproduct and special materials as may have been produced by operation of the reactor."
4. Change paragraph 2.C.(1), Maximum Power Level, to read: "The licensee is not authorized to operate the reactor."

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5. Change paragraph 2.C.(2), Technical Specifications, to read:

"The Technical Specifications contained in Appendix A, as

! revised through Amendment No. 5, are hereby incorporated in the license. The licensee shall possess and maintain the

! f acility in accordance with the Technical Specifications."

6. Change paragraph 2.0. to read: "The licensee shall maintain in ef fect and fully implement all provisions of the Commis-sion's approved ' physical 'secur'.ty plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).

The approved security plan consists of documents withheld from public disclosure pursuant to 10 CFR 2.790 and entitled 'Phy-sical Security Plan for the AGN-201 Nuclear Reactor Facility 6

and Special Nuclear Material Storage Area at Memphis State University, March 1985.

' i B. Technical Specifications.

1. Amend Section 1.0, Definitions, by adding the following:

"1.15 Reactor Secured - The reactor shall be considered secured when:

(1) It contains insufficient fissile material or moderator present in the reactor, adjacent experiments or control rods, to attain critica-lity under optimum available conditions of moder-ation and reflection, or (2) No work is in progress involving core fuel, control rods or control rod drives unless they are physically decoupled from the reactor, and (3) The console key switch is in the off position and the key is re:noved from the lock."

"1.16 SAFSTOR or Mothball' - The reactor facility is con-sidered to be in a SAFSTOR or mothballed condition when the facility is in a state of protective storage.

The facility may be left intact except that all fissionable materials, radioactive wastes, and radio-active fluids shall be removed from the reactor room.

The reactor fuel shall be in storage containers and located in a remote fuel storage area in accordance with an approved fuel storage pian. Appropriate sur-veillance, radiation monitoring, and security proce-dures are established under a possession-only license

! to ensure that the health and safety of the public is not endangered."

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2. Change Section 2.0, Safety Limits and Limiting Safety System Settings, as follows: t t
a. Delete existing parts 2.1 and 2.2 in their entirety.

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b. Add, " Not App 1*c.able. The reactor shall remain secured j and the facility shall be in mothball status." i
3. Change Section 3.0, Limiting Conditions for Operation, as follows:
a. Delete existing parts 3.1, 3.2, 3.3 and 3.4 in thei r en- ,

tirety.

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b. Add, "Not Applicable. the reactor shall remain secured -

and the facility shall be in mothball status."

4. Delete existing Section 4.0 and replace with the following: ,

i "4.0 Surveillance Requirements j Actions specifled in this section are applicable to the SAFSTOR or mothballed condition of the facility and shall be performed within the specified surveillance period. '

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4.1 Facility Support and Protection Systems Applicability This specification applies to the facility support and I protection systems such as physical barriers, fire pro-tection systems, and radiation monitoring activities.

Objective To assure that the public health and safety are not endangered as a result of physical degradation of the facility during the term of SAFSTOR.

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Specification fi

a. Physical barriers to unauthorized entrance into the reactor facility and fuel storage area, e.g.,

0 building, rooms, doors, and access openings, shall be visually inspected at least once each calendar quarter (intervals not to exceed four months).

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b. Fuel storage containers, container locking rings,  !

and seals _shall be visually inspected at least once '

each calendar quarter (intervals not to exceed four i months).  !

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c. - A radiation survey of the reactor facility and fuel f storage area shall be performed at least once each calendar quarter (intervals not to exceed four  ;

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d. The reactor building fire alarm system, including [;

the reactor room smoke detector, shall. be tested j annually (intervals not to exceed fifteen months). }

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'The physical barriers, e.g. building, rooms doors, and l access openings are inspected to assure that these bar- ,

riers have not deteriorated and that locks and locking f apparatus are intact.

' Storage containers, container locking rings, and seals are inspected to assure integrity of the containers. .

This inspection in conjunction with radiation surveys of the reactor facility and fuel storage area verifies f that radioactive material has not been removed from the containers or is not escaping or being transported I through the containment barriers. In addition, the ra-

. diation surveys provide assurance that radiation doses to facility personnel and to the public are maintained

at a level below 10 CFR 20 limits.  ;

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Tests of the reactor building fire alarm system and reactor room smoke detector verify that these systems are operable."

5. Amend Section 5.0, Design Features, by adding the following new part:

"5.4 SAFSTOR or Mothball Status During a mothballed state of protective storage:

a. The reactor is defuelled and assembled with the Thermal Column Tank, Access Port Liner Tubes, Glory Hole Liner Tube, and Rod Drive Area Cover Plate installed and gasketed to maintain the design fluid-tight integrity. The graphite refl?ctor cylinder, lead shielding, and access port filler plugs are in place. The Shield Tank and Thermal Column Tank are empty of fluids and dry.
b. The defuelled aluminum core tank and safety and control rod fuel capsules are removed from the reactor assembly and are sealed to maintain design fluid-tight integrity. The rod drive assemblies are electrically disconnected and removed from the reactor. Rod control cabling between the reactor and control console is disconnected.
c. All fissionable material used in connection with operation of the reactor is stored in 6J drums, con-taining less than 200 grams of U-235 each, and is located in a designated, controlled fuel storage area in accordance with paragraph 5.2 of these technical specifications."

l 6. Delete existing Section 6.0, Administrative Controls, in its i

entirety and replace with the following:

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"6.0 Administrative Controls 6.1 Organization, Responsibilities and Authority. Respon-sibility for protective storage of the reactor facil-ity shall be with the organization shown in Figure 1 of this section. Individuals at the various manage-ment levels shall be responsible for safeguarding the public and facility personnel from undue radia-tion exposures and for adherence to all requirements of the facility license. Assignment of specific re-sponsibilities shall be as described in the following paragraphs.

6.1.1 President. The President of Memphis State University is the Chief Administrative Officer ultimately responsible to the Tennessee State Board of Regents for the university and its activities. The President is responsible for the reactor facility license.

6.1.2 Vice President for Advancement and Continuing Educa-tion. The Vice President for Advancement and Contin-uing Education is the Administrative Officer directly responsible to the President for maintenance, security and access control, administration, and safety of the reactor facility and fuel storage area. The Vice President may, in this capacity, represent the Presi-dent in matters pertaining to the facility license and, within limitations set forth by the license, have final approval authority and responsibility for decisions, policies, procedures, and events that would affect the facility, the reactor, reactor com-ponents, and reactor fuel. The Vice President for

! Advancement and Continuing Education shall be respon-sible for official communications concerning the r ed r and r en on fac lit re rd .

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The Vice President for Advancement and Continuing Ed-ucation shall be advised by the Radiation Safety Sub-committee in all facility matters involving risks to personnel, health _and safety ' rom ionizing radiation and shall be advised by'the Director, MSU Safety'and

, Security Services, in all matters involving physical security of the facility and reactor fuel. The Vice President may appoint personnel having the appropri-ate qualifications, as necessary, to positions re-porting directly to him for purposes of executing re-quirements of the facility license and assuring safe storage of the facility.

6.1.3 Radiation Safety Subcommittee. The Radiation Safety Subcommittee (RSSC) is a subcommittee of the Univer-sity Standing Committee on Safety (University Safety Committee) whose members are appointed by the Presi-dent. The RSSC is formed to administer the Radiation Safety Program for the university. In this capacity, the RSSC shall be responsible and have approval au-thority for all procedures, policies, and activities which involve risks to the health and safety of per .

sonnel from ionizing radiation. The RSSC shall advise the Vice President for Advancement and Continuing Ed-ucation in radiation control and safety matters re-lated to the reactor facility and fuel storage area and shall be informed by the Office of the Vice Pres-ident of the status and locations of radioactive materials and of any activities involving personnel exposure to ionizing radiation within these facili-l ties.

The Radiation Safety Subcommittee shall hold meetings and shall be responsible for independent reviews and l audits of surveillance and maintenance activities in-cluding radiation surveys. Based upon these reviews and audits, the RSSC shall make appropriate recommen-12

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dations to the Vice President for Advancement and Continuing Education to assure that the state of the facility does not endanger the health and safety of

the public.

6.1.4 Radiation Safety Officer. The Radiation Safety Offi-l cer (RS0) is a member of the Radiation Safety Subcom-f mittee and is empowered to enforce regulations and regulatory procedures established by the university, federal agencies, and state agencies for the control of radioactive materials and protection of personnel from ionizing radiation. The RSO shall be responsible for the performance of radiation surveys and shall l

maintain survey records in connection with the reac-tor facility and fuel storage area. In addition to routine surveillance activities delineated in these Technical Specifications, the RSO shall maintain ma-l terials inventory records and records of personnel exposures to ionizing radiation. The RS0 shall inform

( the Vice President for Advancement and Continuing Ed-ucation, in writing, of surveillance and inspection I

results within 14 days of completing such activities. l The Radiation Safety Officer shall be responsible for and shall supervise activities involving the movement of radioactive materials within the facility and/or l

the packaging and shipment of radioactive materials off-campus. The RSO shall be directly responsible for the proper identification and posting of re-stricted areas within the reactor facility and fuel storage area.

6.1.5 Director, Security and Safety Services. The Director of Security and Safety Services is the management of-ficial directly responsible for the physical security of university property and the enforcement of univer-sity security and safety regulations on the MSU South 13

Campus. In this capacity, the Director of Security and Safety Services shall provide the services and trained security officers necessary to implement the f acility security plan approved as part of this li-cense to assure protective storage of the reactor and fuel. He shall advise the Vice President for Advance-ment and Continuing Education in matters involving physical security and access control of the reactor l f acility and fuel storage area and shall be informed of personnel authorized for access by the Office of the Vice President.

6.2 Radiation Safety Subcommittee Meetings, Reviews, Audits, and Records 6.2.1 Qualifications. The Radiation Safety Subcommittee is established as a subcommittee of the University Safety Committee. Members of the University Safety Committee are appointed by the President. The Subcommittee is appointed by the Chairperson of the University Safety Committee and includes a chairperson, the University Safety Director, the Radiation Safety Officer and several members selected on the basis of their exper- I tise in radiation safety and related matters. The l Subcommittee is empowered to meet and keep minutes independently of the University Safety Committee and with the authority to administer the university's radiation safety program.

6.2.2 Meetings and Quorum. The Radiation Safety Subcommit-tee shall meet as necessary but at least once each calendar quarter (intervals not to exceed four months). A quorum for review and approval functions shall consist of the chairperson, or designated al-ternate, and two other members.

6.2.3 Reviews. The Radiation Safety Subcommittee shall review:

a. All procedures and major revisions thereto per-taining to the reactor facility and fuel storage area and which have radiological safety signifi-cance, or include changes to facility equipment or systems, or affect authorized personnel access to the facility.
b. Proposed changes to the facility license, techni-cal specifications, or charter.
c. Violations of the license, technical specifica-tions, or charter.

l' l d. Reportable occurrences listed in 6.4.

e. Abnormalities in, or deviations from, the normal and expected status of facility equipment and i

protective barriers.

6.2.4 Audits. The Radiation Safety Subcommittee shall con-duct audits that include selective (but comprehensive) I examination of facility and fuel storage area records, logs, and other documents. Discussions with cognizant personnel and observation of activities should also be conducted as appropriate. In no case shall the individual immediately responsible for an area per-form the audit in that area. The following items i shall be audited:

a. Facility operation, surveillance, and maintenance
for conformance to the Technical Specifications f- and applicable license conditions, at least once h

i per calendar year (intervals between audits not to exceed fifteen months).

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b. The results of actions taken to correct deficien-cies that may occur in reactor facility and fuel storage area equipment, systems, structures, and radioactive. materials storage containers, at least once per calendar year (intervals between audits not to exceed fifteen months).
c. The reactor facility and fuel storage area secu-rity plan and implementing procedures, at least once every other calendar year (intervals between audits not to exceed 30 months).
d. The reactor facility and fuel storage area emer-gency plan and implementing procedures, at least once every other calendar year (intervals between audits not to exceed 30 months).

6.2.5 Records and Reports. The Chairperson of the Radia-tion Safety Subcommittee shall ensure that records of i

the committee's activities are prepared, distributed, and retained as follows:

a. Minutes of each Radiation Safety Subcommittee meeting shall be prepared and retained on file in the University Radiation Safety Office. A copy of these minutes shall be forwarded to the Vice President for Advancement and Continuing Educa-l tion within 30 days following each meeting.

l b. A written report or minutes of the findings and recommendations of each review group shall be

._ prepared and submitted to the Vice President for Advancement =and Continuing Education and all Radiation Safety Subcommittee Members in a timely manner after the review has been completed. A copy of each report shall be retained on file in the University Radiation Safety Office.

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c. Deficiencies uncovered that affect radiation safety or protective storage of the reactor or reactor fuel shall be immediately reported to the Vice President for Advancement and Continuing Ed-ucation. A written report of the findings of each audit shall be submitted to the Vice President - l and all Radiation Safety Subcommittee Members  ;

within three months after the audit has been com-  ;

pl eted. ' A copy of all audit reports shall be re- !

tained on file in the University Radiation Safety Office.

d. The Chairperson of the Radiation Safety Subcom-mittee shall submit an annual report to the Pres-ident prior to March 31, of each calendar year.

The report shall contain an assessment of the fa-cility's suitability for continued protective storage of radioactive materials, including the reactor fuel, and any appropriate recommendations.

Copies of this report shall be submitted to the Vice President for Advancement and Continuing Ed-ucation and retained on file in the University Radiation Safety Office.

6.3 Procedures and Procedure Approvals.

6.3.1 -Procedures. There shall be written procedures for the following,

a. Surveillance and testing of equipment and systems required for protective storage of the reactor and reactor fuel .
b. Personnel radiation protection consistant with 10 CFR 20.
c. Access control to the reactor facility and fuel storage area.

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d. Implementation of the security plan and emergency plan.
e. Notification of the proper authorities in the event of unauthorized entries of personnel 'into the facility and significant changes in the radi-ation or contamination levels within the facility.

6.3.2 Procedure Approvals. The Vice President for Advance-ment and Continuing Education shall have final ap-proval authority for all procedures in connection with the reactor facility and fuel storage area. The Radiation Safety Subcommittee shall review and have approval authority for those procedures which may in-clude risks to the health and safety' to personnel from ionizing radiation in addition to those reviews speci fied in 6.2.3. The Director of Security and Safety Services shall review and have approval authority for procedures written to implement the security plan and emergency plan.

6.4 Reporting Requirements 6.4.1 Annual Report. An annual report describing the sta-tus of the facility, the results of environmental and f acility radiation surveys, an evaluation of the per- l formance of security and surveillance measures, per-  !

sonnel exposures to radiation, and any abnormal occurrences during the previous calendar year shall l be submitted to the Director of Nuclear Reactor Regu-lation prior to March 31, of each calendar year.

6.4.2 Reportable Occurrences. Reportable occurrences shall be reported as expeditiously as possible by telephone and confirmed by telegraph, mailgram or facsimile transmission to the Director of the appropriate NRC Regional Office, or his representative, no later than 18

the first work day following the event. A written followup report describing the reportable occurrance including causes, probable consequences, corrective actions, and measures to prevent recurrence shall be i submitted within 14 days. Information provided shall contain narrative material for a complete explanation of the circumstances surrounding the event. The fol-lowing events shall be reported:

a. Discovery of significant, unexplained increase in radiation or contamination levels within or '

f around the reactor facility or fuel storage area.

b. Abnormal degradation discovered in protective barriers for the reactor facility or fuel storage area which would compromise the physical security established for protective storage of the reactor and reactor fuel.

6.4.3 Special Reports. Special reports which may be required by the Nuclear Regulatory Commission shall be submitted to the Director of the appropriate NRC Regional Office within the time period specified for each report.

6.5 Record Retention.

6.5.1 SAFSTOR Records. Records or logs relative to the following items shall be kept and retained until the license is terminated, unless otherwise specified by the NRC:

a. Environmental surveys.
b. Facility Radiation surveys.
c. Inspections of physical barriers. j
d. Abnormal occurrences.
e. Records of meetings of the Radiation Safety Sub- ,

committee, f

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r 6.5.2 Prior Facility Operation.

6.5.2.1 Records or logs relative to the following items shall be retained for.a period of at least five years: " "- '

a. 0perating logs or data which shall identify:
1. Completion of pre-startup checkout, start-up, power changes, and shutdown of the re-actor.
2. Installation or removal of fuel elements, control rods, or experiments that could affect core reactivity.
3. Installation or removal of jumpers, special tags or notices, or other temporary changes ,

to reactor safety circuitry.

4. Rod worth measurements and other reactivity measurements.

I

b. Principal maintenance operations.

l

c. Reportable occurrences.
d. Surveillance activities required by technical specifications.
e. Facility radiation and contamination surveys,
f. Experiments performed with the reactor.
g. Changes to operating procedures.

20

~ - . , - . . . - - . - - - _ _ , , - . __

6.5.2.2 Records or logs relative to the following items shall be retained for the life of the facility, unless otherwise specified by the NRC:

a. Gaseous and liquid radioactive effluents re-leased to the environs.
b. Appropriate off-site environmental monitoring surveys.
c. Fuel inventories and fuel transfers,
d. Radiation exposures for.all personnel.
e. Updated as-built drawings of the facility,
f. Records of transient or operational cycles for those components designed for a limited number of transients or cycles.
g. Records of training and qualifications for mem-bers of the facility staff.
h. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
1. Records of meetings of the Reactor Safety Com-mittee.

l 21 i

PRESIDENT MEMPHIS STATE UNIVERSITY RADIATION SAFETY VICE PRESIDENT DIRECTOR SUBCOMITTEE -------

ADVANCEMENT AND --------

SECURITY AND CONTINUING EDUCATION SAFETY SERVICES RADIATION SAFETY ' REACTOR FACILITY SOUTH CAMPUS OFFICER AND SECURITY FUEL STORAGE AREA 0FFICERS Direct Line of Authority


Advi so ry/ Assi stance Capaci ty FIGURE 1. REACTOR FACILITY SAFSTOR ORGANIZATION" 22

V. SAFETY EVALUATION The Memphis State University AGN-201 Nuclear Reactor Facility and designated fuel storage scheme have been previously assessed in Safety Evaluations by the Office of Nuclear Reactor Regulation in support of Operating License R-127, Docket No. 50-538 (reference 2,3). '

The following evaluation applies to alterations proposed in Part III and-IV of this application.

A. Facility Modifications. The removal of fuel from the reactor, fuel handling activities, and preparation of the fuel for storage will be performed under supervision and in the presence of a Senior Operator licensed pursuant to 10 CFR 55 and the MSU Radia-tion Safety Officer. Defuel procedures have been reviewed and approved by both the Reactor Safety Committee and the Radiation Safety Subcommittee and have been found to be safe and effective during use in a prior defuel evolution. The fuel storage scheme includes adequate measures to prevent criticality, reactivity changes, or releases of radioactivity and has been used in the past without incident. The small quantities and distribution of radioactive materials, including fission product activity, are estimated in Appendix D of this application and are consistent with previously documented low-level radiation exposure rates measured upon contact with the surface of AGN-201 fuel elements.

The SAFSTOR condition of reactor components, shielding, and con-trol systems represented by statements in this application, in addition to the removal of all fissionable materials from the reactor facility, assures that the reactor and control systems cannot be operated. The removal of all liquids from the shield tank and thermal column tank will minimize long-term corrosion of the reactor vessel structures. Radiation surveys will identify 1 surface contamination levels that are greater than acceptable for ~

unrestricted access (references 1,7), any such areas will be pro-perly documented and posted, and restoring the vessel, core tank, and fuel capsules to their design liquid-tight integrity will assure containment of such activity throughout the storage term.

The physical barriers housing these components will not be open for unrestricted access and shall remain locked at any time authorized personnel are not present.

Changes to the administrative organization described in this ap-plication provide for a direct line of authority from, and direct line of communications to, the Senior Executive Officer at Mem-phis State University. Delegated responsibilities and commen- i surate authority are clearly delineated to assure protective cust;ody, proper maintenance, and radiation safety of the reactor i and reactor fuel. Surveillance, security, and radiological con-trols requirements are within the capabilities of normally staffed, full-time positions within MSU and which are at the dis- l

- posal of the Administrative Officer directly responsible to the l President for facility security, safety, and license compliance.

l i

23

i Memphis State University has concluded, based upon the considera-tions discussed above, that:

I the proposed facility modifica-tions, in conjunction with the existing radiation safety program i

and administrative controls, will be accomplished within the t

+

limitations prescribed in 10 CFR 20 for facility personnel and- I

^

without risk to the. environment or public health and safety; the i status of the reactor facility and fuel after the modifications is ' have been accomplished, in conjunction with the proposed adminis-  ;

trative controls and implementing procedures, provides assurance  ;

that an adequate state of protective storage will be achieved and maintained in compliance with NRC Regulations.and; the transition  ;

of.the facility from-an operational to a mothball status in ac .

t cordance with statements made in this application will not involve

an unreviewed safety question. ,

E B. License Amendment. The amendment proposed in this application f would change the scope of authorization and required license to a  !

" Possession Only" status which prohibits operation of the reactor.  !

' The proposed revision to the technical specifications defines  !

acceptable terms (reference 1,8) which clearly describe the con- l dition in which the reactor and reactor fuel shall remain while  ;

in mothball status. Surveillance requirements are specified to l assure that facility support and protection systems remain in an  !

acceptable condition. Periodic radiation surveys are required to l l be performed to assure that radiation and contamination levels t remain within regulatory limits and the amended Design Features  ;

are clearly-descriptive of the facility condition after the pro-posed modifications have been accomplished. -  ;

j The proposed Administrative Controls provide for direct lines of t authority from, and communications to, the Senior Executive j - Officer at Memphis State University for individuals responsible  :

for personnel safety, protective storage of materials, and compli-  ;

ance with the facility license. Provisions are made for approval  ;

authority, reviews, and periodic audits of activities and imple-menting procedures involving radiation safety, facility security, and emergency planning. The proposed amendment provides for the  !

maintenance of records, and establishes reporting requirements to  ;

assure proper documentation and transmission of required infor- '

4-mation to the appropriate authorities. !I Memphis State University has concluded, based upon the above con-

< siderations, that activities in connection with protective stor- -

age of the reactor and reactor fuel will be conducted in compli- t ance with regulatory requirements for a " Possession 0nly" license t and that, in conjunction with an approved security and emergency  ;

plan, approval of the proposed amendment will not be inimical to f

the health and safety of the public.

C. Environmental Considerations. Based upon the proposed modifica-tions and statements contained in this application, Memphis State '

University considers the environmental impact to remain as stated

in reference 2, and that an environmental impact statement for the proposed action would not be required. '

1 i [

24  !

)

VI. REFERENCES

1. American National Standard for Decommissioning of Research Reactors, ANSI /ANS-15.10-1981.
2. Memphis State University Facility Operating License R-127, Docket No. 50-538.
3. Application for Construction Permit and License to Operate the Model AGN-201, serial 108 Nuclear Reactor at Memphis State University, April 11, 1975, as amended (Docket 50-538).
4. " Hazards Summary Report for the AGN-201 Reactor", Aerojet-General Nucleonics, August 1956 (Docket F-15).
5. "AGN Model 201 Reactor, Preliminary Design Study", Aerojet-General Nucleonics, May 1956 (Docket F-15).
6. "AGN-201 Reactor Manual," Aerojet-General Nucleonics, July 1957 i (docket F-15).
7. U.S. Atomic Energy Commission Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors," June 1974.
8. American National Standard for the Development of Technical Spe-cifications for Research Reactors, ANSI /ANS-15.1-1982.
9. Memphis State University Radiation Control and Safety Manual, Re-vised December 1,1980: Memphis State-University.
10. U.S. Nuclear Regulatory Commission Regulatory Guide 10.1, "Compil-ation of Reporting Requirements for Persons Subject to NRC Regu-lations, Revision 4," October 1981.
11. S. Glasstone and A. Silsonske, Nuclear Reactor Engineering, Third

! Ed., Von Nostrand Reini:old Company: New York, 1981.

25

APPENDIX A . . Page 1 of 3 Application for Amendm:nt No. 5 Operating License R-127, Docket 50-538 STATE BOARD OF REGENTS

. The Honorable Lamar Alexander Dr. J. D. Johnson Governor of Tennessee Suite 101, 400 Laboratory Rd.

State Capitol Oak Ridge, TN 37830 Nashville, TN 37219 615/483-7851 615/741-2001 Mrs. Gwen R...Awsumb Mr. James H. Jones, Jr.

4411 Walnut Grove Rd. Mid-Tenn Bank of Mt. Pleasant Memphis, TN 38117 P.O. Box 312 901/682-1478 Mt. Pleasant, TN 38474 615/379-5551 Mr. Thomas W. Beasley Mr. Richard A. Lewis Corrections Corporation of America 706 Monroe St.

28 White Bridge Rd., Suite 206 Nashville, TN 37208 Nashville, TN 37205 615/255-2371 615/356-1885 Dr. G. Wayne Brown The Honorable Robert L. McElrath Tennessee Higher Education Commission Commissioner of Education Suite 300 - 501 Union Bldg. Cordell Hull Bldg.

Nashville, TN 37219 Nashville, TN 37219 615/741-3605 615/741-2731 Mr. Harold T. Conner Mr. C. Scott Mayfield 605 N. McComb St. Mayfield Dairy Farms, Inc.

P.O. Box 25 P.O. Box 310 Martin, TN 38237 Athens, TN 37303 901/587-3441 615/745-2151 Mrs. Ruth Ellis The Honorable William H. Walker III Mountain Empire Bank Commissioner of Agriculture Johnson City, TN 37601 Ellington Agriculture Center 615/929-3138 Box 9039 Melrose Station Nashville, TN 37204 615/360-0100 Mr. J. C. Eof f, Jr. Mr. J. Howard Warf First National Bank 12 South Court P.O. Box 520 Hohenwald, TN 38462 Tullahoma, TN 37388 615/796-3073 615/455-3488 Mr. Ross N. Faires Mr. David V. White Tibbals Flooring Company 2705 Riverside Dr.

Oneida, TN ?7841 Knoxville, TN 37914 615/569-8526 615/546-7008 Mr. William W. Farris Student Regent Suite 1620 First Tennessee Building Mr. Carlton L. Purvis, III Memphis, TN 38103 1105 Shadyside Dr.

901/523-8080 Kingsport, TN 37663 APPENDIX A

~ '

APPENDIX A Page 2 of 3 Application for Amendment No. 5 Operating License R-127, Docket 50-538 KEY MEMBERS OF THE STATE BOARD OF REGENTS STAFF Roy S. Nicks, Chancellor William C. Aiken, Assistant Vice Chancellor for Research Bert C. Bach, Vice Chancellor for Academic Affairs D. Peter Consacro, Assistant Vice Chancellor for Academic Affairs Charles B. Fancher, Associate Vice Chancellor for Academic Affairs Elijah E. Hall, Assistant Vice Chancellor for Information Systems Sandy S. Hall, Administrative Assistant to the Chancellor Tommy G. Hall, Vice Chancellor for Vocational-Technical Education H. Clay Harkleroad, Associate Vice Chancellor for Business and Finance K. Norman Johnson, Vice Chancellor for Facilities Richard G. Rhoda, Executive Assistant to the Chancellor Susan C. Short, l General Counsel and Secretary i l

Howell W. Todd, Vice Chancellor for Research and Systems 1

James R. Vaden, Vice Chancellor for Business and Finance State Board of Regents 1161 Murfreesboro Rd.

I Nashville, TN. 37217  :

(615) 741-4821 i

APPENDIX A L ___ _-___-____- _ _ _ - _ _ _ _ _ _

APPENDIX A Page 3 of 3 Application for Amendment No. 5

- Operating License R-127, Docket 50-538 MEMPHIS STATE UNIVERSITY ADMINISTRATIVE OFFICERS Dr. Thomas G. Carpenter

. President Dr. Jerry N. Boone Vice President for Academic Affairs

. Dr. R. Eugene Smith Vice President for Business and Finance ,

Dr. Van N. Oliphant Vice President for Advancement and Continuing Education Dr. Donald K. Carson Vice. President and Dean of Students I.

APPENDIX A

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APPENDIX C Page 1 of 1 Application for Amendment No. 5 Operating License R-127, Docket 50-538 FUEL INVENTORY (SNM)

ITEM I.D. NO.

Core disc - 4 cm 20439 2138.9 495.32 98.28 Core disc - 4 cm 20440 2141.0 495.67 98.35 Core disc - 4 cm 20441 2027.2 468.05 92.87 Core disc - 4 cm 20450 2048.9 475.15 94.28 Core disc - 2 cm 20443 1259.8 291.10 57.76 Core disc - 2 cm 20444 1262.2 292.51 58.04 Core disc - 2 on 20445 1260.0 291.91 57.92 Core disc - I cm 20446 641.5 148.78 29.52 Core disc - 1 cm 20447 629.9 146.26 29.02 Core fuse 20106 5.93 2.02 0.40 CONTROL & SAFETY R0D FUEL CYLINDERS 4.7 cm dia. 20349 78.89 18.19 3.61 4.7 cm dia. 20350 79.01 18.24 3.62 4.7 cm dia. 20351 78.91 18.24 3.62 4.7 cm dia. 20352 78.91 18.24 3.62 4.7 cm dia. 20354 79.09 18.29 3.63 4.7 cm dia. 20358 79.02 18.29 3.63 4.7 cm dia. 20359 79.01 18.29 3.63 4.7 cm dia. 20360 79.10 18.29 3.63 4.7 cm dia. 20353 78.99 18.24 3.62 4.7 cm dia. 20355 78.92 18.24 3.62 4.7 cm dia. 20356 79.06 18.29 3.63 4.7 cm dia. 20357 78.98 18.29 3.63 2.3 cm dia. 20211 19.80 4.59 0.91 2.3 cm dia. 20212 19.89 4.59 0.91 2.3 cm dia. 20213 19.73 4.54 0.90 2.3 cm dia. 20214 19.78 4.59 0.91 TOTALS 14,442.42 3,344.21 663.56

  • 9 " "

bo!ef0$e kkchis'U82inPoYy$y ne APPENDIX C

' ~

APPENDIX D Page 1 of 4 Applicati n for Amendment No. 5 Operating License R-127, Docket No. 50-538 ASSESSMENT AND STORAGE LOCATION OF RADI0 ACTIVE MATERIALS AND FISSION PRODUCT ACTIVITY The radioactive materials associated with the AGN-201 Reactor include the reactor fuel and the 10 mg Radium-Beryllium neutron source. The aluminum core tank and control rod fuel capsules may contain trace amounts of short-lived activation products which decay to insignificant levels shortly fol-lowing removal from the reactor.

1. Reactor Fuel and Core Fuse. Special Nuclear Material (SNM) contained in the fuel discs and core fuse consists of 2680.65 grams of U-238 and 663.56 grams of U-235. A detailed listing of fuel discs is identified in Appendix C.
a. Natural Activity. The specific natural activity of the fuel may be calculated from the following relation:

Sp. Act. =

NA X 3

A (s.1, io*)

whtre Sp. Act. = pC1/ gram isotope NA

= Avagadro Constant (atom /mol)

A = Decay constant (sec-1)

A = Atomic wgt. (g/mol) 3.7 x 104 = dps/pCi For U238: Assume A = 4.92 x 10-18 sec-1 and A = 238.051 g/mol.

Sp.Act.238 = .336 pC1/ gram U238 For U235: Assume A = 3.12 x 10-17 sec-1 and A = 235.044 g/mol.

Sp.Act235 = 2.16 pCi/ gram U235 APPENDIX D

APPENDIX 0 . . Page 2 of 4 Applicaticn for Amendment No. 5 Operating License R-127, Docket No. 50-538 TOTAL NATURAL ACTIVITY IN REACTOR FUEL AND FUSE: 2.33 millicuries The largest fuel content of any element consists of 397.329 (U238) and 98.359 (U235). Thus, the natural activity of the largest disc is 346 pCuries. The Core Fuse contains 1.629 (U238) and 0.4g (U235) which yields a natural activity of 0.864 pCi.

b. Fission Product Activity. Since December,1976, less than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of operation at critical have been conducted. The highest recorded steady state power level was 80 milliwatts (March,1977) and the longest period of uninterrupted operation at any power level was less than ten hours. The energy generated in Watt-hours per year is shown as follows using the conservative assumption that the total hours of operation at critical during each month of a given year occurred at the maximum recorded steady-state power level for that month:

Watt-hours 1985 <1.0 1980 3.3 l 1984 2.8 1979 6.8 1983 10.4 1978 3.0 1982 5.8 1977 11.1 1981 10.3 1976 1.1 Total Watt-hours (December 1976 - March 1985): 55.6 l

The defuel procedure approved for the MSU reactor requires a mini-mum ten day period following the last shutdown and removal of the l

neutron source to allow for activity decay prior to commencing fuel handling activities. To estimate the fission product activity remaining in the fuel at the time of removal from the reactor, a semi-empirical approach described in reference 11 is used, where:

Total Fission-Product Activity (Ci)* 14 Po (t-To)-0.2 r-0.2 APPENDIX D

_ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _s

APPENDIX D . . Page 3 of 4 Applicati:n for Amendment No. 5 Operating License R-127, Docket 50-538 T = time, in seconds, from startup to the time of interest Po = thennal power level, in Watts, at which the reactor ope rated.

To = time, in seconds, that the reactor operated T -To = time, in seconds, after shutdown to the time of interest.

Based upon the intermittant mode of operation over 81/4 years, a

" time averaged power level" was calculated for P oassuming 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of continuous operation at 80 milli watts (80 Watt-hours) and averaged over a period of 7.23 x 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br />.

Assuming a negligible quantity of fission product activity existed in the fuel in December,1976, and using the following values:

T = 2.61 x 108 seconds Po = .0011 Watts T -To = 8.64 x 10 5 seconds TOTAL FISSION-PRODUCT ACTIVITY AT TIME t = 6.8 x 10-4 Curies Assuming uniform distribution, the Specific Activity referenced to U235 would be 1.02 pCuries/ gram U235 ten days after shutdown.

The largest single fuel element could contain approximately 100 pCuries of fission product activity. The core fuse, the smallest single fuel element and making allowance for a factor of two greater fission rate due to its location in the core, could contain approx-imately 0.8 pCuries of fission product activity.

c. Summary. At the time of fuel removal, the total fuel activity could be as much as 3 millicuries composed of U235, U238, and fission products. The fission product activity would comprise less than 30% of the total and decrease to 10% or less of the total during the first three months of storage. The total activity is APPENDIX 0

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APPENDIX D Page 4 of 4 Application for Amendment No. 5 Operating License R-127, Docket 50-538 A

distributed and contained within the solid polyethylene moderator comprised by nine core elements,16 control rod elements, and the core fuse (polystyrene moderator). The largest single fuel element could contain as much as 446 pCuries of combined U235, U238, and fission product activity at the time of removal from the reactor.

The fuel storage scheme requires that not more than 200 grams of contained U235 be in any one storage barrel . Thus, the maximum activity in any one container at the initial time of storage would be approximately 908 pCuries composed of U235, U238, and fission products. After a reasonable period of time, the prevailing natural activity would be-approximately 704 pCuries (maximum in any barrel ) . All. SNM will be stored in the designated fuel storage area described in Part III of this application.

2. Radium-Beryllium Neutron Source. The AGN-201 neutron source consists of 10 milligrams (approximacely 10 millicuries) Ra-Be sealed in a stainless steel capsule. The source will be placed into its ' original

-lead shield and stored in the 55 gallon 00T (6J) USA 7A Type A shipping container that was used for transport in 1976. The maximum radiation exposure rate at three feet from the outer surface of the 6J container is expected to be less than 1.0 mR/hr. The Ra-Be Source will normally be stored in the Reactor Room of the facility unless an alternate loca-tion is specified by the Radiation Safety Office.

3. Aluminum Core Tank and Control Rod Fuel Capsules. The core tank and control rod fuel capsules are constructed of aluminum and contain the fuel elements during reactor operation. Upon disassembly, trace p amounts of activity may exist due to contamination of the inner surfaces l by the reactor fuel and/or activation by the reactor neutron flux. The
. core tank and fuel capsules will be sealed using their normal gasketed
covers to achieve liquid-tight integrity and stored in the Reactor Room of the facility.

i i

APPENDIX D

.