ML20116L546
| ML20116L546 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 02/22/1993 |
| From: | Takahashi J CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 9608190071 | |
| Download: ML20116L546 (2) | |
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UNIVERSITY OF CALIFOllNI A, LOS ANGELES 3
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j CoMMUNrIY sAffrY I RADIADON sAffrY 2195 WEST MEDICAL. BUILDING 1083311 CONTE AVENUE ths ANCE11S.,CALIfX)RNIA 900241765 February 22.1993 94 gn -7 h9:23 Mr. James 11. Reese. Chief Facilities Radiological Protection Branch
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U.S. Nuclear Regulatory Commission t
Region V 1450 Maria Lane Walnut Creck, CA 94596-5368
Subject:
Docket No. 50-142, License No. R-71: Final Decommissioning Report For the Hoelter Reactor Facility, Dated January 4,1993
Dear Mr. Reese:
We have enclosed UCLA's response to the comments from the Nuclear Regulatory Commission (NRC) and Oak Ridge Institute for Science and Education (ORISE) after their review of UCLA's report and request to release the former reactor facility for unrestricted use. Please attach Addendum I to our report which was dated December 1992.
We have received a facsimile request from Mr. Daniel Hirsch to remove his former Washington D.C. mailing address and to correct the Committee to Bridge the Gap's Los Angeles zip code to 90025.
If there are any questions or clarifications that are needed, you may contact me at (310) 825-7147.
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J h M. Takahashi, C.H.P.
ation Safety Officer / Owner's Representative
Enclosure:
Addendum 1 STATE OF CALIFORNIA COUNTY OF LOS ANGELES On February 22,1993, before me, the undersigned, a Notary Public in and for said County and State, personally appeared Joseph M. Takahashi, known to me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same.
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Witness my hand and official seal Notary Public in and fpr said County and State l
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Distribution List Attached Notory PLAAM:otfomio LOS NCELES CoudsY cortm. exokes FEB 02.1996
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9608190071 930222 PDR ADOCK 05000142 M
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University of California Docket No. 50-142 Los Angeles l
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Department of Justice Robert M. Meyers
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Office of Attomey General City Attorney.
P.O. Box 944255 Lynn Naliboff Sacramento, Ca 94244-2550 Deputy City Attorney 1685 Main St., Room 310 Califomia Department of Health Services Santa Monica, CA 90401 Attn:
Chief Environmental Radiation i
Control Unit Vincent Sato Radiological Health Section Office of City Attorney 714 P Street, Room 498 200 North Main Street-Sacramento, CA 95814 City Hall East, Room 1700 Los Angeles, CA 90012 Dr. Michael Granfield Acting Administrative Vice Chancellor Mr. Alexander Adams Jr., Project Manager University of Califomia Standardizat" & Non-Power Reactor Proj. Directorate 405 Hilgard Avenue Division of Nuclear Regulatory Commission 2107 Murphy Hall Washington, D.C. 20555 Los Angeles, CA 90024 William E. Kastenberg, Professor Christine Helwick, Esq.
School of Engineering and Applied Sciences Glen R. Woods. Esq.
5532 J Boelter Hall Office of General Counsel University of California 590 Unive sity Hall Los Angeles, CA 90024-1597 2200 University Avenue Berkely,CA 94720 Lydia Kowalski, Administrative Officer School of Engineering and Applied Sciences Dean Hansell 7256 Boelter Hall 302 South Mansfield Ave.
University of California l
Los Angeles, CA 90036 Los Angeles, CA 90024-1600 Committee to Bridge the Gap William H. Cormier 1637 Butler Avenue, #203 Director Capital Programs Los Angeles, CA 90025 University of Califomia l
405 Hilgard Avenue l
Mr. John Bay los Angeles, CA 90024 1022 Peralta Street l
Albany,CA 94706 Document Control Desk Attn: Docket No. 50-142 License No. R-71 Mr. James R. Hectan Division of the Nuclear Regulatory Commission Director, Society Services Washington, D.C. 20555 l
American Nuclear Society 555 N. Kensington Avenue
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l La Grange Park,IL 00525 Roger Kohn, Esq.
524 lith Street i
Manhattan Beach, CA 90266 1
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FINAL DECOMMISSION REPORT FOR THE BOELTER REACTOR FACILITY DISMANTLEMENT AND FINAL DECOMMISSIONING PROJECT UNIVERSITY OF CALIFORNIA LOS ANGELES, CALIFORNIA DECEMBER 1992 i
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RESPONSES TO COMMENTS FROM NRC AND ORISE (2/18/93)
GENERAL:
Q:
A statement should be included which indicates why measurementsfor alpha activity were not performed.
Were surveys of the area immediately adjacent to the reactor area performed,for example the transfonner room. Is the survey datafor these areas available?
Throughout the document, one of the release criteria is stated as 5 mremlh above background at I meter. Data supporting this criteria is reported in the same units of mremlh. The guideline is stated as SpRIh above background at 1 meter. Did your data meet this criteria?
A:
Examination of the reactor operating records and measurement of beam port concrete and steel samples on a Germanium Spectrometry system and a Liquid Scintillation Spectrometry system did not reveal the presence of any alpha activity. The isotopes found in these measurements pointed to the relevant category in Table I of the Regulatory Guide 1.86 as the last one, i.e., Beta-gamma emitters except Sr-90 and others. The corresponding limits are:
Average: 5000 dpm beta-gamma /100 cm2 2
Maximum: 15,000 dpm beta gamma /100 cm Removable: 1000 dpm beta-gamma /100 cm2 Moreover, the hot spots found during the final release surveys were also checked for the presence of any fixed alpha activity and majority of the smears were counted for both beta / gamma and alpha activity with a phoswich detector.
The transformer vault, due to its location and status, demonstrates little likelihood of any radioactive contamination.
This vault was considered outside the scope of decommissioning and no surveys were performed inside the vault. The presence of PCBs in the room constituted sufficient risks to preclude a thorough radiation survey which was not considered necessary. The reactor room ramp area would be the nearest surveyed area to the transformer vault.
It is perhaps correct that guidance for the criteria is usually stated as 5pR/h above l
background at I meter. UCLA was, however, following the conditions of Section 2.5 of
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the Atomic Safety and Licensing Board Settlement Agreement dated September 30,1985 which states the criterion as 5prem/h above background at I meter.
Incidentally, we presume there is a typographical error in your statement which reads 5 mrem /h and not 5prem/h.
SPECIFIC:
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Page 5, paragraph 1 - the type and enrichment offuel utilized should be included in the description.
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1 A1:
The fuel was 93% enriched U-235.
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Q2:
Pages 6 and 7, Figures 2 and 3 - Were any difficulties in surveying the reactor area
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encountered due to the presence of the Tokamak? Is there any possibility for cross contamination of the reactor area as a result of activities performed in the Tokamak?
A2:
The former reactor area and the Tokamak facility are sealed from each other by two doors. No difficulty was encountered in surveillance of the area due to the presence of the Tokamak. Very little possibility, if any, exists of any cross contamination of the reactor area as a result of activities in the Tokamak facility which has film badge and area TLD monitors.
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Q3:
Page 10, Processes Performed - Were there any spills or abnormalfunplanned releases (excluding gaseous) during the operating history of theformer reactor?
A3:
An examination of reactor records did not indicate any spills or abnormal / unplanned I
releases that could significantly impact the release of the facility. This was substantiated during the decommissioning process by the absence of unsuspected isotopes or unexpected level of contamination.
Q4:
Page 11 - Is there any explanation for the reported increase in exposure rates reported on Figures 6 and 7 and those reported in the tables in Appendix C, i.e. in the Change Room and Control Room?
A4:
Figure 6 reports the exposure rate in the High Bay Area on the top of the monolith, boundaries of the catwalk, and mactor room wall on the upper level. Figum 7 reports exposure rate ranges in the Control Room and Change Room on the upper level. Note that both figures give exposure rates prior to decommissioning and are measured with a portable Victorcen 450P pressurized ion chamber. This digital instrument is quite unstable at exposure rates below 100 pR/h and hence, a range of fluctuation is given.
Appendix C repons dose-equivalent rates post decommissioning and is measured with an analog tissue-equivalent Bicron micro-rem meter designed to measure low readings in the l
micro-rem range.
Q5:
Page 21, Major Contaminants -In the " concrete chip" and the " concrete sample," the H-3 concentration was 14% and 6% of the total reported activity, respectively. Were the guidelines, as applied to the determination of total surface activity, adjusted to take into account this unmeasurablefraction of the residual activity?
A5:
The activity concentrations reponed on Page 21 reflect the isotope content and l
concentration at a point in the distribution of activated concreta in the monolith released l
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l as LSA. Your suggestion of correcting the guideline of 5000 dpm/100 cm for total 2
surface activity by accounting for the highest contribution of H-3 in a sample at a point has merit. However, for release of materials for unrestricted use, the action level implemented by the Contractor was 3000 dpm/100 cm for the averaged total surface 2
activity.
i Q6:
Page 24, Contaminated Drain Line Removal - Was the embedded drainline completely contained in the area which was surveyed?
A6:
Yes. The contaminated drain lines were removed from the reactor base and disposed into LSA boxes within the Reactor High Bay area. (See pipes within the shaded area shown in the figure in Appendix N of the Final Survey Repon)
Q1:
Page 38, Floor Drains and Piping inlet / Outlets - Is the contamination and direct measurement survey datafor these drains availablefor our review?
A7:
Yes. This data was enclosed as pan of Appendix N in the Attachment entitled, " Final Release Survey Report for the Boelter Reactor Facility Dismantlement and Final Decommissioning Project".
Q8:
Page 39, Soil Sample - At a minimum, the MDAsfor the contaminants potentially present should be included in this section. Is there any explanation for the elevated H-3 concentrations?
A8:
The soil sample results reported from an outside lab using EPA method no. 906 do included lower limits of detection (LLD) for each tritium and C-14 analysis. Specifically, the LLD for tritium in soil was 5.00E-7 pCi/ml and LLDs for C-14 in soil ranged from 1.00E-7 to 8.00e-7 pCi/g (see Appendix 0).
1 The highest reported tritium concentration was 4350 pCi/1. For comparison, as reported by our Contractor, a typical tritium background used at the DOE Pinellas Plant was 5000 pCi/l and the EPA drinking water standard for tritium is 20,000 pCi/l.
Q9:
Were any surface contamination and direct surface measurements made inside the inlet and outlet of the ventilation duct? Is the data available?
A9:
The ventilation duct was surveyed as a separate item and is included in the Reactor Room Walls final survey package as Appendix H of the Attachment aforementioned in A7. The measured exposure rates inside the duct were all 13 prem/h, the removable contamination was all < MDA and the highest direct measurements on the ventilation duct louver was 2
814 dpm/100 cm,
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