ML20149F359

Forwards Review & Comments on Summary of Decommissioning Process of the Univ of UT AGN-201M Reactor Number 107 & Indicates That Further Info Required from Univ to Improve Quality of Document

ML20149F359
Person / Time
Site:	05000072
Issue date:	07/26/1994
From:	Adams W OAK RIDGE ASSOCIATED UNIVERSITIES
To:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20149F347	List: ML20149F343 ML20149F359
References
NUDOCS 9408100100
Download: ML20149F359 (6)

Text

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July 26,1994 i

Mr. Blaine hiurray U. S. Nuclear Regulatory Commission Region IV  ;

611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011  ;

SUBJECT:

DOCUMENT REVIEW "A

SUMMARY

OF TIIE DECOMMISSIONING PROCESS OF TIIE UNIVERSITY OF UTAII AGN-20lM REACTOR NO. i 107", UNIVERSITY OF UTAII (DOCKl:T NO. 050-072)

Dear hir. hiurray:

l The Environmental Survey and Site Assessment Program (ESSAP) of the Oak Ridge Institute  :

for Science and Education (ORISE) has reviewed the subject document. In general, it is the opinion of ESSAP that the document lacks certain information/ data which would enable the reader to determine the true and complete radiological status of the site. The inclusion of i additional information, as described in the attached comments, would substantially improve the l

thoroughness and technical quality of the document. Further direction from the NRC, in terms  !

! of survey scope, is requested by ESSAP to enable preparation of a proposed survey plan. l The attached comments are offered for your consideration. If you have any questions or  :

comments please contact me at (615) 576-0065 or Jack Beck at (615) 576-5031.

Sincerely,  !

Y(-

Wade C. Adams Health Physicist / Project Leader Environmental Survey and Site Assessment Program WCA:dac Attachment cc: T. Mo, NRC/NMSS/T 'I N/8A33 J. Berger. ORISE/ESSAP f D. Tiktinsky, NRC/NMSS/TWFN/8A23 J. Beck, ORISE/ESSAP PMDA, NRC/NMSS/TWFN/8A33 File /263 L. Norderhaug, NRC/ Region IV/ Walnut l Creek Office  !

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DOCUMENT REVIEW A

SUMMARY

OF TIIE DECOMMISSIONING PROCESS OF TIIE UNIVERSITY OF UTAII AGN-20lM REACTOR NO.107 (DOCKET NO. 050-072)

General Comments

1. The primary contaminants at this site and the applicable exposure rate and surface contamination guidelines are not clearly specified. Survey results should be reported in -

the same units as the guidelines (dpm/100 cm2 ) to permit guideline comparison and ,

determination of compliance. The data provided in this report are not sufficient to ,

demonstrate compliance with the NRC surface contamination guidelines. For example:

(nj In many cases the report states that the measurement was collected over the entire surface of an item. The NRC guidelines state that surface contamination should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each such object. Was the entire surface area of the item less than 1 square meter? -

(b) Background data should be provided. Different surfaces have different backgrounds, such as metal and concrete. Were these types of background differences accounted for during the final survey data calculations? It was not clear how surface activities were calculated from individual measurements.

2. In general, it is the opinion of ESSAP that the documentation lacks certain information/ data that are consistent with that provided from similar facilities in which similar types of work have been performed. A final status report should provide all the necessary information to allow the reader to evaluate the final radiological status of the items / facility in question. Further detail should be provided for the technical reviewer to evaluate the adequacy of the final status report. This information should include:

(a) General Information such as a site history and description and the objectives of ,

the survey activities. )

1 (b) Methodologies for:

(1) surface scans (2) direct measurements (3) grid block averaging i (4) miscellaneous sample collection if applicable (drain, vents, residues) l (5) calculations of surface activity measurements and MDA determinations (c) Instrument calibration and QC procedures (i.e. routine operational  !

checks)/ operating parameters (including efficiencies, backgrounds, and detection capabilities)

(d) Procedures for evaluating results, relative to guidelines and conditions.

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3. Uranium is mentioned as a possible contaminant, and in some cases, only alpha measurements were performed. Measurements of beta activity levels, rather than alpha activity levels, provide a more accurate representation of uranium surface activity, due to conditions of building surfaces, (e.g., dusty, pory.is, or rough), which may selectively attenuate the alpha activity. Therefore, due to site conditions, it may be more appropriate to use beta activity levels for comparison with the guideline values.

4. The quality of data presentation and report preparation is poor. Although data are provided, it is not clear as to how the data was compared to the NRC surface contamination guidelines.

5. The report presents the results, but does not provide a discussion and/or assessment of the data. ESS AP recommends that information be included that discusses the final status of the decommissioned areas.

6. Figures, when provided, are not drawn to scale or labeled clearly. Figures should also be labeled with the direction and should have a figure title and a legend.

7. It is not clear from the report which items or rooms / areas are to be re! eased for unrestricted use. Will the AGN Reactor Room (Room 1205-E) be released? If so, were there other surveys performed on floors, walls, ceilings, and penetrations into this area?

8. The last page provided in the report had a page number of xxv. Was this page intended to be in this report, and, if so, are there other pages that are missing?

Soccific Comments Ic11

1. Page 1: The first paragraph states that the report is a brief summary of the decommissioning activities that complied with the NRC approved decommissioning plan.

ESSAP would like to review this plan since on Page 3, the licensee states that the plan "contains in detail the steps and procedures that were used to decommission the AGI.-

20lM reactor." This information would be helpfulin reviewing the documentation and in preparing a confirmatory / radiological survey plan.

Appendix A: Parts list and location

2. Page A3: The figure is blurry and difficult to read.

Anoendix B: Disassembly procedures

3. Pages B2-B5: Provide an explanation as to why some of the procedure steps were not performed (marked NA).

4 Page B6: This page is missing.

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5. Page B7: Provide an explanation as to why Form NEL-104 is incomplete; this form is the check-off list for the defueling procedure.

6. Page B8: This form should be labeled NEL-106.

7. Page B12: Is an adequate measurement sensitivity achieved for a smear by gamma spectrometry?

8. Page B13: The handwritten data is difficult to read.

Appendix E: Parts to be disposed of as unrestricted waste

9. There were no survey results attached for these pans (in this section) and the copies of the pictures (photographs) were poor. Please describe, in more detail, the survey l procedures uscd for the alpha, beta, and gemma contamination surveys (See General I Comment 2).

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Appendix G: Survey results

10. Pages G3 and G4: It was stated that the exterior of the AGN reactor was surveyed "using both direct metering and swipes and have found no removable contamination."

Was any fixed contamination found? A TBM-3 was used for the surveys for beta l

. contamination, were there any surveys performed for alpha contamination? It is .

recommended that an explanation be provided for the data.

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11. Page G7: The licensee states that the first stage of the survey of the concrete block used for shielding involves scanning the surface (one side) of the concrete block (presumably the side that faced the reactor). If the block was acceptable, it was placed on a pallet with the monitored side face down. The licensee then states that the "second stage of the i survey therefore involves passing the frisker over this surface of the block..." It is not  :

clear as to which surface the licensee is referring. )

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12. Page G8, third paragraph: The licensee states that " blocks exceeding a count rate of  !

250 cpm on any surface will be rejected as contaminated material." Background count rates ranged form 60 cpm to 150 cpm. Provide additional information for thejustification of using 250 cpm as the " criterion for rejection of concrete block as contaminated i material..." and explain how this information compares to the release guidelines. Has the possibility of activation of the concrete block and any structural reinforcement bars been considered?

13. Page G13: Explain the meaning of a " cave" background.

14. Page G21: It is not clear as to why maximum readings are less than the background reading in some cases. It is also unclear as to why a background reading (with the same instrument on the same day) can vary by a factor of almost two (80 cpm to 150 cpm).

15. Page G22: It is unclear as to which background applied to each measurement.

16. Pages G25 - G27: There is no data provided for the " Number Set Aside" column.

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17. Page G26: One of the measurements exceeds twice the background level. On Page G7, the licensee states that the " criterion for the rejection of concrete block as contaminated material ...... is a measurable count rate in excess of twice the average area background count rate on the day of the measurement." It appears that this measurement exceeds the licensee's criteria. Also, is this criterion appropriate (See Specine Comment 12)?

18. Page G29: It is unclear as to what the data means. Please provide units and more detail on calculations and procedures (See General Comment 2).

19. Page G32: The data should be provided. Ware any alpha measurements performed?

20. Page G3'i: It is unclear how this data can be compared to guidelines.

21. Pages G42 - G44: This data is confusing, i.e. are there 3 individual measurements for removable contamination or is there only one measurement? How were 3 separate measurements (in cpm) converted to one measurement (in dpm)? Explain how this data is compared to guidelines. Exposure rates a e typically measured at I m above the surface and not at contact, if compared to the 5 pR/h above background criterion.

22. Page G45 - G48: The copied data are dif6 cult to read and understand.

23. Page G53: Provide an explanation for the data. There are several data entries that are

< MDA; the MDA s:.ould be provided with the data.

24. Page G55: Provide an explanation as to why beta-gamma fixed measurements were not performed (See General Comment 3).

25. Page G68: All of the net counts for the smears are listed as zero. It appears that an inappropriate background was used in the calculations since it is expected that there would be a normal distribution above the background, with some positive and some negative values for net counts. Perhaps the background was high and all numbers that were negative were reported as zero.

26. Page G70: Provide an explanation for the data presented on this page.

27. Pages G72 - G83: There is no consistency in the presentation of the data. For example, the units for the direct counting column are reported for each part number while the units for the alpha counts and liquid scintillation counts are reported in the column headings.

It is recommended that the table should have a title and that the heading for each column of data should be provided ca each page. Provide an explanation for 0/0 in the LSC column.

28. Page G75: For Part #86 the columns labeled " Alpha" and "LSC" reports for the data "see below." These data were not provided.

29. Page G79: For Part # 58, and for other parts on some of the following pages, provide an explanation for the data in the alpha column which is listed as 1(0). Also, on Page '

G82, provide an explanation for Part MM in the "LSC" column where the data is presented as 27/0.

Universey of Utah - July 27.19'*4 4 h \cansp\lecernimurray 007 ,

Appendix H: Survey instruments and ooeration data

30. Page Hl: The efficiencies listed for H-3 (0.03) and C-14 (0.04) seem quite low.

Typically for liquid scintillation counters, these efficiencies are approximately 40% and 80%, respectively. Provide an explanation.

31. Page Hl: The calibration sources used to calibrate the thin-window GM probes were C-14, P-32, and Cl 36. Were these appropriate choices for the possible contaminants of concern? How were the different efficiencies applied to different areas? Was sampling and analysis performed to provide information on the nature of the contaminants?

32. Page H2: The Micro-R meter, mentioned in the calibration data, is typically calibrated with Cs-137. Due to the energy dependence of this instrument, the response of this instrument to the gamma energies present should be indicated.

33. Page H2: Provide a copy of the calibration data for the EPA calibrated detectors.

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