ML20149F373

Forwards Review & Comments Re Brigham Young Univ Rept on Decommissioning Survey for L-77 Research Reactor.More Info Requested to Determine True & Complete Radiological Status & Complete Radiological Status of Site

ML20149F373
Person / Time
Site:	05000262
Issue date:	07/25/1994
From:	Adams W OAK RIDGE ASSOCIATED UNIVERSITIES
To:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20149F370	List: ML20149F367 ML20149F373
References
NUDOCS 9408100108
Download: ML20149F373 (6)

Text

i O R J: SE rw -

July 25,1994 hir. Blaine hiurray i U. S. Nuclear Regulatory Commission l Region IV  !

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

SUBJECT:

DOCU51ENT REVIEW - DECOMMISSIONING SURVEY FOR TIIE I 77 RESEARCII REACTOR, BRIGIIAM YOUNG UNIVERSITY (DOCKET NO. 050-262)

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 l 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 )

additional information, as described in the attached comments, would substantially improve the  !

thoroughness and technical quality of the document.

The attached comments are offered for your consideration. If you have any questions or l comments please contact me at (615) 576-0065 or Jack Beck at (615) 576-5031.

Sincerely, C.

Wade C. Adams  !

IIcalth Physicist / Project Leader ,

I Environmental Survey and Site Assessment Program WCA:dac I

, cc. T. hio, NRC/NhtSS/TWFN/8A33 D. Tiktinsky, NRC/NhtSS/TWFN/8A23 )

Ph1DA, NRC/NhtSS/TWFN/8A23 l L. Norde-haug, NRC/ Region IV/ Walnut Creek O Y.

J. Berger, ORISE/ESSAP J. Beck ORISE/ESSAP File /262 9408100108 940805 I PDR ADOCK 05000262 P PDR e u sex 117. cM MG MM.E55FE 3M3 0117 j we-ca a-o one c'co n M Rme Aux aws t ~ve s i ci 6er e t 5 Dew *e" c' E-e av

DOCUMENT REVIEW DECOMMISSIONING SURVEY FOR TIIE I 77 RESEARCII REACTOR BRIGIIAM YOUNG UNIVERSITY (DOCKET NO. 050-262)

General Comments

1. The primary contaminants at this site and the applicable exposure rate and surface contamination guidelines should be specified. Survey results should be reported in the same units as the guidelines and should be directly compared to those guidelines. The data provided in this report are not suf6cient to demonstrate compliance with the NRC surface contamination guidelines.

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. Further detail should be provided for the technical reviewer to evaluate the adequacy of:

(a) Methodologies for:

(1) surface scans (alpha, beta. and gamma)

(2) direct measurements (3) grid block averaging (4) miscellaneous sample collection if applicable (drain, vents, residues)

(5) calculations of direct measurements and MDAs 1

(b) Instrument calibration and QC procedures (i.e. routine operational checks)/ operating parameters (including efEciencies, backgrounds, and detection capabilities)

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

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

4. In general, the quality of data presentation and report preparation is poor. Although the raw data (e.g., for removable surface contamination and sample analyses) are provided, the results are not tabulated. Figures, when provided, are not drawn to scale or labeled clearly. Figures should also be labeled with the direction and should have a Dgure title and a legend. It is also recommended that the pages in each section be physically bound (e.g., by a staple) and the sections separated (e.g., by a title page). Page numbers would be useful in determining if data or text is in a particular order or missing.

5. Measurement locations should be indicated on the Sgures, or if taken in a particular pattern, e.g. at I m intervals, the pattern should be identified.

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6. It is not clear from the report whether there are miscellaneous parts / items / equipment to be released, for which ESSAP is expected to perform radiological surveys.

Soecific Comments ,

1. Page 4-1: Proposed Final Radiation Survey Plan  !

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(a) It appears that this is section 4 of a larger report. If so, then perhaps other  ;

portions of the report may contain vital information that should be provided in a  ;

final status report, i.e., site history, procedures, guidelines, etc.

(b) How were termination survey locations selected? '

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(c) Please explain what is meant by the word " surveyed". Does this mean that l surfaces were scanned and that direct (sta'ic) measurements and removable l activity measurements were performed? Please provide a description of the l procedure (See General Comment 2).  !

(d) Provide an explanation for establishing a " virtual" 3-m square grid. What criteria t was used to select a single 1 m square grid out of the 3-m square grid pattern for j survey activities?

l (e) Provide more detail on drain and floor penetration survey activities. Were there l other types of penetrations i.e., walls, ceilings, and ventilation systems that l should have been accounted for in the survey?  !

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(f) The report states that 1 m averages of grid blocks are determined by performing a 5 minute surface scan over the 1 m2 surface and integrating the counts. The ,

2 maximum activity in a 100 cm area (hot-spot) was determined in a similar f manner with a one minute surface scan. Removable activity was estimated for  !

each 1 m2 area by smearing a 100 cm2 area of each I m 2. Were these techniques  !

appropriate and how can these measurements be directly compared to NRC i guidelines, particularly for the maximum guideline condition?  !

t (g) Are the calibration sources t

• 230 and Tc-99), used to calibrate the survey  !

instrumentation, appropriate for the radionuclides of concern (See General j Comments 1 and 2)?

(h) Provide the model number for the Eberline alpha scintillation detector.

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2. Page 4-2: i (a) Use of the Eberline PG-2 low energy gamma probe (Nal scintillator) for  !

2 determining exposure rates by integrating over a 5 minute period within a 1 m g is questionable. Any measurement of a gamma radiation level with this instrument f

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is influenced by the speciDe energy of the gamma source for which the instrument was calibrated and calibation with Cs-137 might not be appropriate. The use of this instrument for measuring gamma radiation levels is an unusual choice since -

it is a low energy gamma probe and its response to high energy gammas, which ,

would most likely result from the possible contaminants, may be poor. Was the j measurement performed at contact or 1 m above the surface?

(b) Different surfaces have different backgrounds, such as sheetrock and brick walls.

Were these types of background differences accounted for during the final survey ,

data calculations?

3. Letter to Alexander Adams on March 9,1992, RE: Response to questions received from  ;

A. Adams on January 9,1991. 1 (a) ESSAP only received two pages of the completed letter since the signature page is missing.

(b) Core samples were to be obtained by drilling a 1/4 inch hole in the respective material and then counting the materialin a liquid scintillation countu. Was this performed, and, if so, what were the results?

2 l (c) The guidelines provided do not include the maximum limit for a 100 cm area and do not indicate that the limit listed is for the average contamination over 1 m 2.

4. Instrument Calibration Data (a) The ef6ciencies of 61% and 64% for an HP-260 seem high, and may be based on 2 x geometry; if so, the measurement data may be underestimated by a factor of 2. The same may be true for the AC-3-7 alpha scintillator. Please provide more detail on how the calibrations were performed. For example, the calibration sheet should provide information on the calibration source used (i.e.,

radionuclide, activity, NIST traceability, etc).

(b) The SPA-3 instrument, mentioned in the calibration data, is different from the one mentioned in Specific Comment 2a. This instrument was calibrated with Cs-137. Due to the energy dependence of the SPA-3, the response of this instrument to the gamma energies present should be indicated.

1 (c) The lines on the QC Charts should be labeled to indicate QC Positive and QC Negative. On June 10, the QC Negative value was exceeded for the Gamma QC Chart and then the instrument was retested and passed. Please indicate how these values were calculated and what were the appropriate procedures to follow when an instrument failed its daily QC check, i

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5. Figures  !

(a) The figures are difficult to follow since sections marked on one figure are shown  !

in other figures at different sizes and there are no scales provided (See General Comment 4).

l (b) One of the Control Room grid blocks is not labeled. Perhaps this is grid block CRC 5. Also need to provide direction for the floor and ceiling since it is difficult to determine if one is looking "up" at the ceiling. j (c) It is difficult to determine the location of some of the walls when trying to relate back to the floor plan. An example is that the wall section labeled LRTW6 is  !

I indicated as a north wall when it is actually facing west.

(d) The figure for the Large Room West Wall is missing.

(f) The Reactor Room Floor figure indicates that grid blocks RRF21 and RRF22 are rectangular in shape. Are these grid blocks approximately 1 m 2?

(g) Does the Reactor Room West Wall not extend all the way to the ceiling as is indicated by the figure of the Reactor Room East Wall?

6. Raw Survey Data I

(a) The units for the data should be reported or pre nted in the column headings.

(b) Please provide an explanation for SLOC Ol A-OlF and if the measurements were performed in a particular pattern.

7. Difference Data (a) It is stated that the raw count is multiplied by a correction factor to obtain the difference data. Provide an explanation for the terms used in the correction factor and include a sample calculation.

(b) Background data should be provided. Different surfaces have different natural backgrounds associated with the material fiam which it is made, i.e., a higher background measurement is typically associated with red brick than for asphalt or concrete (See Specific Comment 2b). It was not clear from the data how backgrounds were subtracted from individual measurements. Backgrounds should be subtracted prior to dividing by the correction factor (c) Provide an explanation and an example calculation for the acronym BEU.

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Bngham Young Uruversdy 4 hiessapuenen\murray.005 I

I (d) With one exception, all of the GAMMAD measurements are negative. This appears to indicate that an inappropriate gamma background was used in the calculations. Provide more information on how background levels were i determined. Were the backgrounds determined in the same manner as the raw l counts, i.e., a 5 minute scan over a 1 m2 grid block?  !

(e) The Acceptance Criteria does not mention the maximum guideline value.

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Bngham Young University 5 h*. c*acamon.rus

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