ML20198M118

Decommissioning Plan Manhattan College Zero Power Reactor

ML20198M118
Person / Time
Site:	05000199
Issue date:	12/31/1997
From:	Stanton C MANHATTAN COLLEGE, RIVERDALE, NY
To:
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ML20198M114	List: ML20198M111 ML20198M118
References
NUDOCS 9801160194
Download: ML20198M118 (120)

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DECOMMISSIONING PLAN 1

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MANHATTAN COLLEGE ZERO POWER REACTOR'

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License No. R-94 Docket No. 50-199 i

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^l December 1997 i

Prepared by 1

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SUMMARY

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l'.1 Introduction 1-1 1.2 Background; 1

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- 1.2.1 Reactor Decommissioning: Overview-2 j

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' Estimated-Cost 2

1. 2, 3 :-

Availability.of_. Funds

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--1.2.4; Program Quality Assurance' 3.

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DECOMMISSIONING ACTIVITIES-31 j

j 12.1l. Decommissioning Alternative

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-l 2.2 Facility. Radiological' Status!

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- Facility Operating History BL l

2.2.2 Current ' Radiological Status 1of the Facility 8

2.2.3 Release LM.teria -

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2.3..' Decommissioning Tasks.

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12 c2.3.1 Activities and Tasks E

2.3.2 Schadule

.14 2.4L Decommissioning Organization and Responsibilities 15

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~ 2. 5,.: Training Prograr.

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2. 6 - Contractor Assistance-16'

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Decontamination-and Decommissuning Documents 16 1

and-Guides 1

~ 3 PROTECTION OF THE HEALTH AND SAFETY OF RADIATION WORKERS

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-AND THE PUBLIC,

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,3.1' Radiation' Protection 17 F

3.1.1 Ensuring?As LowcAs Reasonably Achi'ovable_

17 Radiation Exposures 1

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.3.1.2 Health Physics' Program 18 3.1 '. 3. - - Dose Estimates 18.

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3.2:~Radioactiv'aiWaste Management' 19 3.2.1 FueltRemova1-19

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Radioactive. Waste: Processing:

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Radioactive: Waste Disposal 1 20 13.2'.4:. General-. Industrial Safety-Program 20 l

?3.3: RadiologicallAccident Analysis 2 PROPOSED: FINAL' RADIATION SURVEY PLAN 21-

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?50 TECHNICAL SPECIFICATIONS

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in if PHYSICAL" SECURITY PLAN 23 s

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7 EMERGENCY PLAN

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ENVIRONMENTAL REPORT.

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-9' CHANG::S TO THE' DE/;OMMISSIONIN3 PLAN 24 10 REFERENCES.

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LIST OF FIGURES 1-1 Location of Leo Engineering Building e

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1-3 Plan of.Second Floor of the Leo Engineering Building 5 4 Organizational Structure ~- MCZPR Decommissioning 7

2-1 Measured Radiation Irvels in Storage Area 10 2-2 Measured Radiation Levels in ZPR Room (11/95) 11 APPENDICES A

QUALIFICATIONS OF DECOMMISSIONING ORGANIZATION PERSONNEL B

RADIATION SAFETY PROGRAM C

TECHNICAL SPECIFICATIONS - POSSESSION ONLY AND DECOMMISSIONING D.

EMERGENCY PLAN e

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SUMMARY

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1 L1.1 - Introduction-This decommissioning - plan -is -submittod in support ofc Manhattan college's.-request to the-Nuclear;Rogelatory Ccamissirm (NRC for Lauthorization to_ decommission the reactor anditerminate its li) ense c

.(No.-R-94).

The Manhattan College Zero Power Reactor (MCEPR) is a-l

= heterogeneous pool type reactor, light water moderated and fueled i

with 19.75% onriched-uranium. - - It -is locatodion the campus _ of Manhattan College in the Riverdale section:of the Bronx in New York City.

Tha reactor is~in a Nuclear Engineering Facility within-the Leo Engineering Building at:3825 Corlear Avenue.

TheLMCEPR is. licensed to operate at a maximum power level'of'100 milliwa.tts through March 2 6,. 2005 in - accordance with license amendment No.

6, issued March 26, 1985.

Manhattan College - is i

seekinch to' decommission the reactor and terminate the license at

.this tame to reflect the lack of current and anticipated academic

?need for the facility.. The intent is to remove all radioactive material and release the area for unrestricted use.

Decomeissioning will be. performed under the direction of the Dean

-of Engineering, with consultation with the campus Radiation Safety Committee. ' Catherine C. Stanton has been retained as a consultant by Manhattan College to prepare this decomutissioning plan.

Mrs.

Stanton has served as the Chief Reactor Supervisor since June 1993.

She-has been an adjunct member of the-faculty since 1981 and holds I

a Senior Reactor Operator's license for this facility.

She will

-oversee the actual decommissioning activities,; including the final N

radiological _

survey, which will be conducted with college maintenance = personnel and student - assistance.

Surveys to date (e.g., in support of the conversion from HEU to LEU fuel) have indicated that virtually all of the material in the facility will meet - the - release criteria in Regulatory Guide 1.8;.

Once the decommissioning plan is adopted, an interim radiation survey will be performed to document any changes due to operation with the LEU core.- Contractor assistance-is expected to be limited to shipment of activated metal for disposal'if needed based on the results of the interim radiation survey.

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1.2 Background

J The MCZPR isJ1ocated on-the Manhattan College ~ campus on the first i

andEsecond floors of>the. Leo. Engineering' Building located at 3825 Corlear Avenue.

The Leo Engineering Building provides classrooms, 1 laboratories, = library,.and._ computer Lfacilities for an estimated 11800 students at any'one time. Faculty,. Administration and student 4

. activity? offices are also located in the building.

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Engineering Facility is designed for isolation from-the rest of the engineering f building.

The' MCZPR has been in the same location L-d' r-m-

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' The campus is' in the Riverdale section of the New York City borough of the Bronx.

The area is residential and is easily accessible from the Major Deegan Expressway.

Figure 1-1 shows the location of the Leo Engine Jing Building.

The shaded areas on Figures 1-2 and 1-3 show the location of the first floor and second floor levels, respectively, of the Nuclear Engineering Facility within the Leo Engineering Building.

Manhattan College also has two suberitical facilities located on the second floor level adjacent to the MCZPR (Room 221 on Figure 1-3).

The College plans to decommission these facilities simultaneously-with the work on the MCZPR to levels that will permit unrestricted release of the entire area indicated.

(New York City licensing authority is in effect for the subcritical facilities.)

-Manhattan College was founded in New York City in 1853 and chartered by the Legislature and the Board of Regents in April 1863.

It is a private, independent institution that provides both liberal arts educaticn and concentrations in specific disciplines including businesa, education and engineering.

The College moved to its present location in 1923 and has owned the Leo Engineering Building in which the MCZPR is located since 1963.

The MCZPR achieved initial criticality in March 1964.

Operating license R-94 was renewed for an additional 20 years in 1985 and conversion from high enriched to low enriched uranium fuel (HEU to LEU) was accomplished in 1991.

1.2.1 Reactor Decommissioning Overview Manhattan-College has selected the DECON method of decommissioning for the MCZPR.

Review of surveys previously performed in support of operations, HEU to LEU fuel conversion, and tank remediation indicate that only minimal amounts of activated metal, if any, will require removal and disposal as low level radioactive waste for the facility to meet the criteria for release for unrestricted use.

There have been no instances of contamination during the reactor's operating lifetime and therefore no significant decontamination efforts are anticipated.

1.2.2 Estimates Cost It - is estimated that the decommissioning process will cost approximately $65,000, including the cost of the final radiation survey, transfer of sources and-disposal of related low level radioactive waste.

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l 1.2.3 Availability of Funds Manhattan College has established an external sinking fund for this purpose. Annual deposits will be made to ensure that funds are available at the anticipated date needed. 1.2.4 Program Quality Assurance Dr. Robert E. Berlin will provide QA oversight of the

pianning, dismantlement, radiological surysys and material shipmentt associated with decommissioning the MCZPR.

Dr. Berlin, now retired from Manhattan College, served as Reactor Administrator for eight l years. He is a private consultant with a practice in radioactive site decontamination, decommissioning and site remediation. His resume is included in Appendix A. ~ As shown in the organizational chart (Figure 1-4) Dr. Berlin will report directly to the Dean of Engineering who will have overall responsibility for this project on behalf of Manhattan College and will also oversee the contrat tor, maintenance personnel and student assistants performing the actual tasks. 2 DECOMMISSIONING ACTIVITIES 2.1 Decommissioning Alternative Manhattan College has chosen the DECON option for decommissioning the MCZPR. This approach includes remova?. of all radioactive material exceeding the levels in RG 1.86 and compliance with the criteria in proposed 10 CFR 20.1402 that the total effective dose equivalent to the average member of the critical group would not exceed 25 mrom/ year. Based on review of the facility operating

history, in particular the fact that there has never been contamination of the facility and the very low neutron fluxes achieved, it is anticipated that only minimal amounts of activated metal (if any) will require removal and disposal to achieve these conditions.

The objective of decommissioning the MCZPR is to release the laboratory space for other use by the School of Engineering. No specific use of the space has been identified to date but it is anticipated. that some use as a laboratory would be likely with limited occupancy (less than 40 hours per week). Transfer of fuel and PuBe sources to DOE are expected to be the . pacing factors.in completing the decommissioning. Manhattan College is actively working with DOE representatives at INEL to schedule fuel removal. At present the DOE spent fuel management-plan provides for acceptance of all Al clad research reactor fuel 6

r I i i FIGURE 1-4 i ORGANIZATIONAL STRUCTURE MCZPR DECOMMISSIONING MANHATTAN COLLEGE CORPORATION BOARD OF TRUSTEES John P. Lawler, Ph. D., Chairman Level 1 k PRESIDENT OF THE COLLEGE Bro. Thomas Scanlon, F.S.C., Ph.D. l r PROVOST Weldon Jackson, Ph.D. i DEAN OF THE SCHOOL OF ENGINEERING John D. Patterson, Ph.D. Level 2 HEALTH PHYSICIST Larry Luckett, C.H.P. QUALITY ASSURANCE MGR. Robert E.

Berlin, D.P.H.

-lRADIATIONSAFETYCOMMITTEEl ACTING REACTOR ADMINISTRATOR Catherine C. Stanton, M.S. Level 3 ---l l MAINTENANCE STAFF l STUDENT ASSISTANTS 7

at Savannah River Laboratory. Because of the extremely low radiation levels of the MCZPR fuel (<2 mrem /hr on contact on removal) there is a possibility that this fuel may instead be accepted at the Y-12 plant in Oak Ridge. No firm date for this transfer has yet been established but an estimate of' a 1-2 year lead time has been discussed. DOE Chicago operations office has listed the PuBe sources present at Manhattan College (owned by DOE and licensed either under the reactor license, R-94, or SNM license 1892) as surplus and available for transfer to an authorized recipier'. Replies to this notice have been requested by December 1, 1997. More likely the sources will need to be transferred to Los Alamos National Laboratory for recovery of the Pu. Manhattan College has contacted personnel operating this program and been placed on the list for acceptance of the sources. Based on current operating schedules it is estimated that the sources could be transferred in the year 2000. They will remain in secure storage until that time. 2.2 Facility Radiological Status 2.2.1 Facility Operating History 0 at of the Department of Physics at its installation in 1964, the MCZPR has been operated by the Mechanical Engineering Department since November 1969. The original license was renewed for an additional twenty years in accordance with Amendment No. 6 dated March 26, 1985. Conversion from High Enriched Uranium Fuel (HEU) to Low Enriched Uranium Fuel (LEU) to comply with 10 CFR 50.64 limiting the use of HEU in domestic research and test reactors was authorized by Amendment No. 8 dated March 12, 1990. In characterizing the HEU fuel prior to shipment off site, staff estimated that it had generated 8.8 w-br (0.0004 MWD / clement) of energy since startup at Manhattan College. No information was available on the earlier operating history at American Machine and Foundry from 1961-1964. LEU elements were loaded into the core in February 1991. The reactor was defueled in July 1992 to facilitate extended repair and tank remediation. It was refueled in April 1995 and is conservatively estimated to have produced 0.8 watt-hours prior to defueling in December 1996. 2.2.2 Current Radiological Status of the Facility The fuel has been removed and placed into secure storage in the first floor level of the facility, as have all other licensed sealed sources (PuBe startup source and Cs-137 source). All materials were leak tested prior tc being placed into storage and determined to be intact. The storage area and measured radiation '8

h levels are indicated on Figure 2-1. i The second floor level of the facility, shown on Figure 2-2, includes the reactor

tank, platform and operating console.

Measured radiation levels as of November 1995 (with fuel and startup source present) are indicated on this Figure. Some metal rods (about 4 inches long) are present in a shielded container and they will be measured for activity as part of the interim survey. Background radiation levels in portions of the building remote from the reactor facility have previously been measured to be 10-12 microR/hr gamma nnd 0.0-0.02 microR/hr beta. The tank currently contains moderating water which will be discharged to the sanitary sewer system following analysis that documents compliance with 10 CFR 20 limits as provided in the Radiation Safety Program. i Radiation levels for the tank and internal components will be measured when the moderator water has been drained. Surveys performed prior to the tank remediation in 1994 indicated that all structures caused area radiation levels less than 5 microRem/hr greater than background at one meter from the surf ace. Remediation efforts in the tank at the time of the HEU/ LEU conversion as well as the subsequent tank coating and refurbishment were performed in direct contact with components and surfaces. The maximum annual exposure incurred for these programs was 160 mrem. Cumulative exposure was less than 1 person rem. The interim survey to be performed once the tank is drained will document existing radiation levels within tha tank and on internal components. It is anticipated that conditions will be essentially the same as those existing prior to operation with the LEU based on the limited number of times criticality was achieved, the short duration of operation at critical and the very low power level. 2.2.3 Release Criteria The unrestricted release criteria limits for surface contamination shall be below the limits specified in Table 1, " Acceptable Surface Contamination Levels", of USNRC Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors". The proposed radiological criteria for unrestricted use in 10 CFR 20.1402 will be met. That is, the total effective dose equivalent to an average member of the critical group will not exceed 25 mrem / year as the result of residual radioactivity at the facility that is distinguishabic from background. Residual radioactivity will be reduced to levcis that are as low as reasonably achievable. The final survey will _be in accordance with NUREG/CR-5849, " Monitoring for Compliance with Decommissioning Termination Survey Criteria". 9

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2.3 Decommissioning Tasks 2.3.1 Activities and Tasks The Manhattan College Decommissioning Plan includes all tasks whose completion is required in order to remove all radioactive components from the MCZPR' facility. Any components remaining in the facility at the time of the final survey will be below the contamination limits of Regulatory Guide 1.86 and will meet the criteria of proposed 10 CFR 20.1402 for unrestricted use. These tasks are: 1. Dispose of moderating water. Upon verification that the water meets the limits in 10 CPR 20 for discharge to the sanitary sewer system, it will be disposed. This action is not unique to decommissioning and has been performod previously as authorized under the existing license and Technical Specifications in relation to facility maintenance, remediation and fuel conversion. 2. Perform interim survey. This survey will determine the extent of material, if any, that exceeds the release criteria and requires removal and disposal as radioactive waste. This survey will be performed as soon as the tank is drained and access is available. It will follow the requirements in NUREG/CR 5849 so that as much of the interim survey results as possible (that is, in areas in which no other radioactive material in present or other decommissioning actions need to be taken) can be used for the final radiation survey. 3. Remove components exceeding release criteria. Any components requiring disposal as radioactive waste will be disassembled or sectioned using expendable tools and equipment. Both components and tools will be packaged and disposed as low level radioactive waste. Possible materials that would be so handled include the control rods and guide tubes, in-core instrumentation, startup source guide tube, and the previously identified metal rods in the shielded storage. The only other material expected to exceed release criteria are the fuel and sealed sources which are discussed separately below. 4. Clean floor and walls. Areas in which component removal was performed will be surveyed subsequently to identify any surface contamination exceeding the limits in Regulatory Guido 1.86. Any such areas will be cleaned using standard techniques and disposable materials. They will be resurveyed to verify compliance with the release criteria and cleaning materials will be added to the low level radioactive waste to be shipped for disposal. 5. Transfer fuel to DOE. Upon receipt of shipping containers and authorization to transfer fuel from DOE, the elements will be removed from their storage containers, placed in the shipping containers, surveyed, sealed and shipped in accordance with DOT regulations. The old 12

) t storega. containers (the original sylcor shipping containers) will l be surveyed to verify that they meet. the criteria for unrestricted i I release. Any contamination found exceeding the release limits will be cleaned using standard techniques as described for the _ floors / and walls--of the facility._ _After successful cleaning and 3 1 resurveying,~ the storage containers will be released for disposal j j as non-radioactive trash. i 6. Transfer PuBe source to DOE. j Manhattan college will work with DOE representatives at the Los Alamos National Laboratory to accomplish the transfer of the startup source for Pu recovery. The procedures will be similar 1 to those for transfer of spent fuel, involving transfer of the source to the shipping-container provided (after leak testing and verification that it is intact), surveying, sealing and shipping in l accordance with DOT regulations. The used storage container will i also be surveyed to verify that it meets release criteria, cleaned if necessary and released for disposal as non-radioactive trash.- 7. Transfer sealed source to authorized recipient. e Amendment No. 10 to Facility License R-94 authorizes possession and use of a sealed source up to 5 millicuries for calibration of radiation monitoring channels. It is expected that this source will be transferred to another authorized user, possibly within the college, for use in ongoing projects. 8. Ship Waste for Disposal Any material identified as exceeding the release criteria will be packaged and shipped for disposal in accordance with DOT regulations. ' A licensed broker / waste transporter will be retained to perform the shipment of materials prepared by decommissioning staff. 9. Perform final radiation survey. The final radiation survey, following the requirements of NUREG/cR-5849, will be performed following completion of transfer of all radioactive material off site. To the extent feasible, this survey will be performed in stages. That is, areas such as the i second floor. level of the facility from which radioactive material I can be removed-early will be surveyed and verified as clean as soon as the material is removed. First floor levels in which fuel and the PuBe - source are stored until they can be tranuferred to DOE F will' be surveyed following transfer. Previously surveyed areas will not be resurveyed unless_ radioactive material was introduced subsequent to-the prior survey, 10. Submit final report to NRC requesting verification of final survey and license termination. There are'no'special health or safety considerations related to theodocommissioning tasks described here. With the possible exception of pipe segmentation, - the decommissioning act:.ons are similar-to others performed l during earlier-maintenance and - remediation of - the ' f acility. None -of-these actions incurred radiation exposures exceeding'the investigative levels-defined in

.the ' facility-' Radiation Safety Program for routine operation.

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less than or equal to those from these prior projects. General safe lab practices involving such things as cleaning materials, noving heavy packages and climbing ladders, will be observed at all times. No materials or procedures requiring changes to fire protection or increased ventilation are expected to be used during decommissioning. 2.3.2 Schedule 1. Dispose of moderating water January 1998 2. Perform interim survey Within 3 months of decommissioning approval 3. Remove components exceeding Within 4 months of release criteria decommissioning approval 4. Clean floor and walls Within 5 months of decommissioning approval 5. Transfer fuel to DOE TBD (1999?) 6. Transfer PuBe source to DOE TBD (2000?) 7. Transfer sealed source to authorized recipient Spring 1998 8. Ship Waste for Disposal Within 30 days of transfer of fuel and sources 9. Perforu final radiation survoy 30 days after fuel and source transfer 10. Submit l'inal report to NRC 90 days after fuel transfer As outlined in the table above, the pacing items in accomplishing the decommissioning of the MCZPR are the transfer of fuel and startup source to the DOE designee. Initial contacts have been made with the INEL personnel responsible for scheduling fuel transfer and with both the Chicago operations office and the LANL personnel responsible for PuBe source return. No definitive date for transfer has yet been identified by either organization. It appears that some extended storage under a Possession Only License may be necessary for this material. Actions within Manhattan College's control will be performed in a timely manner subsequent to receipt of the Decommissioning order from the NRC. All actions will be performed with the objective of progressively reducing the restracted and controlled area as quickly as possible and minimizing the possibility of subsequent contamination. Whenever

possible, interim surveys and documentation will be prepared in a format that will be acceptable for the_ final survey thereby reducing the time needed to prepare the final report supporting license termination.- When possible, material and equipment (such as electronics and instrumentation) 14

will be transferred for reuse at another educational facility to minimize wasto generation. Most of this material is non-radioactive. When necessary (e.g., for the Cs-137 source), Manhattan College will verify tht the recipient is licensed to receive the material transferred. 2.4 Decommissioning Organization and Responsibilities The organization for the management of the MCZPR during the decommissioning phane is shown in Figure 1-4. The orgallization builds to the fullest extent possible on the orgas.ization authorized for facility operation as defined in Section 6 of the Technical Specifications for Facility License R-94. Three levels of authority are provided for, as follows: Level 1: Responsible for the facility license and site administration. Level 2: Responsible for safe accomplishment of the reactor decommissioning program. Level 3 Responsible for carrying out decommissioning actions. Overall continued responsibility for public and facility personnel safety rests with the Board of Trustees of the College and top management. Management has requested the Dean of the School of Engineering to assume direct responsibility for the safe completion of the decommissioning program. The Dean will be the point of contact for the College for all communications with regulatory authorities for this program. Manhattan College has contracted for the assistance of Catherine C. Stanton to serve as Acting Reactor Administrator during the deccamissioning program. In this capacity, Mrs. Stanton will serve as the facility Radiation Safety Officer as provided in the Technical Specifwations. She will be assisted by building maintenance personnel and student assistants with training in radiation measurement. All decommissioning actions will be taken with the concurrence of the campus Radiation Safety Committee. This change from the former Reactor Operations Committee reflects the change from an operating to a possession and storage status for the radioactive material on site at the MCZPR. The Radiation Safety Ccmmittee will provide continuing institutional oversight of the materiti if extended storage is equired prior to transfer to DOE, The current membership and expertise in radiological protection of the Radiation Safety Committee is shown in Appendix A. 15 1

( 2.5 Training Program As stated previously, the actions taken during the decommissioning phase will be similar to previous efforts during tank remediation and HEU to LEU fuel conversion. As such, no separate training program is planned for personnel participating in decommissioning. The ex pertise required includes knowledge of radiation and its biologtcal offacts, monitoring and instrumentation, regulatory limits on radiation exposure (and related site administrative limits provided in the Technical 3pecifications), and measures for maintaining radiation exposure as low as reasonably achievable. Decommissioning staff have expertise in each of these areas as the result of prior operating experience at the MCZPR, through academic training, and job experience. 2.6 Contractor Assistance Manhattan College has contracted with Catherine C. Stanton to provide oversight of the deco'nmissioning activities. Mrs. Stanton, a licensed Senior Reactor Operator and Chief Reactor Supervisor for the MCZPR, will serve as the Acting Reactor Administrator and radiation safety officer. lier status as a contract employee is analogous to her long standing status as an adjunct member of the faculty since she was retained on a semester to semester basis to fill a specific need of the College. Previously that need was an academic one. At present, it is to decommission the MCZPR. The only other contractor assistance that may be required is a waste trans porter / broker who would transfer low level radioactive waste for d:.sposal should that be necessary based on the results of the interim survey. Because that requirement has not yet been established, this contractor has not yet been selected. Contractor selection will consider prior experience with similar tasks, including compliance with all applicable HRC, Agreement State and DOT requiremente. Decommissioning staff will prepare and package the material to be shipped, if any. All contractors will be directly recponsible to the Dean of the School of Engineering who will have authority to oversee the quality and timeliness of the work. 2.7 Decontamination and Decommissionjng Documents and Guides Decommissioning-related operations will be governed by pertinent sections of relevant

federal, state and local regulations, regulatory guides, and standutds associated with nuclear research reactor dismantling, safety, radiological and environmental health, and industrial hygiene.

Those believed applicable are: 16

American National Standards Institute /American Nuclear

Society, ANSI /ANS 15.10,

" Decommissioning of Research Reactors", ANS, LaGrange Park, Illinois, 1981. American National Standards Institute /American Nuclear Society, ANS7/ANS 15.19, " Shipment ind Receipt of Special Nuclear Material from Nuclear Research Reactors", 1991. Code of Federal Regulations, Title 10, " Energy" and Title 49, " Transportation". In particular, 10 CFR Parts 20, 30, 50, 71 and 73 and 49 CPR Parts 170-189. US Nuclear Regulatory Commission, Draft Regulatory Guido DG-

1006,

" Records Important for Decommissioning of Nuclear Reactors", September 1989. US Nuclear Regulatory Commission, IE Circular 81-07, " Control of Radioactively Contaminated Material", May 14, 1981. US Huclear Regulatory Commission, IE Information Notico 83-05, " Obtaining Approval for Disposing of Very Low-Level Radioactive Wasto", February 24, 1983. US Nuclear Regulatory Commission, IE Information Notico 85-92, " Survey of Wastes Beforo Disposal from Nuclear Reactor Facilities", December 2, 1985. US Nuclear Regulatory Commission, NUREG/CR 5849, " Monitoring for Compliance with Decommissioning Termination Survey Criteria", June 1992. US Nuclear Regulatory Commission, Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors", 1974. Other information will be referenced as nooded. For example, specific shipment instructions from DOE or its designees for transfer of spent fuel and PuBe source (s) will be followed. 3 PROTECTION OF Tile HEALTli AND SAFETY OF RADIATION WORKERS AND THE PUBLIC 3.1 Radiation Protection 3.1.1 Ensuring As Low as Reasonably Achievable (ALARA) Radiation Exposures Manhattan College has developed and implemented a program to maintain radiation exposures at the Nuclear Engineering Facility ALARA. As specified in the Radiation Safety Program for the MCZPR, 17 s

i l t a cop:r of which is included as Appendix 3 to this Plan, College admin;,stration has delegated the responsibility for. maintaining i radiation exposures AIARA to the Radiation Safety Officer. 1 Implementation involves a combination of training of workers and students, periodic review and evaluation of occupational exposures and records of radiation level. surveys, and modification of l equipment and procedures if warranted _to reduce exposures. l All decommissioning activities will be conducted in accordance with the existing AIARA program to minimize radiation exposure - of decommissioning _ staff. This will-involve training, personnel i monitoring, surveys and use of procedures reviewed and approved by i the -Radiation safety Officer.- It is expected that refresher i training in preparing material for shipme: t will-be the primary deviation-from the general training program. Procedures used'for the HEU/ LEU fuel conversion will form the basis for the shipment j f Instrumentation available for survey samples includes a Ludlum 1000 3 with 43-10 probe for alpha and two Eberline ESP-2s with an HP-260-probe for beta-gamma and an Eberline SPA-1A for alpha. A Bicron-microR meter is available for area radiation surveys. - t No significant personnel exposures are anticipated based on prior experience and the fact that no contamination or activation has been found in surveys performed during-fuel conversion and tank i remediation. Personnel exposure will be monitored with portable radiation detectors, and individual film badges with both beta-gamma and neutron sensitivity. Primary responsibility for personnel radiation safety will rest l with the Radiation Safety Officer (RS0). Policies and procedures will be reviewed and approved by the Radiation Safety Committee before implementation. As indicated on Figure 1-4 the RSO will report directly-to the Dean of the School of Engineering who will have' authority to stop or modify work if necessary to ensure that radiation exposures remain ALARA. 3.1.2 Health Physics Program The health physics program in place for the operation of the facility : will be continued through the end of decommissioning. 1 There are no differences expected that would. increase potential j radiation exposures from existing conditions or procedures. j .i Portable radiation detectors will be used to verify area dose rates during decommissioning and shipping procedures. . The : health i

physicist will : verify _thati all mater.al transferred. from the-facility meets regulatory requirements.

i l 3. l~.' 3 Dos'e'~ Estimates Fuel'and source shipment, interim radiation survey and removal of 18 +- g-

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activated metal, if any, are the tasks that could entail personnel radiation exposure. Several similar tasks have been performed previously (e.g., HEU/ LEU conversion and fuel shipment) with radiation exposures below detectable levels. Dose estimates for the decommissioning program are estimated to be similar to those from the previous operations. Individual exposures are expected to be below Investigational Lovel I, the level at which no further actions are required to maintain exposures As Low As Reasonably Achievable according to the MCZPR Radiation Protection Program. Investigational Level I corresponds to a whole body exposure of 125 mrom/ calendar quarter. Cumulative exposures are expected to be less than one person rem for the entire decommiresioning program. All exposures will be external because only solid material will be and no caaes of contamination have occurred in the handled facility. The bulk L the exposures are expected to result from leak testing the fuel and sealed sources prior to shipment. Portable radiation monitors will be used to verify expected or identify differences which could require exposure rates procedures to be modified to ensure compliance with 10 CFR Part 20 and the ALARA program. Prior experienco at this facility indicates that total exposures will be a fraction of the regulatory limit. 3.2 Radioactive Waste Management 3.2.1 Puel Removal Dased on current DOE schedules it is anticipated that all other decommissioning tasks will precede fuel and PuBe source transfer. As previously stated, the fuel and source will be maintained in secure storage in the first floor area currently authorized for temporary storage. It is within the controlled area and the existing emergency plan and physical security provisions will be maintained until the fuel and source are removed from the site. No radioactive wasto is expected to be generated as a result of fuel removal. 3.2.2 Radioactivo Waste Processing To date no radioactive waste has uJen generated from operation of the MCZPR and therefore no processing has been required. Existing practices for screening materials prior to release will be continued. This involves wiping potentially contaminated materials I according to approved procedures and counting the wipes to verify that removable contamination (alpha and beta / gamma) is below release levels. Microrem meter readings will also be used to "erify that the exposure rate at one meter is less than 5 microRem/hr above background. All measurements will be reviewed by the health physicist prior to release of the material or eqv.ipLent, as provided in the Radiation Safety Program. 19 i

Should any equipment exceeding the release criteria be identified, it is expected that it will result from activation of metal and that the exposure rates will be close to those acceptable for I release. For planning purposes, approximately one cubic foot of such material has been estimated to require disposal. No liquid or gaseous wastes are expected to be generated from decommissioning. 3.2.3 Radioactive Wasta Disposal i If the interim survey described in Section 2.3.1 indicates that operation with the LEU core has not significantly changed the radiological status of the facility from what was determined in the early 1990's, there will be no need for radioactive waste disposal. i For planning purposes, it has been estimated that approximately one i cubic foot of activated metal might exceed the release criteria and require disposal. If disposal is required, a licensed broker / waste transporter will be retained to transfer the material to the Barnwell facility, assuming it remains available to low level radioactive waste generators from New York State.- All packaging, monitoring and i shipping will be in accordance with dot regulations and the disposal site acceptance criteria. As stated previously, any i material which does not meet the release criteria for unrestricted use (as verified by the Health Physicist) will be disposed of as i radioactive waste. 3.2.4 General Industry Safety Program The decommissioning program will be performed in accordance with the college's general safety proceduros. As described previously, anticipated decommissioning actions do not include any hazards different from those present during operation and routine maintenance. No non-radioactive airborne hazardous materials will be used and dust masks and eye protection will be used when indicated. Access to the reactor vessel for surveying and dismantlement of internal structures will be via ladder from the reactor platform. All work will be. performed in teams with support in the event of falls, etc. Decommissioning staff will be in contact with on . campus and off campus medical _ support personnel if needed, r 3.3 Radiological Accident Analysis This section discusses the likelihood and consequences of accidents occurring during-and after the decommissioning process,.resulting -from human - crror, equipment malfunction, or external natural phenomena. 1 The decommissioning will be conducted under the supervision of the 20

Acting Reactor Administrator. Safety-rolated activities will be monitored by the !!aalth Physicist and reviewed and approved by the Radiation Safety Committee. During fuel shipment the only possible scenarios that could result in damaged fuel are handling accidents involving dropping of a fuel element. This could occur during transfer of the fuel from the storage containers to the shipping containers. One accident scenario evaluated during the core conversion process considered a maximum drop of the fuel element from the second to the first floor of the reactor room (about eight feet). Such a drop, in terms of the fuel weight (about 5.5 kilograms per element), will yield approximately 37 )(iloj oulos potential energy to the outor 1/8" thick aluminum cylinder. This small amount of energy will neither bend the outer supporting cylinder nor crack the innor concentric fuel plates, based on the results of the previously performed impact test on a dummy fuel element. Transfer to shippang containers on the first floor level of the facility would involve at most a six foot drop which would similarly not result in damage to the fuel element. Once the fuel elements are in place in the containers and they are closed, the containers will protect the fuel from impact resulting from any on site handling accidents. There are no postulated natural phenomena (e.g., seismic event, severe weather, etc.) that would result in offects more severe than those from the fuel drop postulated above. Transportation of the fuel oloment casks to the designated receipt point will be the responsibility of the DOE. The casks are designed to maintain their integrity under any postulated severo accident conditions that could occur during transportation. In the highly unlikely event that an accident occurs that breaches a shipping cask and exposes the fuel element, no elevated personnel exposures would occur based on measured dose rates at the fuel surface. Similarly, a ruptura of a fuel element would not result in any appreciable relense of fission products or personnel exposure because of the very low fuel burn up. 4 PROPOSED FINAL RADIATION SURVEY PLAN The final verification radiation survey will include both the first and second floor levels of the HCZPR facility and all components, material and equipment used during operation and decommissioning. No material will be released until it has been surveyed. Background radiation conditions will be attained in the MCZPR facility upon completion of decommissioning. Details of the final radiation survey will depend upon the results of the interim survey to be performed as one of the first tasks 21

under the decommissioning plan. All floor (and walls up to 2 meters) surface areas larger than one square meter will be marked off in a grid of one mater square blocks. The entire interior of the reactor vessel will be divided into one square meter blocks for surveying. The survey will include a wipe sample of 100 square centimeters (nominal) within each block to identify removable contamination. Wipes for each grid unit will be counted for alpha and beta contamination. Total al pha and beta levels will be measured at the same locations. L:.mits for fixed and removeblo contamination will be those in Regulatory Guide 1.86, Table 1. A beta-gamma survey will be performed at the center of each block at a distance of one meter from the surface. Residual activity less than 3 microRem/hr above background will be acceptable for free release of the structure. This level corres)onds to the proposed unrestricted use criteria of 10 CFR 20.1402 s;.nce external radiation will be the only potential exposure pathway. The reference background will be the highest of corresponding measurements in the Leo Engineuring Building remote from the HCZPR. Prior measurements 1.1dicate a background level of 10-12 microR/hr gamma and 0.0-0.02 microR/hr beta. Result.s of the survey and the procedures used to obtain and analyze data will be audited by the RSO and by Dr. Robert Berlin, the Quality Assurance Manager, to ensure the accurm f and completeness of the data. Ten percent of all samples will be subject to QA verification. Small objects, for which a one meter grid is inapplicable will be wipe tested and surveyed in a manner which is consistent with the procedure used for leak testing sealed sources. Limits for removable contamination and residual radioactivity will be those described in the preceding paragraph. Available instrumentation for survey sample analysis and area radiation surveys was described in Section 3.1.1. If indicated, additional instrumentation would be acquired for the final survey. Instruments used for the surveys will be currently-calibrated in accordance with applicable ANSI standards. All equipment will be operating indoors at room temperature and pressure and measurements will be made manually, not automated. Final data analysis will follow the methods prescribed in NUREG-5849, " Monitoring for Compliance with Decommissioning Termination Survey Criteria". A final report documenting the results of the survey will be prepared and submitted to the Nuclear Regulatory Commission (NRC). The NRC or its designee will perform a validation survey prior to terminating the license. 5 TECHNICAL SPECIFICATIONS Proposed amended technical specifications, applicable to possession only status, are included as Appendix C to this decommissioning 22

plan. 6 PHYSICAL SECURITY PIAN All SNM of low strategic significance held under license R-94 (fuel and PuBe startup source) is stored in the authorized temporary storage area within the controlled Access Area (CAA). It will remain there until it is packaged for transfer to DOE's designeo. ( The approved operational physical security plan and safeguards and security procedures will remain effective while this material remains on site. The physical security plan and safeguards and security procedures have been amended to conform to administrative changes applicable during decommissioning rather than operation. These documents, provided under separate cover, are proprietary information and not for public dist losure as provided in 10 CFR 73.21.. 7 EMERGENCY PIAN Because transfer of the fuel is likely to be the pacing item in decommissioning the MCZPR, the existing Emergency Plan (Appendix D) will remain in effect. Should fuel transfer be accomplished before other portions of the decommissioning operation, Manhattan College will consider whether to revise the Emergency Plan at that time. 8 ENVIRONMENTAL REPORT This section discusses the anticipated environmental impact of decommissioning the HCZPR and terminating license R-94 as required by 10 CFR 51. 8.1 Proposed Action Decommissioning the MCZPR under the DECON alternative will include transfer of all licensed radioactivo material fi 9m the site (e.g., fuel and sources). Reactor internals (control rod blados, guide

• ubes, startup source guide tubo) and instrumentation (uncompensated ion chamber, area radiation monitors and neutron monitor) will be removed from the reactor vessel and monitored.

Equipment and surfaces will be monitored to verify compliance with release criteria for unrestricted use as specified in Regulatory Guide.1.86 and proposed 10 CFR 20.1402. Equipment meeting the release criteria for unrestricted use will be transferred for reuse rather than disposal whenever possible to minimize-waste -generation. Any surfaces or equipment exceeding the removable activity criteria for unrestricted release will be physically washed until those levels are reached. If such decontaraination is not feasible, this 23

m I material will be disposed as low level radioactive waste. Any surfaces or equipment with residual radioactivity distinguishable from background that would cause an average member of the critical group to receive exposures exceeding the criterAa in proposed 10 CFR 20.1402 will be removed and disposed as low level radioactive waste. Whenever possible, licensed materials will be transferred to another-licenses for reuse to minimize low level radioactive waste generation. 8.2 Environmental Impact The only anticipated adverse environmental impact of the proposed action will be that due to transport of the material from the sita. Radiological transportation effects will be minimal because the radiation levels of the fuel are very low (< 2 mrem /hr on contact at removal from the core) due to low burnup. All shipments are of sealed solid material unlikely to be dispersed under accident conditions. Shipments will be in compliance with DOT regulations and subject to physical security and safeguards oversight. The general accident risk is much lower than that for a truck shipment of nonradioactive material because of the required driver

training, truck inspection, routing and notification requirements for such transfers.

No gaseous or liquid radioactive wastes will be generated as a result of the proposed action and there are no postulated accident scenarios that could release radioactive material outside the facility. Therefore, no exposure of the public or the environment will result from decommissioning the MCZPR. As noted in Section 3.1.3 the collective ~ dose to all workers for the entire decommissioning program is estimated to be less than one person rom. After license termination public radiation exposure will be solely due to natural background radiation. 8.3 Alternatives There do not appear to be any feasible alternatives to the proposed action. Manhattan College has determined that there is no further academic need for the facility at this institution and has therefore placed it into a storage rather than an operating mode. The No Action alternative would require that the material remain on site until the license expiration date in 2005. This would entail continued surveillance and physical security by College personnel and the inability to use three rooms for other academic purposes. It is not an acceptable condition based on AIARA, economic or resource utilization considerations. 9 CHANGES TO THE DECOMMISrIONIdi i AN Changes to the Decommissioning Plan necessary to respond to 24

unanticipated conditions may be authorized by the Radiation Safety Committee at the request of the Acting Reactor Administrator. Such t changes must comply with regulatory requirements of the NRC and DOT and the Radiation Safety Program. 10 REFERENCES American National Standards Institute /American Nuclear j

Society, ANSI /ANS 15.10,

" Decommissioning of Research i Reactors", ANS,-LaGrange Park, Illinois, 1981. American National Standards Institute /American Nuclear Society, ANSI /ANS 15.19, " Shipment and Receipt of Special-Nuclear Material from Huclear Research Reactors", 1991. j Code of Federal Regulations, Title 10, " Energy" and Title 49, " Transportation". In particular, 10 CFR Parts 20, 30, 50, 71 and 73 and 49 CFR Parts 170-189. Decommissioning Plan for The Catholic University of America, License No. R-31. t Decommissioning Plan for the University of Kansas Training l Reactor, License No. R-78. i US Nuclear Regulatory Commission, Draft Regulatory Guide DG-i

1006,

" Records Important for Decommissioning of Nuclear Reactors", September 1989. US Nuclear Regulatory Commission, IE Circular 81-07, " Control of Radioactively contaminated Material", May 14, 1981. US Nuclear Regulatory Commission, IE Information Notice 83-05, " Obtaining Approval for Disposing of Very Low-Level Radioactive Waste", February 24, 1983. US Nuclear Regulatory Commission, IE Information Notice 85-92, " survey of wastes Before Disposal from Nuclear Reactor Facili':les", December 2, 1985. US Nuclear Regulatory Commission, NUREG/CR 5849, " Monitoring for Compliance with Decommissioning Termination Survey Criteria", June 1992. US Nuclear Regulatory Commission, Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors", 1974. 25

l 1 l APPENDIX A QUALIFICATIONS OF DECOMMISSIONING ORGANIZATION PERSONNEL v ~

i CATHERINE C. STANTON Position: Acting Reactor Administrator, Radiation Safety Officer i Experience: 27 Years Experience Summary: Mrs. Stanton has been a member of the Manhattan College adjunct faculty since

1981, teaching in the Departments of Radiological and Health Sciences, and Mechanical Engineering.

She has experience in Agreement State licensing as a staff member of the NYS Committee on Licensingt has served as the Chief Reactor Supervisor for the MCZPR since 1993 and is a licensed Senior Reactor operator; has taught Health Physics and Health and Safety for Remedial Site Workers in the graduate program in Waste Management and Pacility Restoration; through independent consulting has provided technical support for licensing efforts by utility, government, industrial and institutional clients especially on radioactive waste management and transportation matters. Education AEC Program in Licensing Procedures, Bethesda, 1970. M.S., Nuclear Engineering, Ohio State University, 1970 (AEC Fellow in Nuclear Engineering) B.A., Mathematics, St. Joseph's College, Brooklyn, New York, 1968.

1 i i I' LARRY W. LUCKETT Position: Health Physicist Experience 24 Years Experience Summary: Mr. Luckett has extensive experience in radioactive waste characterization and cleanup of contaminated sites in accordance with NRC regulations and DOE orders; was commissioned as a Health Physics officer in the US Army Medical Corps 1971-1993 (ratired at rank of Lieutenant Colonel) # was an Associate Professor of Physics at the US Military Academy at West Point responsible for the operation and safety of a subcritical assembly, a Van de Graff particle accelerator and radioactive sources. Certifications and Trainings [ Comprehensive Health Physics, American Board of Health Physics DOE Radiological Worker Training (I and II) OSHA Hazardous Materials Worker Training (40 hours) Hazardous Waste Site Supervisor Training (8 hour) Update to Revised DOT /NRC Transportation Regulations 1997 Education: Ph.D. (Candidate), Nuclear Engineering, Pennselaer Polytechnic Institute M.S., Nuclear Engineering / Health

Physics, Texas A&M University, 1973.

t B.S., Physics, cum Laude, Trinity University, Texas, 1971. f o r 4 1 . _ ~,

ROBERT E. BERLIN Positions Manager of Quality Assurance Experience: 38 Years Experience Summary: Dr. Berlin -extensive et,serience in radicactive waste characterization and cleanup of contaminated sites in accordance with HRC regulations and DOE Orders; participated in development of 10 CFR Part 61; was a faculty member in - the Manhattan College Mechanical = Engineering Department responsible for the nuclear program'and served as the Reactor Administrator for eight years. Certifications and Training: Professional Engineer, New York. Educations -Dr. P.H., Industrial Health / Environmental Science Concentration, Columbia University, School of~Public Health, 1985. M.S., Industrial Engineering, New York University, 3010. M.S., Engineering Science, Rensselaer Polytechnic Institute, 1959. B.S., Mechanical Engineering, City College of New York,1956. { m

l l Item 12 Radiation Safety Program item 12.1 Radiation Safety Committec Dr. Lance Evans, Radiation Safety Officer Dr. Louis Uffer Dr. John Mahoney Dr. Edward Brown Deaa of the School of Science Representing Management See Supplement III for each individual on the Committee. (Pages 12 2. >l2 6) 0 [ q. 9 4 9

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AfrPENDIX B RADIATION SAFETY PROGRAM f, ., =,

-6.0-RADIATION SAFETY AND PERIODIC TEST REQUIREMENTS This section clearly identifies the radiation safety y slicy in MCEPR. This section also discusses a number of tests' performed regularly on the ZPR' components. 6.1 RADIATION SAFETY MANUAL 1 6.1.1 POLICY The radiation safety manual has been prepared to guide the activities of faculty members and students using-the reactor, the radiation facilities, and radioactive materials in the Manhattan College Nuclear Engineering Facility. A number of general rules and procedures have been adopted, intended to safeguard all personnel. These rules are intended to further the educational mission of Manhattan College and the Zero Power Reactor facility. To that end they may exceed the regulatory requirements applicable. under the terms of the reactor license from the Nuclear Regulatory Commission. They are used to instill good radiation safety practice in the faculty and students that is applicable regardless of the facility in which they eventually function. The Reactor Administrator will approve significant changes after review by the Reactor Operations Committee. The rules and procedures are designed to protect all individuals with a minimum of interference in their activities, consistent with the applicable rules and regulations of the Nuclear Regulatory Commission (NRC), with the terms and conditions of Manhattan College's License for Special Material, with the Manhattan College Reactor Facility License and with applicable regulations of the State and City of New York. The r3diation safety manual is based on the following assumptions the moral obligation to maintain personnel health and safety + with respect to all radiological ordinances can never be compromised; the low power and inherent safety of the Manhattan College Zero Power Reactor (MCZPR); the need to include reasonable - and proper Health Physics procedures by requiring students to know - and follow these regulations; personnel safety must be the first consideration at all times, + and no requirements will be allowed to override safety considerations; and an obligation to initiate an ALARA (As Lcw As Reasonably + Achievable) program in keeping with federal (NRC) guidelines. 6.1.2 RESPONSIBILITIES AND AUTHORITY MCZPR MANUAL * $ECil0N 6 6"1

_ _ _ _ _ _. _. _ _ _ _.. _ _ _ _ _ _ _ _ ~ No set of rules-is expected to cover-_ all situations. Administration of and adequate-provision for radiation protection-c and contamination controlz are the-prime responsibilities of the -

Nealth Physicist-to = assure that allL radiation protection 1 and; contamination-control regulations are observed. and ' that the procedures set in the Radiation Safety manual are followed.

The-Health Physicist is) responsible for recommending changes in any 4 operation believed not-to be evaluated realistically, for bringing- .the situation to the attention of personnel concerned, and to the Reactor Administrator for correction. I The; Health Physics staff is available to advise and make. i-recommendations - regarding radiological protection. The Health-i Physics' staff will-initiate radiat3on surveys, wipe tests, air ~

sampling, Eero Power Reactor water sampling, and such other-4 e

sampling and environmental analysis as may be requested by the Chief Reactor Supervisor, Reactor Administrator, or by the NRC, either as a directive or as part of revised procedures. 6.1.3-REACTOR OPERATION 8 COMMITTEE I i h 6.1.3.1 FUNCTION l The Reactor Operations Committee shall administer the Manhattan College Zero Power Reactor and isotope program. All on-site ] radioisotope production in the reactor and disposal -will be - i reviewed in' advance for conformity with policies adopted by the committee and will be recorded. All proposed procedures for non-routine or unusual operations, handling and experiments i. involving radioisotopes shall be reviewed fem the point of radiation safety. All radioactive waste dispo a procedures shall be determined by this committee.

6.1.3.2 -

FREQUENCY-OF MEETINGS i The: Reactor-Operations Committee will routinely meet once a L memester or as-necessary.- 6.1.3.3~ QUALIFICATIONS OF-LICEN8ED.. ISOTOPE USERS i-Persons proposing to work with-radioactive materials'must prepare an outline of qualifications and experiences in the handling and useLof radioactive materials. The information submitted will be reviewediby the Reactor Operations Committee. Committee members . will-be available ' as consultants -to. users, and will directly supervise or arrange for supervision of the use of radioisotopes where considered necessary or advisable. Personnel who are L c approved L to. work l with radiation-shall' be placed in : one of two L-categories:- '1) certifled : to work with radioactive materials l without supervision; and 2) certified-to work with radioactive L materials only with supervision. Faculty ' members and research [ collaborators who use by-product materials,: in exempt or non-exempt L HCZPR MAEML

• SECT!ON 6 6-2

? _j

. _ _. _ _ _ _.. _. _ _ _. ~. j i

quantities,;as definediin Article-175 of the'New York City Health Code,-. Must submit ' and file this -information.

Students taking' courses where Jradiation'is used.inithe laboratos.y. are exempt from this regulation. Students shall be under the control of' qualified faculty. _when working 'in-the reactor area: ~or.'with radioactive ~ isotopes.- 6.1.3.4 PROCUREMENT AND INVENTORY OF RADI0 ISOTOPES i Reactor' W d nistrator will authenticate the inventories of - The i ,o opes in the reactor facility. - This will-be 1Pensed Lred - t at splished-ohrough comparison of written records of the persons-4 in posession of-radioisotopes with those of the Reactor Operations -Committee.- Confirmation of:the records by physical inventory of-i ~the licensed radioisotopes in-the Reactor Facility ~will be . requested at.least annually by committee. -6.1.3.5 RECORDS OF COMMITTEE NEETINGS i The: committee secretary will prepare-permanent written record of committee proceedings for committee approval, such written record to be maintained and presented at the following meeting.for L approval. A 6.1.4 -EXTERNAL RADIATION l 6.1.4.1- ' PERMISSIBLE DOSES The Maximum Permissible Dose (MPD) of radiation, as establiNhed by the NRC in regulations appearing in the Federal Register, Title 10, 7&f Chapter 1, Part 20, Standards for Protection Against Radiation" MJWJh

1. 4-(herein-after referred to as 10CFR20) will-govern at Manhattan College. = Exposures are stated in rema for the present; future dose yJE values will be presented in sieverts (SV).

occupational dose SAy limits are given in-10CFR20.1101. Students are covered under the [ dose limits for individual members of the public in 10CFR20.1301. y 6.1.4.2 PERSONNEL NONITORING Personnel monitoring devices are required. Body type film badges, as - supplied J by ' a comme * :ial vendor, shall - be issued to those l individuals working wit' adiation. Records = indicating absorbed doses-from radiation: rec alved on the site will be maintained in the 4 reactor area for review by. the Chief Reactor Supervisor,- the Health Physicist and-by thelReactor Operations Committee. A -- record - of + ~ ~ personnel exposures, similar to that.provided by NRC Form 5, will be maintained or incorporated in the film: badge record sheets. 421.4.2.1-BETA-GAMMA FILM BADGES Thesef badges _ contain : _ beta-gamma film only and are developed -~ c regularly.: They;are worn by student personnel who normally enter-4 nczpa manuAt stenom 6. 6-3 mr e e r at w

• v

.ey -.,-y e- .'mm e.s -- ~

l* i l the reactor rooms. 6,1.4.2.2 BETA-GAMMA-NEUTRON PILM BADGES These badges contain both beta-gamma and neutron film and are developed regularly. They are worn by all reactor operator personnel normally working in the reactor rooms. '6.1.4.2.3 VISITOR FILM BADGES Each group of visitors will be accompanied by an escort. The escort shall wear a special film badge to be worn only while escorting visitors. 6.1.4.3 SPECIAL PROTECTION PROCEDURES Normally no special precautions are necessary for personal safety in radiation fields where the total body dose' is less than 1 mrem /hr. However, it must be remembered that the field at a short distance from a radioantive source will be much greater than the field at normal work ng distances. Some sources must be handled with tongs or other remote handling equipment. It is also recommended that no person should plan to work for extended periods of time in a field where total body dose rate is greater than 1 mrem /hr. Any field of 2 mReu/hr must be clearly defined and posted with signs containing the radiation symbol and the words, " CAUTION - RADIATION AREA." The Health Physicist shall be notified of any changed circumstances which may be expected to alter the radiation field. 6.1.4.4 MAINTENANCE AND ALTERATIONS When maintenance and alteration is planned, the Health Physicist w!11 be notified in advance, so that radiation and contamination surveys can be made, and planning for necessary film badges, monitoring, tool decontamination, protective clothing, etc., can be carried out. Special work permits may be required when a person is working in an area where actual or potential radiation or contamination hazard exists. Such permits will be issued only for outside contractor personnel. 6.1.5 INTERNAL RADIATION 6.1.5.1 PERMISSIBLE DOSE The permissible annual-occupational dose is the lesser of either 1) a total effective dose equivalent of 5,000 mrem or the sum of the deep-dose equivalent and the committed dose equivalent to any-individual _ organ or tissue other than the lens of the eye of 50,000 mrem. - The dose from internal exposures will be considered additive MCZPR MANUAL

• SECTION 6 6"4

~ p to ' dose-. received from. external radiation when calculating total -Offective wholeibody dose equivalert as provided in 100FR20.1202. 6.1.5.2

OONTROL OF INTERNAL RA TION NASARDS - CONDITIONS I

i The list of radioisotopes _given in Appendix B to Sections.20.1001- - 20.2401 of 10CFR20 show a wide variety of substancest-and range of tolerance' levels involved.in the control. of internhl radiation. l Toxicity is only indirectly related to measured activity since it varies with _the degree of absorption into the body, e.g., ingestion, -inhalation, contamination of wounds, or - absorption through skin (especially when solvents are involved). For4these reasons, it is not possible to set up general rules to cover all [ cituations and Health Physics must be consulted whenever the possibility of the intake of more than 1/10 the applicable annual --limit on intake (ALI) in Table 1, Columns 1 and 2, of Appendix 3 to Sections 20.1001-20.2401 of any isotope exists or is anticipated. The following regulations must be observed as a basic minimum for the control of internal radiation hazards. 6.1 5 2.1 USE AND STORAGE OF RADIOACTIVE' MATERIALS Each area or room in which radioactive material is used or stored and which contains an amount exceeding ten times the quantity ~of such material as specified in Appendix C to Sections 20-1001-20.2401' of.10CEst20 shall be posted with a sign or _ signs bearing the radiation symbol-and the words " CAUTION - RADIOACTIVE MATERIALS." .6.1.5.2.2 FOOD STUFF 8 No beverages, foodstuffs, or application of cosmetics are allowed in the ZPR, graphite or counting areas. -4.1.5.2.3 SMOKING Smoking is not: allowed per college regulations. 6.1.5.2.4 PIPETTING No radioactive-liquid is to be pipetted by mouth, 6.1.5.2.5 SPECIAL-RANDLING EQUIPMENT ^ Some special portable equipment, such as long-handled tongs, remote- .pipetters,.ylead carriers, etc., are available for general use in-the Counting Room.- [ '6.1.5.2.6 CONTACT WITH HANDS ~ iRubber_ gloves are to be worn in cases where radioactive material or - solutions of radioactive material may come in contact-with hands - mczen muuat ' stcitoN 6 6-5 t E .,v- -w -4 v,. ,nn - + - - - - - - - - - - - - - - - - - - - - - - - - -

5 1 Lunlessz ~their' use introduces

a. - greater hazard or extreme-inconvenience.

Perso'ns with breaks in the skin must not attempt to work with radioactive substances without consulting with the Health .. Physicist for suitable; protective measures.. 6.1.5.3.7 AIR CONTAMINATION Any room,-enclosure,- or operating area in which-radioactive ' materials - exist. in - concentrations in-excess of the Derived Air Concentrations (DACs) specified in~ Appendix B,, Table I, Column 3 to: Sections 120.1001-20.2401 of 10CFR20 or in which ' they exist in concentrations such that an individual present in the area without respiratory protective equipment could exceed, during the hours an individual;is:present-in a week, an intake of 0.6 percent of the ALI or 12 DAC-hrs, shall be conspicuously posted with a sign or signs-bearing the radiation symbol and the words, " CAUTION AIRBORNE RADIOACTIVE AREA." No person is to enter a room or area where-it is known or_ suspected that the permissible - limit for n airborno activity is exceeded. No operation is-to be performed Twhich might cause radioactivity to become airborne in excess 'of permissible levels. L 6.1.5.2.8 MOVEMENT OF RADIOACTIVE MATERIALS l No radioactive material in to be ~ moved from the Engineering Building in such a manner that_it is possible for the material to escape from the container. Liquids, gases, and dispersible solids must-be transported in. suitable vessels with a protective sheath of shatterproof material. Surface contamination on articles for decontamination or waste disposal' can usually be contained by wrappings of polyethylene sealed with_ adhesive tape. The outside surface of packages which are to be transported must be free from removable contamination so-as te smear below 10 alpha dpm and 100 beta dpa on a standard smear. Materials and equipment- - to be transferred ' from a designated shoe cover.. area must carry HP-2 '" Approved if surface contamination is below 100 dpm beta and 10 dpm alpha".-for standard wipe smear and if object has _ no - activity detectable with a survey met er. p 6.1.5.2.9_ ACCIDENTAL _ CONTAMINATION l Any person believing that radioactive materials may have been absorbed into their_ body should - immediately consult-the Health Physicist, who-- will -initiate appropriate bioassay samples and ~ summon ' medical aid,. if these procedures are deemed necessary. ._ Absorption through the unbroken skin is possible when large amounts of: active material'are! involved, i: 6.1.5.2.10' BIOASSAYS Reactor: personnel -other _than students may - be required to submit urine - samples for radioactive analysis. Such samples will be aca muund secuou 6; 6-6 E e-u -ey -w -3 .,e.a_n- -v-_vt--.ci .,4 p.e.,3.p vi 9 .g++>r + +- 9 n 4- + --y--n- >-y ,.3

P request.ed at' discretion of the Health Physicist or Reactor Operator = when any significant-internal exposure-of radioisotopes is suspected to have occurred. If the sample or samples indicate an J overexposure ' to internal radiation, the Health - Physicist ~ will investigate knd a report of findings will_ be prepared. This report will also include. recommendations to remedy the situation. The-report. is to be submitted to the Reactor Operations Committee for review of Implementation. 6.1.5.2.11 BLOOD COUNTS Personnel, described in part 6.1.5.2.9 above, may be required to provide a blood sample. The'results of the blood count will be received by the Health Physicist and included in the documented report mentioned in part 6.1.5.2.10 above. 6.1'.5.2.12 STUDENT LIMITATIONS Student irradiation of samples will be restricted to solids. This regulation may be modified to include gas or liquid samples. Such modifications are provided by the Reactor Operations Committee, which will review the reasons for the modification and shall demonstrate the radiological safety of the procedures. 6.1.5.3 ALARA The NRC has intcoduced the ALARA program as'a further measure for reducing radiation exposure to radiological workers. The ALARA program is a commitment on the part of each radiological facility to closely monitor all dosimetry values and seek methods or techniques to further reduce the radiation levels that their staff may receive. -The Manhattan College Nuclear Engineering Facility subscribes to this program. Section 6.2 presents the ALARA program as it relates to the Manhattan College Nuclear Engineering Facility. 6.2~ ADMINISTRATION COMMITMENT TO ALARA The administration of Manhattan College and the Manhattan College Nuclear Engineering Facility are committed to the program described in the - following sections for keeping exposures (individual and collective) as low as reasonably achievable (ALARA). In accordance with.this commitment, an administrative organization for radiation safety has been established and will develop the necessary written policy, procedures and instructions to foster the ALARA concept _within. Manhattan College. This organization includes the existing Reactor Operations Committee (ROC) and an appoivated Radiation , Safety officer,(RSO).1 -A'formalt annual review of-the radiation safety p ogum including ALARA considerations will be. performed. This shall include reviews iof operating, procedures and past exposure records, inspections, nem nauAte stenou 6 6-7 L

Ctc., and consultations with the radiation protection staff-or outside consultants. Modification-- to operating and maintenance procedures and to equipment and facilities will be made where they will reduce cxposures unless-the cost, in the judgement of the committee, is considered to be unjustified. The Committee will be able to demonstrate, if necessary, that improvements have been sought, that modifications have been considered, and that they have been implemented where reasonable. K$re modifications have been recommended but not implemented, the committee will be prepared to describe the reasons for not implementing them. In addition to maintaining doses to individuals as far below the lia!.ts as is reasonably achievable, the sum of the doses received by all exposed individuals will also be saintained at the lowest practicable level. It would not be desirable, for example, to hold -the highest doses to individuals to come fraction of the applicable -limit if this involved exposing additional people and significantly increasing the Lum of radiation doses received by. all involved individuals. 6.2.1 REACTOR OPERATIONS COMMITTE3 6.2.1.1 REVIEW OF PROPOSED USERS AND USES The ROC will thoroughly review the qualifications of each applicant with respect to the types and quantities of materials and uses for which he has applied to assure that the applicant will be able to take appropriate measures to maintain exposure ALARA. When considering a new use of by-product material, the ROC will review the efforts of the applicant to maintain exposure ALARA. The user should have systematized procedures to ensure ALARA, and -shall have incorporated the use of special equipment in his proposed use. The ROC will ensure that the user justifies his procedures and that dose will be ALARA (individual and collective). 6.2.1.2 DELEGATION OF AUTHORITY The ROC will delegate authority to the RSO for enforcement of the ALARA concept. The ROC will support the RSO in those instances where it is necessary for the RSO'to assert his authority. Where the RSO has been overruled, the Committee will record the basis for its a: tion in the minutes of the committee's semi-annual meeting. 6.2.1.3 REVIEW OF ALARA PROGRAM HCZPR MANUAL - SECil0N 6 6-8

The.RSO.will encourage-all users to review current procedures and develop new procedures as appropriate to implement the ALARA concept. The RSO will perform a quarterly review of occupational radiation exposure with particular attention to instances where Investigational Levels in Table 6-1 are exceeded. The principal purpose of this review is to assess trends in occupational exposure as an index of the AIARA program quality and to decide if action is warranted when Investigational Levels are exceeded (see Section 6,2.6). The RSO will evaluate our Nuclear Engineering Facility's overall efforts for maintaining exposures ALARA on an annual basis. This review will include the efforts of the RSO, authorized users, and workers as well as those of the Administration of Manhattan College and the Nuclear Engineering Facility. 6.2.2 RADIATION SAFETY OFFICER (RSO) 6.2.2.1 ANNUAL AND QUARTERLY REVIEW Annual Review of the Radiation Safety Program. The RSO will perform an annual review of the Radiation Safety Program for adherence to ALARA concepts. Reviews of specific procedures may be conducted on a more frequent basis. Quarterly review of Occupational Exposures. The RSO will review at least quarterly the external radiation exposures of authorized users and workers to determine that their exposures are AIARA in accordance with the provisions stated in Section 6.2.6. Quarterly review of. records of Radiation Level Surveys. The RSO will review radiation levels in unrestricted and restricted areas to determine that they were at ALARA levels during the previous quarter. 6.2.2.2 EDUCATIONAL RESPONSIBILITIES FOR AN ALARA PROGRAM The RSO will schedule briefings and educational sessions as needed to inform worker of ALARA program efforts. The RSO will assure that authorized users, workers and ancillary personnel who may be exposed to radiation will be instructed in the-ALARA philosophy and informed that administration, the ROC and the -RSO are. committed to implementing the ALARA concept. 6.2.2.3 COOPERATIVE EFFORTS FOR DEVELOPMENT OF ALARA PROCEDURES ' Radiation workers will be given opportunities to participate in I formulation of the procedures that they will be required to follow. ncun MANUAL - $ECHON 6 6-9

. -. - ~. -. - p l 1 The-RSO. Will be1in close contact with all' users -and workers in crder to - develop -- AIARA - procedures : for working with radioactive materials. i The R80 will; establish procedures for receiving and evaluating. the cuggestions1 of individual. workers-for improving health physics practices _and encourage the use'of those procedures. l 6.2.2.4= REVIEWING INSTANCES OF DEVIATION FROM OOOD ALARA PRACTICES-The RSO will investigate all known instances of deviation from good l AIARA practices; and, if possible, ~ determine the causes. When the cause is known, the RSO.- will-require changes in the. program to maintain exposures AIARA. 6.2.3 AUTHORIEED USERS E 6.2."3.1 NEW PROCEDURES INVOLVING POTENTIAL RADIATION EXPOSURE The authorized user will-consult with, and receive the approval of, i the RSO and the ROC during the planning stage before using radioactive materials for a new procedure. The authorized user will evaluate all procedures before using radioactive materials to ensure that exposures will be kept ALARA. ] This may be enhanced through the application of trial runs. I 6.2.3.2 RESPONSIBILITY OF THE AUTHORIBED USER TO THE INDIVIDUALS SUPERVISED The authorized - user will explain the ALARA concept and his e commitment to maintain exposures ALARA to all of those supervised. The authorized user will ensure that the individuals subject to occupational radiation-exposure are trained and educated in good health physics practices and in maintaining exposures ALARA.

6.2.4 PERSONS WHO RECEIVE OCCUPATIONAL RADIATION EXPOSURE The worker will be instructed in the ALARA concept and its relationship lto working procedures and work conditions.

1 The worker will know what recourses are available if it is believed that-ALARAz is~not being promoted on the job, t PRENATAL! ADIATION' EXPOSURE- - 6.- 2. 5 ' R

This

.is: a. J set :- o f- - special instructions to

. females, their W Lsupervisors, and;co-workers regarding prenatal. radiation exposure ~ including - a - brief c description. of-the most vulnerable time for- >nC2PR MANUAL

• SECil0N 6 6-10 I

F

cxposure to occur and the possible consequences. It states the federal allowable limits and the Investigational Levels adopted by Manhattan College. These s pecial instructions must be given both crally and in print. The Lndividuals receiving this instruction must acknowledge their understanding by signature. Retaining this Cocument is discussed in detail in section 9.2.2.1. 6.2.

5.1 BACKGROUND

INFORMATION f It is known that sensitivity of cells to radiation damage is related to their reproductive activity and inversely related to their degree of_ differentiation. It follows that children could be Cxpected to be more radiosensitive than adults, fetuses more radiosensitive than children, and embryos even more radiosensitive. This principle has long been a factor in the development of radiation exposure standards. 10CFR20.1207 places different limits on minors than on adult workers. 10CFR20.1208 relates to embryos ~ or. fetuses. A special situation arises when an occupationally exposed woman is pregnant. Exposure of the abdomen of such a worker to penetrating radiation from either external or internal sources would also involve exposure of the embryo or fetus. Because a number of studies have indicated that the embryo or fetus is more sensitive than an adult, particularly during the first three months after conception, when a woman may not be aware that she is pregnant, the National Council on Radiation Protection and Measurements (NCRP) recommended in its Report No. 39 that special precautions be taken to limit exposure when an occupationally exposed woman could be pregnant. 6.2.5.2 REGULATORY POSITION ON PRENATAL EXPOSURE Instruction to workers performed under 10CFR19.12 should be given prior to assignment to work in a restricted area. In providing instruction about health protection problems associated with -radiation exposure, female workers and those who may supervise or work with them should be given specific instruction about prenatal exposure risks to the developing embryo and fetus. The instruction should ensure that the employees understand: 1. That 10CFR20.1208 requires

that, during the entire pregnancy, the maximum permissible dose equivalent to the fetus from occupational exposure of the declared pregnant woman should not exceed 0.5 rem. This dose is the sum of the deep-dose equivalent to the declared pregnant woman and the dose to the embryo / fetus from radionuclides in

?_ the embryo / fetus and in the mother. 2. The reasons for this recommendation. MCZPR MANUAL * $ECilON 6 6-11 i

, -. -. -.. ~ .( 2 t The e instruction; should ? includC the information z provided : in the - e Appendix to U.S.: Nuclear-Regulatory Commission Regulatory Guide j i8.13-tit'S1 " Instruction concerning PrenataliRadiation Exposure." ? f It should be presented-to the employee, her supervisors,;and:her-co-workers both orally--and in written form. Each individual should

be ' given an-opportunity to ask questions, and each : individual should be asked to acknowledge iniwriting that the instruction has been received.-

4.3.5.3 POTENTIAL NEALTE RISKS DUE TO PRENATAL EXPOSURE j Some recent studies have.shown that the risk of leukemia and other cancers in children increases if. the mother is exposed -to a significant amount of radiation during pregnancy.- According to a 1 report by.the National ' Academy of Sciences, the incidence of leukemia among children from birth to lo years of age in the United-States could rise from 3.7-cases in 10,000 children to 5.6 cases in; -10,000 children-if the children were exposed to 1 rem of radiation- .before birth ( a "ren" la a measure of radiation). The Academy has also estimated that an equal number of other types of cancers could

result. from this : level of radiation.

Although other scientific studies have _ shown a much smaller effect from radiation, the Nuclear Regulatory Commission. (NTS) wants women employees of its licensees to be aware of any possible risk so that the women can 1 take steps they think appropriate to protect their' offspring. As an employee of a NRC licensee, you may be exposed to more radiation than the general public.

However, the NRO has established a basic exposure limit for all occupationally exposed adults.of 1.25 rems per calendar quarter, or 5 rems per year.

No clinical evidence of harm would be expected in an adult working within these levels for a lifstime. .The NCRP has recommended that because fetuses may be more sensitive -to radiation than adults, their radiation dose as a result of --occupational exposure of the mother should not exceed 0.5 rem. The International Council on - Radiation Protectioni (ICRP) has. also - stressed the need to. keep radiation doses.to the fetus as low as-l ' reasonably achievable-(ALARA)'. All NRC ' licensees -1 are now required by 10CFR19 to inform all . individuals'who work in a-restricted area of the health protection problems associated with; radiation exposure. This instruction must

include.information on the pcssible risks to unborn babies.

It is also ': stated Lin 10CFR20: that licensees should keep. radiation. ( exposures as low as reasonably achievable. Therefore, it is'the responsibility" of then employer : to take - all practicable steps.to ~ reduce the individual's' radiation exposure. 10CFR20.1208 requires- -thatLthe dose to the embryo / fetus from occupational exposure cf the - ' daclared s pregnant woman: not exceed 0.5 rem during the - entire - 1

pregnancy.

When idealing with the protection of a fetus, the alternativesfwhich may be considered-by a woman are

j leC2Nt ptANUALM SECil0N 6 6 1 s e hv i-es,-pe-.wa ,+r, y -4 -e .ye= w. + - - -, = = <we y e-c -+ .m-1

l 1. If the woman is currently pregnant or is expecting to be soon, she may decide not to accept or continue assignments in -restricted areas. 2. -. The woman may reduce her exposure, where possible,- by decreasing the amount of time spent-in the radiation area, ' increasing the distance from the radiation source, and using -shielding. 3. If a woman does become pregnant, she could ask her employer to-reassign her to areas involving less exposure to radiation. If this is not possible, then she may consider leaving her job. If this decision is made than it should be done without delay. The fetus is most sensitive to radiation dur'. 7 the first thrse months of pregnancy. 4. The woman could delay having children until she is no longer working in an area where the radiation dose to the fetus could exceed 0.5 rem. 5. The woman may continue working in the higher radiation areas, but with full awareness that she is doing so at some small increased risk to the fetus. The following facts are presented to help a wor,an with this decision. 1. The first three months of pregnancy are the most importent, so the decision must be made quickly. 2. In most cases of occupational exposure, the actual dose received by the fetus is less than the dose received by the mother because some the. dose is absorbed by the mother's body. 3. At the present occupational exposure limit, the actual risk to the fetus is small, but experts disagree on the exact amount of risk. 4. There is no need for a woman to be concerned about sterility or-loss of the. ability to bear children. The radiation dose required to produce such effects is more than 100 times larger than the NRC's dose limits for adults. 5. Even if a' woman works in an area where she receives only 0.5- -rem per three-month period, in 9 months she could receive 1.5 rems and therefore the fetus could receive more than 0.5 rem which is more than the full-term limit required by the NRC. '6.2.'5.4- ' EXPOSURE AT. MANHATTAN COLLEGE ZERO POWER REACTOR ~ Occupational exposures at-the Manhattan College Zero Power Reactor are well'below the federal limits. Within the ALARA program at the . MC2PR MANUAL

• SECTION 6 6"13 i

_ _ _ ~ ~,. _. t 1 -Manhattan College JHuclear Engineering

Facility, a

set -of investigational-levels have 'been developed -for occupational cxternal radiation exposure. - The Radiation. Safety Officer will-1 review : exposure records: on a quarterly basis and 1 the actions- . Cescribed _ in Section 6.2 will ' be taken at the Investigational = Levels: stated-in Table C-1. l The levels adopted by the Manhattan College AIARA program are well I -below the recommended limit of 0.5 rem during the gestation period. At investigational level I, a female will-receive 0.125 ren/ quarter which would total to 0.375 ran for the 9 month gestation period. Anything above this level will cause a review and a report to the ROC where appropriate measures will be taken. I

6. 2. 6 -

ESTABLISNNENT OF INVESTIGATIONAL LEVELS IN ORDER TO NOMITOR INDIVIDUAL OCCUPATIONAL EXTERNAL' RADIATION j EXPOSURES.

The Manhattan College Nuclear Engineering Facility has established Investigational Levels for Occupational external radiation exposure 4

which, when exceeded, will initiate review or investigation by the Reactor Operations Con ittee and/or the Radiation Safety Officer. The Investigational Levels adopted by Manh3ttan College are listed c in Table 6-1 below. These levels apply to the exposure of individuals. TABLE 6-1 MIhpesGgalitenadiAelshuseashpelr?calindar/quaistiern fMhM[h!d N ' '- ? *W t * ? Lev $st lLeiglfI6 Whole Body; head and trunk; active -blood-forming organs; lens of 125 375 eyes; or gonads Female.during gestation period 125 175 Hands ~and forearms; feet and 1250 3750-ankles Skin of whole body 1250 3750- -The Radiation Safety Office will review and record on Form IRC-5, ? . Current occupational External Radiation Exposures, or an equivalent form (e.g.. dosimeter L processor's report), results of. personnel monitoring,1 n o t l e s s.. t h a n once in any calendar quarter. The ~ following-actions will -be' taken -at the Investigational Levels as i . stated in Table-6-1. 6.2.6.1 QUARTERLY-EXPOSURE OF. INDIVIDUALS TO LESS THAN

INVESTIGATIONAL LEVEL I me s t MAmuAL stcitou e 6-14 l

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Except when deemed appropriate by the RSO, no further action will i be taken in those cases where an individual's exposure is less than Table 6-1 values for the Investigational Level I. 4.2.6.2 PERSONNEL EXPOSURES EQUAL TO OR GREATER TRAN 1 INVESTIGATIONAL LEVEL I BUT LESS THAN INVESTIGATIONAL l LEVEL II The RSO will review the exposure of each individual whose quarterly i Cxposures equal or exceed investigational Level I. He will report the results of his reviews at the first ROC meeting following the quarter when the exposure was recorded. If the exposure does not cqual or exceed Investigational Level II, no action related cpecifically to the exposure is required unless deemed appropriate by the Committee. The Committee will, however, consider each such Cxposure in comparison with those of others performing similar tasks as an index of ALARA program quality and will record the review in the Committee minutes. 6.2.6.3 EXPOSURE EQUAL TO OR GREATER THAN INVESTIGATIONAL LEVEL II The RSO will investigate in a timely manner the causes of all personnel exposures equaling or exceeding Investigational Level II, and if warranted, take action. A report of the investigation, actions taken, if any, and a copy of the individual's Form NRC-5 or its equivalent will be presented to the ROC at the first ROC meeting followi.ag completion of the investigation. The details of these reports will be recorded in the minutes. Committee minutes will be sent to the administration of this institution for review. The minutes, containing details of the investigation, will be made available for review. 6.2.6.4 RE-ESTABLISHMENT OF A : INDIVIDUALS OCCUPATIONAL WORKER'S INVESTIGATIONAL LEVEL II ADOVE THAT LISTED IN TABLE 6-1 In cases where a worker's or a group of workers' exposures need to exceed investigational I4 vel II, a new, higher Investigational Level II may be established on the basis that it is consistent with good - ALARA practices for that individual or group. Justification for new Investigation Imvel II will be documented. The Reactor Operations Committee will review the justification for, and will approve, all revisions of Investigational Levels II. In such

cases, when the exposure equals or exceeds the newly established Investigational Level II, those actions listed in section 6.2.5.3 above will be followed.

6.3 CONTAINMENT All radioactive material-must be contained in an appropriate vessel, v1.en not in use and in such condition is known as a source MCIPA MANUAL

• SECil0N 6 6-15

.5

C of.L radiation.. i .Each container in.which there-is: transported, stcred, or-used a' -quantity of radioactive material greater than the quantity shown in Appendix C _ to-- 10CFR20.1001-20.2401' shall-bear =a durable,. clearly ivisible. label bearing the radiation caution symbol;and the words,.

i

" Caution - Radioactive Material." J

However, such a label shall not be required:'

If the concentration of the material in the container does not - exceed that specified in Table I, Column 2, of~ Appendix B to l 10CFR20.1-20.601, s For laboratory containers such as beakers, flasks and-test a tubes used transiently in laboratory procedures, when the user is present. When. containers are used for storage, a " Caution, Radioactive -Material" tag-or equivalent -shall state also the quantities and l kinds of radioactive materials in the container and the'date of the measurement of the _ quantities. In audition to the above requirements, -encapsulated sources and -any other vessels inside such ~ a. container will -also. be labeled whenever practicable and whenever there ts any reasonable possibility of the source or vessel being left outside its container.or being separated.from it in transit.. - The ' label of: sources in transit for use outside the laboratory shall also certify that there is no contamination on the outside of the container. The person dispatching a source is responsible for planning a' safe method of transport and !or ensuring that adequate ~ warnings are given to all personnel likaly to come in contact with i the' source until it reaches its destination'and-is turned over to the custody 1of the recipient. I Sources not-in current use should be shielded so that the radiation field at one foot anywhere outside the shield does not exceed 2.5 l - aren/hr.- .1 -The Manhattan College-Reactor Operations Committee shall provide: I properly pontrolled and labelled storage for_ sources larger-than i those which can'be stored-in the laboratories. The radiation field; H .atLany~ accessible point outside the storage area shall not exceed 2-arem/hr. All containers contnining radioactive sources shall'be

1abeled with the

source strength, and type' of source' in accordance

'with 10CFR20.203. j ~

6.3.1S RADIATION AREAS-TheIManhattan College Reactor. Operations Committee is responsible

'forirequesting;the Health Physicist for surveys so that properly' i -;aczmt muuAt stetlou 6 : 6 '

.- ~ ~ _ _ a marked radiation signs and tags are prominently' displayed in all radiation areas.- The necessity and extent of-isolation and type of-radiation. sign will be determined by the Health Physicist in 3 accordance with 10CFR20.203. 6.3.2 LABORATORY CONTROL The Chief Reactor Supervisor or other persons approved-by the ROC shall be responsible for the control _ of. - contamination' in the -facility.. Working surfaces, walls, and floors must be " clean on wipe" i.e., there must not be removable contamination in excess of-100 dpa beta or 10 dpm-alpha per ' standard smear. Fixed contamination must not exceed 2.5 mR/hr on contact. Since fixed contamination will be gradually liberated by wear of surfaces, the following should be considered for general laboratory conditions: 6.3.2.1 CONTAINERS Containers of active material and all possible equipment shall be -placed in auxiliary containers such as pans or trays, lined with absorbent materials. 6.3.2.2 CONTAMINATED GLASSWARE Contaminated articles such as used pipettes or stirring rods shall not be laid on a table. They shall be placed in a stainless steel or enamel tray or other suitable container, lined with absorbent material. 6.3.2.3 CLEANLINESS Good general laboratory and plant house keeping shall be maintained. -Practices which are undesirable in any ordinary laboratory shall not be tolerated in laboratory containing radioactive material. -6.3.2.4 SPILLS In the event of a spill, place, do not drop absorbent material on the-spill. Advise others in the area to leave the immediate area. Use a _ survey meter _ -(Geiger Mueller type) to-determine areas of contamination and andertake personnel decontamination action if necessary._ The. spread of contamination will be-arrested and then decontamination' pre adures effected. The area will not be opened until: wipes ~ indicate no contamination. 6.3.3 EQUIPMENT Equipment that has been _ surveyed, wipe tested and found to be contaminated shall not -(mandatory) - be used until decontamination procedures are performed. The specific decontamination procedure will' depend-on the type of equipment and extent of contamination. ] \\ aczpa namust i sEcn ou 6 6-17

[ All= equipment, apparatus or-tools that-are contaminated shall be

placed: in plastic-bags and sealed. - Other articles too large for-

-bags shall have plastic ~ sheeting ~ applied about each item and all--- - running edges-shall-be : sealed with tape. : Personnel performing decontamination are to wear gloves and other protective apparel as recommended by the HealthLPhysicist. ~The Health Physicist shall perform such surveys - and wipe tests to detet=ine the - level of-radioactivity and several decontamination procedures may have to be performed before equipment is released - for use.. All' materials and ~

water-or detergents used-in the decontamination procedures _ shall be retained _until _ surveyed by the Health Physicist and appropriate disposal modes approved.

In all. cases - the Health Physicist shall decide upon either a.- - suitable method of decontamination or disposal.. Decontamination of all. contaminated materials that are not disposed of shall be performed by personnel responsible for the articles. 6.3.4 MANDS AND OTHER BODY PARTS survey meters located-in the ZPR room shall be used for monitoring of hands and clothing of individuals suspected =of being contaminated. If hands or face are contaminated: then carry out tho-ugh washing with-water and'a mild detergent. This may have to ia repeated-a i number of times. Each time (after washing) survey the areas that were contaminated. If clothing only has=been contaminated remove the item in question and wash dowr. the material. When washing, use plastic gloves and take care not.to splash any of the rinsing water onto the body. This-may-have to be repeated a number of times. After each washing,-survey the contaminated area. 6.4 WA8TE DISPOSAL i .The chief cause of _ radiation exposure to the public is contamination of-air and water and great care must be taken in the disposal of radioactive waste. Appendix B to 10CFR20.1001-20.2401 listsithe._ maximum' permissible. concentrations of radioisotopes;in air and water for. discharge to the environment. No effluent shall

be released at any concentration and no waste shall be disposed of

'except as'. authorized by_the Reactor Operations. Committee. In_any Levent, only concentration at or below maximum permissible levels listed in Appendix:B in air-and water will be allowed to escape

continuously-to the local ~ environment.

6.4.1 ACCUNULATTON OF ACTIVE WASTES 16.4'.1.11 DRY WASTE inc2Pa manual - sectiou 6. 6-18

Cans marked CONTAMINATED WASTE, COLD WASTE and CONTAMINATED GLASSWARE will be provided as needed. These cans shall be polyethylene-lined and shall not be filled so as to prevent closure of the polyethylene bag liner. They should be-floor-operated in order to reduce the possibility of spread of contamination by handling the lid. . Extreme care should be exercised in keeping contaminated waste out of the cold waste cans, and vice versa. The cans-will be monitored regularly by the Health Physicist and shall be marked with the normal radiation sign if the radiation field is greater than 2.5 mR/hr at any point outside the can. Persons' placing material in the can which has sufficient activity to produce such a field must notify the Health Physicist. 6.4.1.2 LIQUID WASTE Five-gallon polyethylene bottles marked CONTAMINATED WASTE shall be provided as needed. Liquid waste should be kept in these containers and not mixed with other waste. A detailed record of the nature of the liquid and the amount and type of activity in the container must be. kept by the appropriate supervisor. Physical inventories will be requested. 6.4.2 WASTE TRANSFER Health Physicist will supervise the transfer and disposal of all radioactive wastes in accordance with policies adopted by the Reactor Operations Committee. Transfer and disposal of such wastes must not be made without the knowledge and approval of the Health Physicist. The Health Physicist will monitor all such wastes and will decide on the appropriate method of disposal. Solid wastes found in contaminated waste cans will be packaged for off-site disposal. Liquid waste will be transferred to 50-gallon drums for

storage, concentration and subsequent off-site disposal by a licensed waste disposal contractor.

The Health Physicist will keep complete records of the condition and location of all radioactive waste in storage and of final disposition thereof. 6.5 ' MANUALS AND CODES Each

person, student or

faculty, certified to work with radioactivity shall acquire a copy of the radiation safety manual.

Copies of 10CFR20, 10CFR50, and the codes of the State and City of New. York, as well as copies of this manual, will be available for-inspection at -all times upon request. -This material will be 1 maintained. In the - office of the Reactor Administrator or.in the Nuclear' Facility files. i MC2PR MAliUAL'_* $ECilON 6 6-19 l

.~ p D '6.6 REALTR. PHYSICS SURVEYS 6.6.1 SURVEY INSTRUMENTATION survey ' instrumentation shall be maintained in operating conditions at all times in the counting room and/or in.the zero power _ reactor room (EPR room). The equipment shall be capable of measuring: gamma radiation fields.in excess of 10 microR/hrt. + ' alpha and beta /gamaa-surface contamination ; and' one portable neutron survey meter for both facilities + 6.6.2 WIPE SURVEY 8 Wipe samples of the floor and such other areas-as selected by the ' Health - Physicist and/or the Chief Reactor Supervisor shall be performed. The floor areas include the EPR, graphite, counting and lecture rot as as well as connecting corridors and upper level desk areas. Normally this is performed at six month intervals. 6.6.3 AIR SURVEY 8 (.. & Air sampling shall be taken of the areas q9nsidered in 6.575;t above.. Samples shall be taken at a rate of ah least 2.5 cubic feet-per minute for 1/2 to 1 hour at each location. Normally this is performed at six month intervals. 6.6.4 EPR WATER SURVEY 8 EPR water shall be checked at six month intervals. This procedure shall.be accomplished employing a multi-channel analyzer or a scintillation spectrometer. Air and water samples of.the reactor area will be obtained prior to operation of the reactor. These will-he control values. .These values will then be employed and used for comparison purposes of air and water samples taken at the conclusion of-each-semest'er in which the reacter has been operational. -If Iodine-131-is found, Reactor Operator and the Health Physicist will be; notified immediately. 6.6.5. DISPOSAL OF POOL WATER AND DEMINERALIZER RESIN The pool shalllnot be drained until the water has been assayed and shown to b_e at or.below-tolerance as specified in 10CFR20. The Health-_ Physicist.must be notified in advance as to this action. The demineralizer -is a concentrator of radioactivity, ' notably

short-lived Na and Mg-27.

Used resin can never be replaced without' Health-Physicist coverage and= notification'. If assay of the resin showsEit to be radioactive it willibe disposed 'of in nczra MAnuat - stcTion 6 6-20

e l accordance_with 10CFR20,2001. 6.6.6 IOG BOOKS For the time period prior to April 1990, the Health Physicist will maintain a bound log book. All entries will be in ink. No erasures are ever to be made. Incorrect entries are to be crossed-out, (they must still be legible), and the corrections noted above. These logs.will be maintained: radiation surveys wipe records air and water tests + After April 1990, the Health Physics log book will maintain a book with resovable sheets. All Health Physics surveys will be recorded on' standard forms, numbered, and retained in a binder. All entries will be in ink. No erasures are ever to be made. Incorrect entries will be crossed out and the correction noted and initialed. 6.6.7 SURVEY INSTRUMENTS SERVICING AND CALIBRATION All of the portable survey equipments in the ZPR room are checked and calibrated on an annual basis. I MCtPR MANUA:,'+ SECTION 6 6-21 I i i

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REVISION 11 REVISION RECORD REVISION NUMBER COMMENT 0= Submitted to U. S. NRC on August 26,19c3 as part of the Safety Analysis Report for the Manhattan College Zero Power Reactor (MCZPR) 1 Complete revision submitted on January 12,1984 2 - Complete revision submitted on November 15,1984 3 Revisions as noted on pages: 16-1,16-2,16-10,16-11,16-13,16-16,16-23, 16-25, end 16-26 or. December 19,1984 4-Page numbering changes from 16-1 to 1 1, etc. Cover sheet revised from section 16 to Appendix A per USNRC request p Revisions as noted on pages 1, ii, iii, and 1 -1, 2-1, 2-2, 3-1, 3-2, 3-3, 3-4, 3-7,4-1,4-2,4-4,4-8,4-11,5-1,5-2,5-3,5-4,5-5,6-1,6-6,6-8,6-9,6-11,6-13, and 6-14 on March 15,1985 5 (HEU core) Revisions as noted on pages i,it,and 1-1,1-2,3-1, and 3-2 on February 20, 1989 t 6(LEU core) Revisions as noted on pages i, ii, and 2-1,2-2,3 1, 3-2, 5-1, and 5-3 on March 10,1989 7 Revisions as noted on pages i, ii, iv 6-1, and 6-8 on March 26,1987 8 - Revisions as noted on pages i,ii, 1-1,1-2,2-1,2-2,3-1,3-2, and 5-3 on March 12,- 1990 9 No changes-10 Revisions as noted on pages i, ii,4-8,4-9,4-10,4-11,4 12,6-15, and 6-16 on April 13,1992- "I ~l1 Revisions as noted on pages i, ii, and 6-5 on November 22,1994

-~ __. _ _ _ _ _. - _ _.. _ ___._._ i i e ? Amen &sent No. ~12 i REVISION RECORD (cont.) i f i AEVISION i MUMhER COMMENT 12 Revisions as noted on pages 2-1, 3-1, 4-1, 4-2, i 5-1, 6-1, 6-2, 6-3, 6-4, 6-5, 6-8, 6-9. j Submitted with Decommissioning Plan and request - i to terminate license. i 1 1 u t t -i L ? i e i ? i I i I t i I t a I h l. i a k i i 7 ef' u ysueo 9-m.-1* v y my., bv"ie e ghgr27ur' F t*- el w "ke" ' 4 h 5"*PrP*

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.I k h Rev,8 TABLE OF CONTENTS Pare No. Contents TitlePage...............................................<..............................................................! Re vi s l on Rec ord....................................................................................r Tabl e of Con ten ts........................................................................................................< 4 1.0 l> EFI N ITION.................................................................................. 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SE'ITII.'OS...................... 21 3.0 LIMITING CONDITIONS FOr. OPERATION.......................................................... 3-1 4.0 SURVEILLANCE R EQUIREMENTS...................................................................'. 4 1 i 5.0- DESIGN FEATURES........... ....................................................51 6.0 ADMINIS*IRATIVE CONTROLS......................................................................:.. 6 1 I Table 3 1, S afety S yste m...................................................................................... 3-4 Figme 6 1. Table of Organization.............................................................................i 2 i g. iii ~ "Y^ g-am...,,wy,, p.

t [ (t- ; i i 1.0 DETINITIONS The terms Safety Limit, Limiting Safety System Setting, and Limiting Condition + for Operation are a. defined in paragraph 50.36 of 10 CFR Part 50. ALARA is a concept introduced by the Nuclear Regulatory Commission i ALARA The basis of ALARA is that all exposure to THE7 to all reactor facilities. radiation should be kept "as low as reasonably al A channel is the combination of sensor,,line, amplifier and output channel devices which are connected for the purpose of measuring the value of a parameter. A channel calibration is an adjustment of the channel channel calibration such that its output corresponds with acceptable accuracy to known values of r Calibration shall encompass the the parameter which the channel measures. entire channel,_ including equipment actuation, alarm, or trip and shall be deemed to include a $annel test. A channel che a is a qualitative verification of acceptable channel check This verification, where performance by observation of channel behavior. possible, shall include comparison of the channel with other independtnt r channels or systems measuring the same variable, (m.) A channel test is the introduction of a signal into (Le channel test channel for verification that it is operable. Plates fabricated with neutron absorbing material used to control rod establish neutron flux changes and to compensate for routine reactivity losses. This includes safety-type and regulating rods, The portion of the reactor volume which includes the fuel elements, core the source, and the control rods, When converting between absolute - and dollar-delayed neutron fraction value reactivity units, a beta effective delayed neutron fraction of 0.0078 is used. The elapsed time between reaching the complete removal setpoint drop time ~ d-the Tull insertion of a safety-type rod, an excess reactivity -- Excess reactivity is that amount of reactivity that would exist if all control rods (control, regulating) were moved to the maximum reactive condition from the point where the reat. tor is exactly critical-(K,ff=1). 1-1 Amendment No. 8 ...e e ..,o r-e .,,.--...-.n...-- w----.c 4-,--,n--

~ %) Anfobject,otherthanafucielementorhandlingtool,which j experiment is inserted into the volume formed by projecting the grid plate vertically to j i the tank pool water surf ace is to be regarded as an experiment in the core. The measured value is the value of a-parameter as it appears measured value on the output of a channel. An experiment where it is intended that part of or the movable experiment Tentire experiment.may be moved in or near the core or into and out of the reactor pool water. i Operable means a component or system is capable of performing-its operable ~1ntended function, 4 Operating means a component or system is performing its intended operating Tunction. reactivity limits The reactivity limits are those limits imposed on reactor core excess reactivity. The reactivity worth of an experiment reactivity worth of an experiment is the maximum absolute vadT T~the reactivity change that would occur as a result of intended or anticipoced v enges or credible malfunctions that alter i Q experiment position or configuration. The reactor is operating whenever it is not secured or reactor operating shutdown. --(RO)-Anindividualwhoislicensedtomanipulatethe reactor operator _ controls of a reactor. Reactor safety systems are those systems, including reactor safety sgtemstheir associated input channels, which are designed to initiate aul reactor protection or to provide information for initiation of manual protective e 3 action. A reactor is secured when: reactor secured It contains insufficient fissile material or moderator present in the e 1) reactor, adjacent experiments or control rods, to attain criticality under optimum available conditions of moderation and reflection, or k S j: 3_ I 1-2 Amendment No. 8 t + u r e -wzw = ir-.- S =rt-e ew t we' -m w---*+-2--*-tvv -t* ve, mw-- -w-rw-- av 7-r - -++ 4 -m+-

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4* J i .l - teacLar_ ntutdown - The reactor is shutdown if it is suberitical by at least one dollar in the reference core condition and the reactivity worth of all experiments is between 60*F ond 80'F. rfgulnting.r.od - A low-worth control rod used primarily to maintain Its position may be varied by operator an intended power level.

action, research reactor - A research reactor is defined as a dryice designed r,c research to support a self-sustaining neutron chain reaction development, educational training, or laboratory purposes, ard which may have provisions for the production of radioisotopes.

reverse tr.in - The electronic setti6g within the' console instrumentation which will initiate n reverse system and will drive in an electromagnet when certain specified limits are exceeded, s anfety-tyne_ rod - A rod that can be rapidly inserted by cutting off This applies to t,he holding current in its electromagnetic clutch. both control rods. scrain timo - The time for the control rods (shim, regulating) acting under the force of gravity to change the reactor from a critical to Tnie 9111 be e,ua1 to or 1ess then the drop. O. a suscritica1 condition. time. naram trio - The o'ectronic setting within the consoleinstrumen specified limits are exceeded, nenior__renetor conrator - An individual who is licensed to direct th activitie.s of a Reactor Operator (f0) and to manipulate the controls of a reactor, sha.),1. nhould and mav - The word "shall" is used to denote a requirement; the word "should" to denote a recommendation; and the word"may" to denote permission, neither a requirement nor a recommendation. sintriolin menin - Shutdown margin shall mean the minimum shutdown reactivity necessary to provide confidence that the reactor can be made subcritical by means of the control and safety systems starting from any permissible operating condition although the most reactive rod is in its most reactive position, and that the reactor will remain suboritical without further operator, action, uancheduled shutdown -- An unscheduled shntdown is defined as any unplanned shutdown of the reactor caused by actuation of the reactor safety system, operator error, equipment malfunction, or a manual ds - . shutdown in response to conditions which could adversely af fect safe operat. ion, not ' including shutdowns'which occur during testing or checkout operations. -4l; 1-3 +

i i i i I 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS Ii .Not applicable. The reactor shall remain secured. i r l I i t I i L i e ( i i i i r r I i s i G r r b t 1 2-1

Amendment'No. 12

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'3.0 LIMITING CONDITIONS FOR OPERATION-Not applicable. The reactor shall remain' secured. 3-1. Amendment No. 12

1 l l l f 4.O SURVEILIANCE REQUIREMENTS Actions specified in this - section - are required to be performed j during the specifled surveillance period. 4 4.1 Padiation Monitoring System t ] 4.1.1 Applicability s t This specification applies to the surveillance reauirements-for the radiation monitoring system.- i q 4.1.2 objective To specify the frequency and type of testing to assure .that the radiec on mon tor ng sys em is operable i i i t 4.1.3-Specifications l A. A channel check of the portable radiation ~ survey -instruments shall be performed semiannually. - 1 B. The portable radiation survey instruments shall be i i calibrated annually. l C. The environmental film badge and smear surveys in the fuel and source storage area shall be performed semi-1 p annually. D. An ALARA program shall be established and monitored by a Radiation Safety officer (RS0). l i E.- The 5 millicuria source shall be tested semi-annually for leakage and/or-contamiitation- (unless it is in storage)- by a. The licensee, or b. Other persons specifically authorized by the Nuclear l Regulatory Conanission or an Agreement State. The test method shall have_a detection-sensitivity of at 1 east 0.005 microcuries per test sample. 4.1.4 Bases -The= periodic surveillance and calibration - of-the radiation survey instruments in Specifications A-and B will assure that the radiation survey equipment'is operable. Based'on experience at this facility, specifications ~C-E are : adequate to verify radiation-protection. ,i 4-1 Amendment No. 12 .a. a _, _ _ _.,,._,J.,_ ~__ _,_.__

9 i ) 4.2 Reactor Area t 4.2.1 Applicability i These specifications apply to surveillance requirements for the reactor area other then the reactor structure. 4.2.2 Objective To assure the physical and radiation safety of the reactor area to protect the reactor fuel. 4.2.3 Specifications A. The operational condition of the fire alarm shall be tested on an annual basis. I B. The physical barriers (door locks) shall be inspected quarterly. C. An inventory of the fuel and the sources shall be. performed semi-annually. D. A radiation survey of the area shall be performed semi-annually. 4.2.4 Bases Based on experience with reactors of this type, the frequency of inspection and monitoring in Specifications A-C will c.ssure security for the physical safety of the fuel and sources. Monitoring is performed under Specification D to insure that ALARA will be achieved. i 4-2 Amendment No. 12 i .~ z

5.0 DESIGN FEATURES 5.1 Reactor The reactor is described in the Safety Analysis Report for Conversion of Manhattan College Zero Power Reactor (McZPR) to Low Enriched Uranium (LEU) Puel dated April 1989. The reactor has been modified by removing the fuel to make the reactor incapable of achieving criticality. The control console has been disconnected from the power supply and the reactor. 5.2 Puel Storage Fuel shall be stored in containers in the temporary storage area located on the first floor level of the Nuclear Engineering Facility pending return to the Department of Energy. I l 5-1 Amendment No. 12 .]

i q 6.0-ADMINISTRATIVE CONTROLS 6.1 -Organization 6.1.1 Structure l 1.. Tne-organization for-the management of the reactor facility in j Possession Only status and during decommissioning shall be structured as shown in Figure 6-1. Levels of authority indicated l 9 j divide responsibility as follows: i Level 18 Responsible for the fac.ility license and site j administration. 4 - Imvel 2: Responsible for safe accomplishment of the l reactor decommissioning program. Level 3: Responsible for carrying out decommisnioning actions. 7 The Radiation Safety Committee is responsible to the Dean of Engineering for review and evaluation of all proposed operations and procedures in order to insure that the fuel and sources are a stored, and transferred and the reactor facility is decommissioned - in a safe and competent manner. 6.1.2 Responsibility Individuals at the various management levels shown in Figure 6-1, i in addition to having responsibility for the policies and i management of the facility, shall be responsible for safeguarding the public and fanility personnel from undue radiation exposures and for adhering w all requirements of the License and Technical-Specifications. In all instances, responsibilities of one level may be assumed by - designated alternates, or - by higher levels, conditional upon appropriate qualifications. t The detailed description of duties of each individual in Level 2 and Level 3 are as follows:

A.

The Dean of the School of Enaineerina has been directed by the College Administration to assume direct responsibility for the safe-managementz of'the reactor facility while in. Possession Only status and to assure safe completion of decommissioning. B. The Actina Reactor Administrator shall provide-final policy decisions-on al? phases of reactor and materials possession- -and on regulations:for the facility as a whole. -He/she must. be-qualified and':may assume the added position of the Radiation Safety Officer and carry out the' duties of this position when dictated by staffing requirements. He/she will be' advised in all matters concerning the safe management of the facility by-the Radiation Safety Committee. The Acting 6-1 Amendment-No. 12-l [

FIGURE 6-1 ORGANIZATIONAL STRUCTURE MCZPR DECOMMISSIONING I MANHATTAN COLLEGE CORPORATION BOARD OF TRUSTEES John P. Lawler, Ph. D., Chairman l Level 1 ~ r i PRESIDENT OF THE COLLEGE Bro. Thomas Scanlon, F.S.C., Ph.D. PROVOST Weldon Jackson, Ph.D. DEAN OF THE SCHOOL OF ENGINEERING John D. Patterson, Ph.D. Level 2 HEALTH PHYSICIST Larry Luckett, C.H.P. IRobertE. QUALITY ASSURANCE MGR.

Berlin, D.P.H.

l RADIATION SAFETY COMMITTEE l ACTING REACTOR ADMINISTRATOR Catherine C. Stanton, M.S. Level 3 l l MAINTENANCE STAFF l STUDENT ASSISTANTS l 6-2 ~ Amendment No. 12

s Reactor Administrator shall be appointed by the Provost of Manhattan College. C. The quality Assurance Manaaer shall be responsible for the review and evaluation of the proposed radiation surveys and recordkeeping, including the final verificaticn survey. lic/she will verify that surveys conform to the requirements of NUREG/CR 5049. D. The Radiation Saf ety Committee shall be responsible to the Dean of the College of Engineering for the review and evaluation of all proposed operations and procedures in order to insure that possession and transfer of the fuel and sources and facility decommissioning shall be performed in a safe and competent manner. The Radiation Safety Committee shall advise on and be available for advice and assistance on any problems relative to the safe possession of radioactive materials and facility decommissioning. E. The Radiation Safety Officer-shall be responsible for the promulgation and enforcement of

rules, regulations and operating procedures which conform with the regulations set forth in 10 CFR Part 20.

The Radiation Safety Officer in conjunction with the Radiation Safety Committeo shall approve suggested procedures for the possession, storagn and disposition of all radioisotopcs consistent with general or specific licenses for use of byproduct material issued to Manhattan College. The Radiation Safety Officer in conjunction with the Radiation Safety Committee shall be available for advice and assistance on problems involving radiological safety arising from the decommissioning of the facility. F. The IIealth _ Physicist shall be responsible for monitoring records of exposure on film badges. Ile/she shall also review the reactor log, periodic radiation surveys of the critical reactor laboratory, the subcritical laboratory, the storage area, and the counting room. The IIcalth Physicist will review the surveys performed in conjunction with fuel and source shipment off site and confirm that the packages comply with DOT regulations. 11. All other personnol using the facility shall be instructed in the hazards involved, and given a copy of the laboratory regulations concerning use of radioactive material. 6.1.3 Staffing This Specification related to staffing requirements for reactor operation. It is not applicable for Possession Only status because the reactor will remain secured. 6-3 Amendment No. 12

i \\ i 6.1.4 Selection and Training of. Personnel l The Acting Reactor Administrator shall meet the minimum qualifications set forth in ANSI /ANS 15.4, " Standards for Selection and Training of Personnel for Research Reactors. j 4 The Radiation Safety Committee-members shall have at minimum five (5) years of professional experience in the field represented by the member or a baccalauraste degree plus at least two (2) years experience. Generally, these committee members will be College faculty but outside experience may be . sought if necessary. In this case, a baccalaureate degree plus five (5) years experience will be required. i 6.2 Review and Audit The Radiation Safety Committee shall perform the independent I review and audit of the safety aspects of the reactor facility-i decommissioning. 6.2.1' Composition and Qualifications The Radiation Safety Committee is-composed of faculty and administration knowledgeable in the safe use of radioactive materials by virtue of training and professional experience, t Memberr of the Radiation Safety Committee are appointed by the Provost. 6.2.2 Charter and Rules

1. The Radiation Safety Committee shall meet at least annually c

and more frequently as circumstances warrant, consistent with effective monitoring of facility activities. Written records of its meeting shall be kept.

2. The Radiation Safety Committee may appoint one or more qualified individuals to perform the audit function.

6.2.3,- Review Function .The following items shall be reviewed: 1. Proposed changos in the Technical Specifications or the operating License. 2. Reports of f external- (NRC, state and local authorities, ( and' insurers) inspectors and' auditors. 3. Revisions to procedures affecting facility and fuel storage that<have a-radiological significance. 6-4 Amendment No. 12 t F .u

6.2.4 Audit Function The Audit Function shall include selective (but comprehensive) examination of operating records, logs and other documents. The audit-will be performed biennially by an outside individual or group familiar with the research reactor operations. They shall submit a report to the Acting Reactor Administrator and the Radiation Safety Committee. The following items shall be audited: 1. Conformance to Technical Specifications and applicable license conditions. 2. The results of all actions taken to correct those deficiencies that may occur in the reactor facility oquipment, systems, structures, or methods of operation that affect radiation safety. 3. Emergency and Physical Security Plans and implementing procedures. 6.2.5 Changes to the Decommissioning Plan The Radiation Safety Committee shall have the authority to approve changes to the Decommissioning Plan requested by the Acting Reactor Administrator when necessary to respond to unanticipated conditions. Such changes may only be approved ift 1. All regulatory requirements will be met and no reduction in safety is involved. 2. The changes are protective of health and safety of-workers and the public and in accordance with the Radiation Safety Program. 4-y e

i 6.3 P roc edu r e s Written procedures shall be preparmd. reviewed and approved prior to initiating any of the activities listed in t}ds section. The procedure s shall b*e re. viewed by the Reactor Operations Committee 'and approved by the Reactor Administrator. ( 1. Startup, operation, and shutdown of the re' actor. Fuel loading, unl omding and movement within the 2 l r e a ct o r. ~ Ro,utine m'aintenance of major. components o( systems 3, that could have an effect on reactor safety. Surveillance tests and calibrations required by the 4. Technical Specifications or those that may have an effect on reactor safety. Personnel radiation protection consistent with 5. a'pplicable regulations. () 6. Administrative controls for operations and maintenance and for the conduct of irradiations an'd 6se of experiments that could affect reactor safety or core activity. i c al Implementation of the Emergency and Phy 7 Se curity Plans. i I a.I Amendment No. 7 6-7.lo m W&

flev, 4 i i 6 Ext oriments; hvieu and Approval 0,4 Approved laboratoty exercises sin 11 be carried out in accordance uith establisluxi und approved procedure.

1. All new exercices sim11 be reviewed by the Deactor Operations Couwilttee and opproved by the Reactor Mminintrator prior to initiation.

t hall

2. Sub<tontive chmges to previously approvted experimen s s t

Operations Committee and opproved by the Mmittistrator. t ) 9 o s d i G 11

i i 6.5 Reguired Actions - i 6.5.1 Action To Be Taken in the Event of an Occurrence of the Type Identified in 6.6.2-1.a or 6.6.2-1.b. i 1; occurrence shall be reported 'to the Acting Reactor Administrator or a designated alternate and to the-Nuclear Regulatory Commission. All written reports shall l be sent within the prescribed interval to the NRC, Washington, D.C., 20555, Attn Document Control Desk, with a copy to the Regional Administrator,-Region I. 2. Occurrence shall be reviewed by the. Radiation Safety Committee at its next scheduled meeting. 6.6 Reports i l 6.6.1 ~ operating Reports Internal reports are kept a minutes of the annual meetings of the Radiation Safety Committee. A report summarizing facility operations will be prepared 4 annually where the reporting period ends August 31. A copy of this report shall be submitted to the Nuclear Regulatory Commission (NRC) Region. I office'by October 15 of each year, with a copy to. i the Director. Office of Nuclear Reactor Regulations,

NRC, j

Washington, D.C., 20555. The report shall include the followingt I

1. A narrative summary of facility experience.

5-5 Amendment No. 12 l

2. A description ~ of actions taken in accordence with the Decotanissioning Plan.

3. A summarized result of any radiation surveys performed by the-facility personnel, j

4. A summary of exposures received by facility personnel and visitors where such exposures are greater than 25%

i of that allowed or recommended. 6.6.2. Special Reports -1. There shall_be_a special report not later than the following - working. day ' by - telephone and confirmed 'in writing by. telegraph or similar conveyance to the Nuclear Regulator Commission to be followed by a written report that describes the circumstances + of the event within'14' days of any-of the following' a. Release of - radioactivity 'from the site above allowed limits (see 6.5.2). l 6-8 Amendment No. 12 j 1 c, --n, ,e, e, er ,e w, -ma .,v..-.-,, -- m w w,n m -

~. _ ~.. i i b._Any of the following (see 6.5.2):

1. ' Abnormal and significant degradation in reactor fuel, or cladding, or both which could result in i

exceeding prescribed radiation exposure levels t or-personnel or environment, or both.

2. An observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to fuel and source storage.

i 2. A written report within 30 days to the Nuclear Regulatory Commission.concerning the following j

a. Permanent changes in the organization involving the Acting Reactor Administrator or the Radiation i

Safety Officer, r i 6-9 Amendment No. 12 I J J \\

a 6.7 Records 6.7.1 Records to be Retained for a Period of at least Five Years or for the Life of the Component if Less than five Years 1. Normal reactor facility operation (but not including supporting documents such as checklists, log sheets, etc., which shall be maintained for a period of at least one year). 2. Principal maintenance operations. 3. Reportable occurrences. 4. Surveillance activities required by the Technical Specifications. 5. Reactor facility radiation and contamination surveys _where required by applicable regulations. 6. Laboratory exercises performed with the reactor. 7. fuel inventories, receipts, and shipments. 8. Approved changes in operating procedures. Records of meetings and audit reports of the Reactor Operations 9. Committee.

10. Records of scaled @urce leak tests.

11. Records of annual-physical inventory of sealed source material of record.

6.7.2 Records to be Retained for at least One Training Cycle Retraining and requalification of licensed operators:. Records of the most recent complete cycle shall be maintained at all times the. Individual is employed. -6.7.3' Records to be Retained for-the Lifetime of the Reactor facility Applicable annual. reports, if they contain all of the required information, may be used as records in this section. J1. Gascous-and-liquid radioactive effluents, if any, released to ,the. environs.= 24-On-sit'e environmental monitoring surveys required by the Technical Speci fications.- _ g Amendment No, 10 g .)_-

. 3. Radiation exposure for all personnel monitored. 4. Drawings of the reactor facility. 1 P f ) O 6 - 14 Amendnent 14o.10 \\

--,_-.--,-n.---,.--- O r 9 9 APPENDIX D EMERGENCY PLAN

i I -i i ? t i, l a THE EMERGENCY PLAN FOR THE f r MANHATTAN COLLEGE ZERO POWER REACTOR l ? t 8 Facility Operating License: R-94 I i Ibcket No 50-199 4 4-3 I .i t -4 1 1 .k k. = August 1983 M ' 6 4, i ' { _~

4 TABLE OF CONTENTS Page 1

1. 0 Introduction 6

2. 0 Definitions 12

3. 0 Organization and Responsibilities 17

4. 0 Emergency Classification System 22 l

5.0 Ernergency Action I,evels for Notification of Unused Events 23 6.0 - Emergency Planning Zone 24

7. 0 Emergency Response 27

8. 0 -

Emergency Facilities and Equipment 29

9. 0 Recovery 10.0 Maintaining Emergency Preparedness 30 i

i 1.t

c i.

.t.3> s i .f. u

_ -. - - _. ~. 4. e t: . j IJST OF FIGURES I i Figure No._ h -j { 1.1 Map of Area Surrounding the Leo Engineering Building 2

1. 2 Location of Leo Engineering Building 3

1. 3 Plan of First Floor of the Leo Engineering Building ~

4 t

1. 4 Plan of Second Floor of the Leo Engineering Building 5'

l 2.1 Plan of First Floor of the Leo Engineering Building 7 showing the ZPR Room (Cross Hatched)- - 2.2 Plan of Second Floor of the Leo Engineering Building 8 ~ showing the ZPR Room (Cross Hatched)-

2. 3.

Plan of First Floor of the Leo Engineering Building 9 - howing the MCZPR Facility (Single Hatched) j s 2, 4 - Pir.a of Second Floor of the Leo Engineering Building 10 l l showing the MCEPR Tacility (Single Hatched) 2.5 Plan of Second Floor of the Leo Engineering Building 11 showing Emergency Support Center (Cross Hatched) - 3.1 - MCZPR Normal Operating Orgardsation 13

3. 2 MCZPR Emergency Organisation Chart -

14 -d 7.1 14 cation of Emorgency Organisation Chart 25 1 1 y 8.1 - Emergency Support Center (Shown Cross Hatched) 28 L-3 k-1 3 i. i a,:u..-.....4 +. -. .-.,_..,w,,-.,. y # ...,,,, + -, y ...--a#- _. ~.. -

1

1. 0 INTRODUCTION 1.1 This Emergency Plan applies to the Manhattan Co'.lege Zero Power Reactor (MCZPR). The reactor is owned and operated by the l

Manhattan College Corporation of Bronx, New York,10471. Under Facility Operating License R-94, Docket No. 50-199.

1. 2 The objectives of this plan are to designate responsibility among the reactor personnel and establish guidelines of action in the event of an accident or incident at the reactor that may present undue risk to the health and safety of individuals, or result in damage to the property. The plan also identifies off-site support organizations that may be activated if required.

1. 3 The MCZPR is a U-235 fueled light water moderated open pool type heterogeneous reactor with plate type fuel elements. The reactor tank is 8 ft. high and 10 ft. In (.nete r.

The core consists of 15 full fuel elements and one partial fuel element. Each full element consistr of six fuel plates containing 200 gm of uranium and the partial element contains 25 gm making a total of 3025 gm of uranium. The reactor is licensed to operate at a continuous maximum power of 0.1 watt. Because of the very low power level no recirculating cooling system is provided.

1. 4 The MCZPR is a research reactor. The major functions of the reactor are training of reactor operators and for experimentation as part of Nuclear Engineering courses offered at Manhattan College.

L

1. 5 The reactor is operated whenever needed for training or for class experiments. All experiments performed on the reactor require prior approval of a Reactor Operations Committee. The Committee closely monitors all experiments performed on the reactor. Based on the operating history of the past three years, the reactor was made 7

critical about 34 times a year with each critical operation lasting an j average of 16 minutes. The power levels were most often well below the licensed level of 0.1 watt.

1. 6 The MCZPR is located in the Bronx, New York. It is easily accessib1:

from Interstate Highway 87 and the ' Henry Hudson' Parkway by 4-connecting roads. An area mau 2 s given in Figure 1.1. The reactor 4 is housed in the Leo Engineering Building on Corlear Avenue between 238 Street and 240 Street. Figure 1,2 shows the todation of the Leo J Engineering Building. The reactor facility occupies portions of the first and second floors of the Leo Engineering Building. The floor plans are shown in Figures 1. 3 and 1.4. Access to the facility is either through door D ion the first floor or through D4 on the second floor. L Access door D is kept locked and bolted from inside at all times. 3 6

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PARK LEO ENGINEERING DUtLDING N Og to MAJOR DCth-b . ca. 1. / e i j,, FIGURE 1. 2 LOCATION OF LEO ENGINEERING BUILDING k

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o 115 116 120 121 122 7 \\\\ l ~ I* i 114 ........r- ? -C 124 1 d 113 117 129 ~ t i .) 119 101 118 O - B a__ --i j 4-s 112 101 M .g W P D3 3 s-7/ E

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/ 101 / 106 104 ~ I E< -l we<W31 Il ~1 f '/ i ri f1 [ / "'- 7 4 ob IWL l" 102) l i = Yu jQT A = 103 9 105 ' + :, 102 L M I 10e e B l l t.. . 4 FIGURE 1 3 PLAN OF FIRST FLOOR OF THE LEO ENGINEERING BUILDING ( REACTOR FACILITY Sil0WN SINGLE HATCHED ) 4-g L

i \\ k S- ,e h;; ~J 1 g i &,1= 245 1 231 233 235 237 238 241 242 "l y _u J243,2AA.N. 7...... q' ' ' _ _L # l-b39 } 1320h.32A 246 r 247 I l l I i ,a ~' 232B 234 i I I 229 289-L 32D r s-227 q 236 249 252 ) 22f ,22,5 ? D6 C 224 [ -253 251 ZPR R004 A e \\ RD5' ? a- \\ W1 s 2 22 1 )2 \\b/ M -254 256 7 n 215 ,qq \\ n. \\ h ,<s w 'l 2E 257 i 259 ,18 258 1 f ] ji

f. L a b"a i

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2094 a 1 g-r70 204 g gg U 1 M p m p 211 212 213 201 202 3 j . :., j_ _ i 1 d, _ __ L 0 1-w FIGURE 1.4 [ PLAN OF SECOND FLOOR OF THE LEO ENGINEERIhU BUILDING h - 5

6

2. O Definitions 2.1:

MCZPR MCZPR stands for the Manhattan College Zero Power Reactor - located in the Leo Engineering Building of Manhattan College.

2. 2 ZPR Room or Reactor Room Consists of rooms on the first and second floors in the Leo Engineering Building in which the reactor is built. The area is shown cross hatched in Figures 2. I and 2. 2

?,, 3 MCZPR Facility or Reactor facility Consists of the ZPR room and rooms 107.108 and 109 on the first floor and room 221 on the second floor which are shown single hatched in Figures 2.3 and 2.4.

2. 4 Emergency Support Center Consists of the platform area of room 221.

This is shown in Figure 2. S.

2. 5 Reactor Operations Committee (ROC)

The ROC consists of the Reactor Administrator who acts as the Chairman of the Committee, the Chief Reactor Supervisor, Health Physicist, Radiation Safety Officer and others who might be helpful in the operation of the reactor and appointed to the Correcittee by the. Reactor Administrator.

2. 6 NRC t

Nuclear Regulatory Commission. 1 E h ?;~ - a. 13 1 m I

I I E -7 d ' g, -115 116 120 121 122 = 114 -c 4........,- 124 } W 113 l - y -119 101 ] 118 CJ - 3 1 ) 4-t 112 101 1 A W 03 ~ N g r

• 4 umuusse g

i 101 1 106 104 I i f nr8 'l y 1 l X g b 108 ri r1 [ <[ 107 N j7d 102j j I r-h,_ ' " " = IIS Dif A Tm. !3 ' 103 I uN + .-,l 105 ' 102 l 102 i B I { FIGURE 2,1 j PLAN.0F FIRST FLOOR OF THE LEO ENGINEERING BUILDING l i SHOWING -THE ZPR ROOM ( CROSS HATCHED ) 1 I

2

t <- -G

^' g 3* c k 245 1 1 \\ ,d 233 235, 237 238 241 242 231 u .2A3<ZL4.\\-- '" I29 3 430 232D 332A. l l I ) 'u _a g 246 r 247 i 232B 2'34 2k b L [ 229 / 3320 m m- . ] 248 250 236 N249l 22f 3 j 252 ~ 2a5 t 216 t g 251 ,253 IPR R0a! j X 221 s b wi 24 256 221 ~C mix / D4-215 ]qq r _mg

6 23t 257 259

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• DIE LEO E' GINEERING BUILDING N

~ SHOWING THE ZPR ROOM ( CROSS HATCHED ) - 8 I

i [ .._ [ t I* 115 116 120 121 -122 ,4 '~ 114 l........ r- -- C-- k 117 123 -j"; e ] 113 l 119 118 C' 101 ] .3 4-t 112 101 M .A i r I I D3 f[ i 1 101 g 106 10'; l I 4"11 <E ' X "A t [ 108 It f1 <'[ --~ N 107 / " " (74 102)l i 1 = f#" S I' f81 j m Mr a f 103 105 ' 102 ~ - - - 102 l B l l 4 +! FIGURE 2 3 a A PLAN OF FIRST FLOOR OF THE LEO ENGINEERING BUILDING ~~ SHOWING TE MCZPR FACILITY ( SINGLE HATCHED ). ) l'

s. I

N4 ~ 1 a. z EL_ : i / l 245 F"M E 5 J 233 235 237 238 241 242 1 I' 5 231 ,d m _2.13,24A.N

7..... 3' I

J b9 3 2320 ^ 32A -i O c,' 2g9 { ,f a 232B 234 246 247 M 229 3 m- .l 248 250 N249j 236 ) -22f 252 m 225 f 216 c 224 251 253 3 221 r, g.D5x x \\ ij g;1 \\ M-215 ~ r c1 \\ \\tN' NI 23f. 257 2M 258 1 718 21g g y rgq Fa 217 a , ojo - r-- g .g,.- 1 . in,i L-m

== ann enemu _, j3 35 p;;;g 2094 a -- -l 204 i 3-a--- L_ g9 g - y -- gy

== g n p' 211l.212 213 201 202 u 3 { i L i 3 1 FIGURE 2.4 PIAN OF SECOND FIDOR OF THE LEO ENGINEERING BUILDING ~ SHOWING THE NCZPR FACILITY ( SINGLE HATCHED ) p 3N' yg , nrar-- G m Qh a m + l= 1; i l j-j $ 1 a J 245

a=

l 231 ,_{, 233 235 237 238 241 242 i e' m _2A3.244.s- - s 'l l ~i 1 b9 ?32db32A nb s ~ c,' 2g9 { 232B 234 246 247 h 229 3 ) s-250 248 236 @249] 22 -) j 252 22 216 c 251 .,253 \\T D'S il [ W1 O O. 22 ij L \\ ~221 ;nx D4 215 n r te' l I y 259 i* '18 258 ] 3 J 1' rLa ya i 217 a a 3 co o -- mf ' - 3,.~' enin - sum L===, ,,,,f N I"f"H3 1 3 I5 , hys:d -I 20 m u - N. 204 71 0 yg -g mg re ~ n 211,212 213.. 201 202 3 + t-i -- - t E. i FIGURE 2.5 i PIAN OF SECOND FLOOR OF THE LEO ENGrNEERING BUILDING SHOWING EMERGENCY SUPPORT CENTER ( CROSS HATCIED ) 4

• 11 =

-h 12 63.0 Organization and Responsibilities:

The Manhattan College Zero Power Reactor Emergency Plan is _ c'- designed to provide a means of meeting the additional demands that' H-would be encountered if an emergency situatim arises. To effect - this ' goal an Emergency Organization drawn primarily from the normal operr. ting personnel is identified. One single individualis assigned the responsibility to direct all emergency related activities, i 3,1 Normal Organization Structure ~ ~ Figure 3.1 shows the normal operating organization of the CZPR.- i 3.2-Emergency Organizatim Structure Figure 3.2 shows the Emergency Organization. This organizatimis formed from the normal operating organization so that a smooth transition is possible. 4 7. 3.2.1 Emergency Director The Reactor Administrator will be the Emergency Director. In his i absence, the Chief Reactor Supervisor, Reactor Supervisor on duty i or the Reactor Supervisor to arrive first on the scene will be the Acting Emergency ~ Director, in that order. -y ' k ' The Emergency Director is responsible for taking all action necessary i Basic Function i to manage any reactor related emergency. !i b Primary Responsibilities The Emergency Director-1. - Coordinates and directa activities of the MCZPR Emergency Organization. 2 Classifies and declares an emergency when needed. o. 3. Assures notification of College, local and federal agencies

[

as delineated in the procedures required. The actual notifica- .(-_ tion of. outside agencies will be made, if time allows; only j by the Reactor Administrator. Issuing instructions to the Emergency Organization and L 4. assuring that appropriate action is taken.

5. -

- Insures health physics activities on campus. p L- -6.. = Declares termination of emergency. ] Authorizes re-entry into the1ZPR Room after an emergency.- 7. .g 4 (L . 8. - Authorizes volunteer emergency workers to incur ~* radation exposure in excess of 10CFR20 limits, i n g y i 5 y e r .,v... .+.-. - - + n. -.n.

---

e,-

'i E t Mar. attad College i 'esident e PROVOST ~~~~~~~~~~'l t Dean of Manhattan College Engineerirg Radiation Protection Council I .:t' I~ Reactor g Operations --q committeo I-- - - Reactor l l Administration Reactor Reactor 3 Radiation Health . Physicist Safety Officer' Chief !s Reactor i-Supervisor [1 Reactor Supervisor

e..

I Reactor 'l Operators t.. . r l. i Fipire 3 1 MCZPR DRGANIZATION CHART -a . 13 - y eg

u. n o

'i

f

[ e t .x, ' Manhattan College Pre sident - e, Provost Dean of Eme rgency, Enginee ring - News Center o 1 4 Off-Site Eme rgency. ___I Suppo rt - Director - I' Organizations 1 ) Health Radiation Physicist Safety 7 Office r 5 Emergency

{:

- Operations .. l. Supervisor i. Emergency Operators i . i:. 9 lg. I k. 6 3 Figure 3. 2 l O'- MCZPR Emergency Organization Chart .gi. .L.. 4 'c

7 +_ - ~, -..,. ~. ~. J . 15 1 ? 9.: Prepares _ news release s to th'e public when requested by? the Dean of Engineering. 110..

Reports to the Dean of Engineering.

3. 2. 2 5 [mergency Ope rations Supervisor -

The Chief Reactor Supervisor will b'e the' Emergency Operations:- Supe rvisor. In his absence, the Emergency Director will appoint = i . one of the reactor supervisors to act as the Emergency Operations Supe rvisor. , Basic Furctions i - The Emergency Operations Supervisor is responsible. for_ the-implementation of activities connected with safe shutdown and; rnaintaining of conditions that would minimize the effect on health and safety of the public. - The' Emergency Operations Superv%or-1. Reports to the Emergency Director t>_ 2 ' Implements reactor emergency procedures ' ~ 3. Supervises reactor _. emergency personnel in work at the reactor connected with the emergency 4. Supervises recovery operations .iL 3.2.3 Emergency Operators, Emergency Operators v.re drawn from the Reactor Operating personnel. 3, Basic Function The basic function of the Emergency Operators is to assist the Emergency Operations Supervisor in his activities connected with 't an emergency. They report to the Emergency Operations Supervisor.- i

3. 2.4 Radiation Safety Officer

y

' The Reactor Radiation Safety Officer will continue to function as the. m Radiation Safety Officer during an emergency. g Basic Function - The baeic function of the' Radiation Safety Officer during an emergency ~ p - is t-advise the Emergency Director on matters of radiation' safety il-during an emergency. He reports to the Emergency Director. -

3. 2. Si L Health Physicist

= The MCZPR Health Physicist will continue to function as the _ health physicist during an emergency. 1 - ;t: = i_ -.. . x -u -i.j- =

16 Basic Function 1

F The basic function of the Health Physicist during'an emergency

_ is to implement procedures that would minimiae *he radiological effects on the health and safety of the. personnt 1 involved in an emergency work and that of the public. The Health Physicist 1. Reports to the Emergency Director I 2 Develops plan-and procedures for checking for contamination 3.2.6 Eme rgency News Cente_ r,, The College Relations office of Manhattan College will serve as .l the Emergency News Center. Any news pertaining to an emergency will come to the Emergency News Center for the Dean of Engineering or his designate. 3.3 - Off-Campus Service Support' ' To assist Manhattan College Emergency Organization, outside 3 j agenciew may be called to actionby the Emergency Director.

3. 3.1 Medical Assistance l

St. Joseph's Medical Center, Yonkers, New York has medical Il- - facilities needed to render immediate treatment to contaminated and non-contaminated injured personnel. Appendix 3A is a copy of the letter of understanding between Manhattan College and St. Joseph's Medical Center. 3.3.2 Ambulance Service g; I.. St. Joseph's Medical Center will provide ambulance service = when needed.

3. 3. 3 Police

- The-Manhattan College Security Department will provide routine security for the reactor. If additional security is needed, the Iblice Department of the City of New York will provide the needed extra L. . security. i 3 3.4. Fire Assistance 4 The Fire Department of the City of New York maybe called for ' assistance if the need arises. -3.3,5 Nuclear Regulatory Commission ' 'If the need arises assistance may be sought from the Nuclear - Regulatory Commission, Region I office in King of Prussia, Pa.

APPENDIX 3A-' PAGE1 45 JOsg - osehhys 6s;m,1. g St. .t" y /

o. =

y. V R+ 2: Medical Centez % $o 127 Souh Doodway, Ycdm New Ycrk 10701 i June 13, 1983 Dr. Ronald Kane Director of Mechanical Engineering tianhattan College Manhattan College Parkway Riverdale, N.Y. 10471

Dear Dr. Kane,

This letter is to confirm St. Joseph's Medical Center's ability to handle potential radiation hazards from your college due to its reactors. Currently our department along with the hospital's Radiation Safety Committee is updating and modifying both the internal ond external Radiation Safety policies and nrocedures. Once this process has been completed, I will forward a ecpy to your office for your records. Again, St. Joseph's has procedores and protocols designed to handle most Radiation Emergencies 24 hours per day, seven days per week. Our Nuclear f** *

• cine and selected Radiologic technical personnel are trained in F.

.ation Emergencies. The Emergency Room personnel also have procedures to follow in case an accident occurs during evening end weekend hours. In the meantime, I have supplied you some information that may be beneficial in case an emergency occurs (attached). If af ter reviewing this letter you have additional questions or concerns, please call me. A copy of our final report will be sent to you when j completed. t Since, rely, [h;. hd.: m j Robert Kleinbauer 6 Administrator-Radiology Services St. Joseph's Medical Center BK/sr CC: Dr. Puljic Dr. Marsden j Mr. Hyde b Radiation Safety File BK File Hospitol (914) 9656700 Nursing Home (914) 9654400

f n

APPENDIX 3A - PAGE 2 ATTACHMENTI t

t NUCLEAR MEDICINEDEPARTMENT: HOURS OF OPERATION: MONDAY - FRIDAY 7:30 AM-5:30PM EMERGENCY COVERAGE: CALL ADMINISTRA*IOR ON CALL OR RADIOLOGIST ON CALL ' PHONE NUMBERS: 914-378-7000 EXT. 683-5,687-8 PERSONNEL: MR. GENE TOLENTINO. NUCLEAR MED. TECHNICIAN MR. WILLIAM *10 BIN - ADMINISTRA*IOR MR. !iMIlJAN PULJIC - DIRECTOR OF RADIOIAGY IN CASE NUCLEARWMICINE DEPARTMENT IS CLOSED, CALL EMERGENCY ROOM (EXT. 471), EXPLAIN SITUATION, LEAVE NAME AND PHONE NUMBER; THEY WILL CONTACI' ALI. APPROPRIATE STAFF. i \\ - i i s( y

e c.

- 17 4, 0 - Emergency Classification System 4.1 Conceptually, all possible emergencies at any research and test reactor have been classified into four groups,-_ Appendix I of the - r Standard Review Plan [1] (. repeated on the next few pages) lists them as '1. Notification of Unusual Events 2 Alert 3. Site Area Emergency 4 General Emergency For the MCZPR licensed at O. I watt and with no recirculating cooling requirements, only the first class of emergency, viz; Notification of Unusual Event is hypothesized as the most severe credible i accident. +

4. 2 Notification of Unusual Events The emergency class " Notification of Unusual Evento". hypothesized 2

to exist at MCZPRif events are in progress or have occurred which indicate potential degradation of the safety of the reacter. Specific action levels are detailed in Section 5.0, Emergency Action Levels 1 o Notification of Unusual Events. iL- [1]- E.F. Bates, B. K. Grimes and S. L. Ramos Standard Review Plan for the Review and Evaluation of Emergency P1rns for-Research and Test Rea'etors _ [' > U. S. Nuclear Regulatory Commission NUREG-0849, May 1982. 6~

i. -

1 er +

18 APPENDIX 1 EMERGENCY CLASSES AND EXAMPLE EMERGENCY ACTION LEVELS Emergency Class Example Action Levels Notification of 1 Actual or projected radiological effluents at the Unusual Events site boundary exceeding 10 MPC for unrestricted areas when averaged over 24 hours or 15 mrem whol body accumulated in 24 hours. .l_/ 2 Report or observation of severe natural-phenomenon that are imminent or existing such as: (1) earthquakes that could adv ersely affect the reactor safety systems, (2) high or low natural water sources that could adversely affect reactor safety systems and: (3) tornado or hurricane winds that could strike the facility. 3. Threats to or breaches of security. 4. Fuel damage accident that could release radio-1 nuclides to confinement or containment. 5. Fire within the facility lasting more than 10 minutes. 9 f se It should be noted that the radiation dose levels of the emergency action !? Icvels established for the various emergency classes are slightly different from those specified for power reactors. However, in the judgment of the 4-NRC staff, the radiation dose levels specified are adequate for the credible { accidents associated with the operation of research and :ast reactors, and the specified action levels provide reasonable assuranc,e that protective measures associated with the action levels specified can and will be H taken, provided appropriate emphasis is also given to developing emergency action levels that relate directly to facility pararreters (c. g., pool water levels and area radiation monitors). L* 4

-....m.__., _ -. - -~ e i 3 i 19 - l Emergency Clay _ Example Action Levels-ij - f Alert - 1.- Actual or projected radiological effluents at the-- L j site boundary exceeding 50.MPC for unrestricted are: F when averaged over 24 hours or 75 mrem whole. q body accumulated in 24 hours._ 1,,/ , ; i :-- 2 Radiation levels ~ at the site boundary of 20 mrem /hr = for-1 hour whole body or five times this level to. the thyroid. _l,_/ - 3. Abnormal loss of water used for shielding =or. coolant to irradiated reactor fuel at a rate which. either exhausts the initial backup system capacity. or exceeds makeup capacity. 4 Loss or radioactive material control that causes 1 radiation dose rates or mirborne radionuclides to. -L incresse ambient exposure levels by a factor of 1: 1000 throughout the reactor building. F 5 Fire that may affect any reactor safety system (s). 1 6 Other inuninent'or existing hazards such as (1) misa'les impacting on the reactor facility, I (2) explosion that affects facility operation, and (3) uncontrolled release of toxic orflammable gases into the facility environs, - 7 Radiation dose rates in the reactor building-U requiring evacuation of all personnel (e. g., 100 mrem /hr for one hour throughout the { reactor building. 1 -b t If It should be noted that the radiation dose levels of the emergency action . levels established for the various emergency classes are slightly different from those specified for power reactors. However, in the judgment of the I,:. NRC staff, the radiation dose levels specified are adequate for the credible. - L accidents associated with the operation of research and test reactors,: and ~ the specified action levels provide. reasonable assurance that protective g, -measures associated with the action levels specified can and will be . taken,L provided appropriate emphasis is 'also given to developing emergency - action levels that relate directly to facility parameters (e. g., pool-I l [ _. - water-levels and area radiation monitors). w: 1e F i n A va ,.ier, f-r s-yu O-_.,.w ws... - <. - -.. + ' E ..-v. v y-- w w -,w-w 4 -..e

-20 Emergency Class Example Action Levels - Site Area 1. ' Actual or' projected radiological effluents at the. - Eme rgency site boundary exceeding 250 MPC for unrestricted t areas when averaged over 24 hours or 375 mrem accumulated in 24 hours. 1.] 2. Actual or projected radiation levels at the site boundary of 100 mrem /hr for I hour whole body -./ I or five times this level to the thyroid. 3. Abnormal continuing loss of reactor coolant, to fuel requiring coolant, at a rate greater than the capacity of the backup system (s). 4. Imminent loss of physical control of the reactor, 5. Several natural events being experienced. Examples include: I a) earthquake that is causing observable damage i to the reactor safety equipment within the building. b) high or low na'. ural water levels that are affecting the operability of any reactor safety ] system; and c) ~ tornado or hurricane winds that are damaging i the reactor structure. g.. 9 i l/ It 'should be noted that tb-radiation dose levels of the emergency action levels established for the various emergency classes are slightly different from those specified for power reactors. However,in the judgment of the r L, NRC staff, the radiation dose' levels specified are adequate for the credible accidents associated with the operation of research and test reactors, and the specified action levels provide reasonable assurance that protective e measures associated with the action levels specified can and will be L taken, provided appropriate emphasis is also given to developing emergency action levels that relate directly to facility parameters (e, g., pool water levels and area radiation monitors).

p

...~ t - 21 } Emergency Class,- Example - Action Levels. General: 1. Sustained actual _or projected ra'diation ~ m. Emergency Zl-- levels at the site boundary of 500 mrem /hr.

2. --

. Actuat or projected doses radiation levels at the site boundary in the exposure pathway of l I rem whole body or S. rem thyroid.-- -3. Ioss of reactor coolant that could lead j to fuel melt. 4. Loss of physical. control of the. reactor building or-reactor control room and areas housing 1

• ~

vital equipment. j' 5. Events that have caused or will cause massive _ facility or_ reactor system damage that could

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lead to fuel melt. ~ -g 1 o v- < y 1 I 4 4 3 - 2/ --- Generally.not specified for facilities with authorized power levels less - than or equal to 2.MW thermal and determined on a case by case basis i=- . above the-level.1 jU -L L. ,g a =

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. 22 -

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5. 0.-

Emergency Action Levels for Notification of Unusual Events: - 1. . Indication of fuel damage by increased concentr'*lon of ' radionuclides in the reactor wateri-l ~2. Loss of Confinement integrity. 3. Threats to or breaches of security e 4.- Fire within the facility lasting more than 10 minutes j 5. Report or observation of severe natural phenomenon that are imminent or are existing such as, a) ea rthquake b) hurricane - I c) flood ? _j 6. Other hazards or events at the facility such.as:- 4 a) aircraft crash N b) explosion c) release of toxic or flammable gas l 7. ]njury to personnel (contaminated or not) that requires - ~ 1 - transportation to an off-campus medical facility ~* It is recognized that the above items have very low probability + of occurrence at the MCZPR facility. 9' S 1 2 h4. il v q. l T 4 - 1 + I_- 1

s N m 23' -x 6; 0 -1 Emergency Planning Zone ~ .. No radiological emergency that could result in off-site plume ~ - exposures exceeding I rem whole _ body _or 5 rem thyroid is i plausible at MCZPR and hence no Emergency Planning Zone is identified for MCZPR. v i i d t y l g. 1 ' .ij 4 .w e et- {.

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-~ _.- .m _ _. _. _.. _ ~ _ s 24 - 7.04 - Emergency Response Emergency classes of Alert, Site Area Emergency and Oeneral-Eme'rgency are not postulated to occur at MCZPR.- Hence,l the emergency response is given only for the emergency class,- c Notification of Unusual Events; < j 7.1 Activation of Emergency Organization-The Emergency Organization will be activated by the following steps: L 1. If and when a MCZPR staff member becomes aware of or is informed of the possible existence of an emergency, he notifies. the Reactor Administrator, the Chief Reactor Supervisor or a Reactor Supervisor, whoever he can reach in that order.

2. - The first person who is entitled to act as the Emergency Director to reach the-Reactor Facility verifies the existence of an emergency, declares an emergency and assumes the role of the Emergency 4

Director, h

32 A Reactor Supervisor who assumes the role of the Emergency Director will relinquish that role to the Chief Reactor Supervisor when the latter reaches the facility. The Chief Reactor Supervisor .l will relinquish the role of the Emergency Director when the Reactor Administrator arrives at the facility. 4. The Emergency Organization is activated by_ the Emergency '[p Director. The call-out roster of the members of the Emergency L Organization with their telephone numbers (both home and office) shall be posted at the Control Console of the reactor and at the t. Emergency Support Center. These locations are shown in Figure 7.1. 1 The roster will also contain telephone numbers of the off site agencies such as NRC, ambulance, hospital, police and fire .T - department that may be activated if necessary, b . Telephones are provided at the Reactor Control Console and at the Emergency Support Center. Telephones are also available in faculty. and department offices and in the Dean's. office. '~ s

17. 2-Assessment Action

{ The reactor operations staff are provided with film badges. Extra badges are also available. These may be used to assess radiation idoses, if any,~ to personnel during an emargency. ~f ' ~ y -t f I'

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== 0 V l l 201 202 u 211 212 213 L i i I L ., j _ O CONTROL CONSOLE M EMERGENCY SUPPORT CENTER FIGURE 7 1 2. LOCATION OF EMERGENCY ORGANIZATION CHART I L

~, - 26 s Calibrated portable radiation meters are available at the reactor ~ facility.- An assessment of radiation levels may be made using - thece instruments.: If deemed necessary, the health physicist will take wipes and air ' samples and assess the extent of the contamina-tion, if any. 7.- 3 Notification " Notification of an Unusual Event" shall be made no later than the next working day to NRC, Region 1, King Of Prussia, Pa. by the Reactor Administrator. If this cannot be accomplished by the Reactor Administrator in the allotted time due his absence, then the Emergency Director who acts in that capacity on behalf of the Reactor Administrator will accomplish the notification process. 7.4 Leaving the Facility Before the Termination Of An Emergency If the Emergency Director has te leave the facility for any reason, he may do so only after appointing a qualified substitute to act as the Emergency Director.

7. 5 -

Termination of Emergency When appropriate, the Emergency Director shall declare the termination of emergency.

7. 6 Emergency Log An Emergency Log will be maintained by the Emergency Dit ector.

The log should contain the time date of the declaration of every emergency, the name of the Emergency Director, action taken during an emergency, time and date of the declaration of the termination of -l the emergency. The Emergency Log should be kept at the Emergency Support Center, k, V 1 i, ' (;- t is. .)

~. I =s. 27

8. 0 :

Emergency Facilities and Equipment 8,1 Emerge.ncy Support Center ~ The platform in Room 221 (shown double hatched in Figure 8.1) will serve.as the Emergency Support Center. 8.,2 : Em1 y Equipment ~ Portable Radiation Survey meters are available in the ZPR' room.

8. 3 First Aid Facilities First ala supplies are available in cabinets at the Emergency Support Center.

8, 4 Communications Equipment Telephones are provided at the Reactor Control Console and at the ~ Emergency Support Center. - Additional phones are availabic in the offices of the Dean of Engineering and faculty and department offices. l

8. 5 Decontamination Equipment Decontamination equipment is provided at the Emergency Support C ente r.

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8. 6 ~

Handling of Injured and/or Contaminated Personnel Arrangements have been made with a medical center (Appendix 3A) for the handling of injured and/or contaminated personnel. ~ 6 s -r -k. ~. 1. 1 3 x" -' nt $; 4.. + , I _.

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==y ~ i M g,,,7. 209p-g 35 a m s-L 2'~S 204 l up .gg ? dis 3 U ) l p 211 212 213 . 201 202 u . :., f _ -8 I t_ i !L FIGURE 8.1 i i E!ERdENCY SUPPORT CENTER ( SHO'dN CROSS HATCHED ) l!u.

a I .[ 'l -- 9, 0 : Recovery i9. - 1 Recovery Manager The Chief Reactor Supervisor, or~ in his absence, c Reactor. Supervisor' will act as the Recovery Manager, The Recovery Manager will: 4 1. See that the ' facility is brought back to normal for the-- normal operation of the reactor

2..

Perform the normal checkout procedures of the rets cto r. 3. Enter in the Reactor Operations Log book that the reactor has been recovered after the emergency and that the reactor is ready for normal operation. I __f. - to - 4. ,9 9 ? s 4 jy ..h _ J... ' \\: + .-i 3

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\\ l 30 i 10.0 $8,ntaining Emergency Preparedness 10.1 Annual Review-These emergency plans shall be reviewed by the Reactor Operations Cornmittee at least once a year. l 10.2 The Emergency Organization chart and the call out roster shall be corrected whenever necessary and the updated charts 4 should be posted and distributed as needed. 10.3 Imple;nenting procedures affected by any emergency plan changcs shs11 be ravised, approved and distributed to authorised recipients within30 days after the revised plans have been issued. N 1 ha i Q s 4 4 1 g i 1 6 + 4 1 p' I} j j 1 1 l ? .. -}}