ML20204H051

Safety Evaluation Supporting Amend 12 to License R-94

ML20204H051
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Site:	05000199
Issue date:	03/23/1999
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NUDOCS 9903260380
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.12 TO FACILITY OPERATING LICENSE NO. R-94 MANHATTAN COLLEGE ZERO POWER REACTOR DOCKET NO. 50-199

1.0 INTRODUCTION

By letter dated December 18,1997, as amended on July 21, October 29, November 10, 1998 and January 6,1999, Manhattan College (licensee) submitted a request for approval of its decommissioning plan, authorization to dismantle and dispose of component parts of the Manhattan College Zero Power Reactor (MCZPR), and to terminate Facility Operating License No. R-94 following the completion of decommissioning. A major part of the decommissioning will be the transfer of the reactor fuel and plutonium startup source to DOE, the transfer of a cesium source to an existing radioactive meterials license, and the transfer of low level radioactive waste to a licensed waste dispos il company. The intent of Manhattan College is to remove all radioactive materiale fror i the facility and release the area for unrestricted use.

2.0 EVALUATION 2.1 Introduction The staff has reviewed the licensee's application. Eventually, once fuel has been removed, the licensee wishes to terminate Facility Operating License No. R-94.

The application includes an initial Decommissioning Plan (DP) (Ref.1) which was later amended (Ref. 3) to include additional information based on responses on July 21,1998, (Ref. 3) to the Nuclear Regulation Commission (NRC) questions (Ref. 2) submitted on May 20,1998. Also, additional clarification was provided on October 29, November 10, 1998, and January 6,1999. Because of scheduling requirements of DOE, the reactor fuel and the plutonium-beryllium neutron source may be shipped back to DOE after dismantlement and disposal of the reactor components.

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The staff's review considered the discussion in the amended DP of (a) management responsibilities and commitments to continue following applicable regulations, regulatory guides, standards and personnel protection plans, including procedures; (b) changes in the Technical Specifications to reflect the possession only and decommissioning status of the reactor; (c) use of appropriate equipment, and instrumentation, radiation survey methods, training, personnel dosimetry, and radioactive waste disposal; and (d) the final radiological survey of the facility.

Termination of the facility license requires that the NRC conclude that: (1) the reactor fuel and neutron source have been returned to DOE; (2) the sealed cesium calibration source has been transferred to an authorized user; and (3) sufficient reactor-related radioactive material has been removed to allow release of the property for unrestricted use. The acceptance criteria used by the NRC staff are given in several guidance documents such as Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors," and NUREG-1537 (Chapter 17).

2.2 Site and Facility Description The MCZPR is located on the Manhattan College Campus in the Riverdale section of the New York City borough of the Bronx (Fig.1). It is located on the first and second floors (Figs. 2 and 3) of the Leo Engineering Building,3825 Corlear Avenue, Bronx, New York.

The MCZPR retains NRC license No. R-94, which will allow MCZPR to possess but not operate the reactor. The MCZPR license includes the reactor structure, the reactor instrumentation systems, the rooms on two floors housing the facility, a cesium calibration source and the reactor fuel and neutron source in storace in their shipping containers.

The MCZPR is a heterogeneous pool-type reactor, which is light water moderated and fueled with low enriched uranium (LEU). It has been licensed to operate at a maximum power level of 100 milliwatts. The reactor was shut down and defueled in December 1996.

Manhattan College has developed a detailed DP to address the activities required to terminate the MCZPR license. The activities required for license termination are:

(1) disposal of the moderating water; (2) performance of an interim survey to determine if any material exists which exceeds the release criteria; (3) removal of components with detectable radioactivity; (4) decontamination of floors and walls; (5) transfer of fuel to DOE; (6) transfer of Pu-Be neutron source to DOE; (7) transfer of sealed cesium source to an authorized user: (8) shipment of radioactive waste [if any] for disposal; (9) performance of final radiation survey; and (10) submission of final report to NRC. The DP contains a time schedule for accomplishing these tasks. Following successful completion of these decommissioning activities, Manhattan College plans to request termination of NRC License No. R-94.

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The DP has been prepared based on the regulatory requirements as stated in 10 CFR 50.82(b). The MCZPR has been operated at a low power (100 milliwatts) and there have been no instances of significant contamination during the operating lifetime of the reactor.

Therefore, it is expected that no significant decontamination efforts will be needed during the decommissioning of the reactor.

The staff concurs with the conclusion in the DP that no significant events in the operating history have occurred that would adversely impact the decommissioning of the reactor; therefore, the staff finds this section of the DP adequate.

2.3 Decommissioning Plan Background and MCZPR Management During Decommissioning Decommissioning, as defined in the DP, will be accomplished by removal and disposal of the moderating water, reactor tank and internal, reactor fuel, Pu-Be neutron source and cesium source. In addition to these activities, decontamination, if necessary, of walls and floors will be performed. These activities are required for the ultimate release of the area for unrestricted use.

The DP outlines the organizational structure (Fig. 4) by which decommissioning will be managed and implemented. The direct responsibility for operational oversight of decommissioning activities conducted under the R-94 License lies with the Acting Reactor Administrator. The overall responsibility rests with the Dean of the School of Engineering, who also has rcsponsibility for the functional groups for (a) operation, (b) health physics, (c) quality assurance, and (d) the camous Radiation Safety Committea.

The Radiation Safety Officer (RSO) during the decommissioning will be the Acting Reactor Administrator. Policies and procedures will be reviewed and approved by the Radiation Safety Committee before implementation. The health physics program in place during operation of the facility will continue through the end of decommissioning and license termination. The RSO has direct access to senior management.

The Reactor Operations Committee has been replaced by the campus Radiation Safety Committee. This change reflects the change from an operating status to a possession and storage status for the radioactive material on site at the MCZPR. Policies and procedures l

for decommissioning will be reviewed and approved by the Radiation Safety Committee before implementation in addition, the Radiation Safety Committee will review and j

approve changes to the DP that do not require prior NRC approval (10 CFR 50.59).

The staff considers the discussions and connitments in the DP appropriate and acceptable based in pM a the fact that, except for the reactor fuel, there has been little radioactivity and contamination produced by the operation of the zero power reactor. The only other radioactivity is in the sealed sources.

l Figure 4 Organizational Structure MCZPR Decommissioning i

MAN *rL;TTAN COLLEGE CORPORATION l

E'ARD OF TRUSTEES f

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Chairman Level 1 FRESIDENT OF THE COLLEGE Bro. Thomas Scanlon, F.S.C.,

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DEAN OF THE SCHCOL OF ENGINEERING Level 2 HEALTH PHYSICIST Larry Luckett, C.H.P.

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Catherine-C. Stanton, M.S.

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f 8-2.4 - Current Radiological Status of the Facility The MCZPR was converted to LEU fuelin February 1991. Extended repairs and tank remediation took place in July 1992. Radiation measurements performed during these operations indicate that the tank and all internal structures cause area radiation levels less than 5 microR/hr above background at one meter from the surface. Background radiation levels have been measured to be 10-12 microR/hr gamma and 0.0-0.02 microR/hr beta.

The high enriched uranium (HEU) fuel, which had generated about 8.8 w-br of energy, has already been returned to DOE. The LEU fuel, which is presently stored in its original shipping containers, has generated about 0.8 w-br of energy.

The moderating water is well below the limits of 10 CFR Part 20 for discharge to the sanitary sewer.

Figure 5 presents the measured radiation levels in the storage area.

Figure 6 presents the measured radiation levels on the second floor, which includes the reactor tank. These measured levels are with the fuel and source present along with some radioactive non-reactor metal rods.

The staff has reviewed all the dose rates identified and concludes that the information in the DP is complete. Therefore, the staff considers the licensee's estimates of the radiolocical conditions to be reasonable and the planning for additional radiation measurements described in the DP to be acceptable.

2.5 Decommissioning Alternative The DP states that it has chosen the DECON decommissioning alternative which involves decontamination of building surf aces down to levels required for termination of the license, transfer of solid waste to a licensed f acility, return of fuel and source to DOE and transfer of a cesium source to an authorized recipient.

2.6 Decommissioning Organization and Responsibility The DP identities the overall organizational structure by which the licensee will manage the facility dismantlement leading to decommissioning. An organizational chart (Fig. 4) identifies the roles of personnel and identifies key positions for both implementation and oversight of the project.

The staff concludes that the licensee is adequately aware that experienced and highly competent staff are required to dismantle the reactor while maintaining due regard for protecting the public, environment, and workers from significant radiological risk.

Accordingly, the staff considers the licensee's plan acceptable in this respect.

l Figure 5 Measured Radiation Levels in Storage Area e

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2.7 Regulations, Regulatory Guide and Standards The licensee acknowledges respcnsibility for both Manhattan College's and contractors' compliance with all applicable regulations. Section 2.7 of the DP lists the relevant federal, state, and local regulations, regulatory guides and standards associated with research reactor dismantling, safety, radiological and environmental health, and industrial hygiene.

The plan states the licensee's intention to fo; low these and any other applicable regulations.

Accordingiy, the staff judges the licensee's awareness of Manhattan College's responsibilities in this area to be acceptable.

2.8 Training and Qualifications The DP discusses the need to utilize trained individuals during the dismantlement process (Section 2.5 of the DP). However, Manhattan College concludes that the actions taken during dismantlement are similar to those already used during conversion to LEU'and tank remediation. Manhattan College states that the decommissioning staff has acquired experience, through prior operating experience, academic training and job experience in areas such as knowledge of radiation and its biological effects, monitoring and instrumentation, regulatory and site limits on radiation exposure, and ALARA measures.

Manhattan College plans no new training for personnel who previously participated in the LEU conversion and tank remediation. The reactor RSO will provide basic radiatisn protection and general safety instruction to any decommissioning staff who need it, using axisting training materials and procedures.

Contractor assistance may be required in the area of solid waste disposal. If this becomes necessary, contractor selection will be based on the contractor's experience with similar tasks and appropriate training will be provided.

The stati considers the discusr;on of personnel training and qualifications to be acceptable.

2.9 Radiation Protection Program The DP discusses the licensee's radiation protectior, program. It is clear to the staff that both industrial and radiological health and safety are considered by the licensee to be top priority for the entire dismantling and decommissioning project. The DP de:ignates direct responsibilities and oversight functions of key positions in the decommissioning organizaticn, and also commits that all tasks will be performed using written procedures that have considered ALARA objectives. No release of airborne radioactivity to the l

unrestricted environment is expected. Therefore, the public will not receive any radiation l

exposure related to the reactor dismantlement.

The staff considers that the licensee's plan places adequate emphasis on control of radiation exposures, and is acceptable.

2.10 Industrial Safety and Hygiene Program The DP discusses (DP Section 3.2 A) various aspects of industrial safety and hygiene to control and limit potential non-radiological risks and hazards. The discussion is based on Manhattan College's general safety procedures.

The staff considers this approach acceptable.

2.11 Cost Estimate and Funding The DP presents a cost estimate to complete the tasks and commitment by Manhattan College to provide the necessary funds. It is expected that the funds will continue to be made available.

The staff flnds the cost estimate and the funding commitment acceptable.

2.12 Dismantling and Decontaminating Tasks, Schedules and Expected Doses The DP presents task analysis, schedule for completion (DP-Section 2.3.2), and radiation dose estimates for the decommissioning project. The DP discusses segmenting and removing radioactive components and materials, contamination control, respiratory protection and radioactive waste disposal. The radiation doses expected from equipment and the doses expected for individuals (DP-Section 3.1.3 and Section 8.2) are projected.

The staff considers the discussion in the DP of tasks, schedules and expected doses acceptable. The estimated doses are based on the prior measurement of the licensee during ::onversion to LEU and tank refurbishment and on calculations. From an audit of the doses estimates, the staff agrees thet the dose estimates are reasonable.

2.13 Safeguards and Physical Security The reactor fuel and startup source are of low strategic significance and are stored as authorized within a Controlled Access Area (CAA). The licens - Sas committed to maintain this CAA until such time as the fue,1 can be transferred to DOE (DP, page 25).

The staff has reviewed the physical security plan and has found it to be acceptable.

2.14 Radiological Accident Analysis The licensee has addressed the likehood and consequences of accidents occurring during or after the decommissioning process resulting from human error, eouipment malfunction, or external natural phenomena. Because of the low radiation levels of not only the structures to be riecommissioned but also of the fuel, a radiological accident with serious consequences is not possible.

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t 13-The licensee has analyzed an accident that consists of dropping a fuel element during its transfer to a shipping container. Assuming the maximum drop possible, the licensee concludes that no r'.~magt, that would result in radiation exposure of the public would occur.

Once the fuel elements are in the containers, the elements are protected from damage.

Metal to metal corrosion is prevented by the addition of an inner cardboard sleeve.

While awaiting shipment, the fuel will be stored in an area that has a sprinkler system, a non-water fire extinguisher, and a fire alarm, which will be periodically tested. Because of this equipment, the consequences of a fire will be negligible.

Because of the training of allinvolved personnel, the very low quantity of radioactive material on site, and the radiation protection program, the postulated accidents are expected by the staff to be highly improbable and the consequences small.

2.15 Radioactive Materials and Waste Management The DP addresses the potential sources of solid and liquid radioactive wastes and disposal.

Solid waste consists of the reactor tank and its internal components mentioned previously. Some particulate radioactive materials may be generated if the disassembly requires sawing, grinding, or similar activities. If necessary, these items will be packaged and shipped to a licensed low level radioactive waste disposal facility. The licensee is committed to following all applicable regulations for the disposal of solid waste.

Liquid waste results from the moderator water, from washing contaminated surfaces, and from any dust suppression activities that might be necessary. Allliquid waste disposal will be in accordance with 10 CFR Part 20. Gaseous radioactive waste is not expected.

The staff considers these aspects of the DP acceptable.

2.16 Technical Specifications The licensee submitted a revised set of TSs in the July 21,1998, DP submittal. These TSs are applicable when implemented and will continue to be applicable during decommissioning. The staff finds the revised TSs included in the amendment acceptable.

2.17 Proposed Termination Radiation Survey Plan The Manhattan College oecommissioning activities will result in the removal of all l

radioactive material associated with License No. R-94. The DP provides for a Final I

Radiation Survey.

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- The method for determining that the'MCZPR f acility has met the decommissioning

- abjectives and prercquisites for. license termination will be an independent verification that all radioactive materials, including the fuel and neutron source, have been removed and

- that the Final Radiation Survey is satisfactorily completed. This independent verification will be performed and docurr.ented.

The staff finds this aspect of the plan satisfactory.

3.0 ENVIRONMENTAL CONSIDERATION

The Commission has prepared an Environmental Assessment and Finding of No Significant impact (EA), which was published in the Federal Reaister on March 22,1999, (64 FR 13830.

t On the basis of the EA and this safety evaluation, the Commission has dctermined that no l

environmental impact statement is required and that issuance of this amendment approving decommissioning will have no significant adverse effect on the quality of the human environment.

4.0 CONCLUSION

Based on the staff's review of the licensee's DP, it is concluded that the licensee is adequately cognizant of its continuing responsibilities to protect the health and safety of both werkers and the public from undue radiological risk. The DP provides reasonable evidence that the licensee is prepared to dismantle the reactor, dispose of the fuel, sources, and all significant rea: r-related radioactive materials in accordance with applicable regulations and applicable NRC guidance. The staff, therefore, finds the licensee's plans to be acceptable.

The staff has concluded, based on the considerations above that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed activities; (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or the health and safety of the public.

5.0 REFERENCES

1.

Letter to U.S. Nuclear Regulatory commission from Weldon Jackson, Provost, Manhattan College, dated December 18,1997.

2.

Letter to Weldon Jackson from U.S. Nuclear Regulatory Commission, dated May 20, 1998.

3.

Letter to U.S. Nuclear Regulatory Commission from Weldon Jackson, Provost, Manhattan College, July 21,1998.

Principal Contributors:

F. DiMeglio, INEEL/LMITCO J. Miller, INEEL/LMITCO T. Michaels, NRC Date:

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