ML20210E941
| ML20210E941 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 07/22/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210E929 | List: |
| References | |
| NUDOCS 9907290073 | |
| Download: ML20210E941 (9) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 2006&4001 4
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.14 TO FACILITY OPERATING LICENSE NO. R-97 GEORGIA INSTITUTE OF TECHNOLOGY DOCKET NO. 50-160 ;
1.0 INTRODUCTION
l By letter dated July 1,1998, as amended on February 8, and May 28,1999, the Georgia Institute of Technology (GIT or the licensee) submitted a request for approval of its decommissioning plan (DP), authorization to dismantle and dispose of component parts of the Georgia Tech Research Reactor (GTRh). Decommissioning, as described in the plan, will consist of transferring licensed radioactive equipment and material from the site, and decontamination of the facility to meet unrestricted release criteria (this is called the DECON option). With the DP, the licensee submitted a radiological characterization report (Books 1,2, and 3, dated May 1998), in addition, the DP describes the methods and controls for the final radiological survey which will be performed by the licensee to verify that the release of the decommissioned areas and structures for unrestricted use is acceptable.
The heavy-water moderated, cooled, and reflected GTRR was licensed and first operated in 1964. The 5-megawatt thermal reactor was shut down on November 17,1995. This shutdown was in preparation to remove the high-enriched uranium fuel. All fuel was removed by the end of February 1996, to allow conversion to low-enriched uranium fuel and to be defueled during the Olympic Games in the summer of 1996. No new GTRR fuel has been received. By letter dated July 1,1997, GlT informed the NRC that the GTRR would be permanently shut down. The licensee applied for a possession only status on August 7,1997. By License Amendment No.12 issued on April 2,1998, the NRC discontinued the authority to operate and authorized possession of the residual radioactive materials. -
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A " Notice and Solicitation of Comments Pursuant to 10 CFR 20.1405 and 10 CFR 50.82(b)(5) Concerning Proposed Action to Decommission Georgie Institute of Technology Georgia Tech Research Reactor" was published in the FEDERAL REGISTER on February 1,1999, (64 FR 4902). It was also published in the Atlanta Journal-Constitution on February 14,1999, and in the Georgia Technique on February 12,1999. Comments were received from an individual and from the Georgians Against Nuclear Energy. The NRC staff has considered and responded to these comments under separate cover. The responses have been sent to everyone who will receive this safety evaluation.
2.0 LVALUATION The NRC staff has reviewed the licensee's proposed actions to decontaminate, dismantle and dispose of component parts of the GTRR and to perform a final radiological surm which will permit release of the decommissioned areas for unrestricted use and termination of the Facility Operating (Possession Only) License No. R-97. The NRC staff's review includes consideration of (a) management responsibilities and commitments to continue following applicable regulations, regulatory guides, standards and personnel protection plans, including procedures, (b) use of appropriate equipment and instrumentation, radiation survey methods, training, personnel dosimetry, radioactive waste disposal, and (c) the final radiological survey of the facility.
In July 1997, the Commission promulgated Subpart E to Part 20, in which it set forth criteria for release of facilities. By the terms of the License Termination Rule, a licensee that applied for decommissioning before August 20,1998, and whose plan is authorized by the Commission before August 20,1999, is permitted to use the Site Decommissioning Management Plan criteria in lieu of the new criteria in Subpart E. GlT has applied under 10 CFR 20.1401(b)(3) and NRC's review is, accordingly, pursuant to the criteria in the Site Decommissioning Management Plan including Reg. Guide 1.86.
2.1 Site and Facility Description The GTRR site is on the campus of GlT in a residential and commercial area just north of the center of downtown Atlanta. The GTRR includes a three floor containment building housing the reactor structure, reactor systems, rabbit system, ventilation systems and storage facilities, in addition, the license includes items outside of the containment such as the exhaust stack.
Laboratories, office space and a variety of support facilities are housed in a three story building adjoining the containment building. The support building includes a hot cell, radiochemistry laboratory, decontamination room and storage facilities. This building will be decontaminated as required.
3-2.2 Radiological Status of the Facility A radiological characterization survey of the facility was performed and reported with the DP. Measurements of exposure rates and amounts of fixed and loose contamination were made throughout the facility including the support building adjacent to the containment building. Exposure rates and smear results from all areas were provided. The NRC staff has reviewed all the dose rates and contamination levels identified and concludes that the report is complete.
The decommissioning plan indicates that, during the lifetime of the facility, two small leaks developed, which led to some minor contamination. The first leak was in the reactor coolant level sensing line. The second leak was in the bismuth shield blocks cooling system. This contamination and its cleanup have been discussed in the DP.
The NRC staff concurs with the conclusion that no significant events occurred in the operating history of the facility which would inhibit the acceptable decommissioning of the reactor as proposed. Further, the NRC staff considers the licensee's estimates of the radiological conditions and proposed radiation measurements to be acceptable.
2.3 Decommissioning Alternative As previously stated, the DP notes that decontamination down to the levels required by the NRC for termination of the license (the DECON alternative) was proposed by the licensee because of the desire for unrestricted use of the property and remaining facilities.
The DP presents task analysis, schedule for completion and radiation dose estimates for specific tasks. The DP discusses segmenting and removing radioactive components and materials, contamination control, respiratory protection, local shielding and radioactive waste disposition. Decommissioning, as defined in the DP, willinclude:
(a) area and equipment decontamination; I (b) removal of beam tubes and gates, safety rods and drives, and shield plugs and plates; (c) removal of reactor vessel; (d) removal of retention tanks; (e) removal of biological shield; and (f) packaging, shipping and disposal of irradiated and contaminated material, '
equipment and rubble at a licensed repository.
Decontamination activities will continue until the remaining GTRR facility, including the support building, is suitable for unrestricted use.
The NRC staff concludes that the choice of DECON and associated proposed plans are consistent with the provisions of 10 CFR 50.82(b)(4)(i) for decommissioning without significant delay and are, therefore, acceptable.
4 2.4 GTRR Management, Organization, and Associated Controls During Decommissioning The DP outlines the organizational structure by which dismantling and decontaminating will be managed and implemented, The DP describes in detail the duties and responsibilities of each position.
The overall responsibility for direction of the DP and activities to ensure radiation safety rests with the Director, Neely Nuclear Research Center, of which the GTRR is a part. The Director has the authority and responsibility to suspend any activity involving radiation if he believes the activity is unsafe.
The decommissioning project manager is an employee of the decommissioning contractor (DC) and is responsible for ensuring that all contractual and quality assurance j
requirements are fulfilled. He is also responsible for the implementation of policies and j procedures. He is the main point of contact between the DC and GIT. I The executive engineer is the decommissioning consultant for GlT providing overall ;
contractual direction to the DC. The executive engineer will coordinate the G!T review of )
the DC documents, monitor the contractor's performance, and routinely report progress to GlT. He has the authority to cease operations if the work is not being performed in accordance with approved procedures.
The DC will be an experienced nuclear decontamination and decommissioning firm that will be responsible for the actual field performance of the dismantling and decontamination program. The DC will be responsible for the preparation of detailed work plans, radiological monitoring and control of its own work, safe removal of all radioactive materials, the final radiation survey, and preparation of the final report in support of the license termination application. The DC will implement its own radiological control and quality control programs.
1 The Radiation Safety Officer (RSO) heads the GIT Office of Radiation Safety and l supervises a professional staff providing health physics coverage to the campus and to the decommissioning program. The RSO will review and approve all Radiation Work Permits.
The RSO has the authority and the responsibility to suspend any activity involving the use of radiation if the methods used are determined to be unsafe or contrary to regulations.
The Technical Safety Review Commit' tee will review and approve all plans, policies and ;
procedures to be performed under the GTRR Decommissioning Project.
The DP identifies the overall organizational structure by which the licensee will manage the facility decontamination and dismantlement leading to decommissioning. A decommissioning contractor is an integral part of the organization. An organizational chart identifies the roles of personnel and identifies key positions for both implementation and oversight of the project. The interface between the contractor and the GlT is described in I the DP. The staff judges that the DP provides acceptable organizational structure and control to decontaminate and dismantle the GTRR facility while maintaining due regard to protecting the public, environment and workers from significant radiological risk.
2.5 Radiation Protection Program The DP designates the responsibilities and oversight functions of key positions and committees in the decommissioning organization including the DC, and also commits to the use of written radiation work permits that willinclude ALARA objectives for all relevant tasks.
1 The DP discusses the use of self-contained ventilation systems, including filters to prevent the releaw of airborne radioactive particles either to the rest of the containment building or to tho (nvironment. In this regard, the licensee recognizes that the location of the decommissioning project in the center of a population area requires an environmental monitoring program to ensure that no releases exceeding reguiatory limits will occur during )
the decommissioning.
The estimated collective doses in person-rem for individual deconimissioning tasks are presented in the DP. No releases of airborne radioactivity to the unrestricted environment are expected. Therefore, it is not expected that the public will receive more than minimal radiation exposure related to the reactor m commissioning. The DP indicates that 10 CFR Part 20 requirements for radiological exposures and protection will be met.
Based on the above, the NRC staff concludes that the licensee's plan on radiation protection is acceptable.
2.6 Radioactive Materials and Waste Management l The DP addresses the potential sources of solid, liquid and gaseous radioactive waste and disposal. In eddition, the plan addresses the sources and disposal of mixed wastes (i.e., I radioactive and hazardous waste). Examples of mixed waste are the antimony beryllium neutron source, lead bricks and activated cadmium control rod blades.
Solid waste will consist primarily of reactor components such as tanks, demolished concrete and graphite. Solid waste will be packaged and shipped to a licensed low level radioactive waste disposal facility in accordance with regulatory requirements.
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Liquid waste may result from washing contaminated surfaces, de-watering activitWs, or dust suppression activities. All liquid waste disposal will either be in accordance with 10 CFR 20.2003 or by solidification and treatment as low level radioactive solid waste.
Gaseous waste will probably consist of airborne particulates generated during the demolition process. These particulates will be contained and trapped in HEPA filters that will be disposed of as solid waste in accordance with applicable requirements.
Mixed waste will be packaged and disposed of at an appropriately licensed facility.
The staff considers these aspects of the DP acceptable.
2.7 Training and Qualifications The DP discusses the training of the staff to perform the decontamination and dismantlement, and outlines the tra , ag areas and the performance of training. Training will be conducted to implement the s low as reasonably achievable (ALARA) principle and will be conducted by the decommissioning contractor using personnel qualified in the program content.
The training program for all personnel working on the decommissioning and in the vicinity of the containment building will consist of instructions in radiation safety prior to the commencement of their work activities. There will be three levels of training performed by the DC:
(a) non-radiation worker training; (b) radiation worker training; and (c) supervisor training.
The training will ensure that decommissioning project personnel have sufficient knowledge to perform work activities in accordance with the requirements of the radiation protection program and to accomplish ALARA goals and objectives. The principal objective of the training program is to ensure that personnel understand the responsibilities and the required techniques for safe handling of radioactive materials and for minimizing exposure to radiation.
The training topics willinclude:
(a) General employee training in compliance with 10 CFR 19.12 for all personnel involved with radioactive materials or those in the vicinity of radioactive materials;
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7 (b) Radiation worker training in compliance with 10 CFR Part 20 including personnel monitoring, radiation surveillance and monitoring, controlled areas, ventilation, access control, health physics and administrative controls; .
(c) Respiratory protection in accordance with ANSI Z-88.2, NRC Regulatory Guide 8.15, NUREG-1400 and 29 CFR 1910.134; j (d) Hearing conservation training to meet the requirements of 29 CFR 1910.25; (e) Hazards communication training to meet the requirements of 20 CFR 1910.1200. Radiological and demolition-induced hazards will be reviewed together along with precautionary measures; and i (f) Technical training including mockup simulation and pre-performance briefings to ensure proper equipment usage and achievement of ALARA. Topics will include decontamination, material segmentation and demolition, packaging )
and shipping.
Records of each individual training session will be maintained on the job site.
The staff considers the DP's discussion of personnel training controls to be acceptable.
2.8 Industrial Safety and Hygiene Program The DP discusses various specific plans to control and limit potential non-radiological risks and hazards. Employee training will include an eight hour occupational safety and health OSHA recertification class.
On December 5,1998, the NRC exempted the GTRR facility from having a radiological emergency plan using the guidance of 10 CFR 30.72 Schedule C. However, an onsite emergency plan that is site specific as well as project specific will be prepared by the DC to account for the responsibilities of allindividuals involved in the project during an emergency. Potential accidents, such as spillage or minor contamination spread, may be possible. Such minor accidents are typical of decontamination and decommissioning projects and do not pose a significant radiological concern. The DC's emergency plan will be implemented if such accidents occur to ensure coordination of radiological and industrial safety concerns.
The staff c ;isiders these steps acceptable.
2.9 Accident Analysis Radiological accident analysis consists of worst case analysis performed for two accidents that would contribute dose to a decommissioning worker or an individual at the site boundsry.
4 The first accident analysis (dose to a decommissioning worker) assumes that de-watered sludge from a waste tank with the highest available concentration is contained in a 55 gallon drum. This drum is dropped during transport and a nearby worker inhales a percentage of the oispersed activity. Using conservative assumptions, the licensee calculates that the committed effective dose equivalent (CEDE) to the worker will be 0.0285ALI (Annual Limit on intake), or 143 mrem.
The second accident analysis (dose to an individual at the site boundary) assumes that a fire occurs in the graphite of the biological shield and components. This analysis was done for the current possession only technical specification amendment and submitted to the NRC by GlT letter dated February 4,1998, Appendix 2. This worst case scenario would not result in a release to the offsite environment in excess of applicable 10 CFR Part 20 effluent concentration limits.
Because of the training of allinvolved personnel, the quantity of radioactive material on site and the radiation protection program, the staff expects the probability and consequences of the identified postulated accidents are low. Therefore, the use of these conservative analyses to demonstrate protection from potential accident conditions is acceptable.
2.10 Proposed Final Radiation Survey Plan Section 4 of the DP includes a proposed final radiation survey plan to ensure that the facility meets unrestricted release criteria. The final radiation survey plan includes provisions to develop specific procedures, use appropriate instrumentations and methodologies, and provide documentation.
GIT will submit documentation of the satisfactory completion of its Final Radioactive Survey to the NRC. The NRC will review and evaluate this documentation.
The staff finds this aspect of the plan acceptable.
2.11 Cost Estimato and Funding The DP presents a detailed cost estimate to complete the tasks and a commitment by GlT
, to provide the necessary funds. The staff finds the cost estimate and funding commitment acceptable.
2.12 Technical Specifications A possession only license and associated technical specificar .1 were issued on April 2, 1998. The current technical specifications were developed to include potential decommissioning activities and are, therefore, acceptable.
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9 2.13 Quality Assurance Provisions ,
The licensee has committed to the use of ANS/ ANSI 15.8, " Quality Assurance Requirements for Research Reactors," to develop the Quality Assurance program for decommissioning. This consensus standard provides adequate guidance to ensure that decommissioning activities for the GTRR will be acceptably performed.
2.14 Safeguards and Physical Security The fuel has been shipped off site. Safeguards provisions, therefore, are no longer necessary. Since the fuel and used heavy water have been shipped off site, the physical security task has been reduced to ensuring access control of the facility. The DP describes acceptable access control to prevent inadvertent exposure to workers and members of the public.
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 July 13,1999 (64 FR 37817).
On the basis of the EA and this safety evaluation, the Commission has determined that no environmentalimpact statement is required and that asuance 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 conc!uded that the licensee is adequately cognizant of its continuing responsibilities to protect the health and safety of both workers and the public from undue radiological risk. The DP provides reasonable evidence that the licensee is prepared to dismantle the reactor, and dispose of all significant reactor-related radioactive materials in accordance with applicable regulations and applicable NRC guidance. The staff., therefore, finds the licensee's plans to be acceptab!cs 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.
Principal Contributors: F. DiMeglio, INEEL/LMITCO J. Miller, INEEL/LMITCO M. Mendonca, NRC Date: July 22, 1999