ML20214C435

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Requests Decommissioning of AGN-201,License R-127.Fuel Removed & Placed in Safstor Status.Electrical Connections Between Reactor & Control Panel Disconnected & Drive Rod Assemblies & Core Tank Removed,Surveyed & Stored
ML20214C435
Person / Time
Site: 05000538
Issue date: 11/10/1986
From: Oliphant V
MEMPHIS STATE UNIV., MEMPHIS, TN
To: Thomas C
Office of Nuclear Reactor Regulation
Shared Package
ML20214C373 List:
References
NUDOCS 8611210102
Download: ML20214C435 (44)


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             ,            2                MEMPHIS STATE UNIVERSITY E             $

1 MEMPHIS TENNESSEE 38152 me tr Off ce of the Vice President Telephone: 901/454-2991 for ' Advancernent and Continuing Education November 10, 1986 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Mr. C. O. Thomas, Chief Standardization and Special Projects Division of Licensing Gentlemen: Transmitted herewith is application for decommissioning of the AGN-201 held by Memphis State University under Facility Operating License No. R-127, Docket 50-538. This application is submitted pursuant to 10 CFR 50.82(a). As per license R-127 and Amendment No. 5 the fuel has been removed and placed into storage. The reactor has been placed into SAFSTOR status. Electrical connections between the reactor and the control panel have been disconnected. The drive rod assemblies and core tank have been removed, surveyed for evidence of contamination and stored in a locker in the reactor room. Available records show that the AGN-201 was operated at critical at MSU for a total of 963.73 hours since December 1976. This includes a total of 2,408 startups. The inherent design features of this reactor and the low power at which it is operated preclude the buildup of significant amounts of fission products and the fission product inventory is considered to be negligible. Pursuant to 10 CFR 51.22(b) and provisions of Amendment No. 5 to the license R-127, no environmental impact statement or environmental assessment was prepared in connection with this request as eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) has been met. Arrangements have been made with the Institute for Resource Management Inc. (IRM) to take possession of the reactor and all related components except for the fuel. The fuel will be shipped to a secure facility as designated by the U.S. Department of Energy. hojl210102861112 p ADOCK 05000538 PDR An EqualOpportunity University

         ~4 Mr. C. O. Thomas Page two November 10, 1986 The fuel having been removed and MSU having performed comprehensive radiation surveys, Memphis State University is
               -requesting termination of license R-127 and residual reactor hardware and facilities.                                       IRM for the near future intends to maintain a possession only status until a decision is made regarding final disposition of the reactor.

Should you have any questions, please contact Robert R. Riley, Jr., our project manager for the facility, at (901) 454-2256. 1 -. Sincerely,i

  • 1 \ _h 3 1 .h Oliphany[

Van N. Vice President Advancement and Continuing Education

er 1 s

Enclosures:

Amendment No. 5 to MSU Operating License R-127, Docket No. 50-538. (3) Signed Originals 2 (19) Copies cc: Mr. L.B. O' Kelly Mr. R.R. Riley l Dr. P.S. Rushton 5 I i b i

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1.0 PLAN BACEGROUND AND MANAGEMENT 1.1

SUMMARY

DESCRIPTION Description of Reactor Facility The MSU Reactor Facility is in an annex to the ground floor of Building 113 which is situated in the northwest corner of the MSU South Campus. The reactor is in SAFSTOR status (possession-only) per Amendment No. 5 to Facility Operating License No. R-127, Docket No. 50-538 and dated June 17, 1985. As approved in Amendment ho. 5 all fuel discs, including the small fuel discs inside the control rod fuel capsules, have been removed, placed in their original shipping / storage containers, sealed and stored in room 010 of the facilty with area radiation monitors and alarms remaining operational. Less than 200 grams of U-235 is stored in any one container to preclude criticality. The 10 mg radium-beryllium sealed neutron source was removed from the reactor, and is in a shield container inside a shipping container in the reactor room. The aluminum core tank and control rod assemblies were removed from the reactor and are stored with covers and gaskets in place in the reactor room. Also per Amendment No. 5 the reactor configuration for possession-only status is as follows: the thermal column tank, access port liner tubes, glory hole liner tube, control rod cover plate, graphite reflector cylinder, lead shielding, access port filler plugs and neutron detectors with interconnecting instrument cables are installed. The control rod cover plate has a gasket to keep the reactor vessel sealed. The power cable to the reactor console control power circuits are disconnected and removed. The radiation monitor and alarm in the reactor room is operational. The shield tank and thermal column tank water was sampled for ! radioactivity and drained according to approved procedures in l the HSU AGN-201 Maintenance and Storage Manual. The reactor vessel interior including the core tank and fuel capsules were surveyed for residual radioactivity and loose surface contamination; it was then placed in storage. The reactor room and control room are locked at all times when authorized personnel are not present. Description of Operation and Usage The MSU AGN-201 Nuclear Research and Training Reactor was in operation at MSU from December 10, 1976 to March 31, 1985. MSU conducted more than 2,400 startups and accumulated approximately 960 hours of operations at critical during its eight years of active operation. The core has never operated l at steady-state power levels exceeding 0.1 Watt (thermal). l The inherent design features of this reactor and the low power at which it.was operated precludes the buildup of

significant amounts of fission products and the fission product inventory is considered to be negligible (refer to info here). ' Synopsis of DP MSU chose to place its reactor in SAFSTOR status at the time the MSU Center for Nuclear Studies was terminated in December 1984. Training commitments were completed by March, 1985 at which time MSU applied for Amendment No. 5 to their Facility Operating License No. R-127 requesting that the reactor be placed in SAFSTOR status until the university was able to complete the decommissioning and dismantling process. Amendment No. 5 was approved by NRC on June 17, 1985 and the reactor was placed in SAFSTOR status as outlined in Amendment No. 5. MSU did not consider any of the other alternatives to the decommissioning process. The Institute for Resource Management Inc. (IRM) has agreed to purchase the reactor. Therefore, the decommisssioning and dismantling process can be reinitiated and terminated through approval of this i requested decommissioning plan. There will be no costs to Memphis State University to dismantle and decommission this reactor. All costs will be covered by IRM. The major expenses / tasks are 1) purchase of the reactor, 2) consultant fee, 3) removing and replacing a brick wall, 4) removing and replacing a metal wall, i

5) loading crew and equipment, 6) trucks, and 7) drivers.

The estimated cost to IRM is $5,000; no outside funding is i necessary. Memphis State's desired target date for completion is August 1, 1986. . 4 As per Amendment No. 5, surveys of the reactor facility and fuel storage area will be taken periodically. Once permission is obtained to remove the reactor and related equipment and actual removal is completed, the facility will be surveyed by appointed NRC employee /s as well as the Radiation Safety Officer at MSU to determine if the area can be designated for unrestricted use. ! In completing the approved process to place this reactor in SAFSTOR status, the reactor, all reactor components, and all equipment which was in contact with radioactive materials have been surveyed for contamination. All readings were i found to be within acceptable limits (see Amendment I). Consequently, it is anticipated that any exposure received i during dismantling will be well below allowed amounts. 4 1.2 FACILITY OPERATING HISTORY During the eight years of operation of the MSU AGN-201 l

l l reactor the only operational occurrences that necessitated reporting were those of power failures. Reports were filed each time and in accordance with license requirements. None of these power A f ilures resulted in radioactive spills or releases. J There were no occurrences which could impact decommissioning safety during the operating history of this reactor. i 1.3 CURRENT RADIOLOGICAL STATUS OF FACILITY Since the AGN-201 was placed in SAFSTOR status, surveys for , L radiation levels of the various systems, structures, and components have been taken as outlined in the approved Amendment No. 5. To this time all surveys show that the radiation levels do not exceed background levels as set forth by NRC regulations. Additional radiation surveys will taken at the previously determined intervals until the decommissioning process is completed. Results of these surveys will be forwarded to NRC as required. Sources of radiation include the Radium-Beryllium neutron source, reactor fuel (core) including the core disks and drive rod fuel capsules, and activation products. The Radium-Beryllium neutron source was removed, placed in a shielded container, and placed in room 147 of the facility. The reactor fuel (core) including the core disks and drive rod fuel capsules have been placed in their original

          ,       shipping containers and stored in room 010 of the facility.

As stated in license R-127, Docket No. 50-538, the inherent design features of this reactor and the low power at which it is operated preclude the buildup of significant amounts of l fission products and the fission product inventory is considered to be negligible. Smear surveys were conducted to , detect the prescence of activation products and none were 1 detected (see the attached survey forms). All of the preceding activities were completed in accordance with provisions of the operating license. Please see Amendment II - ! for an in depth description of the sources of radiation. l These pages are taken in their entirety from Amendment No. 5, j Operating License R-127, Docket No. 50-538. The location of the sources of radioactivity can be found in a plant layout diagram in Appendix III. There is no source radioactivity located in the reactor due to the SAFSTOR status. I Exposure pathways are located in a posted restricted area. Therefore, there is no exposure to unauthorized persons. , 1.4 DECOMMISSIONING ALTERNATIVE l

A complete and thorough description of the partial i dismantling of this reactor which resulted in the placement of the reactor in SAFSTOR status can be found in the , approved Amendment No. 5 dated June 17, 1985. The reactor will remain in SAFSTOR status until permission from NRC is received which allows completion of the dismantling process and the shipment of the reactor vessel. Fuel, which was . placed in storage in a remote vault per Amendment No. 5, will remain as is until shipped to a secure facility as designated by the Department of Energy under the University Assistance Program. E. G. & G., Idaho Falls, Idaho will be assisting in the shipping arrangements. Due to the SAFSTOR status of the reactor all that remains in the dismantling process is the actual removal of the reactor from its present location. This task will be completed as follows: Once a brick wall and metal wall insert has been removed, the four anchor bolts of the reactor will be removed. The vessel will be lifted by crane to the bed of a truck. The control console and a metal locker containing the empty core tank and drive rods will be transferred to a truck bed in the same manner. Final surveys of the room will be taken and area warning and restriction signs will be removed. This entire process will be supervised by the , Radiation Safety Officer. i Through surveys taken, there was no radiation found above the allowed levels for unrestricted use to this date. No radiation is anticipated, but release for unrestricted use is contingent upon NRC approval. 1.5 DECOMMISSIONING ORGANIZATION AND RESPONSIBILITIES Organization and Responsibilities Responsibility for protective storage of the reactor facility is with the organization shown in the Amendment IV. Individuals at the various management levels are responsible for safeguarding the public and facility personnel from undue radiation exposures and for adhering to all requirements of the facility license. Assignment of specific responsibilities is described below. President The President of MSU is the Chief Administrative Officer ultimately responsible to the Tennessee State Board of Regents for the university and its activities. The President is responsible for the reactor facility license. Vice President for Advancement and Continuing Education

       .      The Vice President for Advancement and Continuing Education                                 '

is the Administrative Officer directly responsible to the President for maintenance, security and access control, administration, and safety of the reactor facility and fuel storage area. The Vice President may, in this capacity,

represent the President in matters pertaining to the facility license and, within limitations set forth by the 3 license, have final approval authority and responsibility for decisions policies, procedures, and events that would affect the facility, the reactor, reactor components, and reactor fuel. The Vice President for Advancement and Continuing Education shall be responsible for official communications concerning the reactor facility and fuel
,                       storage area including all reports and retention of i                        facility records. The Vice President for Advancement and Continuing Education shall be advised by the Radiation Subcommittee in all facility matters involving risks to personnel health and safety from ionizing radiation and shall be advised by the Director of MSU Safety and Security Services, in all matters involving physical security of the facility and reactor fuel. The Vice President may appoint personnel having the appropriate qualifications, as necessary, to positions reporting directly to him for purposes of executing requirements of the facility license 1

and assuring safe storage of the facility. Radiation Safety Subcommittee The Radiation Safety Subcommittee (RSSC) is a subcommittee of the University

  .                    Standing Conmittee on Safety (University Safety Committee) whose members are appointed by the President. The RSSC is formed to administer the Radiation Safety Program for the university. In this capacity, the RSSC shall be responsible and have approval authority for all procedures,
policies, and activities which involve risks to the health and safety of personnel from ionizing radiation. The RSSC i

shall advise the Vice President for Advancement and

Continuing Education in radiation control and safety i matters related to the reactor facility and fuel storage area and shall be informed by the Vice President of the 4

status and locations of radioactive materials and of any activities involving personnel exposure to ionizing ! radiation within these facilities. J The RSSC shall hold meetings and shall be responsible for independent reviews and audits of surveillance and i maintenance activities including radiation surveys. Based upon these reviews and audits, the RSSC shall make appropriate recommendations to the Vice President for Advancement and Continuing Education to assure that the state of the facility does not endanger the health and l safety of the public. Radiation Safety Officer The Radiation Safety Officer (RS0) is a member of the RSSC and is empowered to enforce regulations and regulatory procedures established by the

university, federal agencies, and state agencies for the control of radioactive materials and protection of personnel from ionizing radiation. The RSO shall be i responsible for the performance of radiation surveys and
shall maintain survey records in connection with the i

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;                                                                                                                                                I reactor facility and fuel storage area. 'In addition to routine surveillance activities delineated in the Technical Specifications, the RSO shall maintain materials inventory records and records of personnel exposure to ionizing radiation. The RSO shall inform the Vice President for
Advancement and Continuing Education, in writing, of l surveillance and inspection results within 14 days of ,

i completing such activities. The RSO shall be responsible for and shall supervise

 !                                          activities involving the movement of radioactive materials
within the facility and/or the packaging and shipment of
 ]                                          radioactive materials off campus. The RSO shall be directly responsible for the proper identification and
posting of restricted areas within the reactor facility and fuel storage area.

1 { Director Security and Safety Services The Director of Security and Safety Services is the management official i directly responsible for the physical security of university security and safety regulations on the MSU South Campus. In this capacity, the Director of Security and Safety Services shall provide the services and trained . security officers necessary to implement the facility security plan approved as part of this license to assure protective storage of the reactor and fuel. He shall advise the Vice President for Advancement and Continuing j Education in matters involving physical security and access i control of the reactor facility and fuel storage and shall

!                                           be informed of personnel authorized for access by the                                              t f                                            Office of the Vice President.

I

Radiation Safety Subcommittee Meetings Reviews, Audits, ,

and Records  ! l ! Qualifications The Radiation Safety Subcommittee (RSSC) is established as a subcommittee of the University Safety { Committee. Members of the University Safety Committee are j appointed by the President. The Subcommittee is appointed l_ by the Chairperson ofthe University Safety Committee and l includes a chairperson, the University Safety Director, the l Radiation Safety Officer and several members selected on ! the basis of their expertise in radiation safety and related matters. The Subcommittee is empowered to meet and keep minutes independently of the University Safety l Committee and with the authority to administer the  ; university's radiation safety program. Meetinas and Quorum The RSSC shall meet as necessary but I at least once each calendar quarter (intervals not to l exceed four months). A quorum for review and approval functions shall consist of the chairperson, or designated alternate, and two other members.

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l - Reviews The Radiation Safety Subcommittee shall review:

a. All procedures and major revisions thereto pertaining to the reactor facility and fuel storage area and which have radiological safety significance, or include changes to facility equipment or systems, or affect authorized personnel access to the facility.
b. Proposed changes to the facility license, technical ,
,                    specifications, or charter.
c. Violations of the license, technical specifications, or charter.

j d. Reportable occurences listed in the following section i regarding reporting requirements.

e. Abnormalities in, or deviations from, the normal and expected status of facility equipment and protective barriers.

l 1

       ,       Audits The RSSC shall conduct audits that include selective (but comprehensive) examination of facility and fuel storage area records, logs, and other documents.
Discussions with cognizant personnel and observation of -
!              activities should also be conducted as appropriate. In no i               case shall the individual immediately responsible for an I

area perform the audit in that area. The following areas shall be audited: I a. Facility surveillance, and maintenance for conformance to the Technical Specifications and applicable license conditions, at least once per calendar year (intervals between audits not to exceed fifteen months).

;              b. The results of actions taken to correct deficiencies I'                    that may occur in reactor facility and fuel storage area equipment, systems, structures, and radioactive i

materials' storage containers, at least once per { calendar year (intervals between audits not to exceed fifteen months). i

;              c. The reactor facility and fuel storage area security j                     plan and implementing procedures, at least once every

, other calendar year (intervals between audits not to { exceed 30 months).

d. The reactor facility and fuel storage area emergency plan and implementing procedures, at least once every other calendar year (intervals between audits not to

{ exceed 30 months). Records and Reports The Chairperson of the RSSC shall ensure that records of the committee's activities are prepared, distributed, and retained as follows: 1 _r,. ..,e r ,+,. -w-,,,-- ,%-em+. u--+ym,--,

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a. Minutes of each Radiation Safety Subcommittee meeting shall be prepared and retained on file in the University, Radiation Safety Office. A copy of these minutes shall be forwarded to the Vice President for Advancement and Continuing Education within 30 days following each meeting.
b. A written report or minutes of the findings and recommendations of each review group shall be prepared and submitted to the Vice President for Advancement and Continuing Education and all Radiation Safety Subcommittee Members in a timely manner after the review has been completed. A copy of each report shall be retained on file in the University Radiation Safety Office.
c. Deficiencies uncovered that affect radiation safety or protective storage of the reactor or reactor fuel shall be imMetHately reported to the Vice President for Advancement and Continuing Education. A written report of the findings of each audit shall be submitted to the Vice President and all Radiation Safety Subcommittee Members within three months after the audit has been completed. A copy of all audit reports shall be retained on file in the University Radiation Safety Office.
d. The Chairperson of the RSSC shall submit an annual report to the President prior to March 31, of each calendar year. The report shall contain an assessment of the facility's suitability for continued protective storage of radioactive materials, including the reactor fuel, and any appropriate recommendations. Copies of this report shall be submitted to the Vice President for Advancement and Continuing Education and retained on file in the University Radiation Safety Office.

Procedures and Procedure Approvals Procedures There shall be written procedures for the following:

a. Surveillance and testing of equipment and systems required for protective storage of the reactor and reactor fuel.
b. Personnel radiation protection consistent with 10 CFR 20.
c. Access control to the reactor facility and fuel storage area.
d. Implementation of the security plan and emergency plan.

_ _ _ _ ~ . . _ _ _ - - . _ _ _ ,

e. Notification of the proper authorities in the event of 1

unauthorized entries of personnel into the facility and significant changes in the radiation or contamination levels within*the facility. Procedure Approvals The Vice President for Advancement and l Continuing Education shall have final approval authority for all procedures in connection with the reactor facility and fuel storage area. The RSSC shall review and have ' approval authority for those procedures which may include risks to the health and safety of personnel from ionizing ] radiation in addition to those reviews specified in the 4 preceding section titled ' Reviews', The Director of

Security and Safety Services shall review and have approval authority for procedures written to implement the security plan and emergency plan.
Reporting Requirements Annual Report An annual report describing the status of

, the facility, the results of environmental and facility - radiation surveys, an evaluation of the performance of

.I security and surveillance measures, personnel exposures to radiation, and any abnormal occurrences during the previous

) calendar year shall be submitted to the Director of Nuclear 1 Reactor Regulation, ATTN: Document Control Desk, with a , i copy of the Regional Administrator, Region II, prior to March 31, of each calendar year.

Reportable Occurrences Reportable occurrences shall be t

reported as expeditiously as possible by telephone and confirmed by telegraph, mailgram or facsimile transmission to the Administrator of NRC Region II, or his 4 representative, no later than the first work day following the event. A written followup report describing the reportable occurrence including causes, probable consequences, corrective actions, and measures to prevent recurrence shall be submitted within 14 days. Information provided shall contain narrative material for a complete explanation of circumstances surrounding the event. The l following events shall be reported:

a. Discovery of significant, unexplained increase in l radiation or contamination levels within or around the l reactor facility or fuel storage area.
b. Abnormal degradation discovered in protective barriers for the reactor facility or fuel storage area which
would compromise the physical security established for
protective storage of the reactor and reactor fuel.

j Special Reports Special reports which may be required by

the Nuclear Regulatory Commission shall be submitted to the 4

Director of Nuclear Reactor Regulation. ATTN: Document ! Control Desk, with a copy to the Administrator, Region II, 4 i ?

within the time period for each report. Records Retention

                     ~

Records Records or logs relative to the following items shall be kept and retained until the license is terminated, unless otherwise specified by the NRC:

a. Environmental surveys.
b. Facility radiation surveys.
c. Inspections of physical barriers.
d. Abnormal occurrences.
e. Records of meetings of the Radiation Safety ,

Subcommittee. Prior Facility Operation Records or logs relative to the following items shall be retained for a period of at least five years:

a. Operating logs or data which shall identify:
1. Completion of pre-startup checkout, startup, power changes, and shutdown of the reactor.
2. Installation or removal of fuel elements, control rods, or experiments that could affect core reactivity.
3. Installation or removal of jumpers, special taas or notices, or other temporaray changes to reactor safety circuitry.

4 Rod worth measurements and other reactivity measurements.

b. Principal maintenance operations
c. Reportable occurrences.
d. Surveillance activities required by technical specifications.
e. Facility radiation and contamination surveys.
f. Experiments performed with the reactor.
g. Changes to operating procedures.

Records or logs relative to the following items shall be retained for the life of the facility, unless otherwise specified by the NRC:

a. Gaseous and liquid radioactive effluents released to

the environs.

b. Appropriate off-site environmental monitoring surveys.
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c. Fuel inventories and fuel transfers.
d. Radiation exposures for all personnel.
e. Updated as-built drawings of the facility.
f. Records of transient or operational cycles for those components designed for a limited number of transients or cycles.
g. Records of training and qualifications for members of the facility staff.

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h. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59..
1. Records of meetings of the Reactor Safety Committee.

1.6 REGULATIONS REGULATORY GUIDES AND STANDARDS The following references will be used to guide the decommissioning process described in this application. i 1. American National Standard for Decommissioning of Research Reactors, ANSI /ANS-15.10-1981.

2. Memphis State University Facility Operating License

. R-127, Docket No. 50-538.

3. Application for Construction Permit and License to Operate the Model AGN-201, serial 108 Nuclear Reactor at Memphis State University, April 11, 1975, as amended (Docket 50-538).
4. " Hazards Summary Report for the AGN-201 Reactor",

, Aerojet-General Nucleonics, August 1956 (Docket F-15).

5. "AGN Model 201 Reactor, Preliminary Design Study",

Aerojet-General Nucleonics, May 1956 (Docket F-15).

6. "AGN-201 Reactor Manual". Aerojet-General hucleonics, July 1957 (Docket F-15).
7. U.S. Atomic Energy Commission Regulatory Guide 1.86,
                         " Termination of Operating Licenses for Nuclear Reactors",

June 1974.

8. American National Standard for the Development of Technical Specifications for Research Reactors, ANSI /

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ANS-15.1-1982. I

9. Memphis State University Radiation Control and Safety Manual. Revip4d December 1, 1980: Memphis State University.
10. U.S. Nuclear Regulatory Commission Regulatory Guide 10.1, .
                                         " Compilation of Reporting Requirements for Persons Subject to NRC Regulations, Revision 4", October 1981.
11. S. Glasatone and A. Sesonske. Nuclear Reactor i

Engineering, Third Ed., Von Nostrand Reinhold Company: New York, 1981. 4 1.7 TRAINING AND QUALIFICATIONS

,                             Individuals from IRM have performed these duties several
times in the past at various sites and have been formally
,                             trained. Mr. Robert R. Riley, the Radiation Safety Officer for Memphis State University, will be monitoring all
;                             activities during the removal process.

2.0 OCCUPATIONAL AND RADIATION PROTECTION PROGRANS 2.1 RADIATION PROTECTION PROGRAM Radioactive contamination could arise from three sources:

;                             the reactor core, activation products outside the core and i

the Radium-Beryllium startup source. Fixed surface contamination produces external radiation exposures; airborne contamination adds an inhalation hazard. Thorough surveys of the reactor and core during defueling showed no evidence of any contamination (see Amendment V). Said defueling was done i in accordance with Amendment No. 5 license No. R-127 and was ! supervised by the University Radiation Safety Officer. With l all radioactive components removed and surveys showing no j contamination, it is unlikely there will be any measureable i exposure ot personnel. All workers will be supplied with l coveralls and gloves. In addition, the workers will be j monitored for exposure to neutrons, gamma and beta radiation by means of TLD badges and rings supplied by R.S. Landauer , Jr. and Co., as a precautionary measure. 'i , The following instruments will be checked for proper ' operation and placed in the reactor room for use: '

1. Air Sampler.
2. Neutron Survey Meter.

i

3. Gamma Dose Rate Survey Meter.

l 4 Contamination Survey Meter l The following supplies will be collected and placed in the i reactor room:

1. Filters and holders for air sampling.

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2. Filters for wipe tests.
                                                                        )
3. Individual containers for air sar-ples and wipe test '

filters.

4. Appropriat,e breathing apparatus.(face mask to be worn ,

as required by the Radiation Safety Officer). '

5. Coveralls, lab coats, and gloves.
6. Radioactive waste container.

2.2 INDUSTRIAL SAFETY AND HYGIENE PROGRAM The most probable type of accident is that which might be called ' mechanical' and might result from either human error or mechanical failure. The probability of human error will be minimized by making adequate preparation for the work and by following predetermined procedures which will be discussed in a briefing of all personnel. The probability of mechanical failure will be minimized by thorough inspection of all equipment in advance. Exposure to airborne non-radioactive affluents is not anticipated but will be monitored. Workers will be wearing coveralls and gloves. Filter masks will be supplied if necessary. 2.3 CONTRACTOR ASSISTANCE Memphis State University has entered an agreement with the Institute for Resource Management inc. (IRM) for removal of the AGN-201. IRM has performed this service on several occassions for other facilities. The personnel are trained and experienced in such operations. The reactor dismantling will be supervised by the University Radiation Safety Officer and monitoring badges will be provided by the University. IRM will be responsible for all tasks associated with removal of the reactor vessel. 2.4 COST ESTIMATE AND FUNDING The Institute for Resource Management Inc., based on their past experience in removing AGN-201 reactors, has stated that the cost to them will be approximately $5,000.00. The University anticipates no expenditures associated with this removal. 30 DISMANTLING AND DECONTAMINATION TASKS AND SCHEDULES 3.1 TASKS In accordance with Amendment NO. 5 to license R-127, Docket No. 50-538 the AGN-201 has been defueled. With all radioactive components having been removed and connections

between the control console and reactor vessel having been disconnected, all that remains to be done, pending approval from NRC, is to remove the securing bolts on the floor and load the reactorftessel on to a truck. This will necessitate the use of a crane. The control panel can be pushed to the outside and loaded by crane. There is a three ton hoist in place in the reactor room which will be utilized to remove the Thermal Column Tank or other components as may be necessary to facilitate inspections and smears by NRC personnel. 3.2 SCHEDULE Decommissioning of the reactor license cannot be completed until such time as the fuel is removed from the site. The fuel will be shipped to a secure facility as designated by the Department of Energy. Actual removal of the reactor and fuel can be accomplished in one day after licenses and approvals are issued. 3.3 TASK ANALYSES . As indicated in section 3.1, tasks will include removing bolts and hoisting the reactor vessel to a truck. It is not anticipated that there will be any special health cr safety considerations. 3.4 SAFE STORAGE As per Amendment No. S the reactor has been placed in SAFSTOR status. Procedures were outlined in this document and were followed accordingly. A brief decscription of the actual storage status is as follows: The reactor is defueled and assembled with the Thermal Column 'iank Access Port Liner Tubes, Glory Hole Liner Tube, and Rod Drive Area Cover Plate in stalled and gasketed to maintain the design fluid-tight integrity. The graphite reflector cylinder, lead shielding, and access port filler plugs are in place. The Shield Tank and Thermal Column Tank are empty of fluids and dry. The defuelled aluminum core tank and safety and control rod fuel capsules are removed from the reactor assembly and are sealed to maintain design fluid-tight integrity. All fissionable material used in connection with operation of the reactor is stored in 6J drums, containing less than 200 grams of U-235 each, and is located in a designated, controlled fuel storage area in accordance with the following paragraph regarding fuel storage.

i l Fuel, including fueled experiments and fuel devices, not in the reactor is stored in locked rooms in the reactor building. The storage array is such that Keff is no greater than 0.8 for all conditions of moderation and reflection. Fixed radiation monitors and alarms in the reactor room and fuel storage area are functional. 4.0 SAFEGUARDS AND PHYSICAL SECURITY In order to complete the decommissioning process it is not necessary to make any changes to the already NRC-approved physical security plans and the NRC-approved material control and accountability plan which are in Amendment No. 5 and Facility Operating License No. R-127, Docket No. 50-538. 5.0 RADIOLOGICAL ACCIDENT ANALYSES The fuel was previously removed in order to place the reactor - in SAFSTOR status. There were no radiological accidents related to the fuel handling for the decommissioning process.

                                                                         \

6.0 RADIOACTIVE MATERIALS AND WASTE MANAGEMENT 6.1 FUEL DISPOSAL All fuels have been placed in storage as approved in Facility Operating License R-127. They will remain unchanged and unmoved until the DOT, NRC and the Department of Energy grants permission to ship the fuel to a secure facility designated by the D. O. E. IRM will then be responsible for the shipment of the fuel in accordance with the requirements of applicable NRC and Department of Transportation regulations. 6.2 RADIOACTIVE WASTE PROCESSING Under provisions of license R-127, Docket No. 50-538 the AGN-201 has been defueled and all radioactive components were removed. Shield water was tested for contamination and drained (see Appendix VI). All swipes, gloves, filter papers, wiping papers and rags were stored in a disposal barrel. This practice will be continued throughout the dismantling operation. 7.0 TECHNICAL AND ENVIRONMENTAL SPECIFICATIONS The Technical Specifications contained in Appendix A of the original Operating License R-127, as revised through

Amendment No. 5, will remain unchanged until a final decommissic;.ing order is received from NRC.

                                     ~

8.0 PROPOSED TERMINATION RADIATION SURVEY PLAN During the defueling process, surveys were performed by several methods. A Gaseous Activity Sample was taken of the reactor room and activities were below minimum detectable activities (see Appendix VII). Swipe surveys were taken of all fuel components and all readings were less than MDA (see Appendix V). Surveys of all drive rod fuel capsules were taken and readings were all within acceptable ranges as seen in Appendix VIII. The reactor shield tank water was tested as described in Appendix V. The facility readings were taken with a Ludlum Model 3 Survey Meter which has a calculated MDA of 260 DPM. These facility readings were of the reactor room, control room, all adjoining rooms and outside (at the - walls and three feet from the building). All readings were acceptable as seen in Appendix I. The fuel storage room and drums were surveyed with the Ludlum Model 3 as well and results can be found in Appendix III. All fixed radiation menitors and alarms will remain in operation until the reactor and fuel have been removed from the facility. When all the reactor components including the fuel have been removed, a final survey of the facility will be performed using a Ludlum Model 3 to detect any area with radiation contamination. Any radiation contamination above levels for unrestricted use will be decontaminmated (see Appendix IX for proposed survey locations). l l l l

e 4 e 4 APPENDIX I I l t I l

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9 6 Ye APPENDIX II ' 1

APPEN0!X C Page 1 of 1

     . Application for Amendment No. 5 Operating License R-127, Docket 50-538 FUEL INVENTORY (SNM)

ITEM I . NO .

  • GROSS WGT. (g) SNM (g) U-235 (g)

Core disc - 4 cm 20439 2138.9 495.32 98.28 Core disc - 4 cm 20440 2141.0 495.67 98.35 Core disc - 4 cm 20441 2027.2 468.05 92.87 Core disc - 4 cm 20450 2048.9 475.15 94.28 Core disc - 2 cm 20443 1259.8 291.10 57.76 Core disc - 2 cm 20444 1262.2 292.51 58.04 Core disc - 2 cm 20445 1260.0 291.91 57.92 Core disc - 1 cm 20446 641.5 148.78 29 52 Core disc - 1 an 20447 629.9 146.26 29.02 Core fuse 20106 5.93 2.02 0.40 CONTROL & SAFETY R00 FUEL CYLINDERS 4.7 cm dia. 20349 78.89 18.19 3.61 4.7 cm dia. 20350 79.01 18.24 3.62 4.7 cm dia. 20351 78.91 18.24 3.62 4.7 cm dia. 20352 78.91 18.24 3.62 l 4.7 cm dia. 20354 79.09 18.29 3.63 4.7 cm dia. 20358 79.02 18.29 3.63 4.7 cm dia. 20359 79.01 18.29 3.63 4.7 cm di a. 20360 79.10 18.29 3.63 4.7 cm dia. 20353 78.99 18.24 3.62 4.7 cm dia. 20355 78.92 18.24 3.62 4.7 cm dia. 20356 79.06 18.29 3.63 4.7 cm dia. 20357 78.98 18.29 3.63 2.3 cm dia. 20211 19.80 4.59 0.91 2.3 cm dia. 20212 19.89 4.59 0.91 2.3 cm dia. 20213 19.73 4.54 0.90 2.3 cm dia. 20214 19.78 4.59 0.91 TOTALS 14,442.42 3,344.21 663.56

  • Gross Weight: Fuel pompogn is g0 2 in Pol thylene except for the core use is U 2jnPolygyrene.

APPENDIX C

APPENDIX D Pa92 1 of 4

    .             Application for Amendment No. 5 Operating License R-127, Docket No. 50-538 ASSESSMENT AND STORAGE LOCATION OF RADIOACTIVE MATERIALS AND FISSION PRODUCT ACTIVITY The radioactive materials associated with the AGN-201 Reactor include the reactor fuel and the 10 mg Radium-Beryllium neutron source. The aluminum core tank and control rod fuel capsules may contain trace amounts of short-lived activation products which decay to insignificant levels shortly fol-lowing removal from the reactor.
1. Reactor Fuel and Core Fuse. Special Nuclear Material (SNM) contained in the fuel discs and core fuse consists of 2680.65 grams of U-238 and 663.56 grams of U-235. A detailed listing of fuel discs is identified in Appendix C.
a. Natural Activity. The specific natural activity of the fuel may be calculated from the following relation:

NA X Sp. Act. = 3 A (s.1 x lo*) where Sp. Act. = pCi/ gram isotope NA

                                                                                     =         Avagadro Constant (atom /mol)

A, = Decay constant (sec-1) A = Atomic wgt. (g/mol) 3.7 x 104 = dps/pCi l For U238: Assume A = 4.92 x 10-18 sec-1 and A = 238.051 g/mol. Sp.Act.238 = .336 pC1/ gram U238 For U235: Assume A= 3.12 x 10-17 sec-1 and A = 235.044 g/mol. Sp.Act235 = 2.16 pC1/ gram U235 APPENDIX D

       - . - ,_     , . . . , . _ _ . . _ _ - . _ _ _ .  ,.          _ _ . _ _ _ , . . _ _        -__.m___.. ,, __. _ _ , _ _ - - , . - _ _ . _ _ _ _ _ . _ . _ .            , . _ . - . _ _ . , ,

APPENDIX D Page 2 of 4 Ap' plication for Amendment No. 5

                   . Operating Licensa R-127, Docht No. 50-538 TOTAL NATURAL 1.CTIVITY IN REACTOR FUEL AND FUSE:                                      2.33 millicuries The largest fuel content of any element consists of 397.329 (U238) and 98.35g (U235). Thus, the natural activity of the largest disc is 346 pCuries. The Core Fuse contains 1.62g (U238) and 0.49 (U235) which yields a natural activity of 0.864 pCi.
b. Fission Product Activity. Since December,1976, less than 1000 hours of operation at critical have been conducted. The highest recorded steady state power level was 80 milliwatts (March,1977) and the longest period of uninterrupted operation at any power level was less than ten hours. The energy generated in. Watt-hours per year is shown as follows using the conservative assumption that the total hours of operation at critical during each month of a given year occurred at the maximum recorded steady-state power level for that month:

Watt-hours 1985 <1.0 1980 3.3 1984 2.8 1979 6.8 1983 10.4 1978 3.0 1982 5.8 1977 11.1 1981 10.3 1976 1.1 i Total Watt-hours (December 1976 - March 1985): 55.6 i The defuel procedure approved for the MSU reactor requires a mini-mum ten day period following the last shutdown and removal of the neutron source to allow for activity decay prior to commencing fuel handling activities. To estimate the fission product activity l remaining in the fuel at the time of removal from the reactor, a semi-empirical approach described in reference 11 is used, where: I l Total Fission-Product Activity (C1)28 14 Po (T-To)-0.2 t -0.2 APPENDIX D

                           ,----,,.,.,--.----.-w.,,.,                -.,.--,     , _ . , - - . . - , - . . . , __ n,-- - , - - _ _ . _             - - . , - - - . . . _ _ - _ _ - _ - - - -
   ~

APPENDIX D Pag 2 3 of 4 A'pplication for Amendment No. 5

     . Operating Licensa R-127, Dockct 50-538 T =-time, in seconds, from startup to the time of interest Po = thermal p,ower level, in Watts,. at which the reactor operated.

To = time, in seconds, that the reactor operated T -To = time, in seconds, after shutdown to the time of interest. Based upon the intermittant mode of operation over 81/4 years, a

                   " time averaged power level" was calculated for P oassuming 1000 hours of continuous operation at 80 milli watts (8') Watt-hours) and averaged over a period of 7.23 x 104 hours.

Assuming a negligible quantity of fission product activity existed in the fuel in December,1976, and using the following values: T = 2.61 x 108 seconds Po = .0011 Watts j T -To = 8.64 x 10 5 seconds

                 ' TOTAL FISSION-PRODUCT ACTIVITY AT TIME t = 6.8 x 10-4' Curies Assuming uniform distribution, the Specific Activity referenced to U235 would be 1.02 pCuries/ gram U235 ten days after shutdown.

l The largest single fuel element could contain approximately 100 pCuries of fission product activity. The core fuse, the smallest single fuel element and making allowance for a factor of two greater fission rate due to its location in the core, could contain approx-imately 0.8 pCuries of fission product activity.

c. Summary. At the time of fuel removal, the total fuel activity could be as much as 3 millicuries composed of U235, U238, and fission products. The fission product activity would comprise less than 30% of the total and decrease to 10% or less of the total during the first three months of storage. The total activity is APPENDIX 0 l

l

APPENDIX 0 Paga 4 of 4

                 . Application for Amendment No. 5                                                                                                                                                         l Operating License R-127, Docket 50-538 distributed and corttained within the solid polyethylene moderator comprised by nine core elements,16 control rod elements, and the core fuse (polystyrene moderator). The largest single fuel element could contain as much as 446 pCuries of combined U235, U238, and                                                                                                      ;

fission product activity at the time of removal from the reactor. The fuel storage scheme requires that not more than 200 grams of

                     -                   contained U235 be in any one storage barrel. Thus, the maximum activity in any one container at the initial time of storage would be approximately 908 pCuries composed of U235, U238, and fiss~fon products. After a reasonable period of time, the prevailing natural
                                        ' activity would be approximately 704 pCuries (maximum in any b arrel ) . All SNM will be stored in the designated fuel storage l                                        area described in Part III of this application.

, 2. Radium-Beryllium Neutron Source. The AGN-201 neutron source consists of 10 milligrams (approximately 10 ml111 Curies) Ra-Be sealed in a stainless steel capsule. The source will be placed into its original lead shield and stored in the 55 gallon DOT (6J) USA 7A Type A shipping container that was used for transport in 1976. The maximum radiation exposure rate at three feet from the outer surface of the 6J container is expected to be less than 1.0 mR/hr. The Ra-Be Source will normally be stored in the Reactor Room of the facility unless an alternate loca-tion is specified by the Radiation Safety Office.

3. Aluminum Core Tank and Control Rod Fuel Capsules. The core tank and control rod fuel capsules are constructed of aluminum and contain the fuel elements during reactor operation. Upon disassembly, trace amounts of activity may exist due to contamination of the inner surfaces by the reactor fuel and/or activation by the reactor neutron flux. The core tank and fuel capsules will be sealed using their nonnal gasketed covers to achieve liquid-tight integrity and stored in the Reactor Room of the facility.

APPENDIX 0

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9 4 APPElfDIX III 1

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0 e m APPENDIX IV l l ) [ t I O l

PRE'SIDENT --- MEMPHIS STATE UNIVERSITY i

T*0:; S;FETY VICE PRESIDE?iT
         ,       ..i 0".!!!EE              -------

A3?ANCEME:,7 A'iD -------- D: REC 703 SECURITY A*G C0'iTINUI'iG EDUCATION SAFETY SERVICES

                                                                                       -r RADIATION SAFETY                                   REACTOR FACILITY OFFICER                                                                               SOUTH
                                                                                                         -      CA'4 PUS AND SECURITY FUEL STORAGE AREA                           0FFICERS Direct Line of Authority
              ----------- Advi sory/ Assistance Capacity FIGURE 1.

REACTOR FACILITY ORGANIZATION FOR " POSSESSION-ONLY" STATUS 17

4 e APPENDIX Y 1

LO'] r AGN-201 REACTOR DEFUEL CHB:KLIST ~

     .                                                                                                                             geto    .?. - 19 E T
1. Briefing conducted for defuel personnel including precautions and procedures:

Date E - /'/ 9 "

                                                                                                                ~
2. Date of shutdowns 3-F-Pf Date2 neutron source removed: 3-6 6f Initial conditions satisfied: /DG-Signature -

l 3.a. Glory Hole liner removed / 1. Surface of core. tank 2..O ar/br , b. Thermal Column Tank removed / me n. Thimble fitup to upper c, .: ore tank top (cover on): .c8 mr/hr core-half full thk. disca

         >. A *
  • d. Gaseous activity sample 4 m oet ne/ml e,f. Top reflector activit < MDW RfMARKS: $R l aked l m
.g. Top of core (cover off)y:  : &L O ar/hr gg gg my, 4 L
       ,,,,e....
             '          )       h.(1) poly disc activity:                                 '< th D A                  o. (T-5) full thk. fuel disc (2) Top of' fuela                             g                                                           ID nc450

) fixed alpha ,yITeoo I4.O ar/hrtem 2.' gr , ar/hr smear c010 cm.a fixed alpha 7000 .c% _i. Top (T)fthk.fueldisc: ' smear 4 #Ab A' ID 20496 p. This61e contamination <mana p,y 23 ar/hr q,r. Lower care Half: fixed alpha 14 con caen (T-6) full thk. disc (T-1) f thk. fuel disca smear ef 20 um ' ID AbNl gr 30 nr/hr ID M.0447 fixed alpha e coo es. fixed alpha Ar 23 mr/hr smear < MDM

                                                                                         /0 000 cam                    (T-7) full thk. disc smear            ' < M'bA '                                            ID 20V3Ct (T-2) i thk. fuel disc                                                                                  Ar       2M ar/hr ID 20WY                                        fixed alpha           Q1co cam p,y 27            ar/hr                              smear           4 MbK fixed alpha // con esm                                  (T-8) full thk. disc ID 1 0 44 0 smear             4.m OA (T-3) i thk. fuel disc                                                                                  g,y 25      -

ar/hr ID 20 WS~ fixed alpha li 000 com gy 12 mr/hr smear < Mt 4

                                                        +     fixed alpha 12.000 c.am                                  Core Fuse              ID '2. 0 t o a smear              < Mb4 '                                           gy F.O ar/hr (T-4) } thk. fuel disco                                                                    fixed alpha           Aobo tem ID 20W3                                              smear o< : 2.o com-s,s       22 mr/hr                 s. kower reflector activity < mDA fixed alpha /4000 csm                                t. Core tank interior Ar .01 mr/hr smear at:f # N i.om                                            smear            < MDA
j. Dummy discs and graphite ,r.M _ /-

reflector installed V

k. Core tank cover and ,f i
                                     ' lifting rig installed                                  v                                                                         _
u. FINAL DISPOSJTIp OF (X)RE TANK AND AGN-201 FUEL: f doRE TMte. - K,c Am t */e A 1 -

AcM*2at fvet. font % M M . y g ' g j ojo.-c, ), ' o. J.

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Revision 1 (11/81)

                                    ,  . ' . . !. . .Y i ..

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i 1 e d APPENDII VI 4 s e 4 e 4 8 4 e O e e di O O d a h a 9 1

C- 5 ?'f /. ,

             " ~ REACTOR SHIELD TANK; VISUAL INSPECTION--DATA SHER
          ?" "h                 .                                                        -

1\ n a

1. Fuel capsules and neutron source removed:

ReagforSupervisor

                                                                                           '3-/W-W Date
2. Shield Tank Water Sample (activity): < MMA uc/ml, 'du NM
  • E"
3. Approval to drain shield tank: 3 - N - ? ,'

Radiation Safety Oficer Date 4.

                                 ~

Radiation Survey per OP-8 (attached): I//J-

5. Highest level of radiation at inner shield tank wall: A! mr/hr.

Location:

6. Inspection results/ rem rks:
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7. Shield tanicfittEd ith de-ic.i::d w:ter: .. i nch es . ' ' ' '

h); - Completed by: c '

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Reviewed: i ') i Reactor Supervisor Date SP-BA2-3

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9 9 APPENDII VII

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D G Je APPENDIX VIII 1 e 1 l l l i I ( t i

         ..                                                                                                                                                                   ..                <w - o
                             .                                                                                                                                             HHc SP-BA-1 SAFETY AND CONTROL ROD DRIVE ASSEMf.IES; VISUAL INSPECTION--DATA SHEET
1. Beta-Ganna Activity; Capsule Assemt9,ed. Stidss o d at# d b u 5 *2 )

(PIL Lu ca+0 su SAFETY-1: t/,3 /./ mrem /hr. _

                                                                                                                                         '0 /                       4/     mf/L SAFETY-2:                      4.3                   //     mrem /hr.                       _
                                                                                                                                         //                        /I-mR/h C0 ARSE        :               9.o                   /./    mrem /hr.                           //                        l'I dd 7

FINE  : 2./ o.5 mrem /hr. #'# - M[4 SURVEY INST: /er8pm- 1 serial no. 8 /0,'f

2. Loose Surface Contamination: Alpha Activity (F4ed oc) Smee Le SAFETY-1: /s;ono cm 30 CPM SAFETY-2: /s.ooo -,. Jn CPM COARSE  : /f[ coo cr=

40 CPM FINE  : /dopo cs4 <lo CPM Survey Inst. lo!'~n.3 uf Ser. No. Soll Awdn-S s's.4HJag, (r+.e.s~'2' ,.'a*u ': .

3. Inspection Results: #3T)

JR *1 Aksmm 9)de bi'"d] I 'h* ( cJ ' ' ^r ' l 5 R *2 Ata.,,ea,,, eo,,ula 6w~l)

  • 4 ox.d.(in, co<.) , p -y n J Inule I Cearse 4/aa 4 capuk @kmal) / < 40o.da (e-) , g y _ s,/ay.

Rh %. ram capule SWmi) '

                                                                                                       < 100 go(a.) , y _, _ gggg ob'otmdes W-*'#

los 4Mhsfemel)

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i

                                                                                                                 /                   -CAPSULE                                                                  l 1

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SAFETY l s FlLLER 9933/ goyqq AOJSy 3.0352 SAFETY 2
FILLER 20340 203fd 540319 203 # #

1 COARSE: FILLER 20357 A03f5 203.f3 40356 FINE : FILLER JoJ// 203/V 202/3 202/2 1-NOTE: Record fuel I.D. numbers in the appropriate blocks. FIGURE 1 Fuel Capsule Loading Diagram j l SP-BAl-4 i

zn>; Performed by: ~ (1) Date SRO(2) 2 3-/Y"If

                                 /                   Date

() Reviewed: 3-/Y"8[ Date Reactorppervisor

                                                          ~

3-4-RS ~

t:r ^."-".i:tr:t:r . Date lbhbah $

r SP-BAl-6

9 e e APPENDIX IX t

i BUILDING 113 . . FIRST FLOOR $ = /2 7cu r/ M y g 2r / .-

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   '%         /                                                 June 17,1985 Docket No. 50-538                                                                 --

Dr. D. W. Jones, Director Center for Nuclear Studies Memphis State University Memphis, Tennessee 38152

Dear Dr. Jones:

SUBJECT:

CONVERSION OF LICENSE TO POSSESSION ONLY STATUS The Nuclear Regulatory Commission has issued Amendment No. 5 to Facility Operating License No. R-127, which authorizes possession, but not operation, of the nuclear reactor located at Memphis State University in Memphis, Tennessee. . This amended license is in response to your application dated March 15, 1985, requesting conversion of your license to a possession-only status while plans are being developed for decommissioning and license termination. We have restated the license in its entirety, incorporating the changes necessary to reflect the possession-only status. The amendment also includes the technical specification changes requested in your applica-tion. Copies of Amendment No. 5 and the related Safety Evaluation are enclosed. Sincerely, G a 4 O. % ~ Cecil 0. Thomas, Chief Standardization and Special Projects Branch Division of Licensing

Enclosures:

As stated cc: See next page f 5 (jk % b 5 0 ^ 2t1

Memphis State University 50-538 Mayor of the City of emphis -. City Hall - Poom 700 125 North Main . Memphis, Tenhessee 38103 Tennessee Department of Public Health ATTN: Director, Bureau of Environmental Health Services Cordell Hull Building Nashville, Tennessee 37219 Mr. Richard Dietz Center for Nuclear Studies Memphis State University Memphis, Tennessee 38152 Attorney General Supreme Court Ruilding Nashville, Tennessee 37219

           %,                               UNITED STATES 8      o NUCLEAR REGULATORY COMMISSION g       a                            wAswiscTom. o. c. 20sss
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l l i MEMPHIS STATE UNIVERSITY DOCKET NO. 50-538 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 5 License No. R-127

1. The Nuclear Regulatory Comission (the Comission) has found that:

A. The application for amendment to Facility Operating License No. R-127, filed by Memphis State University (the licensee), dated-March 15, 1985, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's rules and regulations as set forth in 10 CFR Chapter I;

8. The facility will be maintained in conformity with the amended license, the provisions of the Act, and the rules and regulations of the Comission; C. There is reasonable assurance: (1) that the activities authorized by this amended license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations; D. The issuance of this amended license will not be inimical to the common defense and security or to the health and safety of the public; E. The issuance of this amended license is in accordance with 10 CFR Part 51 of the Comission's regulations and all applicable requirements have been satisfied; and F. Publication of notice of this amended license is not required since it does not involve a significant hazards consideration nor amendment of a license of the type described in 10 CFR Section 2.106(a)(2).
       @ m W 3pp.
2. Accordingly, Fa 111ty Operating License No. R-127 is hereby amended by changes to the technical specifications, as indicated in the attachnent to this amended License No. R-127, and is further amended as follows:

A. This license applies to the Model AGN-201, Serial No.108, nuclear research reactor and associated equipment (the facility) owned by Memphis State University. The facility is located on the campus in Memphis, Tennessee, and described in the licensee's application dated April 11, 1975, for construction permit, operating license and amendments thereto. . B. Subject to the conditioas and requirements incorporated herein, the Commission hereby licenses Memphis State University: (1) Pursuant to Section 104c .nf the Act and 10 CFR Part 50,

                         " Domestic Licensing of Prbduction and Utilization Facilities,"

to possess, but not to operate, the facility at the designated location in Mcaphis, Tennessee, in accordance with the procedures and limitations set forth in this license. (2) Pursuant to the Act and 10 CFR Part 70 " Domestic Licensing of Special Nuclear Paterial," to possess, but not to use, up to 700 grams of contained uranium-235 enriched equal to or

                  . less than 20%, and (3) Pursuant to the Act and 10 CFR Part 30 " Rules of General Applicability to Domestic Licensing of Byproduct Material "

to possess, but not to separate, such byproduct materials as may have been produced by operation of the reactor. C. This license shall be deemed to contain and is subject to the conditions specified in Parts 20, 30, 50, 51, 55, 70 and 73 of 10 CFR Chapter I, to all applicable provisions of the Act, and to the rules, regulations and orders of the Commission now or hereafter in effect and to the additional conditions specified below: (1) Operation The licensee shall not operate the reactor nor install fuel or experiments within the reactor core or core area. (2) Technical Specifications The technical specifications contained in Appendix A, as revised through Amendment No. 5, are hereby incorporated in the license. The licensee shall possess and maintain the facility in accordance with the technical specifications.

(2) Physic ~al Security Plan The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security plan, including all amendments and revisions made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p), which are part of the license. This plan, which contains information withheld from public disclosure under 10 CFR 2.790, is entitled " Physical Security Plan For The AGN-201 Nuclear Reactor Facility And Special Nuclear Material Storage Area At Memphis State University." D. This amended expire June 15, license 1996. is effective as of the date of issuance and shall FOR THE NUCLEAR REGULATORY COMMISSION 044O.CL== Cecil 0. Thomas, Chief Standardization and Special Projects Branch Division of Licensing

Enclosure:

Appendix A Technical Specifications DATE OF ISSUANCE: June 17,1985

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4 UNITED STATES '8 4 NUCLEAR REGULATORY COMMISSION N $ WASHINGTON, D. C. 20555

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 5 TO , FACILITY OPERATING LICENSE NO. R-127 MEMPHIS STATE UNIVERSITY DOCKET NO. 50-538

Background

On March 15, 1985, Memphis State University (MSU) submitted an application, pursuant to 10 CFR 50.90, for a change of status from operating to possession-only for their 0.1 W AGN-201 Research and Training Reactor. The application included descriptions of current status and proposed facility mod.ifications, revised technical specifications compatible with the possession-only status and a safety analysis of the facility modifications. Facility Status All fuel discs, including the small fuel discs inside the control rod fuel capsules, will be removed from.the reactor in the presence of an NRC licensed Senior Operator and the MSU Radiation Safety Officer. The fuel discs will be placed into their original shipping / storage containers, sealed and stored in room 010 of the facility with area radiation monitors and alarms remaining operational. Less than 200 grams of U-235 will be stored in any one container to preclude criticality. The 10 mg radium-beryllium sealed neutron source will be removed from the reactor, placed into a shield container and stored in a shipping container in the reactor room. The aluminum core tank and control rod assemblies will be removed from the reactor and stored with covers and gaskets in place in the reactor room. The reactor configuration during the possession-only status will be as follows: the thermal column tank, cccess port liner tubes, glory hole liner tube, control rod cover plate, graphite reflector cylinder, lead shielding, access port filler plugs and neutron detectors with interconnecting instrument cables will remain installed. The control rod cover plate will have a gasket to keep the reactor vessel sealed. The power cable to the reactor console control power circuits will be disconnected and removed. The radiation nonitor and alarm in the reactor room will remain operational. SWYW c29q.

                                                                                                                                                     ~

The shield tank and thermal column tank water will be sampled for radioactivity and drained according to approved precedures in the MSU AGN-201 Maintenance and Storage Manual. Prior to storepe, the reactor vessel interfor including the core tank and fuel capsules will be thoroughly surveyed for residual radioactivity and loose surfree contamination. Surface contamination in excess of acceptable concentrations will be clearly identified and documented for future reference. The reactor room and control room.will remain locked at all times when authorized personnel are not present. The technical speci#ications and the adninistrative organization will be modified to reflect the possession-only status. Technical specifications addressing performance, safety, surveillance and reporting related to reactor operation will be deleted. Technical specifications addressing fuel storage, monitoring and surveillance, staff and public safety, and related reporting j requirements will be retained. . Evaluation Fuel removaT will be supervised and will conform with the defueling procedures approved by both the Reactor Safety Conmittee and the Radiation Safety Subcommittee of MSil. The fuel storage scheme provides for prevention of criticality, reactivity changes and radioactivity releases. Removal of fuel and rod control assemblies assures that the reactor and control systems cannot be operated. Removal of all liquids from the shield tank

                          'and therma,l column tank will minimize long-term corrosion of the reactor structures. As fuel is still on site, the area radiation monitors and alarms will remain operational in the reactor room and in the fuel storage j                            area. Radiation surveys will identify surface contamination levels that are greater than acceptable for unrestricted access end such areas will be properly documented and posted. Restoration of the reactor vessel, core tank and fuel capsules to their designed liquid-tight integrity will assure containnent of any trace residual radioactivity. Physical barriers housing l

these components will not be open #cr unrestricted access and shall remain l locked at any time authorized personnel are not present. The revised technical < specifications reflect the possession-only status of the reactor facility

and will continue to assure the health and safety of the reactor staff and l the public.
                          ' Environmental Consideration This amendment involves changes in the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 l                             and changes in inspection and surveillance requirements. The staff has
 --,---,-,ev   .     - , , - - - - - - - , -- . - . . -         ,--- .    , ,--. _      - , - - - - - - - , . ~ - . - - --r.---~~- - - - - - - - - .     ,     ---n-     --.

determined that the amendment involves no significant hazards. consideration i (as discussed belowl, there is no signf#icant change in the types or signiff-  ! cant increase in the amounts of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure. Accordinoly, this amendment meets the eligibility I criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.EP(b), no environmental inpact statement or environmental assessment need be prepared in connection with the issuance of this amendment. Conclusion Accordingly, the staff concludes that anendment o# this license to a possession-only status is appropriate. We have further concluded, based on the considerations discussed above, that: (1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously evaluated, does not create the possibility of a new or different kind of accident from any accident previously evaluated, and does not involve a significant reduction in a safety margin, the amendment does not involve.a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed activities, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or the the health and safety of the public.

        ~ Principal ' Contributor: Angela Chu Dated: May 23, 1985 l

l 1 1

O ATTACHMENT TO LICENSE AMEN 0 MENT NO. 5 FACILITY LICENSE NO. R-127 DOCKET NO. 50-538 -. Revised Appendix A technical specifications are as follows: Remove Pages Insert Pages All pages New pages 9

APPENDIX A _.. LICENSE NO. R-127 , TECHNICAL SPECIFICATIONS FOR MEMPilIS STATE UNIVERSITY AGN-201 (SERIAL 108) DOCKET NO. 50-538 DATE: MAY 1985 9 l

                                                    /

9

 .                                            TABLE OF CONTENTS PAGE 1.0 D E F I N I T I 0 NS '.' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      I
                                                                                                             ~~

2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS... 2

                                                                                                                  ~

3.0 LIMITING CONDITIONS FOR OPERATION................... 3 4.0 SURVEILLANCE REQUIREMENTS........................... 3 4.1 Facility Support and Protection System.. ... . . .. . 3 4 5.0 DESIGM FEATURES..................................... 4 5.1 Mo th ba l l S ta tus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5.2 Fuel Storage.................................... 5 6.0 ADMINISTRATIVE CONTR0LS............................. 6 6.1 Organization, Responsibilities and Authority.... 6 6.1.1 President................................. 6 6.1.2 Vice President for Advancement and Continuing Education................ 7 6.1.3 Radiation Safety Subcommittee............. 7 6.1. 4 Radia tion Sa fe ty Officer. . . . . . . . . . . . . . . . . . 8 6.1.5 Director, Security, and Safety Services... 8 6.2 Radiation Safety Subcommittee Meetings, Reviews, Audits, and Records.................. 9 6.2.1 Qualifications............................ 9 6.2.2 Meetings a nd Quorum. . . . . . . . . . . . . . . . . . . . . . . 9 6.2.3 Reviews................................... 10 6.2.4 Audits.................................... 10 6.2. 5 Records a nd Reports . . . . . . . . . . . . . . . . . . . . . . . 11 6.3 Procedures and Procedure Approva1............... 12 6.3.1 Procedures................................ 12 6.3.2 Procedure Approvals....................... 13 6.4 Reporting Requirements.......................... 13 6.4.1 Annual Report............................. 13 6.4.2 Reportable Occurences..................... 13 6.4.3 Special Re po rts . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 6.5 Record Retention................................ 14

6. 5.1 Mothball Status Records . . . . . . . . . . . . . . . . . . . 14
6. 5.2 Prior Facil i ty Opera tion. . . . . . . . . . . . . . . . . . 15 Figure 1. Reactor Facility Organization for Possession-Only Status............... 17 i

1.0 DEFINITIONS 1.1 Measuring Channel - A measuring channel is the combination of of sensors, lines, amplifiers, and output devices which are connected for the purpose of measuring or responding to the value of a process variable. , 1.2 Safety Channel - A safety channel is a measuring channel in the reactor safety system. 1.3 Reactor Safety System - The reactor safety system is that combination of safety channels and associated circuitry which forms the automatic protective system for the reactor or provides information which requires manual protective action be initiated. . 1.4 Reactor Component - A reactor component is any apparatus, device, or material that is a normal part of the reactor assembly. 1.5 Operable - Operable means a component or system is performing its intended function in its normal manner. 1.6 Operating - Operating means a component or system is perfonning its intended function in its normal manner. 1.7 Channel Check - A channel check is a qualitative verification of acceptable performance by observation of channel behavior. This verification may include comparison of the channel with other independent channels or methods measuring the same variable. 1.8 Channel Test - A channel test is the introduction of a signal i into the channel to verify that it is operable. 1

  ,                                             1.9 Chann21 Calibration - A channel calibration is an adjustment of the channel such that its output responds, within acceptable range and accuracy, to known values of the parameter which the channel measures. Calibration shall encompass the entire channel, including equipment, actuation, alann, or trip.

1.10 Reactor Secured - The reactor shall be considered secured when: (1) It contains insufficient fissile material or moderator present in the reactor, adjacent experiments or control rods, to attain criticality under optimum available conditions of moderation and reflection, or (2) No work is in progress involving core fuel, control

                                                 .         rods or control rod drives unless they are physically decoupled fran the reactor, and (3) The console key switch is in the off position and the
                                              ,            key is removed from the lock.

1.11 Mothball - The reactor facility is considered to be in a mothballed condition when the facility is in a state of protective storage. The facility may be left intact except that all fissionable materials, radioactive wastes, and radioactive fluids shall be removed from the reactor room. The reactor fuel shall be in storage containers and located in a remote fuel storage area in accordance with an approved fuel storage plan. Appropriate surveillance, radiation monitoring, and security procedures are established under a possession-only license to ensure that the health and safety of the public is not endangered. 2.0 SAFETY LIMITS AND LIMITING SAFFTY SYSTEM SETTINGS Not Applicable. The reactor shall remain secured and the facility shall be in mothball status. 2

l l 3.0 LIMITING CONDITIONS FOR OPERATION Not Applicable. The reactor shall remain secured and the facility shall be in mothball status. 4.0 SURVEILLANCE REQUIREMENTS Actions specified in this section are applicable to the mothballed condition of the facility and shall be performed within the specified surveillance period. 4.1 Facility Support and Protection Systems

                           . Applicability This specification applies to the facility support and protection systems such as physical barriers, fire protection systems, and radiation monitoring activities.

Objective To assure that the public health and safety are not endangered as a result of physical degradation of the facility during the term of the possession-only license period. Specification

a. Physical barriers to unauthorized entrance into the reactor facility and fuel storage area, e.g., building, rooms, doors, and access openings, shall be visually j inspected at least once each calendar quarter (intervals not to exceed four months),

i

b. Fuel storage containers, container locking rings, and seals shall be visually inspected at least once each calendar quarter (intervals not to exceed four months).

i 3

 ,                    c. A radiation survey of th> reactor facility and fusi storage area shall be performed at least once each calendar quarter (intervals not to exceed four months).
d. The reactor building fire alarm system, area fixed radiation monitors and elems, and reactor room smoke detector, shall be tested annually (intervals not to exceed fifteen months).

Rases The physical barriers, e.g. building, rooms doors, and access openings are inspected to assure that these barriers have not deteriorated and that locks and locking apparatus are intact. Storage containers, container locking rings, and seals are inspected to assure integrity of the containers. This inspection, in conjunction with radiation surveys of the reactor facility and fuel storage area, verifies that radioactive material has not been removed from the containers or is not escaping or being transported through the containment barriers. In addition, the radiation surveys and continued operational radiation monitors and alams provide assurance that radiation doses to facility personnel and to the public are maintained at a level below 10 CFR 20 limits. Tests of the reactor building fire alann system, area fixed radiation monitors and alarms, and reactor room smoke detector verify that these systems are operable. 5.0 DESIGN FEATURES 5.1 Mothball Status of the Reactor During a mothballed state of protective storage: ! 4

a. The reactor is defuelled and assembled with the Thermal Column Tank, Access Port Liner Tubes, Glory Hole Liner Tube, and Rod Drive Area Cover Plate installed and
                                           -g'asketed to maintain the design fluid-tight integrity.

The graphite reflector cylinder, lead shf61 ding, and access port filler plugs are in place. The Shield Tank and Thermal Column Tank are empty of fluids and dry,

b. The defuelled aluminum core tank and safety and control rod fuel capsules are removed from the reactor assembly and are sealed to maintain design fluid-tight integrity.
c. All fissionable material used in connection with operation of the reactor is stored in 6J drums, containing less than 200 grams of U-235 each, and is located in a designated, controlled fuel storage area in accordance with paragraph 5.2 of these technical specifications,
d. Fixed radiation monitors and alarms in the reactor room and fuel storage area will remain functional.

5.2 Fuel Storage Fuel, including fueled experiments and fuel devices, not in the reactor shall be stored in locked rooms in the reactor building. The storage array shall be such that K,ff is no greater than 0.8 for all conditions of moderation and reflection. 5

l 6.0 ADMINISTRATIVE CONTROLS  ! 6.1,. Organization, Responsibilities and Authority. Respon-sibility for protective storage of the reactor facil-ity shall be with the organization shown in Figure 1 of this section. Individuals at the various manage-ment levels shall be responsible for safeguarding the public and facility personnel from undue radia-tion exposures and for -adherence to all requirements

             .                  of the facility license. Assignment of specific re-sponsibilities shall be as described in the following paragraphs.

t 6.1.1 President. The President of Memphis State University - is the Chief Admir.1strative Officer ultimately responsible to tne Tennessee State Board of R,egents for the university and its activities. The P, resident i is responsibie for the reactor facility license. 6.1.2 Vice President.for Advancement and Continuing Educa-tion. The Vice President for Advancement and Contin- ' uing Education is the Administrat!ve Officer directly responsible to the President for maintenance, security and access control, administration, and safety of the reactor facility and fuel storage area. The Vi.e-President may, in this capacity, represent the Presi-dent in matters pertaining to the facility license and, within limitations set forth by the license, have final approval authority and responsibility for decisions, policies, procedures, and events that would affect the facility, the reactor, reactor com-ponents, and reactor fuel. The Vice President for Advancement and Continuing Education shall be respon-sible for official communications concerning the reactor facility and fuel storage area including all required reports and retention of facility records. 6 __ _ _ _ _ _ _ . _ _ i _ _ _ _ _ _ . _ _ _ __- ___ _ . _ _ _ _ _

The Vice President for Advancement and Continuing Ed-ucation shall be advised by the Radiation Safety Sub-

                                                         /       committee in all facility matters involving risks to personnel health and safety from ionfiing radiation and shall b,e advised by the Director, MSU Safety and Security Services, in all matters involving ph'ysical security of the facility and reactor fuel. The Vice President may appoint personnel having the appropri-ate qualifications, as necessary, to positions re-porting directly to him for purposes of executing re-

' quirements of tne facility license and assuring safe storage of the facility. 4 - - 6.1.3 Radiation Safety Subcommittee. The Radiation Safety Subcommittee (RSSC) is a subcommittee of the Univer-sity Standing Committee on Safety (University Safety , Committee) whose members are appointed by the Presi-dent. The RSSC is formed to administer the Radiation Safety Program for the university. In this capacity, the RSSC shall be responsible and have approval au-thority for all procedures, policies, and activities which involve risks to the health and safety of per-sonnel from ionizing radiation. The RSSC shall advise the Vice President for Advancement and Continuing Ed-ucation in radiation control and safety matters re-lated to the reactor facility and fuel storage area and shall be informed by the Office of the Vice Pres-ident of the status and locations of radioactive materials and of any activities involving personnel exposure to ionizing radiation within these facili-ties. j The Radiation Safety Subcommittee shall hold meetings and shall be responsible for independent reviews and audits of surveillance and maintenance activities in-ciuding radiation surveys. Based upon these reviews 4 and audits, the RSSC shall make appropriate recommen-7

l

                .                                       dations to the Vice President for Advancement and Continuing Education to assure that the state of the facility does not endanger the health and safety of                 l
                                                 , . . the public.

6.1.4 Radiation Safety Officer. The Radiation Sa'fety Offi-cer (RS0) is a member of the Radiation Sa'fety-Subcom-mittee and is empowered to enforce regulations and regulatory procedures established by the university, federal agencies, and state agencies for the control of radioactive materials and protection of personnel from ionizing radiation. The RSO snall be responsible for the performance of radiation surveys and shall maintain survey records in connection with the reac-l tor facility and fuel storage area. In addition to routine surveillance activities delineated in these 4 - Technical Specifications, the RSO shall maintain ma-terials inventory records and records of pers'onnel exposures to ionizing radiation. The RSO shall inform the Vice President for Advancement and Continuing Ed-ucation, in writing, of surveillance and inspection results within 14 days of completing such activities. t The Radiation Safety Officer shall be responsible for and shall supervise activities involving the movement of radioactive materials witain the facility and/or the packaging and shipment of radioactive materials off-campus. The RSO shall be directly responsible l for the proper identification and posting of re-

stricted areas within the reactor facility and fuel

\ storage area. J 6.1.5 Director, Security and Safety Services. The Director t of Security and Safety Services is the management of-ficial directly responsible for the physical security of university property and the enforcement of univer-

                       ,                            sity security and safety regulations on the MSU South 8

_ _ _ _ . - _ _ _ _ _..,__ _ __ ___ _ _ _ _ __ 1 . _ _ _ . _ . _ _ _ --- _ _ _ . _ _ _ _ -

Campus. In this capacity, the Director of Security and Safety Services shall provide the services and trained security officers necessary to implement the facility security plan approved as part of .this li-cense to asgure protective storage of the reactor and , fuel. He shall advise the Vice President for Advance-ment and Continuing Education in matters involving physical security and access control of the reactor facility and fuel storage area and shall be informed of personnel authorized for access by the Office of tne Vice President. 6.2 Radiation Safety Subcommittee Meetings, Reviews.

                                                                                                                                                        ~

Audits, and Records 6.2.1 Qualifications. The Radiation Safety Subcommittee is established as a subcommittee of the University Safety Committee. Members of the University Safety Committee are appointed by the President. The Subcommittee is i appointed by the Chairperson of the University Safety Committee and includes a chairpersen, the University Safety Director, the Radiation Safety Officer and several members se.lected on the basis of their exper-tise in radiation safety and related matters. The Subcommittee is empowered to meet and keep minutes 1 independently of the University Safety Committee and with the authority to administer the university's radiation safety program. 6.2.2 Meetings and Quorum. The Radiation Safety Subcommit-tee shall meet as necessary but at least once each calendar quarter (intervals not to exceed four months). A quorum for review and approval functions > shall consist of the chairperson, or designated al-ternate, and two other members. 4 s ^

  . - _ . . - .          . - . - - ,_ , . _ - . - - - - , _ - . . . _ - - - . -                                 .L-...._.--_.---.-_,..__-.
                     .                                                 6.2.3 Reviews. The Radiation Safety Subcommittee shall review:
a. All procedures and major revisions thereto per-taining to the reactor facility And fuel storage area and which have radiological safety signifi-i cance, or include changes to facilit'y equipment or systems, or affect authorized personnel access to the facility.

J j b. Proposed changes to the facility license, techni-cal specifications, or charter.

                                    '.                                                    c. Violations of the license, technical specifica-
                   '                                                                           tions, or charter.
d. Reportable occurrences listed in 6.4.

{ e. Abnonnalities in, or deviations from, the normal and expected status of facility equipment and protective barriers. 6.2.4 Audits. The Radiation Safety Subcommittee shall con-duct audits that include selective (but comprehensive) examination of fac'111ty and fuel storage area records, logs, and other documents. Discussions with cognizant personnel and observation of activities *should also be conducted as appropriate. In no case shall the individual immediately responsible for an area per-form the audit in that area. The following items shall be audited:

a. Facility surveillance, and maintenance for conformance to the Technical Specifications and applicable license conditions, at least once per calendar year (intervals between audits not to exceed fifteen months).

) 10

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b. The results of actions taken to correct deficien-cies that may occur in reactor facility and fuel
                                   ,.-          storage area equipment, systems, structures, and radioactive materials storage containers, at least once per calendar year (intervals between audits not to exceed fifteen months).
c. The reactor facility and fuel storage area secu-rity plan and implementing procedures, at least
                   .                           once every other calendar year (intervals between audits not to exceed 30 months).
d. The reactor facility and fuel storage area emer-
  • gency plan and implementing procedures, at least '

once every other calendar year (intervals between audits not to exceed 30 months). . 6.2.5 Records and Reports. The Chairperson of the Radia- ) tion Safety Subcommittee shall ensure that records of the committee's activities are prepared, distributed, and retained as follows:

a. Minutes of each Radiation Safety Subcommittee meeting shall 'be prepared and retained on file in the University Radiation Safety Office. A copy of these minutes shall be forwarded to the Vice President for Advancement and Continuing Educa-tion within 30 days following each meeting.

4

b. A written report or minutes of the findings and recommendations of each review group shall be
              ,                             prepared and submitted to the Vice President for Advancement and Continuing Education and all
Radiation Safety Subcommittee Members in a timely manner after the review has been completed. A
                ,,                          copy of each report shall be retained on file in the University Radiation Safety Office.

11

c.

    .                                   Deficiencies uncovered that affect radiation safety or protective storage of the reactor or reactor fuel shall be immediately reported to the Vice President for Advancement and Continuing Ed-ucation. A written report of the--findings of each audit shall be submitted to the Vice President
                                                                              ~

and all Radiation Safety Subcommittee Members within three months after the audit has been com-pleted. A copy of all audit reports shall be re-tained on file in the University Radiation Safety Office.

d. Tne Chairperson of the Radiation Safety Subcom-mit:.ee shall submit an annual report to the Pres-ident prior to March 31, of each calendar year.

The report shall contain an assessment of the fa-cility's suitability for continued protective

                                                                            '    ~

storage of radioactive materials, including the reactor fuel, and any appropriate recommendations. Copies of this report shall be submitted to the Vice President for Advancement and Continuing Ed-ucation and retained on file in the University Radiation Safety Office. i 6.3 Procedures and Procedure porovals. I 6.3.1 Procedures. There shall be written procedures for the following.

a. Surveillance and testing of equipment and systems i required for protective storage of the reactor and reactor fuel,
b. Personnel radiation protection consistent with 10 CFR 20.
            ,                c. Access control to the reactor facility and fuel storage area.

12

d. Implementation of tha security plan and emergency plan. -
                                        ,.-      e. Notification of the proper authorities in the event of unauthorized entries of personnel into the facility and significant changes.in the radi-ation or contamination levels within the facility.

6.3.2 Procedure Approvals. The Vice president for Advance-ment and Continuing Education shall have final ap-proval authority for all procedures in connection with the reactor facility and fuel storage area. The Radiation Safety Subcommittee shall review and have ~

        ~              -

approval authority for those procedures which may in-clude risks to the health and safety to personnel from ionizing radiation in addition to those , reviews specified in 6.2.3. The Director of Security,and Safety Services shall review and have approval authority for procedures written to implement the security plan and emergency plan. 6.4 Reporting Requirements 6.4.1 Annual Report. Ari annual report describing the sta-l tus of the facility, the results of environmental and facility radiation surveys, an evaluation of the per-formance of security and surveillance measures, per-sonnel exposures to radiation, and any abnormal occurrences during the previous calendar year shall be submitted to the Director of Nuclear Reactor Regu-lation, ATTN: Document Control Desk, with a copy of l the Regional Adninistrator, Region II, prior to March 31, of each calendar year. 6.4.2 Reportable Occurrences. Reportable occurrences shall be reported as expeditiously as possible by telephone and confirmed by telegraph, mailgram or facsimile transmission to the Administrator of NRC Region II, or his representative, no later than 13

tha first work day following th2 event. A writtsn followup report discribing the reportable occurrence including causes, probable consequences, corrective actions, and measures to prevent recurrence shall be

                                                          ~
                                                             ..             submitted within 14 days. Infomation provided sha11 contain carrative material for a complete explanation of circumstances surrounding the event., The following j                                                                           events shall be reported:

d

a. Discovery of significant, unexplained increase in
                                                      '                         radiation or contamination levels within or around the reactor facility or fuel storage area.
b. Abnormal degradation discovered in protective barriers for the reactor facility or fuel storage area which would compromise the physical security established for protective storage of the reactor and reactor fuel. *
  • 6.4.3 Special Reports. Special reports which may be required by the Puclear Regulatory Commission shall be submitted to the Director of Nuclear Reactor Regulation, ATTN: Document Control Desk, with a l copy to the Administrator, Region II, within the i

time period for each report. ' 6.5 Records Retention. 6.5.1 Records. Records or logs relative to the following items shall be kept and retained until the license is teminated, unless otherwise specified by the NRC: I

a. Environmental surveys.
b. Facility radiation surveys.
c. Inspections of physical barriers.
c. Abnormal occurrences.

' e. Records of meetings of the Radiation Safety Subcomittee. 14 _ _r-nrw7"-N'-N'" '"% ' W - - . - - - - - -- - '-- - -1'

o o 6.5.2 Prior Facility Operation. 6.Si2.1 Records or logs' relative to the following items

                                                                             ~~

shall be retained for a period of at least five years: ,

a. Operating logs or data which shall identify:
   ,                                        1. Completion of pre-startup checkout, start-
                   .                            up, power changes, and shutdown of the re-actor.
2. Installation or removal of fuel elements, -

I control rods, or experiments that could affect core reactivity.

3. Installation or removal of jumpers,, special tags or notices, or other temporary changes
                         .                     to reactor safety circuitry.
4. Rod worth measurements and other reactivity measurements.
b. Principal ma'intenance operations.
c. Reportable occurrences.
d. Surveillance activities required by technical specifications.
            ,,                      e. Facility radiation ind contamination surveys.
f. Experiments performed with the reactor.

9 Changes to operating procedures, a: 15 i

        +

k 6.5.2.2 Records or logs relative to the following items shall be retained for the life of the facility,

                                  ,.-   unless otherwise specified by the NRC:
a. Gaseous and liquid radioactive effluents re-leased to the environs.
b. Appropriate off-site environmental monitoring surveys.
c. Fuelinventohtesandfueltransfers.
d. Radiation exposures for all personnel.
e. Updated as-built drawings of the facility.
f. Records of transient or operational cyc~les for
                                                                                    ~

those components designed for a limited number of transients or cycles.

g. Records of training and qualifications for mem-bers of the facility staff.
h. Records of reviews performed for changes made to procedures ur equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
1. Records of meetings of the Reactor Safety Com-mittee.

l , \

                     *i I

4 i 16

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