ML20215D800

Responds to Questions Raised Re Application for Possession Only Amend to License R-78,per Enforcement Conference Rept 50-148/86-01.Summary of Disassembly Activities on 860321 & 24 & Radiation Safety Svc Permit Application Encl

ML20215D800
Person / Time
Site:	05000148
Issue date:	11/25/1986
From:	Rosson H KANSAS, UNIV. OF, LAWRENCE, KS
To:	Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8612170041
Download: ML20215D800 (9)

Text

> A '(g o, . s h z i THE UNIVERSITY OF KANSAS LAWRENCE, KANSAS 66045-2223 DEPARTMENT OF CHEMICAL AND PETROLEUM ENGINEERING

'k Tai 2 November 25, 1986 U.S. Nuclear Regulatory Commission 6 a Plaza Drive, Suite 1000 DM2 V Arlington, TX 76011 f

DEC 2 1986 i Attn: Mr. Richard L. Bangart i.

I jl9 Re: Enforcement Conference, NRC Inspection Report 50-148/86-01

Dear Mr. Bangart:

Some of the material which we have prepared in response to questions regarding our application for a Possession-Only amendment to our license may be of interest to you. The following documents are enclosed:

1. Summary of Disassembly Activities and Inventory of Remaining Activated Materials

2. Processing and Disposal of Activated and Contaminated Reactor Components (RSS-1 Project 1) 3 Exposure ALARA Considerations for RSS-1 Project 1

4. Radiation Safety Service Permit Application, Permit no. RSS-1.

The disassembly activities described in Item 1 were performed on March 21 and 24, 1986. Thus Item 2 represents an apparant contradiction to statements made at the enforcement conference and to the next to last sentence in Item 3 of my letter to you of November 7. What I was thinking of was approval by the Nuclear Reactor Committee (which did not consider the issue) and to be honest, I had forgotten about the approval by the Radiation Sources Committee.

I hope this additional information is helpful.

Since ly,

'/ 5 Harold . Rosson Reactor Director

Enclosures:

As stated GY 8612170041 861125 0 PDR ADOCK 0500 Ml ,

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SUMMARY

OF DISASSEMBLY ACTIVITIES AND INVENTORY OF REMAINING ACTIVATED MATERIALS November, 1986 All nuclear fuel has been removed and shipped to DOE facilities. The fission chamber has been transferred to Kansas State University.

The neutron detection chambers, control rod drive motors, magnets, armatures, rod drive extension rods, and guide tubes have been removed.

This material is not activated and presently is being stored on top of the reactor catwalk.

The following activated components have been removed from the tank and are stored in a shielded vault in the hot lab:

Description Activity (mci) Weight (lbs)

Control rods and sheaths (3 ea) negligible 22 Grid plate assembly (2 plates) 0.06 18 Aluminum angles (2) and stainless steel bolts (20) 0.90 _5 Total- 0.96 45 (Co-60)

Disassembly of all components was accomplished by removal of bolts or threaded studs. Nothing was cut or sawed.

The balance of the activated material is contained within the reactor shielding which includes the aluminum tank, the graphite thermal column, the beam port plugs, and the concrete biological shield. The specific activity of this material has not been determined.

All natural uranium plates, rods, and scrap has been shipped to ADC0 Services, Inc. for disposal. This material is not part of the reactor, but is covered under our facility license.

No other material has been removed or shipped off site.

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PROCESSING AND DISPCSAL OF ACTIVATED AND CONTAMINATED REACTOR COMPONENTS RSS-1 Project 1 Approved by. majority vote of Radiation Sources Committee March 17,_1986.

I. Introduction It is proposed that all remaining contaminated components of the reactor, exclusive of the structural shielding, be appropriately processed for efficient packaging and disposal as radioactive waste under our usual procedures.

II. Procedures The general procedures described under permit RSS-1. will be followed.

1,1ecifically, it has already been' determined that radiation fields at 12 inches from any surface are less than 30 mR/hr.

Protective clothing will be worn in disassembling the components.

Radiation monitoring will be carried out continuously by a second person.

Pocket chambers will be worn.

Exposure in any one week will be kept well-below 25 mrems by calculation.- Smears of components will be made before any cutting or sawing is accomplished.

If components need to be cut or sawed, drop cloths will be used and

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work will'be carrie'd out in a draft-free environment. Face masks with particulate filters will be used with eyes protected. All filings and other materials will be disposed of as radioactive.

Comprehensive smear tests will be performed at the end of any given operation to verify the absence of any contamination.

Estimates of activity will be made from radiation levels. Analysis of

. Spectra may be used, as appropriate, for identification of products.

.o ->5 EXPCSURE ALARA CONSIDERATIONS FOR RSS-1 PROJECT 1 The potential for a total dose of 25 mrems was deemed acceptable for the benefit obtained in reducing the potential continuous doses from distributed but easily removable sources within the reactor tank.

Furthermore, a check for potentially removable activity was also important for future planning for further reductions in radiation sources.

A total time of 45 minutes in the tank would yield a dose less than 25 mR and was used as the maximum time that would be required.

. .e e 's 't l Permit No. RSS-1 l l Effective Date j l completed by RSS l Radiation Safety Service PA-RLap Permit Application

1. (a) Name and Department Address l Alternate's Name, Department Home and University Phone No. Home and University Phone No.

I Radiation Safety Service Michael Lemon Benjamin S. Friesen l Assistant RSO Director and Radiation Safety Of ficer home phone 841-8260 of fice - 217 Nuclear Reactor Cent er l of fice phone 864-4089 Judith deChamplain g

home phone 843-4373 Radiation Protection Specialist I home phone 842-3180 (b) Rooms where radioactive materials will be used or stored.

NRC - rooms 207, 210A, 203, 218, Ill, 112, 132, 126, 125, 142 Haworth 904, 906, 10-1 Nichols 142 (n!! other nonrnved 1nkn-nrories)

2. Type of Request (Initial) (Renewal) [ Amendment) to replace all Circle designation which applies. previous approvals

. Previous Permit number (Applicable only if renewal or amendment request.)

3. Isotopes

, I I I I (a) l (b) l (c) l (d) l (e)

Radioactive l Compound (s) l Stock Storage l Requested l Possession Limit T eotope l and/or Fora l Location l Possession Limit l (completed by RSS) i I I I I I I I Any listed In forms listed 203, 111 NRC At levels li ted At levels listed in F2dioactive in 38-C019-01. in 38-C019-01 ' in 38-C019-01.

! I I I Materials License Waste and I  !

35-C019-01 I Sealed Sources!

I I (copy attached) l 111, 112, 132,l l (appropriate portio s) 207, 210A, NRCl l l l 904, 906, 10-1 l l l l Haworth l l 142 Nichols i I I I I I I i

4. Class of Laboratory (Circle appropriate class.)

Type D Type C Type B (Variable through all three)

a. , ..

I S. Training of Laboratory Supervisor duration of on the f o rmal Tvpe of training where . . l training job l course (a) Principles and practices of radiation protection, See e 1 closed vitae. ,es no yes no t

(b) Radioactivity measurements, monitoring techniques, instrument capabilities, yes no yes no standardizations, (c) Mathematics and calculations basic to the use and measurement yes no yes no of radioactivity, (d) Biological effects of radiation including estimates of risk. yes no yes no

6. Experience of- Laboratory Supervisor

" *#* **E*# ""C" "##E "

isotope maximum amount type of use was gained experience See enclosed vitae.

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7. Radiation Detection Instruments (Include RSS instruments only if on a semi-permanent loan.)

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use type of instrument radiation detected ef ficiency (average) monitoring, surveying or sensitivity  ;

measuring <

e See appropriate por tions of License Number 38-C019-01.

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8. Method, frequency, and standards (sources) used in calibrating and checking proper opera ,an of instruments listed above.

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e *, n RSS-1 Application cont. PA-RSSI.386

9. The TR-TDI is enclosed.

10. Bloassays Staf f members handling quantities of radioactive materials at levels requiring bloassays will process them. (Handling of unopened shipments is a

" gray" area. Staff members handling shipments will have bloassrys performed at least once each quarter.)

11. Laboratories and Facilities Room 111 is a hot lab and contains a radiological hood, concrete storage vaultr. and remote handling equipment. Lead bricks are available for temporary shielding. Rooms 203 and 207 have hoods. Haworth 906 has a new filtered radiological hood. Haworth 10-1 has the holdup-dilution tanks for controlling sewer disposal. Room 203 is our instrumentation room and contains supplies for all types of work with radioactive materials including emergency equipment.

12. Radiation Protection Program

a. General:

The representations and commitments made in our broad license 38-C019-01 and the referenced " Radiation Safety Standard Procedures" are followed.

(These have been reviewed at various times and are available to any Committee members for additional review.)

The procedures covered are summarized below:

I. Calibrations Air monitors, direct reading dosimeters, radiation survey instruments, & TLD's II. ~~ Actions and Responses to Permit Violations III. Emergency Procedures IV. Exposure Records (including bioassays)

V. Inventories VI. Directives VII. Permit Authorizations VIII. Purchasing Procedures IX. Shipment Inepections X. Surveys and Sampling (including leak tests)

XI. Training XII. Waste Disposal

b. Specific Items

1. Possession:

The intent of the possession limits requested on the cover page should be clarified. The RSS does not anticipate that it will possess all such materials at any one time. However, since all shipments come through our labs, the possession must cover all materials that may come to the university. We also have custody of several irradiators and store various

e *. s materials either in stock f orm or in waste form for users for variable lengths of time. The RSS, for itself. may need reference sources, classroom materials, and calibrations sources. All items are so stored that unrestricted areas will not exceed applicable 10CFR20 regulations.

2. Approach to non-routine projects:

By its very nature, the RSS neede to have approval to handle, manipulate, and appropriately process all radiation sources which the University possesses. The general procedure by which new situations are approached is described below.

1. All documented information available for defining the situation is gathered first. ( In cases of emergency, only immediately available information would be utilized.)

II. In addition to documentation, " approach" surveys and measurements are made to avoid unnecessary exposure and to provide information for making decisions about required protective procedures. (In unknown situations, step I is not possible.) An "aparoach" survey is one in which the radiation fields or concentration., of radioactive materials are measured or estimated starting with a position far from the potential source of radiation. In general, fields in excess of 30 mR/hr at 12 inches are totally avoided except for the possibility of quick assessment (fractions of minutes). Between 2.5 and 30 mR/hr.

time limitations are established.

III. Dry runs are performed for unfamiliar operations whenever possible.

IV. From analysis of operations to be accomplished, necessary shielding arrangements are calculated and installed.

V. All appropriate safety precautions are followed:

1. Protective clothing-includes lab coats and gloves as a minimum.

May include respirators, hooded garments, and bootles.

2. Protective drop cloths are used if radioactive materials might be spread.

3. Hoods or dry boxes are used as required.

4. "Second person present" rule is applied if appreciable fields or materials are involved.

S. Film badges are worn.

VI. Accident Analysis These are performed as required for planned procedures. If they have been performed under specific permits to users, they need not be performed again because the RSS has already reviewed them.

3. Procedures for Contaminated Facilities and Equipment I. The discussion under Section 12. b.2. above applies.

II. The nature and level of radiation fields are established. If

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appropriate, w2 pes are made to establish the level of removable activity.

III. Materials are isolated and segregated by levels and types of materials to_the extent possible.

IV.

For removable activity and chemicals, the levels are established by direct assessment of activity. For fixed radioactive materials, the levels are estimated on the basis of measuring radiation fields at a specified distance.

V.

If components need to be disassembled or cut into smaller segments, procedures are designed to contain the materials during processing.

4._ Any safor project will be submitted.for review and approval on a one time basis.

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