ML20247G032

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Safety Evaluation Supporting Dismantling of Facility & Disposition of Component Parts,Per Licensee 880108 Application & 890131 & 0414 Ltrs
ML20247G032
Person / Time
Site: Berkeley Research Reactor
Issue date: 09/12/1989
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247F960 List:
References
NUDOCS 8909180347
Download: ML20247G032 (8)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION DISMANTLING OF FACILITY AND DISPOSITION OF COMPONENT PARTS THE UNIVERSITY OF CALIFORNIA AT BERKELEY FACILITY OPERATING LICENSE NO. R-101 DOCKET NO. 50-224 1.0 -INTRODUCTION

' . By application dated January 8,1988, as supplemented on January 31, 1989 and April 14, 1989, the Regents of the University of California at Berkeley, (UCB) requested authorization for the dismantlement and disposition of component parts of the 1-MW TRIGA Mark III Berkeley research reactor facility located on the UCB campus. - The reactor has not been in operation since December 1987; its fuel was returned to the Department of Energy, in accordance with DOE, NRC and DOT requirements, in July 1989. The proposec decommissioning plan has two phases: (1) removal and shipment of the irradiated fuel from the reactor, which has been completed under the Facility Operating License, and (2) dismant-lement end removal of the reactor and its component parts.

Opportunity for hearing on this action was afforded by a " Notice of Proposed Issuance of Orders Authorizing Disposition of Component Parts and Terminating facility License" published in the FEDERAL REGISTER on March 10, 1988 (53 FR 7823). The City of Berkeley filed a " Petition To Intervene In License Amendment Proceeding, Request For Hearings And further Relief." The City of Berkeley and the licensee held discussions which led to a settlement agreement. . The licensee provided to the city of Berkeley additional infor-mation concerning the decommissioning process and emergency preparedness.

Upon joint motion for dismissal of hearing procedures by the parties, which was supported by the NRC staff, an Order was issued by the Atomic Safety and Licensing Board on January 5,1989, which dismissed the proceedings.

2.0 FACILITY DESCRIPTION The reactor is located in Etcheverry Hall in Room 1140 a high bay room. The reactor is at the east end of the room; various research and teaching facili-ties are distributed throughout the remainder of the room. Room 1140 and the rest of Etcheverry Hall is constructed of reinforced concrete. '

The reactor is a standard TRIGA Mark III manuf actured by General Atomics. It is a 1 MW (theran1), pool-type, heterogeneous reactor. The fuel was solid )

uranium-zironium hydride enriched to less than 20f uranium-235 clad in stainless steel. The reactor core was suspended from a movable bridge and could be moved laterally within the reactor tank to accomodate experimental needs. The reactor 8909180347 8909 W PDR P ADOCK050]{

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l 2-I was cooled by demineralized light water which also served as a moderator and I radiation shfeld. Control of the reactor was achieved by positioning four neutron-absorbing control rods within the core. The reactor was licensed for (See figures pulsing)with I and 2 reactivity insertions not to exceed three dollars.

Room 1140 is equipped with an independent ventilation exhaust system using high  ;

efficiency particulate air filters. There is also an emergency ventilation system. In addition to the existing ventilation system, a HEPA-filtered, negative pressure containment barrier surrounding the reactor will be in place during decontamination activities.

3.0 DISCUSSION In October 1985, a low-level release of radioactive material within the reactor room (Room 1140) was detected by the monitoring system attached to an air filter in the room. The leak, traced to three possible fuel rods, occurred during full power operation. When the leak was originally detected by the staff, Room 1140 ventilation system was switched to the emergency mode. All three suspect rods were removed from the reactor core and stored in the reactor pool.

UCB complied with all NRC requirements in regards to this incident, and nomal reactor operations were resumed. No radioactivity was released to the environment. Leakage from the fuel rods did not occur under storage conditions.

The UCB reactor was in operation from August 1966 to December 23, 1987. It was used primarily as a teaching facility to train reactor operators and engineers in the fundamental theoretical principles of reactor operation. The decommis-sioning plan proposed by UCB entails two phases. The first phase, which is complete, was the removal from the reactor, loading into shipping casks, and shipment of the reactor fuel as directed by its owner, the Department of Energy.

The disposition of the remaining byproduct material neutron sources and special nuclear material authorized and possessed by the license under facility Operating License No. R-101 is discussed below.

Five plutonium-beryllium (Pu-Be) neutron sources (4-1 Ci,1-10 C1) will be returned to their owner, the Department of Energy. One Pu-Be source (1 C1) and an americium-beryllium (2 C1) neutron source will be transferred to State of California License No. 1333-62. A polonium 210-beryllium (10 C1) source will be disposed of as radioactive waste. A fission chamber containing 4 grams of uranium-235 will either be disposeo of as radioactive waste or transferred to the State of California licensa.

In the second phase of the decommissioning plan, the material made radioactive by proximity to the fuel during reactor operation would be removed and shipped to a disposal site. The rotary specimen rack, the core shroud, portions of the aluminum pool liner, parts of the reinforced concrete monolith surrounding the reactor pool, and slightly contaminated concrete dust, metal chips, plastic, and rags would be included in these shipments. Nonradioactive debris would also be removed during this phase.

, In the decommissioning plan for +he reactor, the licensee proposes removal of radioactive materials down to levels that would permit release of the site for unrestricted use,.as defined in NRC Regulatory Guide 1.86. Dismantling of nonradioactive components and structures would begin after the Facility i Operating License is terminated. The issuance of an Order authorizing license termination follows the removal of all radioactive material and j completion of a termination radiation survey which is confirmed by the NRC.

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4.0 EVALUATION The principal concerns raisec by the decommissioning plan are: (1) personnel

' exposure and (2) safe handling, shipping, and disposal of radioactive materials.

. The staff has reviewed the UCB decommissioning plan to dismantle, decontaminate, and deconmiission the reactor. facility and dispose of its component parts and radioactive material. In its review, the staff considered management's responsibilities and commitments; the radiation protection program including procedures, equipment, instrumentation, survey techniques, training, and personnel dostmetry; waste disposal; and the final survey. Most of these functions and activities were ongoing during operation of the facility and would be continued at an appropriate level of effort during its dismantlement.

The acceptance criteria used by the staff are stated in 10 CFR Part 19

" Notices, Instructions, and Re provisions of 10 CFR Part 20, ports to Workers; Standards Inspection,"

for Protection Against and, the ALARA Radiation,"

and Reg. Guide 1.86, " Termination of 0perating Licenses for Nuclear Reactors."

Although the aforementioned areas of review were ongoing during operation of the UCB reactor, they will be maintained and remain in effect during its dismantlement.

4.I' Health and Safety Management The radiation protection program for the dismantlement and decommissioning of the facility is an extension of the existing program. The UCB Chancellor will maintain all responsibility for all activities at the facility. The Chancellor has appointed the Chairman of the Decommissioning Progran. Committee (Prof.

Fowler, Reactor Administrator) to manage all dismantlement, decontamination, and decommissioning activities. He will report to the Chancellor and will be responsible for daily activities and direction of the numerous crafts personnel and crews operating on site. Additional membars of the UCB staff include the Decommissioning and Deputy Decommissioning Project Engineer, a Radiation Safety Officer and a Reactor Health Physicist. The licensce's Contractor will provide additional staff members consisting of one certified Health Pisysicist and two Professional Engineers. The staff has reviewed the resumes of principal decommissioning staff and finds them acceptable. The licensee's stated policy is that all operations be planned and executed to conform with NRC regulations and appropriate regulatory guides and to maintain exposure to as low as reasonably achievable (ALARA) levels. The staff finds this staffing plan and operating policy to be acceptable.

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4.2 Radiation protection Program The goal of the radiation protection program is to ensure that the criteria for release of the facility and equipment therein for unrestricted use are satisfied and that the facility is released in such a way that exposure to the workers and the general public will be ALARA.

Health physics functions will be provided by both UCB and its contractor personnel.

The reactor facility and its environs will be monitored during the decommis-sioning operation in the same manner as that during its normal operating period. Additional monitoring will be performed and documented during the dism6ntling phase to ensure a complete radiation record of the facility.

Health physics personnel will be responsible for (1) the maintenance of radio-active exposure records, (2) implementation of the environmental survey program ensuring compliance with work procedures, (3) trainfo, and (4) specific work tasks. Additionally, health physics personnel together with industrial hygiene personnel will be responsible for conducting area and airborne radioactivity surveys; administering the respiratory protection program; assisting in decontamination of personnel, equipment, and facilities; conducting radiation protection training; personnel dosimetry; and ensuring that all personnel working in radiation areas use protective clothing properly. The staff finds the radiation protection program acceptable.

4.3 Quality Assurance Quality assurance will be the responsibility of the UCB Quality Assurance Supervisor who reports directly to the Chairman of the Decommissioning Steering Committee. This person will be responsible for the monitoring, auditing, and job performance records and for ensuring that the established safety review procedures have been followed. In order to meet the requirement of Reguletory Guide 1.33, " Quality Assurance Program Requirement" (Decommissioning), the licensee has committed to ensure the accuracy of all measurements that are part of its final report to the NRC.

4.4 " Unrestricted Use" Release Criteria The NRC staff's surface contamination criteria used in past decommissioning of non-power reactors for release of areas for unrestricted use or unrestricted access are found in Regulatory Guide 1.86, Table 1. In addition, external exposure rates must be less than 5 uR/hr above natural background at 1 meter from the measured surfaces. Alternately, levels greater than 5 uR/hr would be acceptable if it can be shown that the maximum radiation exposure to an indi-vidual would be less than the staff's recommended annual exposure limit of 10 mR/yr, considering potential occupancy in the vicinity of the radiation source. The licensee will perform and submit to NRC for confirmation a close-l out survey to demonstrate compliance with these criteria.

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. l 4.5 Occupational Dose Assessment The licensee has estimated that the collective dose equivalent expected for the entire decontamination / dismantling operation will be less than 8 person-rems.

This estimation is based on the expected levels of radioactivity from all sources, the manner in which experienced and well-trained workers will be performing their tasks in the expected radiation fields, review of dismantling plan procedures by the Radiation Safety Committee and the contractor with the aim of maintaining personnel exposure to a minimum, and the use, when appropriate, of enclosures, controlled atmospheres, and filtration systems to control movement of radioactive particulate. The staff finds that these measures for ensuring that the collective exposure will be ALARA are acceptable.

4.6 Health Physics Instrumentation!

Health physics personnel will continually evaluate the radiological status of the facility during the dismantling and cleanup process. Radiation levels will, therefore, be known at all times in areas where personnel are working.

During dismantlement, each component of the reactor will be surveyed for fixed and removable contamination using portable radiation monitoring instruments available at the UCB facility. After dismantlement a total building survey will be performed using the same type of instruments. Exposure rate measure-ments will be made at floor levels and 1 meter from the floor throughout the building. Exposure rate measurements will be made outside of the building at the wall adjacent to the reactor room and 1 meter from the wall.

The staff's review indicates that the instruments to be used by the licensee during the dismantling and decontamination operation, and the plan for sample analysis, are acceptable for use in a final termination survey to characterize the status of the reactor facility with respect to unrestricted use of its equipment and facilities. The staff has reviewed the list of equipment which UCB intends to use and finds it acceptable.

4.7 Radioactive Materials and Waste Management Byproduct material neutron sources and special nuclear material are discussed in Section 3.0. "" .ias made tentative arrangements to ship solid radwastes generated during e decommissioning activities to one of three licensed disposal sites in the United States. Department of Transportation regulations (49 CFR Part 173) will be used to provide radiation level ifmitations for the transportation of the packages of radioactive materials. All packaging and shipping of any low-level radioactive waste for burial will adhere to 10 CFR Part 71, " Packaging and Transportation of Radioactive Material,"

10 CFR Part 20 " Standards for Protection Against Radiation", and 49 CFR Parts " Department of Transportation Hazardous Material 170-199 Regulations",

and the standards set forth by the UCB Radioactive Shipment Checklist.

Liquid radwastes generated during decommissioning attivities will be collected, nonitored, and released to the sanitary sewage system if the conditions of 10 CFR 20.303, " Disposal by Release Into Sanitary Sewage Systems," can be met.

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I Otherwise, the water will be treated by an existing demineralized to remove the radioactive contamination'or processed for disposal as low-level radioactive-waste.

Close-capture ventilation'will be.used to reduce airborne dust and radio---

activity during core drilling operations. The licensee's control of airborne radioactive materials meets the acceptance criteria of 10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas,". as it relates to ventilation, monitoring, and dose assessment in restricted areas; and 10 CFR 20.106 " Radioactivity in effluents to unrestricted areas."

4.8 DECON l UCB intends that the reactor site and the remainder of the reactor facility be available for unrestricted use. There will be no requirement for SAFSTOR. The licensee has picked the immediate dismantling and decontaminating (DECON) decom-missioning alternative.

5.0 ENVIRONMENTAL CONSIDERATION

l An environmental assessment and finding of no significant impact relative to the proposed action was published in the Federal Register. Pursuant to 10 CFR 50.32, the Commission has determined that the issuance of this Order will have no-significant impact on the environment.

6.0 CONCLUSION

Based on our review of the facility health physics organization, equipment, and procedures, the staff concludes that the licensee's health physics program is in' compliance with the guidelines of Regulatory Guides 1.86 and that they provide adequate protection to assure a radiologically safe program for dismantling the UCB facility, disposing of associated radioactive material, .nd decontamination for unrestricted use. The' staff also concludes that the dismantling and decontamination operations can be conducted without undue risk to the health and safety of the public or UCB staff and without any significant impact on the environment. The staff, therefore, finds the licensee's plan to be acceptable.

Principal Contributors: John Minns Alexander Adams, Jr.

Date: September 12, 1989

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