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=Text=
=Text=
{{#Wiki_filter:ust 6, 2014
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ust 6, 2014


==SUBJECT:==
==SUBJECT:==
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==Dear Mr. Vasbinder:==
==Dear Mr. Vasbinder:==
On October 28-31, 2013, the U.S. Nuclear R egulatory Commission (NRC) conducted a safety inspection at the Buffalo Materials Research Center (BMRC) in Buffalo, New York. Additional information in documents provided by BMRC dated May 16, May 22, June 5, and June, 25, 2014, were also examined as part of the inspection. The inspection was an examination of your licensed activities as they relate to radiation safety and to compliance with the Commission's regulations and the license conditions. The inspection consisted of observations by the inspectors, interviews with BMRC and contractor personnel, a review of work plans and records, and a confirmatory survey for the free release of the building, and collection of soil samples.
On October 28-31, 2013, the U.S. Nuclear Regulatory Commission (NRC) conducted a safety inspection at the Buffalo Materials Research Center (BMRC) in Buffalo, New York. Additional information in documents provided by BMRC dated May 16, May 22, June 5, and June, 25, 2014, were also examined as part of the inspection. The inspection was an examination of your licensed activities as they relate to radiation safety and to compliance with the Commission's regulations and the license conditions. The inspection consisted of observations by the inspectors, interviews with BMRC and contractor personnel, a review of work plans and records, and a confirmatory survey for the free release of the building, and collection of soil samples.


The NRC contracted with Oak Ridge Associated Universities (ORAU) to perform the confirmatory survey of the building and perform analyses of soil samples obtained by the inspectors. ORAU provided the results of the confirmatory survey and sample analysis in a report, "Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York," dated July 24, 2014, [Agencywide Document Access and Management System (ADAMS) Accession No. ML14206A989]. The results of the inspection were discussed with you via telephone on August 6, 2014, and are described in the enclosed report. No health and safety concerns were identified.
The NRC contracted with Oak Ridge Associated Universities (ORAU) to perform the confirmatory survey of the building and perform analyses of soil samples obtained by the inspectors. ORAU provided the results of the confirmatory survey and sample analysis in a report, Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York, dated July 24, 2014, [Agencywide Document Access and Management System (ADAMS) Accession No. ML14206A989]. The results of the inspection were discussed with you via telephone on August 6, 2014, and are described in the enclosed report. No health and safety concerns were identified.


In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure(s), and your response, if provided, will be made available electronically for public inspection in the NRC Public Document Room or from ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response, if provided, will be made available electronically for public inspection in the NRC Public Document Room or from ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.


Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Nuclear Materials; Med, Ind, & Academic Uses; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 obtain these documents by contacting the Govern ment Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).
Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Nuclear Materials; Med, Ind, & Academic Uses; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).


No reply to this letter is required. Please contact Steve Hammann at 610-337-5399 if you have any questions regarding this matter.
No reply to this letter is required. Please contact Steve Hammann at 610-337-5399 if you have any questions regarding this matter.
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Sincerely,
Sincerely,
/RA Mark Roberts f/
/RA Mark Roberts f/
Patricia A. Silva, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety  
Patricia A. Silva, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety Enclosure:
 
Inspection Report No. 05000057/2013003 cc w/enclosure: State of New York
Enclosure: Inspection Report No. 05000057/2013003  
 
cc w/enclosure: State of New York


=EXECUTIVE SUMMARY=
=EXECUTIVE SUMMARY=
NRC Inspection Report No. 05000057/2013003  
NRC Inspection Report No. 05000057/2013003


An announced inspection was conducted on October 28-31, 2013, at the BMRC, in Buffalo,
An announced inspection was conducted on October 28-31, 2013, at the BMRC, in Buffalo,
New York. The inspection reviewed BMRC's decommissioning activities associated with their research and test reactor (RTR). Additional information in documents provided by BMRC dated May 16, May 22, June 5, and June 25, 2014, were also examined as part of the inspection. The inspection consisted of observations by the inspectors, interviews with BMRC and contractor personnel, review of work plans and records, a confirmatory survey for the free release of the building, and collection of soil samples. The NRC contracted with Oak Ridge Associated Universities (ORAU) to perform the confirmatory survey of the building and perform analysis of soil samples obtained by the inspectors. ORAU provided their survey results and soil analysis results in a report, "Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York" dated July 24, 2014 (ADAMS Accession Number: ML14206A989). The NRC's program for overseeing the safe decommissioning of a RTR is described in Inspection Manual Chapter (IMC) 2545, "Research and Test Reactor Inspection Program."
New York. The inspection reviewed BMRCs decommissioning activities associated with their research and test reactor (RTR). Additional information in documents provided by BMRC dated May 16, May 22, June 5, and June 25, 2014, were also examined as part of the inspection. The inspection consisted of observations by the inspectors, interviews with BMRC and contractor personnel, review of work plans and records, a confirmatory survey for the free release of the building, and collection of soil samples. The NRC contracted with Oak Ridge Associated Universities (ORAU) to perform the confirmatory survey of the building and perform analysis of soil samples obtained by the inspectors. ORAU provided their survey results and soil analysis results in a report, Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York dated July 24, 2014 (ADAMS Accession Number: ML14206A989). The NRC's program for overseeing the safe decommissioning of a RTR is described in Inspection Manual Chapter (IMC) 2545, "Research and Test Reactor Inspection Program.
 
Based on the results of the inspection, no health and safety concerns were identified. The


ORAU confirmatory survey and additional survey data submitted by BMRC confirmed that radiological conditions were commensurate with the building release criteria contained in BMRC's decommissioning plan (DP). The analysis of soil samples collected by the NRC indicated activity levels above background levels within areas that had not yet been remediated by BMRC. It should be noted the soil samples were taken for informational purposes only. The tank farm area has not yet undergone final remediation and survey for release by BMRC.
Based on the results of the inspection, no health and safety concerns were identified. The ORAU confirmatory survey and additional survey data submitted by BMRC confirmed that radiological conditions were commensurate with the building release criteria contained in BMRCs decommissioning plan (DP). The analysis of soil samples collected by the NRC indicated activity levels above background levels within areas that had not yet been remediated by BMRC. It should be noted the soil samples were taken for informational purposes only. The tank farm area has not yet undergone final remediation and survey for release by BMRC.


1 Inspection Report No. 05000057/2013003 G:\WordDocs\Current\Insp Report\RR-77.2013003.doc
ii Inspection Report No. 05000057/2013003 G:\WordDocs\Current\Insp Report\RR-77.2013003.doc


=REPORT DETAILS=
=REPORT DETAILS=


1. Summary of Facility Status  
===1. Summary of Facility Status===


The BMRC RTR is owned by the State University of New York at Buffalo and is located on the south campus of the University. The RTR was placed into operation in 1961 and operated until 1963 using materials testing reactor (MTR) type fuel with a maximum steady state power of 1 MWt. In 1963, the reactor was modified to use Pulse Training Assembled Reactor (PULSTAR) type fuel at power levels up to 2 MWt. The reactor was shut down in 1994, and in 1997, the license was amended to possession only. In 1998, the unused fuel was shipped to North Carolina State University, and in 2005, the spent fuel was shipped to the Idaho National Engineering and Environmental Laboratory.
The BMRC RTR is owned by the State University of New York at Buffalo and is located on the south campus of the University. The RTR was placed into operation in 1961 and operated until 1963 using materials testing reactor (MTR) type fuel with a maximum steady state power of 1 MWt. In 1963, the reactor was modified to use Pulse Training Assembled Reactor (PULSTAR) type fuel at power levels up to 2 MWt. The reactor was shut down in 1994, and in 1997, the license was amended to possession only. In 1998, the unused fuel was shipped to North Carolina State University, and in 2005, the spent fuel was shipped to the Idaho National Engineering and Environmental Laboratory.


On November 5, 2012, the Nuclear Regulatory Commission (NRC) approved the DP for the BMRC RTR (ADAMS Accession Numbers: ML12286A352 and ML12290A694). During decommissioning activities Enercon Services Inc. [Design and Oversight Contractor (DOC)] is providing field management and industrial and radiological safety services. BMRC is also using LVI Services as the Demolition Contractor (DC) for the decommissioning activities.
On November 5, 2012, the Nuclear Regulatory Commission (NRC) approved the DP for the BMRC RTR (ADAMS Accession Numbers: ML12286A352 and ML12290A694).


In December 2012, BMRC began decommissioning activities, which included mobilization and training of personnel and facility preparation (removal of clean debris and limited hazardous material removal). Dismantlement activities started in January
During decommissioning activities Enercon Services Inc. [Design and Oversight Contractor (DOC)] is providing field management and industrial and radiological safety services. BMRC is also using LVI Services as the Demolition Contractor (DC) for the decommissioning activities.


2013, and were completed in October 2013. BMRC's DOC and DC have completed dismantlement and decontamination activities and conducted free release surveys of the building.
In December 2012, BMRC began decommissioning activities, which included mobilization and training of personnel and facility preparation (removal of clean debris and limited hazardous material removal). Dismantlement activities started in January 2013, and were completed in October 2013. BMRCs DOC and DC have completed dismantlement and decontamination activities and conducted free release surveys of the building.


2. Research and Test Reactor Decommissioning
===2. Research and Test Reactor Decommissioning===


====a. Inspection Scope====
====a. Inspection Scope====
(Inspection Procedure 69013)
(Inspection Procedure 69013)
An announced inspection was conducted on October 28-31, 2013, at the BMRC, in Buffalo, New York. The inspection consisted of observations by the inspector, interviews with BMRC and contractor personnel, review of work plans and records, and a confirmatory survey for the free release of the building, and collection of soil samples. The NRC contracted with ORAU to perform the confirmatory survey of the building and perform analysis of soil samples obtained by the inspectors. ORAU provided their survey results and soil analysis results in a report, "Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York"
An announced inspection was conducted on October 28-31, 2013, at the BMRC, in Buffalo, New York. The inspection consisted of observations by the inspector, interviews with BMRC and contractor personnel, review of work plans and records, and a confirmatory survey for the free release of the building, and collection of soil samples.


dated July 24, 2014 (ADAMS Accession Number: ML14206A989). The NRC's program for overseeing the safe decommissioning of a RTR is described in IMC 2545, "Research and Test Reactor Inspection Program."
The NRC contracted with ORAU to perform the confirmatory survey of the building and perform analysis of soil samples obtained by the inspectors. ORAU provided their survey results and soil analysis results in a report, Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York dated July 24, 2014 (ADAMS Accession Number: ML14206A989). The NRC's program for overseeing the safe decommissioning of a RTR is described in IMC 2545, "Research and Test Reactor Inspection Program.


====b. Observations and Findings====
====b. Observations and Findings====
The inspectors reviewed BMRC's organization and temporary staffing to determine if it satisfied the DP requirements, license, and technical specification (TS) requirements.
The inspectors reviewed BMRCs organization and temporary staffing to determine if it satisfied the DP requirements, license, and technical specification (TS) requirements.


2 Inspection Report No. 05000057/2013003 G:\WordDocs\Current\Insp Report\RR-77.2013003.doc The inspectors verified that BMRC adequately provided oversight and control of the DOC  and DC. The inspectors reviewed work plans and records of decommissioning activities and determined they had been implemented as specified in the DP and TS.
Inspection Report No. 05000057/2013003 G:\WordDocs\Current\Insp Report\RR-77.2013003.doc


The inspector verified that BMRC and its contractor's radiation protection and As Low As Reasonably Achievable (ALARA) programs were being maintained in accordance with site procedures, DP, and NRC regulations.
The inspectors verified that BMRC adequately provided oversight and control of the DOC and DC. The inspectors reviewed work plans and records of decommissioning activities and determined they had been implemented as specified in the DP and TS.


The inspectors reviewed radiation work permits (RWPs) and verified that areas were posted for the radiological conditions in accordance with the requirements in 10 CFR Part 20. The inspectors determined that radiation instrumentation calibrations were current and also reviewed dosimetry records.
The inspector verified that BMRC and its contractors radiation protection and As Low As Reasonably Achievable (ALARA) programs were being maintained in accordance with site procedures, DP, and NRC regulations. The inspectors reviewed radiation work permits (RWPs) and verified that areas were posted for the radiological conditions in accordance with the requirements in 10 CFR Part 20. The inspectors determined that radiation instrumentation calibrations were current and also reviewed dosimetry records.


The inspectors reviewed waste disposal records for completed radioactive waste  
The inspectors reviewed waste disposal records for completed radioactive waste shipments to determine if the records and manifests met the NRC and Department of Transportation (DOT) regulations.


shipments to determine if the records and manifests met the NRC and Department of Transportation (DOT) regulations.
Building Free Release Surveys BMRC had surveys performed for the free release of the building. The release criteria for the building are based upon detectable contamination levels provided in NRC IE Circular 81-07 (Control of Radioactively Contaminated Material), and as specified in the DP. As described in IE Circular 81-07, detectable levels of contamination are defined as total beta-gamma surface activity levels greater than 5,000 dpm/100 cm2 and removable surface activity levels greater than 1,000 dpm/100 cm2, based on the detection sensitivity of common survey instruments at the time of publication. During the confirmatory surveys, ORAU identified eleven areas where surface activity levels exceeded the release criteria. BMRC immediately remediated the areas of elevated activity and then re-surveyed the areas and found them to be below the release criteria. ORAU also found some concrete blocks stored outside the 10k tank room that had elevated activity levels.
 
Building Free Release Surveys BMRC had surveys performed for the free release of the building. The release criteria for the building are based upon detectable contamination levels provided in NRC IE Circular 81-07 (Control of Radioactively Contaminated Material), and as specified in the DP. As described in IE Circular 81-07, detectable levels of contamination are defined as total  
 
beta-gamma surface activity levels greater than 5,000 dpm/100 cm 2 and removable surface activity levels greater than 1,000 dpm/100 cm 2, based on the detection sensitivity of common survey instruments at the time of publication. During the confirmatory surveys, ORAU identified eleven areas where surface activity levels exceeded the release criteria. BMRC immediately remediated the areas of elevated activity and then re-surveyed the areas and found them to be below the release criteria. ORAU also found some concrete blocks stored outside the 10k tank room that had elevated activity levels.


BMRC surveyed the blocks and disposed of those blocks with elevated activity levels as radiological waste. During the review of the BMRC survey package, ORAU noted two areas of concern. First, areas with activity greater than the release criteria had been found in areas classified in accordance with the guidance in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) as Class 2 or Class 3 survey areas.
BMRC surveyed the blocks and disposed of those blocks with elevated activity levels as radiological waste. During the review of the BMRC survey package, ORAU noted two areas of concern. First, areas with activity greater than the release criteria had been found in areas classified in accordance with the guidance in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) as Class 2 or Class 3 survey areas.


These areas were considered misclassified and should have been classified as MARSSIM Class 1 survey areas. Second, BMRC used a surface efficiency of 0.50 for the survey calculations. A surface efficiency of 0.25 would have been more appropriate per the guidance in ISO 7503-1, "Evaluation of Surface Contamination - Part 1."
These areas were considered misclassified and should have been classified as MARSSIM Class 1 survey areas. Second, BMRC used a surface efficiency of 0.50 for the survey calculations. A surface efficiency of 0.25 would have been more appropriate per the guidance in ISO 7503-1, Evaluation of Surface Contamination - Part 1.


BMRC reclassified the areas in question and performed additional surveys using the more appropriate surface efficiency of 0.25. The additional surveys were submitted to the NRC for review. Along with the additional survey data, BMRC sent information clarifying the following technical issues: selection of release criteria, statistical analysis, assessment of areas exceeding investigational limits, and assessment of the number of sampling points. The additional BMRC submissions reviewed for this report were dated May 15, May 22, June 5, and June 25, 2014.
BMRC reclassified the areas in question and performed additional surveys using the more appropriate surface efficiency of 0.25. The additional surveys were submitted to the NRC for review. Along with the additional survey data, BMRC sent information clarifying the following technical issues: selection of release criteria, statistical analysis, assessment of areas exceeding investigational limits, and assessment of the number of sampling points. The additional BMRC submissions reviewed for this report were dated May 15, May 22, June 5, and June 25, 2014.


3 Inspection Report No. 05000057/2013003 G:\WordDocs\Current\Insp Report\RR-77.2013003.doc The only remaining areas reported to have contamination levels greater than the release criteria are load-bearing columns and embedded pipes. These areas have been marked with fluorescent paint and will be removed as radiological waste during building demolition. The list of areas to be removed as radiological waste is included with the
Inspection Report No. 05000057/2013003 G:\WordDocs\Current\Insp Report\RR-77.2013003.doc


most recent BMRC submission (ADAMS Accession Number: ML14181B121). The NRC staff intends to perform inspection acti vities during the building demolition.
The only remaining areas reported to have contamination levels greater than the release criteria are load-bearing columns and embedded pipes. These areas have been marked with fluorescent paint and will be removed as radiological waste during building demolition. The list of areas to be removed as radiological waste is included with the most recent BMRC submission (ADAMS Accession Number: ML14181B121). The NRC staff intends to perform inspection activities during the building demolition.


Soil Sample Analysis
Soil Sample Analysis NRC inspectors collected seven soil samples from areas around the building considered non-impacted and three soil samples from the tank farm area. Prior to the collection of the soil samples, BMRC had excavated and removed the tanks and found that one of the tanks had leaked. The bottoms of the excavated areas were remediated and then temporarily backfilled with soil that had been removed during the tank excavations. All of the soil samples were analyzed by gamma spectroscopy for gamma-emitting radionuclides of concern and six of the ten samples, including the three from the tank farm area, were analyzed for Sr-90. The results of the sample analysis indicated all three of the soil samples from the tank farm area were above the DP screening value for Sr-90 and two of the samples were above the DP screening value for Ag-108m. The seven soil samples from the non-impacted areas did not indicate elevated activities for radionuclides of concern. It should be noted the soil samples were taken for informational purposes only. The tank farm area has not yet undergone final remediation and survey for release by BMRC.
 
NRC inspectors collected seven soil samples from areas around the building considered non-impacted and three soil samples from the tank farm area. Prior to the collection of the soil samples, BMRC had excavated and removed the tanks and found that one of the tanks had leaked. The bottoms of the excavated areas were remediated and then temporarily backfilled with soil that had been removed during the tank excavations. All of the soil samples were analyzed by gamma spectroscopy for gamma-emitting radionuclides of concern and six of the ten samples, including the three from the tank farm area, were analyzed for Sr-90. The results of the sample analysis indicated all three of the soil samples from the tank farm area were above the DP screening value for Sr-90 and two of the samples were above the DP screening value for Ag-108m. The seven soil samples from the non-impacted areas did not indicate elevated activities for radionuclides of concern. It should be noted the soil samples were taken for informational purposes only. The tank farm area has not yet undergone final remediation and survey for release by BMRC.


====c. Conclusions====
====c. Conclusions====
Based on inspections and independent surveys and sampling conducted by Region I staff, NRC headquarters staff, and ORAU personnel , the results of the confirmatory surveys were consistent with the licensee's survey results. The licensee adequately surveyed the facility and applied the free release criteria in accordance with the DP.
Based on inspections and independent surveys and sampling conducted by Region I staff, NRC headquarters staff, and ORAU personnel, the results of the confirmatory surveys were consistent with the licensees survey results. The licensee adequately surveyed the facility and applied the free release criteria in accordance with the DP.


With the exception of a few specific areas that have been identified for later radiological control and disposal of any radiological wastes identified during building demolition, the building is acceptable for free release.
With the exception of a few specific areas that have been identified for later radiological control and disposal of any radiological wastes identified during building demolition, the building is acceptable for free release.
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Based on the results of this inspection, no findings of safety significance were identified.
Based on the results of this inspection, no findings of safety significance were identified.


3. Exit Meeting The results of the on-site portion of the inspection were discussed with Dave Vasbinder, BMRC Director, and other members of the BMRC staff, on October 31, 2014. The final inspection results were discussed with Dave Vasbinder on August 6, 2014, following the  
===3. Exit Meeting===
 
The results of the on-site portion of the inspection were discussed with Dave Vasbinder, BMRC Director, and other members of the BMRC staff, on October 31, 2014. The final inspection results were discussed with Dave Vasbinder on August 6, 2014, following the review of all BMRC submissions.


review of all BMRC submissions.
Inspection Report No. 05000057/2013003 G:\WordDocs\Current\Insp Report\RR-77.2013003.doc


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


PARTIAL LIST OF PERSONS CONTACTED
PARTIAL LIST OF PERSONS CONTACTED
Licensee Mark Adams, Safety Engineer
Licensee
Mark Adams, Safety Engineer
Jeff Slawson, RSO
Jeff Slawson, RSO
Dave Vasbinder, Director
Dave Vasbinder, Director
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Enercon Services
Enercon Services
Frank Brown, Project Manager
Frank Brown, Project Manager
ORAU Nick Altic, Survey Group
ORAU
Nick Altic, Survey Group
Mike Boice, Survey Group
Mike Boice, Survey Group
James Viars, Survey Group
James Viars, Survey Group
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Inspection Procedure 69013, Research and Test Reactor Decommissioning
Inspection Procedure 69013, Research and Test Reactor Decommissioning
ITEMS OPEN, CLOSED, AND DISCUSSED
ITEMS OPEN, CLOSED, AND DISCUSSED
None LIST OF DOCUMENTS REVIEWED
None
LIST OF DOCUMENTS REVIEWED
5177-PL-01-Draft, Project Specific Plan for Confirmatory Surveys Associated with Buffalo
5177-PL-01-Draft, Project Specific Plan for Confirmatory Surveys Associated with Buffalo
Materials Research Center - ORISE ALS Environmental GC/MS Semivolatiles Case Narrative, Work Order Number: 1305456
Materials Research Center - ORISE
ALS Environmental GC/MS Semivolatiles Case Narrative, Work Order Number: 1305456
Buffalo Materials Research Center, Building Survey Summary, August 2013; September 2013;
Buffalo Materials Research Center, Building Survey Summary, August 2013; September 2013;
and October 2013
and October 2013
Buffalo Materials Research Center, Radiation Safety Inspection Report, August 2013;
Buffalo Materials Research Center, Radiation Safety Inspection Report, August 2013;
September 2013; and October 2013 Decommissioning Curtailment Operations, Operating Procedure #10, 11/14/2013 Drawing 12-UNY-172.DWG, Proposed Utility Removal and Capping Plan
September 2013; and October 2013
Decommissioning Curtailment Operations, Operating Procedure #10, 11/14/2013
Drawing 12-UNY-172.DWG, Proposed Utility Removal and Capping Plan
Guidance for Pre-Demolition Surveys of the BMRC, Rev. 0
Guidance for Pre-Demolition Surveys of the BMRC, Rev. 0
NRC Form 540, Uniform Low-Level Radioactive Waste, Manifest Numbers: 005343027FLE;
NRC Form 540, Uniform Low-Level Radioactive Waste, Manifest Numbers: 005343027FLE;
25-02-0014, 0015, 0016, 00170018, 0019; 0625-03-0001; MSC-002; UB-ES-019, 020, 021   Report of Analysis/Certificate of Conformance, 7/12/2013 and 9/27/2013, Teledyne Brown   Engineering, Inc.
25-02-0014, 0015, 0016, 00170018, 0019; 0625-03-0001; MSC-002; UB-ES-019, 020, 021
Report of Analysis/Certificate of Conformance, 7/12/2013 and 9/27/2013, Teledyne Brown
Engineering, Inc.
Reactor Decommissioning Safety Committee Meeting Minutes, August 2, 2013
Reactor Decommissioning Safety Committee Meeting Minutes, August 2, 2013
RWP-BMRC-017
RWP-BMRC-017
Summary of Radiation Exposures at BMRC, 7/01/2013 - 9/30/2013, Draft
Summary of Radiation Exposures at BMRC, 7/01/2013 - 9/30/2013, Draft
UB-WCD-OP-07, "Utility Isolation Work Plan" University of Buffalo, Supplemental Survey Documentation, dated, May 14, 2014; May 22, 2014;   June 5, 2014; and June 25, 2014
UB-WCD-OP-07, Utility Isolation Work Plan
University of Buffalo, Supplemental Survey Documentation, dated, May 14, 2014; May 22, 2014;
June 5, 2014; and June 25, 2014
LIST OF ACRONYMS USED
LIST OF ACRONYMS USED
BMRC Buffalo Materials Research Center DC Demolition Contractor
BMRC       Buffalo Materials Research Center
DOC Design and Oversight Contractor
DC         Demolition Contractor
DP Decommissioning Plan
DOC       Design and Oversight Contractor
IMC Inspection Manual Chapter
DP         Decommissioning Plan
MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual NRC Nuclear Regulatory Commission ORAU Oak Ridge Associated Universities
IMC       Inspection Manual Chapter
RTR Research and Test Reactor
MARSSIM   Multi-Agency Radiation Survey and Site Investigation Manual
RWP Radiation Work Permit
NRC       Nuclear Regulatory Commission
ORAU       Oak Ridge Associated Universities
RTR       Research and Test Reactor
RWP       Radiation Work Permit
Attachment
}}
}}

Latest revision as of 02:43, 4 November 2019

IR 05000057-13-003 on 10/28/13 - 08/06/14, Buffalo Materials Research Center, University at Buffalo, Buffalo, New York
ML14219A022
Person / Time
Site: University of Buffalo
Issue date: 08/06/2014
From: Patricia Silva
Division of Nuclear Materials Safety I
To: Vasbinder D
University of Buffalo
References
IR-13-003
Download: ML14219A022 (10)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ust 6, 2014

SUBJECT:

NRC INSPECTION REPORT NO. 05000057/2013003, BUFFALO MATERIALS RESEARCH CENTER, UNIVERSITY AT BUFFALO, BUFFALO, NEW YORK

Dear Mr. Vasbinder:

On October 28-31, 2013, the U.S. Nuclear Regulatory Commission (NRC) conducted a safety inspection at the Buffalo Materials Research Center (BMRC) in Buffalo, New York. Additional information in documents provided by BMRC dated May 16, May 22, June 5, and June, 25, 2014, were also examined as part of the inspection. The inspection was an examination of your licensed activities as they relate to radiation safety and to compliance with the Commission's regulations and the license conditions. The inspection consisted of observations by the inspectors, interviews with BMRC and contractor personnel, a review of work plans and records, and a confirmatory survey for the free release of the building, and collection of soil samples.

The NRC contracted with Oak Ridge Associated Universities (ORAU) to perform the confirmatory survey of the building and perform analyses of soil samples obtained by the inspectors. ORAU provided the results of the confirmatory survey and sample analysis in a report, Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York, dated July 24, 2014, [Agencywide Document Access and Management System (ADAMS) Accession No. ML14206A989]. The results of the inspection were discussed with you via telephone on August 6, 2014, and are described in the enclosed report. No health and safety concerns were identified.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response, if provided, will be made available electronically for public inspection in the NRC Public Document Room or from ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Nuclear Materials; Med, Ind, & Academic Uses; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).

No reply to this letter is required. Please contact Steve Hammann at 610-337-5399 if you have any questions regarding this matter.

Sincerely,

/RA Mark Roberts f/

Patricia A. Silva, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety Enclosure:

Inspection Report No. 05000057/2013003 cc w/enclosure: State of New York

EXECUTIVE SUMMARY

NRC Inspection Report No. 05000057/2013003

An announced inspection was conducted on October 28-31, 2013, at the BMRC, in Buffalo,

New York. The inspection reviewed BMRCs decommissioning activities associated with their research and test reactor (RTR). Additional information in documents provided by BMRC dated May 16, May 22, June 5, and June 25, 2014, were also examined as part of the inspection. The inspection consisted of observations by the inspectors, interviews with BMRC and contractor personnel, review of work plans and records, a confirmatory survey for the free release of the building, and collection of soil samples. The NRC contracted with Oak Ridge Associated Universities (ORAU) to perform the confirmatory survey of the building and perform analysis of soil samples obtained by the inspectors. ORAU provided their survey results and soil analysis results in a report, Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York dated July 24, 2014 (ADAMS Accession Number: ML14206A989). The NRC's program for overseeing the safe decommissioning of a RTR is described in Inspection Manual Chapter (IMC) 2545, "Research and Test Reactor Inspection Program.

Based on the results of the inspection, no health and safety concerns were identified. The ORAU confirmatory survey and additional survey data submitted by BMRC confirmed that radiological conditions were commensurate with the building release criteria contained in BMRCs decommissioning plan (DP). The analysis of soil samples collected by the NRC indicated activity levels above background levels within areas that had not yet been remediated by BMRC. It should be noted the soil samples were taken for informational purposes only. The tank farm area has not yet undergone final remediation and survey for release by BMRC.

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REPORT DETAILS

1. Summary of Facility Status

The BMRC RTR is owned by the State University of New York at Buffalo and is located on the south campus of the University. The RTR was placed into operation in 1961 and operated until 1963 using materials testing reactor (MTR) type fuel with a maximum steady state power of 1 MWt. In 1963, the reactor was modified to use Pulse Training Assembled Reactor (PULSTAR) type fuel at power levels up to 2 MWt. The reactor was shut down in 1994, and in 1997, the license was amended to possession only. In 1998, the unused fuel was shipped to North Carolina State University, and in 2005, the spent fuel was shipped to the Idaho National Engineering and Environmental Laboratory.

On November 5, 2012, the Nuclear Regulatory Commission (NRC) approved the DP for the BMRC RTR (ADAMS Accession Numbers: ML12286A352 and ML12290A694).

During decommissioning activities Enercon Services Inc. [Design and Oversight Contractor (DOC)] is providing field management and industrial and radiological safety services. BMRC is also using LVI Services as the Demolition Contractor (DC) for the decommissioning activities.

In December 2012, BMRC began decommissioning activities, which included mobilization and training of personnel and facility preparation (removal of clean debris and limited hazardous material removal). Dismantlement activities started in January 2013, and were completed in October 2013. BMRCs DOC and DC have completed dismantlement and decontamination activities and conducted free release surveys of the building.

2. Research and Test Reactor Decommissioning

a. Inspection Scope

(Inspection Procedure 69013)

An announced inspection was conducted on October 28-31, 2013, at the BMRC, in Buffalo, New York. The inspection consisted of observations by the inspector, interviews with BMRC and contractor personnel, review of work plans and records, and a confirmatory survey for the free release of the building, and collection of soil samples.

The NRC contracted with ORAU to perform the confirmatory survey of the building and perform analysis of soil samples obtained by the inspectors. ORAU provided their survey results and soil analysis results in a report, Independent Confirmatory Survey Summary and Results for the Buffalo Materials Research Center, Buffalo, New York dated July 24, 2014 (ADAMS Accession Number: ML14206A989). The NRC's program for overseeing the safe decommissioning of a RTR is described in IMC 2545, "Research and Test Reactor Inspection Program.

b. Observations and Findings

The inspectors reviewed BMRCs organization and temporary staffing to determine if it satisfied the DP requirements, license, and technical specification (TS) requirements.

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The inspectors verified that BMRC adequately provided oversight and control of the DOC and DC. The inspectors reviewed work plans and records of decommissioning activities and determined they had been implemented as specified in the DP and TS.

The inspector verified that BMRC and its contractors radiation protection and As Low As Reasonably Achievable (ALARA) programs were being maintained in accordance with site procedures, DP, and NRC regulations. The inspectors reviewed radiation work permits (RWPs) and verified that areas were posted for the radiological conditions in accordance with the requirements in 10 CFR Part 20. The inspectors determined that radiation instrumentation calibrations were current and also reviewed dosimetry records.

The inspectors reviewed waste disposal records for completed radioactive waste shipments to determine if the records and manifests met the NRC and Department of Transportation (DOT) regulations.

Building Free Release Surveys BMRC had surveys performed for the free release of the building. The release criteria for the building are based upon detectable contamination levels provided in NRC IE Circular 81-07 (Control of Radioactively Contaminated Material), and as specified in the DP. As described in IE Circular 81-07, detectable levels of contamination are defined as total beta-gamma surface activity levels greater than 5,000 dpm/100 cm2 and removable surface activity levels greater than 1,000 dpm/100 cm2, based on the detection sensitivity of common survey instruments at the time of publication. During the confirmatory surveys, ORAU identified eleven areas where surface activity levels exceeded the release criteria. BMRC immediately remediated the areas of elevated activity and then re-surveyed the areas and found them to be below the release criteria. ORAU also found some concrete blocks stored outside the 10k tank room that had elevated activity levels.

BMRC surveyed the blocks and disposed of those blocks with elevated activity levels as radiological waste. During the review of the BMRC survey package, ORAU noted two areas of concern. First, areas with activity greater than the release criteria had been found in areas classified in accordance with the guidance in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) as Class 2 or Class 3 survey areas.

These areas were considered misclassified and should have been classified as MARSSIM Class 1 survey areas. Second, BMRC used a surface efficiency of 0.50 for the survey calculations. A surface efficiency of 0.25 would have been more appropriate per the guidance in ISO 7503-1, Evaluation of Surface Contamination - Part 1.

BMRC reclassified the areas in question and performed additional surveys using the more appropriate surface efficiency of 0.25. The additional surveys were submitted to the NRC for review. Along with the additional survey data, BMRC sent information clarifying the following technical issues: selection of release criteria, statistical analysis, assessment of areas exceeding investigational limits, and assessment of the number of sampling points. The additional BMRC submissions reviewed for this report were dated May 15, May 22, June 5, and June 25, 2014.

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The only remaining areas reported to have contamination levels greater than the release criteria are load-bearing columns and embedded pipes. These areas have been marked with fluorescent paint and will be removed as radiological waste during building demolition. The list of areas to be removed as radiological waste is included with the most recent BMRC submission (ADAMS Accession Number: ML14181B121). The NRC staff intends to perform inspection activities during the building demolition.

Soil Sample Analysis NRC inspectors collected seven soil samples from areas around the building considered non-impacted and three soil samples from the tank farm area. Prior to the collection of the soil samples, BMRC had excavated and removed the tanks and found that one of the tanks had leaked. The bottoms of the excavated areas were remediated and then temporarily backfilled with soil that had been removed during the tank excavations. All of the soil samples were analyzed by gamma spectroscopy for gamma-emitting radionuclides of concern and six of the ten samples, including the three from the tank farm area, were analyzed for Sr-90. The results of the sample analysis indicated all three of the soil samples from the tank farm area were above the DP screening value for Sr-90 and two of the samples were above the DP screening value for Ag-108m. The seven soil samples from the non-impacted areas did not indicate elevated activities for radionuclides of concern. It should be noted the soil samples were taken for informational purposes only. The tank farm area has not yet undergone final remediation and survey for release by BMRC.

c. Conclusions

Based on inspections and independent surveys and sampling conducted by Region I staff, NRC headquarters staff, and ORAU personnel, the results of the confirmatory surveys were consistent with the licensees survey results. The licensee adequately surveyed the facility and applied the free release criteria in accordance with the DP.

With the exception of a few specific areas that have been identified for later radiological control and disposal of any radiological wastes identified during building demolition, the building is acceptable for free release.

Based on the results of this inspection, no findings of safety significance were identified.

3. Exit Meeting

The results of the on-site portion of the inspection were discussed with Dave Vasbinder, BMRC Director, and other members of the BMRC staff, on October 31, 2014. The final inspection results were discussed with Dave Vasbinder on August 6, 2014, following the review of all BMRC submissions.

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SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

Mark Adams, Safety Engineer

Jeff Slawson, RSO

Dave Vasbinder, Director

Rob Weller, Project Manager

Enercon Services

Frank Brown, Project Manager

ORAU

Nick Altic, Survey Group

Mike Boice, Survey Group

James Viars, Survey Group

INSPECTION PROCEDURE USED

Inspection Procedure 69013, Research and Test Reactor Decommissioning

ITEMS OPEN, CLOSED, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED

5177-PL-01-Draft, Project Specific Plan for Confirmatory Surveys Associated with Buffalo

Materials Research Center - ORISE

ALS Environmental GC/MS Semivolatiles Case Narrative, Work Order Number: 1305456

Buffalo Materials Research Center, Building Survey Summary, August 2013; September 2013;

and October 2013

Buffalo Materials Research Center, Radiation Safety Inspection Report, August 2013;

September 2013; and October 2013

Decommissioning Curtailment Operations, Operating Procedure #10, 11/14/2013

Drawing 12-UNY-172.DWG, Proposed Utility Removal and Capping Plan

Guidance for Pre-Demolition Surveys of the BMRC, Rev. 0

NRC Form 540, Uniform Low-Level Radioactive Waste, Manifest Numbers: 005343027FLE;

25-02-0014, 0015, 0016, 00170018, 0019; 0625-03-0001; MSC-002; UB-ES-019, 020, 021

Report of Analysis/Certificate of Conformance, 7/12/2013 and 9/27/2013, Teledyne Brown

Engineering, Inc.

Reactor Decommissioning Safety Committee Meeting Minutes, August 2, 2013

RWP-BMRC-017

Summary of Radiation Exposures at BMRC, 7/01/2013 - 9/30/2013, Draft

UB-WCD-OP-07, Utility Isolation Work Plan

University of Buffalo, Supplemental Survey Documentation, dated, May 14, 2014; May 22, 2014;

June 5, 2014; and June 25, 2014

LIST OF ACRONYMS USED

BMRC Buffalo Materials Research Center

DC Demolition Contractor

DOC Design and Oversight Contractor

DP Decommissioning Plan

IMC Inspection Manual Chapter

MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual

NRC Nuclear Regulatory Commission

ORAU Oak Ridge Associated Universities

RTR Research and Test Reactor

RWP Radiation Work Permit

Attachment

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