ML12054A119

Buffalo Materials Research Center, Decommissioning Plan

ML12054A119
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Site:	University of Buffalo
Issue date:	02/06/2012
From:	Enercon Services
To:	University of Buffalo, NRC/FSME/DWMEP
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Download: ML12054A119 (239)

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Decommissioning PlanBuffalo Materials Research CenterPrepared for:Buffalo Material Research CenterOffice of Environment, Health, and Safety ServicesCompleted by:4490 Old William Penn HighwayMurrysville, PA 15668February 6, 2012 BMRC Decommissioning PlanRevision 0Prepared By:ENERCON Date:Reviewed By:Date:2/6/2012Robert SandersSenior Technical SpecialistReviewed By:Date:2/6/2012Kurt ColbornSenior QASpecialistApproved By:Date:2/6/2012Dustin G. Miller, CHPDOCProject Manager BMRC Decommissioning PlanRevision 0 i

SUMMARY

OF CHANGESRevisions to the Decommissioning Plan will be tracked when revisions are issued. Changed sections will be identified by special demarcation in the margin. A summary description of each revision will be noted in the following table.Revision NumberDateDescription of Change0February 6, 2012Initial Issue BMRC Decommissioning PlanRevision 0 iiTABLE OF CONTENTS PAGEACRONYMS AND ABBREVIATIONS....................................................................................................V1.0

SUMMARY

OF DECOMMISSIONING PLAN............................................................................11.1Introduction............................................................................................................................11.2Background............................................................................................................................21.2.1Reactor Decommissioning Overview.......................................................................181.2.2Estimated Cost..........................................................................................................191.2.3Availability of Funds................................................................................................201.2.4Program Quality Assurance......................................................................................202.0DECOMMISSIONING ACTIVITIES...........................................................................................232.1Decommissioning Alternatives............................................................................................232.1.1SAFSTOR Alternative..............................................................................................232.1.2ENTOMB Alternative..............................................................................................232.1.3DECON-AAlternative.............................................................................................232.1.4DECON-BAlternative..............................................................................................242.2Facility Radiological Status.................................................................................................242.2.1Facility Operating History........................................................................................242.2.2Current Radiological Status of the BMRC Facility..................................................252.2.3Release Criteria.........................................................................................................2 72.3Decommissioning Tasks......................................................................................................3 12.3.1Activities and Tasks..................................................................................................312.3.2Schedule....................................................................................................................362.4Decommissioning Organization and Responsibilities.........................................................372.4.1University Project Manager......................................................................................382.4.2BMRC Director........................................................................................................382.4.3Radiation Safety Officer...........................................................................................392.4.4Reactor Decommissioning Safety Committee..........................................................392.4.5Design and Oversight Contractor.............................................................................392.4.6Demolition Contractor..............................................................................................402.5Training Programs...............................................................................................................422.5.1General Site Training................................................................................................422.5.2Radiation Worker Training.......................................................................................422.6Contractor Assistance..........................................................................................................442.7D&D Documents and Guides..............................................................................................453.0PROTECTION OF WORKERS AND THE PUBLIC..................................................................473.1Radiation Protection.............................................................................................................473.1.1Ensuring ALARA Radiation Exposures...................................................................48 3.1.2Health Physics Program............................................................................................483.1.3Dose Estimates.........................................................................................................523.2Waste Management..............................................................................................................53 3.2.1Fuel Removal............................................................................................................553.2.2Radioactive Waste Processing..................................................................................55 3.2.3Radioactive Waste Disposal.....................................................................................55 BMRC Decommissioning PlanRevision 0iii3.2.4General Industrial Safety Program...........................................................................573.3Radiological Accident Analyses..........................................................................................583.3.1Fire............................................................................................................................583.3.2Spill Contaminated Water.........................................................................................593.3.3Release of Airborne Contamination.........................................................................593.3.4Transportation Accidents..........................................................................................604.0PROPOSED FINAL STATUS SURVEY PLAN..........................................................................614.1Survey and Sampling Approach..........................................................................................614.2Data Quality Objectives.......................................................................................................624.3Identification and Classification of Survey Units................................................................624.3.1Method for Classification.........................................................................................62 4.3.2BMRC MARSSIM Classifications...........................................................................644.4Data Collection....................................................................................................................644.4.1Buildings, Equipment, and Components..................................................................644.4.2Soils..........................................................................................................................644.4.3Bedrock.....................................................................................................................654.4.4Bedrock Surface Scans.............................................................................................654.5Data Evaluation....................................................................................................................654.6Final Status Survey Report..................................................................................................

665.0TECHNICAL SPECIFICATIONS................................................................................................676.0PHYSICAL SECURITY PLAN....................................................................................................687.0EMERGENCY PLAN...................................................................................................................698.0ENVIRONMENTA L REPORT.....................................................................................................709.0CHANGES TO THE DECOMMISSIONING PLAN...................................................................71

10.0REFERENCES

..............................................................................................................................72APPENDIX A -ACTIVATION ANALYSIS ANDCOMPONENT CHARACTERIZATIONAPPENDIX B -SITE CHARACTERIZATION REPORTAPPENDIX C -DECOMMISSIONING ENVIRONMENTAL REPORT BMRC Decommissioning PlanRevision 0 ivLIST OF TABLESTable 1-1 Decommissioning Cost Estimate

................................................................................................20Table 2-1 Estimated Volumes and Masses of Radiologically Impacted Components and Systems

..........26Table 2-2 NRC License Termination Screening Levels for Surface Soils

.................................................28Table 2-3 NRC License Termination Screening Levels for Building (Bedrock) Surfaces

.........................29Table 2-4 Ag-108m Surface Soil Screening Value

.....................................................................................30Table 2-5 Ag-108m Building Surface Screening Value

.............................................................................30Table 3-1 BMRC Radionuclides of Concern as determined in the Site Characterization Report

..............47Table 3-2 Health Physics Instrumentation

..................................................................................................50Table 3-3 Project Dose Estimate

.................................................................................................................53Table 4-1 Recommended Survey Unit Sizes

..............................................................................................63LIST OF FIGURESFigure 1-1 Location of BMRC on the UB South Campus

............................................................................1Figure 1-2 Artist's Rendering -Interior Cut Away View of the Reactor and Containment

........................6Figure 1-3 Control Deck Plan View

.............................................................................................................7Figure 1-4 Gamma Deck Plan View

.............................................................................................................8Figure 1-5 Neutron Deck Plan View

.............................................................................................................9Figure 1-6 Reactor Plan View -Control Deck Level

.................................................................................11Figure 1-7 Reactor Plan View -Gamma Deck Level

.................................................................................12Figure 1-8 Reactor Plan View -Neutron Deck Level

................................................................................13Figure 1-9 Reactor/Bioshield Elevation View (Northeast Direction)

.........................................................13Figure 1-10 Reactor/Bioshield Elevation View (Southeast Direction)

.......................................................15Figure 2-1 Proposed Project Schedule

........................................................................................................37 BMRC Decommissioning PlanRevision 0 vACM Asbestos Containing MaterialACRONYMS AND ABBREVIATIONSAECAtomic Energy CommissionALARAAs Low As Reasonably AchievableALIAnnual Limit on IntakeARAAirborne Radioactivity AreaBMRCBuffalo Materials Research CenterBSFRBulk Survey for ReleaseC&DConstruction and DemolitionCEDECommitted Effective Dose EquivalentCFRCode of Federal Regulations

cm 2D&DDecontamination and Decommissioningsquare centimeterDAWDry Active WasteDCDemolitionContractorDCGLDerived Concentration Guideline LevelsDDEDeep Dose EquivalentDECON-Acomplete decontamination and structure demolition option DECON-Bcomplete decontamination and release of the structure optionDCFDose Conversion FactorDOCDesign and Oversight ContractorDOEUnited States Department of EnergyDOTDepartment of Transportation DPDecommissioning PlandpmDisintegration per minuteDQOData Quality ObjectivesEH&SEnvironment, Health and SafetyENTOMBEntombment optionEREnvironmental ReportFEMAFederal Emergency Management AgencyFGRFederal Guidance ReportsFSSFinal Status SurveyHASPHealth and Safety Program HAZWOPERHazardous Waste Operations and Emergency Response BMRC Decommissioning PlanRevision 0 viHEPAHigh Efficiency Particulate AirHICHigh Integrity ContainerHMRHazardous Materials RegulationHPHealth PhysicsHRAHigh Radiation AreaHSAHistorical Site Assessment HVACHeating, Ventilation, and Air ConditioningICSIncident Command SystemIFIrradiation FacilityINEELIdaho National Engineering and Environmental LaboratoryISOInternational Standards Organization LLRWLow-Level Radioactive WasteLSALow Specific ActivityLSCLiquid Scintillation CountermmeterMARSSIMMulti-Agency Radiation Survey and Site Investigation ManualMDCMinimum Detectable Concentration MW tmremMilliremMegawattThermalMSHAMine Safety and Health AdministrationMTRmaterials-testing-reactorN-16Nitrogen-16NaISodium Iodide NEINuclear Energy InstituteNEPANational Environmental Policy ActNIOSHNational Institute for Occupational Safety and HealthNISTNational Institute of Science and TechnologyNMSSNuclear Material and Safety and Safeguards NRCUnited States Nuclear Regulatory CommissionNSTCNuclear Science and Technology CenterN2S2Nevada National Security Site NUREGNuclear Regulatory GuideNYS DOHNew York State Department of HealthpCi/gpicocuries per gramP.E.Professional Engineer BMRC Decommissioning PlanRevision 0viiPMProject ManagerPuBePlutonium-BerylliumPULSTARPulse Training Assembled ReactorOSHAOccupational Safety and Health ActQAQuality AssuranceQAPPQuality Assurance Program Plan QCQuality ControlRARestricted AreaRDSCReactor Decommissioning Safety CommitteeRPRadiation ProtectionRPMRadiation Protection ManagerRSORadiation Safety OfficerRWPRadiation Work PermitsSAFSTORNo-Action AlternativeSNMSpecial Nuclear MaterialSCRSite Characterization ReportSSCStructures, Systems, and ComponentsSUNYState University of New York TEDETotal Effective Dose EquivalentTLDThermoluminescent dosimeterUBUniversity at BuffaloUBPMUniversity at Buffalo Project ManagerWRSWilcoxon Rank-Sum yryear BMRC Decommissioning PlanRevision 0 1 1.01.1Introduction

SUMMARY

OF DECOMMISSIONING PLANThe Buffalo Materials Research Center (BMRC) is owned by The State University of New York (SUNY) at Buffalo (UB) and is located on the southern edge of the South Campus of UB off of Rotary Drive in Buffalo, Erie County, New York. The BMRC was a Research and Test Reactor Facility with a pool-type reactor that was designed and constructed by AMF Atomics between 1959 and 1961. The initial criticality date for the reactor was March 24, 1961, while the last day of operation occurred on June 23, 1994. The unit has been in Possession Only status since June 6, 1997. In 1998 the unused fuel was shipped to North Carolina State University. In 2005 the spent fuel was shipped to the Idaho National Engineering and Environmental Laboratory. The BMRC is being decommissioned because there is no future need for the facility.UB is about 20 miles south of the Canadian border at Niagara Falls, New York, 90 miles west of Rochester, New York and 80 miles from the southern border of New York and Pennsylvania. UB is about five miles east of the Niagara River which is a border with Canada. Figure 1-1 shows the location of the BMRC on the UB South Campus. Figure 1-1 Location of BMRC on the UB South Campus BMRC Decommissioning PlanRevision 0 2This Decommissioning Plan (DP) has been prepared in accordance with Chapter 17 of the Nuclear Regulatory Commission (NRC)NUREG-1537 Part 1,Guidelines for Preparing and Reviewing Applications for Licensing of Non-Power Reactorsand NUREG-1757,Consolidated Decommissioning Guidance. This Decommissioning Plan provides guidance on the general process and methods to be used to safely decontaminate, remove and dispose of radioactive materials, equipment, systems, components, and soil associated with the BMRC. Decommissioningactivities will result in the complete removal of the BMRC structures from the site location allowing an unrestricted release of the BMRC site by the NRC and be granted termination of the NRC license as allowed by Title 10, Code of Federal Regulations (CFR), Part 20, Section 1401 (10 CFR 20.1401). Decommissioning Plan SynopsisDecommissioning will be performed in a safe and orderly manner to prevent undue radiation exposure to the workers, public, and environment. Remediation and demolitiontasks include 1) the removal of the reactor core and activated bioshield; 2) removal of reactor and facility systems containing residual radioactive materials; 3) removal of ventilation systems; 4) remediation of concrete surfaces; and 5) disposition of building structural concrete and steel. All structures of the building and facility piping are planned to be removed in their entirety. A final status survey (FSS) will be implemented to demonstrate compliance with default derived concentration guideline levels (DCGLs) in support of the unrestricted release of the site and termination of the facility.1.2BackgroundThe reactor at the BMRC was operated by SUNY at Buffalo under an operating license from the NRC. The reactor at UB was placed into operation in 1961 under License Number R-77 and operated until 1 963 with materials-testing-reactor (MTR) fuel elements with a maximum steady-state power level of 1megawatts thermal (MWGeneral t). In 1964 the reactor was shut down and the core and control systems were modified so that the reactor could operate with Pulse Training Assembled Reactor (PULSTAR) fuel at power levels of up to 2MW tThe UB ceased operations of the reactor on June 23, 1994, and shipped the unused PULSTAR fuel to North Carolina State University in 1998. In 2005, UB with the assistance of theU.S. Department of

.

BMRC Decommissioning PlanRevision 0 3Energy (DOE) shipped the used PULSTAR fuel to the DOE at the Idaho National Engineering and Environmental Laboratory (INEEL).The BMRC currently maintains two NRC Licenses, a Possession Only License (R-77) and a Special Nuclear MaterialLicense (SNM-273) for possession of a Plutonium-Beryllium (PuBe) neutron source; however, this source has been transferred to the UB'sNew York State Department of Health (NYS DOH) agreement state license. In addition to the PuBe source, the NYS DOH license (#1051) authorizes the possession of byproduct materials for calibration and check sources as well as byproduct materials from reactor operations. The reactor was constructed in 1959 and 1960 under Atomic Energy Commission (AEC) Construction Permit No. CPRR-39 and went critical on March 24, 1961. The original licensed power was 1MWHistory twith an original core loading of MTR fuel. The MTR Fuel was replaced with PULSTAR fuel in 1964 and the facility license was amended to operate at 2 MW tDuring its operating history, the BMRC was used for training and education, transient fuel performance testing, nuclear component testing and calibration, materials radiation damage research, isotope production, and neutron interrogation through activation analysis, radiography and delayed fission assay.

.The following is a chronological history of significant licensing events:1959-Initial construction commenced under AEC License # R-77.Licensee name: The Western New York Nuclear Research Center1961-Construction completed in January1961-Initial criticality achieved on March 24 at 2051 hours0.0237 days <br />0.57 hours <br />0.00339 weeks <br />7.804055e-4 months <br /> Full power first achieved on June 1 at 1220 hour0.0141 days <br />0.339 hours <br />0.00202 weeks <br />4.6421e-4 months <br />s1964-Reactor modifications to utilize PULSTAR fuel; Used MTR fuel transferred to McMaster University in Ontario, Canada in AprilInitial criticality of PULSTAR core achieved June 22 at 2112 hours0.0244 days <br />0.587 hours <br />0.00349 weeks <br />8.03616e-4 months <br />;1973-Facility name change: Nuclear Science and Technology Center (NSTC) 1984-Vertical 10k tank placed into service; Tank Farm placed into wet layup1985-Facility name change: Buffalo Materials Research Center1991-Reactor and Primary Coolant System modified to present configuration1994-Reactor activities suspended; Last shutdown on June 23 at 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />; 1997-NRC license R-77 amended to Possession Only Status 1998-Unused PULSTAR fuel shipped to North Carolina State University in July2005-Used fuel shipped to Idaho National Engineering and Environmental Laboratory BMRC Decommissioning PlanRevision 0 4The reactor is a PULSTAR heterogeneous open-pool type water cooled reactor that used solid 6% enriched uranium dioxide fuel clad in Zircaloy similar to commercial nuclear power reactor fuel. The core was cooled by forced convection at higher power levels and by natural convection at lower power levels.

The coolant is purified water and the reflector is water and/or graphite.Reactor DescriptionThe core is immersed in a 13,000-gallon aluminum alloy lined pool surrounded by both high density and regular density concrete. Original design specifications used water to cool the core. The water exited the reactor at the pool bottom and wasthenpumped to a 5,000-gallon Nitrogen-16 (N-16) holdup tank for decay. The water then cycled through a heat exchanger connected to an externalcooling tower located on the southeast side of the Administration Building (Laboratory Wing). The cooled water was then circulated back to the top of the pool. In October 1977 a leak developed in the primary cooling pipe. The leak was repaired by June of1978 and reactor operations resumed. In 1989 a reoccurrence of a leak at the point where the coolant piping penetrated the bottom (horizontal portion) of the reactor liner directly under the reactor led to the decision that modifications needed to be made. These modifications were completed in 1991 and included adding a second aluminum alloy liner on the Neutron Deck level and rerouting the coolant piping through the original twelve-inch beam tube,just above the floor of Neutron Deck level of the Containment Building. The coolant piping on the Neutron Deck is shielded by high density concrete blocks until it penetrates through the containment wall into the N16 Tank Vault.All nuclear fuel has been removed from the site. The reactor and its associated components remain in the pool in the normal operational configuration. Reactor components removed during repairs completed in 1991were stored behind concrete block shielding on the Neutron Deck. These reactor components were removed during the pre-decommissioning cleanout and buried at the EnergySolutions Clive, UT facility..Associated with the reactor within the Containment Building are the following Irradiation Facilities:Flux TrapIsotope TubeVertical StandpipeThermal ColumnPneumatic ConveyorElectron Accelerator BMRC Decommissioning PlanRevision 0 5The BMRC Facility consists of the reactor described above, the Containment Building which encloses the reactor and associated facilities related to use of the reactor, as well as the Administrative Building which contains offices, class rooms, and laboratories. The Administration Building is also referred to as the Laboratory Wing.BMRC FacilityContainment BuildingThe reactor is housed in a tri-level Containment Building as shown in an artist's rendering of the interior of the original Containment Building in Figure 1-2. The three levels (from top to bottom) of the Containment Building include the Control Deck, the Gamma Deck, and the Neutron Deck. Plan views of the Control Deck, Gamma Deck, and Neutron Deck are shown on Figure 1-3, Figure 1-4, and Figure 1-5 respectively. The Containment Building was constructed of reinforced concrete and in a right cylinder shape. The cylindrical Containment Building is approximately 75feet in diameter and 52 feet high with walls that are two-foot thick reinforced concrete. The roof of the Containment Building varies from four to nine inches in thickness and is supported by concrete beams. The walls and the foundation of the Containment Building are constructed onbedrock.Within the Containment Building are the following additional facilities:Hot Cell and Hot Cell Work Room (Room 105)Dry Chamber (Neutron Deck Level)Charpy Cell (Neutron Deck level) (Removed)Hot and Warm Chemistry Labs (Rooms 103, 104, and 108)Neutron Activation Analysis and Counting Lab (Room 109)Other Labs (Rooms 202, and 203)Electronics Shop (Room 200)

BMRC Decommissioning PlanRevision 0 6Figure 1-2 Artist's Rendering -Interior Cut Away View of the Reactor and ContainmentFigure 1-2 Legend:1.Bioshield2.Reactor Plenum3.Thermal Column Plug4.Beam Tube 5.Thermal Column Support 6.Thermal Column Graphite Blocks7.Thermal Column Support Plate8.Thermal Column 9.Flux Trap 10.Beam Tube Chamber 11.Reactor12.Coolant Outlet Plenum13.Coolant Outlet Piping 14.Reactor Pool Lining 15.Vertical Standpipe16.Pneumatic Conveyor Tube17.Isotope Tube 18.Isotope Tube Drive Mechanism 19.Operating Platform20.NA21.Hot Cell22.Hot Cell Crane and Rail23.Pass Tube Isolation Valve24.Hot Cell Lead Shutter 25.Hot Cell Lead Shutter Drive Mechanism 26.Hot Cell Remote Manipulators27.Radiation Shielding Window28.Hot Cell Instrumentation Access Port 29.Hot Cell Removable Access Plug 30.Dry Chamber 31.NA32.Removable Metal Plate Floor Opening Cover33.Pass Tube Isolation Valve Hand Wheel 34.Control Deck Airlock (Access to/from Administration Building)

BMRC Decommissioning PlanRevision 0 7Control DeckThe top level of the Containment Building is called the Control Deck. A plan view of the Control Deck is shown on Figure 1-3. The Control Deck houses a dual-hook overhead crane (with a 10-ton and 2-ton hook) at the ceiling level. Crane access to the Gamma Deck is through three floor openings shown on Figure 1-3. Two of the floor openings are covered with removable metal plates. In addition to the reactor pool, the Control Deck houses the Reactor Control Room (Room 205), Superintendent's Office (Room 207), two labs (Rooms 202 and 203), Fan Room (Room 204), another office (Room 206), Electronics Shop (Room 200), and the New Fuel Storage Room in the airlock (Room 201B). The airlock provides for access to the upper level of the Administration/Laboratory Building. Figure 1-3 Control Deck Plan View BMRC Decommissioning PlanRevision 0 8Gamma DeckThe middle level of the Containment Building is called the Gamma Deck. A plan view of the Gamma Deck is shown on Figure 1-4. The Hot Cell, Hot Cell Work Room (Room 105), Locker Room (Room 106), Room 107, Hot Chemical Lab (Room 108), Medium Chemical Lab (Room 104), Activation Analysis Lab (Room 109), Lower Fuel Vault Room (Room 101A), and Chemical Lab (Room 103) are located on the Gamma Deck. This level also has an Airlock (Room 101) for access to the bottom level of the Administration Building and a truck door for access to the asphalt drive located on the southern side of the Containment Building. TheTruck Door providesvehicular and equipment access to the outside. Prior to 1979, the Truck Door area housed a waste compaction system. Wastesgenerated at the BMRC (NSTC at the time) and under the site-wide radiological program were collected and compacted for volume reduction in this system.Analysis activities involving the use of mercury in conjunction with radiological constituents occurred in the Activation Analysis room. Mercury may be present in the fume hoods in this room and in the low points or traps in waste drain lines. Figure 1-4 Gamma DeckPlan View BMRC Decommissioning PlanRevision 0 9Neutron DeckThe lower level of the Containment Building is called the Neutron Deck. A planview of the Neutron Deck is shown on Figure 1-5. The Neutron Deckisan open area divided by fencing into two sections.

The enclosed (fenced) portion of the Neutron Deck, shown in red hatch in Figure 1-5,is currently a high radiation area (HRA). The HRA is being used to store reactor components removed from the reactor during repairs made in 1991 due to a leak in the reactor liner. These reactor components (Thermal Column Nosepiece, Dry Chamber Nosespiece, Grid Plate Bolts, and Neutron Beam Tube ends) were replaced with new items of similar. The rerouted Primary Coolant piping, 18,000 lbs of Depleted Uranium Shield block,and access to the beam storage tubes is also in the HRA. The beam storage tubes extend ten feet through the Containment Building wall into the surrounding soil. They are used as storage-for-decay of high dose reactor components or experiments. At the point where the tubes exit the Containment Building wall, they are approximately ten feet underground. Figure 1-5 Neutron Deck Plan View BMRC Decommissioning PlanRevision 0 10Reactor, Bioshield, Dry Chamber,and Hot CellThe reactor, bioshield, dry chamber, and hot cell are located inside the Containment Building and portions are located on the various levels of the building. Figure 1-6, Figure 1-7, and Figure 1-8 contain plan views of these items on each level of the Control Deck, Gamma Deck, and Neutron Deck respectively. Figures 1-9 and 1-10 provide elevation views of the reactor and bioshield. These figures reflect the original setup of the reactor and do not include modifications to the reactor tank and coolant piping in 1977 or the tank modification completed in 1991.The bioshield consists of high density concrete with metal aggregate in lieu of typical stone aggregate. The bioshield section on the Gamma deck facing the Truck Door consists of removable concrete blocks set in place by the facility crane. The remaining sections of the bioshield were cast in place after the entire reactor tank, beam tubes, and piping were constructed. It should be noted that floors and floor supports were poured in place concurrently with the Containment Building walls. Therefore, the Gamma Deck and Control Deck floors donot appear to be structurally supported by the reactor bioshield. The structural independence between the bioshield and the floors shouldbe verified by a New York State Professional Engineer using the original facility design drawings and the chronological historical photosbefore bioshield demolition.

BMRC Decommissioning PlanRevision 0 11Figure 1-6 Reactor Plan View -Control Deck Level BMRC Decommissioning PlanRevision 0 12Figure 1-7 Reactor Plan View -Gamma Deck Level BMRC Decommissioning PlanRevision 0 13Figure 1-8 Reactor Plan View -Neutron Deck LevelFigure 1-9Reactor/Bioshield Elevation View (Northeast Direction)

BMRC Decommissioning PlanRevision 0 14 BMRC Decommissioning PlanRevision 0 15Figure 1-10 Reactor/Bioshield Elevation View (Southeast Direction)

BMRC Decommissioning PlanRevision 0 16Ventilation System (Containment Building)Air from the Heating, Ventilation, and Air Conditioning (HVAC) system from the portions of the Containment Building which housed the medical facilities, hot cell, hot chemistry laboratory, beam storage tubes, rabbit tubes, and the thermal column was discharged via underground piping to the 167-foot high stack on the Mackay Heating Plant located southeast of the BMRC facility (see Figure 1-1). Portions of this piping have been removed during renovation of Rotary Road as detailed in theHistorical Site Assessment (HSA).The remainder of the Containment Building ventilation passes through a bank of roughing and absolute filters prior to being discharged from a point on the southeast side of the Containment Building roof.Per the facilityTechnical Specifications, ventilation ducts were designed with hydraulic dampers that would isolate the Containment Building from the Administration Building and the outside areas if alarms indicated an airborne event. Liquid Waste System (Containment Building)

Prior to 1984, liquid waste from the hot cell drain, hot chemistry laboratory, and service area drains was collected in the two 250-gallon tanks located in the tank farm (see Figure 1-5). The tank farm is an underground facility located southeast of the Containment Building. Liquid waste from the Gamma Deck and Control Deck laboratories, change area sinks, and Truck Lock door drain were collected in the two 600-gallon tanks located in the tank farm. Administration Building (Laboratory Wing)

The Administration Building may also be referred to as the Laboratory Wing in this document. Within the Administration Building are the following facilities:Vertical Accelerator (Room 115A)Horizontal Accelerator and Counting Cave (Room 118)Health Physics Office and Counting Room (Room 114)Low Level Labs with Fume Hoods (Rooms 213, and 215)Machine Shop (Room 113)Upper Level -Administration BuildingA plan view of the upper level of the Administration Building is shown on Figure 1-3. The upper level of the Administration Building housed the Men's Locker and Change Room (Room 209) and Men's Bathroom (Room 209B), Women's Locker and Change Room (Room 221) and Women's Bathroom BMRC Decommissioning PlanRevision 0 17(Room 221A), Conference Room (Room212), offices (Room208, Room210, Room214, and Room216), Reception Area (Room208A), Janitor's Closet (Room 209A) and two low level laboratories (Room213 and Room215). There is a fume hood in Room213 and Room215. Based on characterization, there has been little to no radiological impact to the upper level of the Administration Building. Basement Level -Administration BuildingA plan view of the basement level of the Administration Building is shown in Figure 1-4. On the basement level of the Administration Building is housed a Horizontal Accelerator (Room 118) with an adjacent cave area. This level also contained a laboratory (Room 115), Classroom (Room 117), Health Physicist Office and Counting Room (Room 114), The Vertical Accelerator Room (Room 115A),

Machine Shop (Room 113), and Air Conditioning Equipment Room (Room 111). The Electrical Service Room (Room110) is also located on this level. A utility tunnel is located north of the Electrical Service Room (Room 110). The utility tunnel connects to the Campus Service Tunnel system and is locked to prevent access. Subbasement -Administration BuildingA plan view of the subbasement of the Administration Building is shown on Figure 1-5. The subbasement level is located under the western portion of the basement. The eastern portion of the basement levelis supported by caissons and grade beams. The subbasement contains the 5,000-gallon Nitrogen-16 Holdup Tank Room (Room N16), Cooling Water Equipment Room and Sump Pit Room (Room N03), lower Air Conditioning Equipment Room (Room N02) and adjacent area way,Air Handling Duct Room (Room N04), and access to the vertical 10,000-gallon tank room (Room N05) as well as the vertical 10,000-gallon tank room. The floor of Room N16 is located on bedrock. Ventilation System (Administration Building)Air from the HVAC system located in the Administration Building is vented through high efficiency particulate air (HEPA) filters to the roof of the building except for the Machine Shop (Room 113) and Vertical Accelerator Room (Room 115A) fume hoods. Air from these two fume hoods is vented via a duct on the southeast side of the Administration Building.

BMRC Decommissioning PlanRevision 0 18Liquid Waste System (Administration Building)Liquids from the bathrooms, floor drains, sinks, and fume hood drains in the Administration Building are discharged to the South Campus sanitary system. Experiments in the Administrative Building have involved use of H-3 and C-14 in the upper level laboratories (Room 213 and Room 215) fume hoods and H-3 in the Health Physicist Office and Counting Room (Room 114) fume hood.1.2.1Reactor Decommissioning OverviewUB plans to completely dismantle the reactor and its ancillary support systems, remove radioactive materials from the BMRC, and demolish the facility prior to requesting the termination of license R-77.

The facility is being demolished because there is no future need for the facility.Most of the reactor components and systems are either activated or contaminated and will need to be segregated from non-radiological components and surfaces so that they can be disposed of as low-level radioactive waste (LLRW). The BMRC is primarily constructed of concrete and a vast majority of the waste generated during the decommissioning will be concrete rubble from demolition activities. Waste is disposed of based on characterization for radiological constituents. Based on characterization results, it is anticipated that almost all of the structural concrete will be sent for concrete recycling or will be sent to a local industrial landfill. Some concrete, primarily the floor slabs of the subbasement and the Neutron Deck are anticipated to be disposed of as Bulk Survey for Release (BSFR) waste due to the potential for volumetric contamination. Notable exceptions are the concrete associated with the reactor bioshield on the Neutron Deck level as well as the reactor liner and internal components. Some decontamination is expected to be required for the reactor components, bioshield, and hot cell concrete structures that were out of the main neutron activation zone so that the majority ofconcrete and metal from these structures will meet the requirements of BSFR waste. The decommissioning cost estimate assumes that the reactor liner and internal components are to be disposed of as Class A LLRW as shown in AppendixA, BMRC Activations Analysis and Component Characterization, developed by WMG, Inc. of Peekskill, NY while the old Control Blades are to be disposed of as Class B mixed radwaste.The following major decommissioning tasks are necessary for site release. The sequence in which thesetasks occur may vary (see Section 2.3 for more details):Pre-Decommissioning Cleanout -removal of loose legacy equipment and materials (Completed)Isolation and removal of inactive systems (Some prior to approval of DP by the NRC)Removal of hazardous materials (lead, cadmium) and abatement of asbestos containing material (ACM) (Bulk of the materials to be removed prior to approval of DP by the NRC)Perform supplementary characterization (prior to approval of DP by the NRC)

BMRC Decommissioning PlanRevision 0 19Installation of temporary systems and preparation of the facility for decommissioning operations (potentially prior to approval of DP by the NRC)Removal of the irradiated reactor componentsRemoval of and disposition of water in the reactorRemoval of and disposition of the reactor linerDecontamination of concrete associated with reactor, bioshield, and hot and dry cellRemoval of the reactor, bioshield, and hot and dry cellSegregation, packaging and shipment of materials according to radioactivity levelsRemoval of auxiliary systems (rabbit system, water purification, ventilation)Decontamination of building surfacesInterior release survey using Reg Guide 1.86 limitsDemolition of the BMRC facilityPerform the FSS on BMRC footprintSubmit required reports that demonstrates to the NRC that the facility meets the release criteriaRequest license R-77 terminationRestore site: Backfill void created by removing below grade structures for future use by UB.The FSS is to be developed by UB using the criteria provided in NUREG-1575,Multi-Agency Radiation Survey and Site Investigation Manual(MARSSIM) (NRC 2000). An overview of the FSS is provided in Section 4.0 with the Final Status Survey Plan to be submitted and approved prior to commencement.1.2.2Estimated CostThe decommissioning cost estimate is summarized in Table 1-1. It is estimated that approximately $8.9million isrequired to decommission the BMRC. The cost estimate includes the Demolition Contractor (DC) costs, subcontractor costs, and other direct costs. The cost includes the costs of shipping and disposing of waste and the final status survey. The cost estimate is subject to cost increases because there are unforeseeable elements of cost within the defined project scope. A contingency of 20% is included in the decommissioning costs in Table 1-1 to ensure that sufficient funds are available to cover costs that may result from unanticipated conditions or unforeseeable elements in the project scope. Typically, these include factors such as waste disposal rates or increased wastevolumes from undiscovered or uncharacterized areas. In addition, the time duration between the development of the DP and the inception of decommissioning activities can influence the costs associated with changes in the economy and regulatory requirements.

BMRC Decommissioning PlanRevision 0 20Table 1-1 Decommissioning Cost EstimateItem No.DescriptionTOTAL 1Project Planning$ 238,4402Mobilization and Training$ 67,6203Facility Preparation$ 235,4804Neutron Deck remediation and disposal$ 1,792,0925Gamma Deck remediation and disposal$ 221,8826Control Deck remediation and disposal$ 141,9467Administration Buildingremediation and disposal$ 51,0388Waste and HVAC Systemsremediation and disposal $ 983,4299Ancillary systemsremoval and disposal costs$ 406,00010Impacted Soilexcavationand disposal costs$ 99,27011Waste Packaging and Transportation$ 849,80012Demolitionof Administration and Containment Buildings$ 1,801,70013Final Status Survey and Report$ 248,98014Backfill and Site Restoration$ 223,99515Demobilization$ 61,620SUBTOTAL$7,423,292Contingency @ 20%$ 1,484,658TOTAL DECOMMISSIONING COST$ 8,927,9501.2.3Availability of FundsIn accordance with 10 CFR 50.75 (e)(1)(iv), UB is a state institution and as such will provide financial assurance with a statement of intent containing a cost estimate for decommissioning, indicating that funds will be obtained when necessary. The decommissioning of the BMRC is fully funded in the current UB Capital Budget that runs through June 2013. 1.2.4Program Quality Assurance1.2.4.1Independent Contracting and OversightThe UB will select a qualified DC to assist in the physical remediation and dismantlement of the BMRC reactor and associated facilities. In addition, the UB has contracted with a Design and Oversight Contractor (DOC) to provide the UB with Decommissioning Project Management, Health Physics, Safety, Quality, and other oversight support as needed to augment the UB staff in order to meets its license and regulatory obligations during decommissioning. The selected DOC is Enercon Services, Inc.

(ENERCON).The selection of the DOC is discussed in Section 2.6.

BMRC Decommissioning PlanRevision 0 21The dual-contractor approach has beenselected by the UB to assure that decommissioning work activities are subject to continuous and independent compliance oversight. The DOC will report directly to the UB Project Manager (UBPM) for project schedule and cost while reporting to the UB/BMRC Environment, Health and Safety Department in matters affecting quality or safety. The DOC will be responsible for developing a Quality Assurance Project Plan (QAPP) appropriate for the decommissioning of the BMRC and the final status survey. The QAPP will bereviewed and approved by the UB.The DOC shall monitor UB contracted work to assure compliance with the UB's reactor license, the approved DP, and applicable contract requirements and regulations. The DOC will also provide site-specific training [developed and approved by the BMRC Director and Radiation Safety Officer (RSO)] to the selected contractors to assure their familiarity with the requirements of the UB's reactor license and the BMRC DP.1.2.4.2Established Minimum Qualifications for DCThe UB's selection of qualified contractors for the DC role will consider the following criteria as a minimum:a)Ability of the firm to perform the required tasksas demonstrated by past nuclear reactor demolition experience (5 years) of the firm, its field supervisors, and its teaming partners or subcontractors as appropriate.b)Qualifications of key individuals based on education, training, experience and professional licensure.c)The compliance record of the contractor, teaming partners, and key subcontractors; including recordsof any violations or fines for non-compliance with federal, state or local regulations.d)Safety record of the contractor and key subcontractors to include a review of past projects and Occupational Safety and Health Act (OSHA) reportable incidents.e)Relevant experience of contractor, teaming partners, and key subcontractors, particularly with regard to research reactor decommissioning.f)References and recommendations from previous customers/completed projects.g)Financial stability of the contractor and key subcontractors to complete the project and their ability to meet the minimum insurance and bonding requirements.h)Evaluation of the DC's proposed Technical Approach for site demolition.1.2.4.3Quality Assurance Program Plan (QAPP)The DOC will be responsible for preparing and implementing a QAPP to control the decontamination and decommissioning of the BMRC. The QAPP will incorporate industry and regulatory requirements BMRC Decommissioning PlanRevision 0 22applicable to decommissioning project planning and management, decontamination, dismantling, demolition, radiological sampling, analysis, and surveys. The QAPP shall describe the organization, document approval, and quality assurance (QA) aspects for the BMRC decommissioning project, including the following minimum requirements:a)A clear description of the project organization, including a definition of the authorities and responsibilities of key personnel involved in the decommissioning.b)QA actions to be implemented during the BMRC decommissioning project.c)A list of implementing policies and procedures the DOC and DC will use to complete the project, including detailed project work plans for critical project evolutions.d)Work approval, communication, and authority guidelines, including guidelines for the interface of the DC, the DOC, and the BMRC/UB.e)Document control for UB approved work plans and procedures.f)A plan for performing self-monitoring and independent audits of the DOC and DC's activities.g)Maintenance of records for project work, calibration, and characterization data.1.2.4.4ShippingThe DOC will identify appropriate treatment and disposal facilities for wastes generated from the decommissioning project. The DOC will develop a procedure for compliant shipping of BMRC wastes, identifying methods of compliance with 10 CFR 71 subpart H and Department ofTransportation (DOT)

Hazardous Materials Regulations (HMR) as appropriate. The DOC is responsible for waste sizing, characterization, segregation, and packaging. The QAPP and associated procedures will address quality requirements for waste preparation and packaging activities.1.2.4.5Final Status Survey QAPPThe DOC will develop a QAPP specific to the performance of the FSS and associated documentation (e.g. characterization information used in the design of the final survey). The FSS QAPP will be reviewed and approved by the UB. The FSS QAPP will incorporate the appropriate regulatory requirements applicable to the planning and conduct of radiological surveys necessary for the termination of the BMRC license and the release of the site for unrestricted use. The DOC will perform the FSS in accordance with the QAPP and related procedures, and will submit the completed FSS to the UB for approval and submittal to the NRC.

BMRC Decommissioning PlanRevision 0 23 2.0The objective of the BMRC decommissioning activities is to remove licensed radioactive materials from the facility and surrounding grounds necessary to obtain NRC approval for release to unrestricted use of the property and be granted termination of the NRC license. The decommissioning pathway described in this plan is intended to meet the necessary requirements to achieve this objective.DECOMMISSIONING ACTIVITIES2.1Decommissioning AlternativesThere are four alternatives available to, and considered by, the UB: 1) the No-Action alternative (SAFSTOR); 2) the entombment option (ENTOMB); 3) complete decontamination and structure demolition (DECON-A); and 4) complete decontamination and release of the structure (DECON-B). The DECON options are recommended by the NRC for non-power reactors. The selected alternative is DECON-A. The four alternatives are summarized in the following sections.2.1.1SAFSTOR AlternativeThe SAFSTOR alternative would involve the same potential risks and environmental impacts as the proposed action, but for a much greater time period. The alternative would require that the UB maintain current radiological controls, site security, required licensing, a reactor administrator, and the utilities until the DECON option was implemented. The UB would alsohave to incur all of the expenses associated with maintaining the facility. This alternative would require that the UB apply for and obtain an extension to the current NRC operating license. The SAFSTOR alternative would leave the site as unusable space that woulddelay anybeneficial reuse;and the potential for environmental contamination would still exist. This alternative is not environmentally preferable. 2.1.2ENTOMB AlternativeThe ENTOMB alternative places the same requirements on the UBas the SAFSTOR alternative with the additional requirement that the radioactive material beplaced in a long-lived structure, i.e., concrete, or thatthe current structure proven adequate for long-term storage. This alternative delays the impacts of the proposed action and the potential for environmental contamination would continue to exist. This alternative is not environmentally preferable.2.1.3DECON-AAlternativeThe facility records and current facility characterization reveal minimal facility contamination from past reactor operations. This alternative requires the site to be released and restored for unrestricted use. The reactor, the containment building, and the administrative building under this option will be disassembled BMRC Decommissioning PlanRevision 0 24and the radioactive material removed to meet the release criteria. The BMRC facility is located in the center of a growing university and the land area could be reused for future construction; therefore, complete decontamination and demolition (D&D) of the BMRC facility, DECON-A, is the preferred option. This alternative poses minimal risk and impacts to the environment as described the Decommissioning Environmental Report(ER).2.1.4DECON-BAlternativeThe DECON-B alternative is similar to DECON-A, however, the structure would not be removed after remediation. The risk and impacts to the environment are the same as DECON-A for this alternative, but the UB has determined that the reuse of the building is not in its best interests. Additionally, a final status survey of the soils and bed rock under a standing structure is more complicated and requires a significantly greater level of surveying and sampling than releasing an open excavation. This alternative is not preferred by the UB.2.2Facility Radiological Status2.2.1Facility Operating HistoryThe BMRC reactor operated from March 24, 1961 until June 23, 1994. The last of the spent fuel assemblies were removed from the facility in 2005.During the operating lifetime of the BMRC it served several functions related to education, health services, neutron activation analysis, radiological chemistry, radiological biology, nuclear science technology information dissemination, services to industry, and contractual research and design. A sampling of some of the tasks performed at the BMRC is listed below.Testing of nuclear industry componentsin a radiological environment.Study radiation effects on the solid state properties of carbon.Study radiocarbon dating techniques.Production of superfluids (He6).Investigation of Mercury contamination in fetal brain tissue.Study of Mercury in adult brain tissue.Cadmium toxicity studies.Samples tested for gun powder residue to support a criminal justice case.Samples tested for environmental pollution in air, water, and soil.Radiation sensitization of microorganisms.Isotope production for medical applications.The use of radioactive isotopes for visualization of bone lesions for medical applications.Testing of neutron detectors and other radiation detection equipment for industry application.Neutron activation analysis of blood serum.Neutron activation analysis for testing lead contamination and for forensic testing.Calibration of instruments for health physics applications.Demonstration of safe disposal of liquids, solids, and gaseous radioactive waste.

BMRC Decommissioning PlanRevision 0 252.2.2Current Radiological Status of the BMRC FacilityThe BMRC facility has been impacted from the operation of the research reactor. However, the radiological characterization performed to prepare for the development of this DP indicates that practices employed to minimize the spread of radioactive material were effective and therefore the impacts have been limited.A majority of the waste generated from the demolition of the BMRC facility is expecedto be eligible for release. Itshould be possible to recycle and reuse the concrete as aggregate or dispose of the concrete as construction and demolition (C&D) waste in a local permitted landfill. These options reduce both the overall cost of decommissioning and the associatedsafety risk because: (1) the risk of a transportation accident is significantly reduced with local recycling versus interstate transportation for BSFR or Class A LLRW disposal; (2) reduced cost of transportation to a local disposal facility versus distant LLRW landfills or processing facilities;(3) if the concrete is disposed of as C&D waste,the disposal rates are significantly lower than for BSFR waste or Class A LLRW.AppendixB, BMRC Site Characterization Report,provides a detailed status of the radiological conditions at the BMRC. Characterization efforts were guided by a thorough HSA and a characterization plan.

Characterization activities included subsurface soil samples down to bedrock, fixed location alpha and beta measurements on building surfaces, waste tank samples, loose activity smears, smears for hard to detect radionuclides, bioshield concrete samples, scan measurements on building surfaces, 10 CFR Part 61 distribution samples, and a gamma walkover survey. Analytical results from subsurface soil samples adjacent the reactor tank were less than the laboratory minimum detectable concentrations (MDCs) for contaminants of concern. In addition, indications of residual activity were not found outside of areasdescribed in the HSA that were expected to contain elevated levels of radioactive materials.The information obtained from both the site characterization effort and the WMG Activation Analysis and Component Characterization provides sufficient datato demonstrate that it is unlikely that significant quantities of residual radioactivity have gone undetectedin the BMRC. Table 2-1 below provides an estimate of the types and quantities of radioactive materials.

BMRC Decommissioning PlanRevision 0 26Table 2-1 Estimated Volumes and Masses of Radiologically Impacted Components and SystemsComponent/SystemPrimary MaterialWaste typeVolume(a)(ft 3)Mass (lb)Reactor Internals/ComponentsSteel, aluminum, graphiteA2005000Reactor and Bioshield WallsConcrete (b)A2,700401,600Reactor FoundationConcreteA1,300185,400Hot CellConcreteA1,700244,500Reactor Tank liner 6061-T6 alloy (aluminum)(b)A10012,500Old Control BladesNickel Plated PermalloyB(mixed)2200Containments WallsConcreteC&D19,0002,714,200Foundation (Neutron Deck)ConcreteBSFR1,600232,800Neutron Deck CeilingConcreteC&D5,100757,200Neutron Deck ConcreteBSFR2,200328,700Gamma Deck CeilingConcreteBSFR7,2001,188,000Bioshield Walls>12 FtConcreteC&D2,700324,000Hot CellConcreteBSFR22,6003,389,900Gamma Deck RoomsConcreteC&D5,500812,700Gamma Deck Room 109Non-concreteC&D2,400403,300Control Deck CeilingConcreteC&D1,400204,800Control Deck RoomsConcreteC&D3006,800Laboratory WingConcreteC&D6,000896,400Laboratory WingNon-concreteC&D1,600234,200Ancillary StructuresConcreteC&D31,7004,603,800HVAC SystemSteelBSFR6,800168,800SoilSoilBSFR6,600982,100Total A6,000849,000TotalB(mixed)2200TotalBSFR47,0006,290,300TotalC&D75,70010,957,400(a)Estimated packaged volume.(b)Assumes a maximum of 12 ft. height in the activation region is removed.

BMRC Decommissioning PlanRevision 0 272.2.3Release CriteriaThe decommissioning alternative selected by the UBis DECON-A. This section provides the specific radiological criteria that will be applicable for unrestricted release of the site and termination of NRC license R-77.DECON-Aincludes the removal of activated and contaminated materials, equipment and components. Because the BMRC facility will bedemolished, the release criteria for the FSS will be for the soil and bedrock that remain on site. The remaining soil and rock surfaces will be released to less than the NRC required 25 millirem (mrem) annual TotalEffective Dose Equivalent (TEDE) following guidance contained in MARSSIM. The release criterion will be determined to have been met by demonstrating surface or volumetric activities meet their respective NRC screening values as presented in Tables 2-2and2-3.2.2.3.1Release Criteria for Structures, Systems and ComponentsStructures, Systems, and Components (SSCs)destined for reuse, recycling, or disposal as clean waste will be shown to be free of detectable surface contamination in accordance with the guidelines provided by the NRC in IE Circular 81-07 (NRC 1981). Monitoring for residual radioactivity will use instrumentation and techniques (background radiation levels, scan speed, counting times) necessary to detect activity no greater than 5,000 dpm/100cm 2total and 1,000 dpm/100cm 2removable beta/gamma contamination. All instruments shall be calibrated with radiation sources having an energy spectrum and instrument response consistent with the radionuclides being investigated. If alpha contamination is suspected, appropriate residual radioactivity measurements capable of detecting alpha activity no greater than 100 dpm/100cm 2fixed and 20dpm/100cm 2Properly calibrated survey instrumentation with known efficiencies capable of measuring the radionuclide of concern will be used for release surveys. Removable contamination wipes may be measuredin a liquid scintillation counter (LSC) or a wipe/filter counter such as the Ludlum Model No. 3030E or equivalent.removable will be used. Per IE Circular 81-07, the potential dose impacts to members of the public is less than 5 mrem/yr to the maximally exposed individual which will meet the NRC release criteria of 25 mrem/yr. This release criteria is also described in NRC Regulatory Guide(Reg Guide)1.86,Termination of Operating Licenses for Nuclear Reactors, and is known throughout the industry as the Reg Guide 1.86 release criteria.For surface tritium contamination, only removable contamination will be assessed because of the difficulties in measuring total tritium surface contamination directly (ISO 1988). If a removable fraction of 10% is assumed (ISO 1988), analysis for removable tritium must have a minimum detectionlimitno BMRC Decommissioning PlanRevision 0 28greater than 500 dpm/100cm 2so that the total (fixed plus removable) required detection limitof 5,000dpm/100cm 22.2.3.2Release Criteria for Soilsis not exceeded. Tritium wipes shall be measured in an LSC.Characterization data indicates that there has been minimal impact to subsurface soils from operation of the reactor. Soils remaining in place will be shown to meet an annual TEDE of 25 mrem/yr by demonstrating the average volumetric activity is less than the NRC screening values as found in Appendix B of NUREG-1757, Consolidated Decommissioning Guidanceand presented in Table 2-2.The screening values are listed in picocuries per gram (pCi/g) of material.Table 2-2 NRC License Termination Screening Levels for Surface SoilsRadionuclideNRC Screening Value (pCi/g)Ag-108m8.2Am-241*2.1C-1412Co-603.8Cs-13711Eu-1528.7Eu-1548H-3110Ni-632,100Pu-2382.5Pu-239/2402.3Ra-2260.7Sr-901.7*2.2.3.3Release Criteria for Bedrock SurfacesSee Section 2.2.3.4for derivation of Ag-108m screening value.During decommissioning, the entire BMRC structure will be demolished and removed from the site. The bottom concrete slab of the Containment building, i.e. the Neutron Deck floor, was poured directly on the bedrock. After the building is demolished, only the bedrock will remain. The bedrock is not volumetrically contaminated; therefore, the FSS will employ survey methods utilized for building BMRC Decommissioning PlanRevision 0 29surfaces using the NRC screening values for building surfaces as found in Appendix B of NUREG-1757,Consolidated Decommissioning Guidanceand presented in Table 2-3.The bedrock will be prepped prior to the FSS by removing loose materials, i.e. concrete dust, pieces, and dirt. Release criteria for radionuclides not in Table 2-3 will be consistent with the Reg Guide 1.86values stated in Section 2.2.3.1.

The amount of loose radioactive materials shall not exceed 10% of the release criteria.Table 2-3 NRC License Termination Screening Levels for Building (Bedrock) SurfacesRadionuclideNRC Screening Value (dpm/100cm 2Ag-108m)17,000C-14*3,700,000Co-607,100Cs-13728,000H-3120,000,000Ni-631,800,000Sr-908,700

• 2.2.3.4Derivation of Ag-108m Screening CriteriaSee Section 2.2.3.4 for derivation of Ag-108m screening value.The screening criterion provided by the NRC does not list a value for Ag-108m. The NRC's source of calculating a screening value is the computer code DandD developed by Argonne National Laboratory.

This computer code does not have Ag-108m listed in its radionuclide library. In order to avoid the lengthy and time burdensome task of calculating site-specific DCGLs using probabilistic RESRAD runs, the UB DOC has calculated a Ag-108m screening value based on the screening value calculation of Ag-110. The Ford Nuclear Reactor at the University of Michigan experienced the same technical issue with Ag-108m and was the first to calculate screening values for Ag-108m.Isotopes of an element behave the same chemically; therefore, Ag-108m will behave the same as Ag-110in the environment and human body as well as have the same exposure pathways. The only difference between the two radionuclides in the calculation of their screening value in the DandD computer code is the Dose Conversion Factor (DCF) for each radionuclide. The DCFs for Ag-108m and Ag-110m were gathered from Federal Guidance Reports (FGR) #11 and #12. The ratio of the two DCFs was used as a dose factor to multiply to the dose calculated for Ag-110m in the BMRC Decommissioning PlanRevision 0 30DandD model for each individual exposure pathways.This resulted in a dose per pCi/g for Ag-108m for each exposure pathway. The values are listed in Table 2-4 below.Table 2-4 Ag-108m Surface Soil Screening ValuePathwayAg-110m Dose(mrem/1.0 pCi/g)Dose factors(Ag-108m/Ag-110m)Ag-108m Dose(mrem/1.0 pCi/g)External Exposure4.58E+000.5812.66E+00Inhalation1.22E-050.4936.01E-06Sec. Ingestion9.62E-050.7056.78E-05Agricultural5.59E-010.7053.94E-01Drinking Water1.36E-200.7059.59E-21Irrigation1.34E-190.7059.45E-20Surface Water7.26E-220.7055.08E-22Cumulative mrem/(pCi/g)3.05(pCi/g)/mrem0.327Screening Value @25 mrem/y8.19pCi/gUsing the Ag-108m/Ag-110m Dose Factor for each exposure pathway, the resultant cumulative dose per unit of volume (mrem per pCi/g) is 3.05 mrem. This means that an average concentration of 1 pCi/g will result in a dose to the public of 3.05 mrem per year. The inverse of this number provides the average concentration that will result in a dose of 1.0 mrem/yr which is 0.327 pCi/g. The average concentration values normalized to 25mrem/yr is 8.19 pCi/g. In the same process described above, the Ag-108m screening value for building surfaces was calculated as shown in Table 2-5 below. Table 2-5 Ag-108m Building Surface Screening Value PathwayAg-110m DoseDose factorsAg-108m Dose(mrem/1000 dpm/100 cm 2(Ag-108m/Ag-110m))(mrem/1000 dpm/100 cm 2External Exposure

)2.34E+000.6041.41E+00Inhalation1.05E-010.4935.18E-02Ingestion7.88E-030.7055.56E-03Cumulative 1.47E+00Screening Value @ 25 mrem/y17,000 dpm/100 cm

2)

BMRC Decommissioning PlanRevision 0 312.3Decommissioning Tasks 2.3.1Activities and Tasks2.3.1.1Preparation Tasks Prior to approval of the DP by the NRC, several activities are scheduled to be conducted to prepare the reactor facility for decommissioning. Preparation of the facility and the removal of non-reactor structures, systems, and components can advance the overall decommissioning schedule. The following sections describe the preparation tasks scheduled to be performed by the UB, the DOC, and other contractors.2.3.1.1.1Pre-Decommissioning Cleanout Miscellaneous loose materials and equipment that werelocated in the BMRC werepackaged for disposal to prepare for the decontamination and demolition phase of decommissioning. An inventory of the loose materials and equipment was developed and a Request for Proposal was developed. The items sent for disposal were items that did notrequire any type of dismantlement, i.e., unbolting from fixed surfaces or torch cutting. The miscellaneous materials included, but not limited to, shield block, lead bricks, lead aprons, old tank samples, inoperable equipment, reactor components replaced during the 1989 rebuild. By removing the miscellaneous equipment and materials from the BMRC, additional work and storage space isavailable for the D&D phase of decommissioning and additional characterization of the areas that are currently occupied by the waste can be completed.All materials were sent to a licensed radioactive materials processor for proper disposition of the material, (i.e., BSFR, Class A Radioactive Waste Disposal, lead recycling) as authorized by the processor's radioactive materials license. The waste is scheduled to be disposed of prior to the submittal of this DP to the NRC and the UB intent to perform this activity was discussed with the NRC and NYS DOH prior to commencement. Project records, shipping manifests, and inventories are available for inspections as necessary.2.3.1.1.2Isolation and Removal of Inactive Systems Inactive systems that are not required by either technical specifications, or for safety, or for support of decommissioning activities may be isolated, de-energized, and drained prior to approval of the decommissioning plan. This stage is often referred to as interference removal. These systems will be removed from the facility to avoid cross contamination during the removal of activated or impacted items.

Removal of inactive systems is necessary because typically these systems interfere with the physical dismantling and demolitionactivities associated with decommissioning. Any inactive radioactively BMRC Decommissioning PlanRevision 0 32impacted systems will be removed at the direction of the DOC. The remaining (required) systems will be removed after approval of the DP by the NRC.2.3.1.1.3Removal of Hazardous Waste and ACM The UB may contract with a qualified licensed contractor who will be responsible for the disposal of hazardous waste and ACM in compliance with federal, state of New York, and local regulations and requirements. A licensed asbestos abatement contractor will remove ACM utilizing industry practices. The DOC will provide oversight and radiation protection support as necessary during the removal of ACM. To date, characterization activities have not identified radioactively contaminated ACM, however, radiation protection (RP) support will be provided to ensure proper RP controls are in place should they be needed. Similarly, for hazardous waste, the DOC will provide the workers with the appropriate radiation safety training required commensurate with the potential for exposure to radioactive materials and RP support to ensure that radioactively impacted hazardous material will be controlled and segregated from hazardous material that is not radioactively impacted.2.3.1.1.4Facility Preparation for Decommissioning Temporary systems needed to support decommissioning activities such as temporary power, portable lighting, temporary ventilation systems, and air monitoring systems may be installed prior to approval of the DP. If facility modifications are required to facilitate waste handling, they will be performed following approval by the UB.2.3.1.2Tasks and Activities for BMRC Decommissioning The DOC will modify and/or augment existing BMRC and UB procedures to accommodate the decommissioning effort. Additionally, best available industry techniques will be employed during the D&D of the reactorSSCs. These techniques may include, but are not limited to, the use of long handled and standard tools, hydraulic cutters, torches, plasma arc torches, wire saws, needle guns, jackhammers, hand-scabblers, high pressure and ultra high-pressure sprayers and cutters. Any cost-effective tool or technique that achieves the goal of D&D while maintaining the principles of as low as reasonably achievable(ALARA) and considers the end state of the waste will be employed. Procedures and work packages will be developed by the DC designating the specific tool or technique to be employed. These procedures will be reviewed by the DOC and approved by the UB. Methods that will minimize the spread of contamination such as portable high efficiency particulate air (HEPA) ventilation systems or an encapsulation medium may be used. The utilization of temporary shielding will be used to maintain BMRC Decommissioning PlanRevision 0 33personnel exposures ALARA. Water will be left in the reactor pool/liner during the removal of the reactor internal components.It is anticipated that decommissioning will initially focus on the items that have the greatest potential to be radioactively impacted. This includes the reactor and its components, the bioshield, the dry cell, and the hot cell. Then, it is anticipated that any radioactively impacted systems will be remediated. After these items have been remediated, a majority of radioactively impacted material will have been removed from the facility. Therefore, decommissioning can proceed at a more efficient pace because the potential for cross-contamination and undue exposure will be limited due to the fact that very little radioactive material will remain. This approach will also allow work to be performed ALARA. The following activities are presented as an overview (of decommissioning) and the UB may elect to perform the activities in a different sequence. ALARA, safety, cost, and scheduling may dictate that a different sequence be used by the UB. Current BMRC staff has performed the first three activities previously during the rebuild completed in 1991. Their experience and documentation from the rebuild will be used to perform the activities in a manner that is safe and ALARA. 2.3.1.2.1Removal of the Operating PlatformThe operating platform is located above the reactor. It will be removed to allow better access to the reactor and its components. The operatingplatform will be disposed of based on the release criteria in Section 2.2.3 and Section 2.2.5.2.3.1.2.2Removal of Reactor Components Reactor core components include, but are not limited to, the following: the core frame, plenum, core blades and shrouds, thermal column frame, and sleeve for the fission chamber. Reactor components, irradiation facility (IF) tubes for experiments and other items located within approximately three feet of the core for extended periods of time have been activated to levels that will require disposal as LLRW. The upper portion of reactor components, i.e. Control Blade drives, IF tubes, and instrumentation housings, may be surveyed and released or disposed as BSFR waste.Removal of the reactor components should be performed while water is still in the reactor pool to provide shielding so that the work can be performed while keeping exposure ALARA. Long-handle tools and remotely operated equipment may be used to disassemble the components. The components will be lifted using the overhead crane or other device, and will be placed in LLRW containers, with appropriate shielding to keep dose rates ALARA and within DOT and disposal facility acceptance limits.

BMRC Decommissioning PlanRevision 0 342.3.1.2.3Water Removal from the Reactor Tank The water in the reactor tank will be drained, filtered, and discharged to the sanitary system, as approved by the UB using the existing liquid waste system. Radioactive sediments on the bottom of the tank can be removed by agitating the sediments to remove them during pumping, for subsequent filtering.

Alternatively, the sediments may be left still and removed manually after the tank is drained. The tank water will be filtered to remove the suspended solids, stored, and sampled according to current procedures to allow discharge of the water to the sanitary system. Any water from any ancillary systems, such as the water purification system or water in the tanks in the Tank Farm, should also be processed in the same manner. Filter media and water not meeting the discharge limits will be managed as LLRW.2.3.1.2.4Removal of Activated Portions of the Reactor TankLinerIn the rebuild completed in 1991, a liner was installed in the bottom half (Neutron Deck Level) of the reactor tank. Both the tank and the liner are made of an aluminum alloy (6061-T6). The aluminum liner may be removed prior to destructive dismantling of the bioshield. It has been assumed that the inner and outer liner will require disposal as LLRW. However, UB may elect to survey the newer liner material and only dispose of material as LLRW only in theactivation region. Since the bioshield was poured around the completed reactor tank, it is not feasible to remove the original tank separately from the bioshield.2.3.1.2.5Removal of Reactor Bio-Shield, Dry Cell, and Hot Cell After the activated core components (and possibly the reactor liner) have been removed the concrete associated with the reactor bioshield, dry cell, and hot cell will be removed by destructive methods, i.e.

cutting and/or hydraulic shear. As described in Section 1.2, the bioshield, the dry cell, and the walls/ceiling of the hot cell were poured independently from the Containment Building floors and walls.

The concrete waste from the demolition of the portions of these structures between the Neutron Deck and the bottom of the Gamma Deck will bedisposed of as Class A LLRW. The remaining concrete waste from these structures is expected to be BSFR waste. The destructive removal technique for the bioshield will be cuttingby diamond wire, or equivalent, into pieces that can be lifted by the BMRC overhead crane having a maximum capacity of 10 tons. The dry cell and hot cell walls will primarily be removed by diamond wire cutting, but portions may be cut by a rotary saw or blunt force demolition.

BMRC Decommissioning PlanRevision 0 35Cut points will be verified by a New York Licensed professional engineer (P.E.) to ensure the structural integrity of the BMRC is not compromised. Concrete dust from destructive removal operations will be controlled and continuously monitored for industrial hygiene and radiological concerns. 2.3.1.2.6Removal of HVACsystem and other impacted systems HVAC system removal may be necessary prior to Containment Building demolition. Radioactively impacted systems may be disposed of as LLRW if decontamination is not possible or cost effective. Minimally impacted systems will be disposed of as BSFR waste. Any systems that were maintained to support decommissioning activities will be de-energized at this stage to prepare for demolition of the Containment Building. The storm water and sanitary systems will be removed up to thejunction point where they tie into other UB South Campus systems. The tanks used in the current and former liquid waste management systems will be disposed of as LLRW. The soil and gravel covering the tanks, along with the concrete enclosure and berms areexpected to be disposed of as BSFR waste.2.3.1.2.7WasteSystems RemovalThe waste systems consist mainly of the Tank Farm which lies in the subsurface adjacent to the containment building and extends towards the southwest of the containment building (see Figure 1-5) and the 10K Vertical Waste Holding Tank. A smaller 1,000-gallon holding tank in the subbasement that is in line with the 10K Vertical tank will also be removed. The removal of the waste systems will include the removal of tanks and the piping associated with both waste systems. The tanks will be size reduced by industry standard methods and disposed of as LLRW. Due to the expected residual radioactive material in the tanks, the tanks will be flushed prior to removal and local ventilation will be used unless the tanks are shipped offsite for processing at a radioactive waste processing facility.2.3.1.2.8Demolition of Containment Building The Containment Building will be safely demolished after the work described in Sections 2.3.1.2.1 through 2.3.1.2.7 are complete, the activated concrete is removed, and building surfaces are remediated where necessary to meet the limits specified in Section 2.2.3.2. The demolition debris, i.e., concrete and rebar, will be sent to a local recycler or to a local C&D landfill. An exception to this is the bottom slab, i.e., the Neutron Deck floor, which is expected to be disposed of by BSFR due to impacts from the reactor leaks. Although cores through the Neutron Deck floor showed no indication of contamination, it is deemed too costly to perform the amount of surveying on the bottom of the concrete surface required for release to a recycler.

BMRC Decommissioning PlanRevision 0 36Industry standard demolition techniques will be used to demolish the BMRC. The concrete dust will be continuously monitored and controlled to applicable federal, state, and local limits. Air monitoring will also be conducted periodically for radiological parameters.2.3.1.2.9Demolition of Administration Building The Administration Building will be demolished in conjunction with the Containment Buildingbecause there is no future need for the BMRC. It is anticipated that some minor decontamination will be required prior to demolition. It is also anticipated that if there are any radioactively impacted systems they will be removed prior to demolition. Thebuilding is mostly composed of concrete construction materials so a majority of the waste will be concrete rubble. The demolition debris will be disposed of in the same manner as the Containment building, i.e., the subbasement slab as BSFR and the remaining debris to a local recycling company or local C&D landfill.2.3.1.2.10Remediationof Soils and BedrockCharacterization has not shown that there are radioactively impacted soils at the BMRC. The samples collected in the Room N16 were scrapings of dirt on the bedrock. It is possible that a small amount of soil around the waste tanks have elevated levels of radioactive materials. This material is to be remediated and characterized for proper disposal. In addition, removal of impacted bedrock is required in Room N16 due to historical releases. The amount of bedrock to be remediated is expected to be approximately one cubic yard with residual material to be removed by scabbling or chiseling of the bedrock.2.3.2ScheduleThe project duration, from DP approval to completion ofthe FSS, is approximately 15months. The proposed decommissioning schedule is presented in Figure 2.1. Changes to the schedule may be made at the UB's discretion to respond toresource management, availability of a radioactive waste burial site, interference with ongoing UBactivities, ALARA considerations, and/or temporary on-site radioactive waste storage operations. The current project schedule is consistent with other recently completed university research reactor decommissioning projects.The schedule includes activities from project planning through NRC review of the Final Status Survey Report and license termination. Itis based on a 5-day work week with the number of work days listed for each activity.

BMRC Decommissioning PlanRevision 0 37Figure 2-1 Proposed Project Schedule2.4Decommissioning Organization and ResponsibilitiesThe decommissioning of the BMRC facility is under the technical supervision of the UB's Environment, Health and Safety (EH&S) Department who is responsible for assuring that decommissioning activities are conducted in a safe manner and within the requirements of the NRC License, this DP, the UB's Radiation Protection Program, and other state and federal laws and regulations. Personnel in the UB EH&S Department that are providing supervision of the decommissioning for licensing, radiation safety and industrial safety operated the BMRC before it was shutdown in the positions of Director, Operations Manager, Reactor Engineer, and RSO. The UB has appointed a project manager to oversee the decommissioning process. The Organizational Chart in Figure 2-2 at the end of this section shows the lines of reporting at the UB BMRC. The Decommissioning Radiation Safety Staff reports to the RSO for radiation safety and licensing functions which are represented by the dashed reporting line. Additionally, the Decommissioning Industrial Safety Staff will report to the UB Reactor Engineer for safety and compliance reporting for industrial safety concerns.

BMRC Decommissioning PlanRevision 0 382.4.1University Project ManagerThe following duties, at a minimum but not limited to, will be assigned to the UBPM.Selecting a Demolition Contractor in accordance with UB procurement guidelines. Overseeing the DOC and DC performance relative to the terms of their contract. Overseeing the DOC and DC performance relative to plans and procedures.Minimum required qualifications and experience requirements for the UBPMare as follows:Bachelor's degree in Architecture, Civil, Electrical, Mechanical or Structural Engineering or relatedfield AND five (5) years of construction experience which included one year of construction supervisory experience; OR, Nine years of progressively responsible construction experience which included one year of construction supervisory experience; OR, Any equivalent combination of experience, training and/or education approved by the UBHuman Resources department.2.4.2BMRC DirectorThe BMRC Director has management responsibility and technical oversight for facility operations and radiation safety programs. The following duties and responsibilities are assigned to the BMRC Director, or designee:Ensuring that decommissioning activities are performed in compliance with applicable regulations and license conditions. Approval of plans and procedures required fordecommissioning Reviewing and submitting to the Reactor Decommissioning Safety Committee (RDSC) needed changes and subsequent plans and procedures that do not change the original intent of the DP or result in an unreviewed safety question. Communicatingwith the NRC, New York State Agencies, and UB Administration.Minimum required qualifications and experience requirements for the BMRC Director areas follows:Advanced degree (MS or PhD) in Nuclear Engineering or related disciplineor equivalent experienceand five (5) years experience in nuclear reactor operations and/or decommissioning.Familiarity with NRC License R-77, the Decommissioning Plan, the BMRC Radiation Protection Program, and with applicable federal and state regulations.Trained at the level required by the UB RP Program to be in possession of radioactive materials of the types known to be present at the licensed reactor site.

BMRC Decommissioning PlanRevision 0 392.4.3Radiation Safety OfficerThe UB RSO is responsible for monitoring and overseeing radiological safety at the reactorand BMRC. The RSO has the responsibility and authority to stop any plan or activity that has the potential to result in an unacceptable radiological hazard. The following duties and responsibilities will be assigned to the UB RSO, or designee:Supervise the implementation of the UB radiation safety program by DOC radiation safety staff. Review and approve radiation safety procedures.Review and approve radiation work permits.Minimum required qualifications and experience requirements for the RSOare as follows:Advanced degrees (MS or PhD) and/or certified in Health Physics with 10 years experience in radiation safety and health physics.Familiarity with NRC License R-77, NYS Radioactive Materials Licenses, the Decommissioning Plan, the BMRC Radiation Protection Program, and with applicable federal and state regulations.2.4.4Reactor Decommissioning Safety CommitteeThe function, responsibilities, and makeup of the RDSC are defined in the Technical Specifications (UB Research Reactor license R-77). Among those responsibilities are, but not limited to:Approval of plans required for decommissioning.Review and approval of proposed changes to the facility, procedures and Technical Specifications and DP.Determination of whether a proposed change to the DP would constitute an unreviewed safety question or a change in the Technical Specifications as required by 10 CFR 50.59, and review and approval of required safety analysis.2.4.5Design and Oversight ContractorThe DOCis responsible for the direct field management of the BMRC decommissioning and assisting the UB in the administration of the industrial and radiological safety programs. The duties assigned to the DOC PM include, but are not limited to, the following:Manage the safe and regulatory compliant implementation of the UB DPand FSS.Assist the UBPMin overseeing the DC performance relative to subsequent plans and procedures.Development, implementation, and associated costs of a Radiation Safety program compliantwith 10 CFR 20.Development, implementation, and associated costs of an OSHA compliant Health and Safety Program.

BMRC Decommissioning PlanRevision 0 40Review and approval of work plans and procedures necessary for the safe and compliant decommissioning of the BMRC. Assist the UB in acquiring applicable permits for radiological waste disposal and transportation.The DOC will assign a PM with the following minimum required qualifications and experience:B.S. Degree and 10 years combined experience in decommissioning, project management, and radiation safetywith at least five (5) of the years specific to nuclear reactor decommissioning.Experience in the decommissioning of university research and test reactors.Familiarity with applicable federal and state regulations, MARSSIM andNRC decommissioning guidance. See Section 2.6 for additional criteria usedinthe selection of the DOC.2.4.6Demolition ContractorThe DC is responsible for the development, implementation, and associated costs of work plans and procedures for the safe and compliant demolition of the UB BMRC. The DC will report directly to the DOC Project Manager for implementation of the DP, but will be contracted directly to the UB. The DC is also assigned the following responsibilities:Development and safe implementation of work plans and procedures for the demolition of the BMRC. Compliance with the BMRC DP.Compliance with the BMRC Decommissioning Radiation Safety program.Compliance with the BMRC Decommissioning Health and Safety Program.The minimum required qualifications and experience for the selection of a DC isdiscussed in Section 2.6.

BMRC Decommissioning PlanRevision 0 41Figure 2-2. Organizational ChartVice President for University Life and ServicesAssociate VP for University FacilitiesDirector Facilities, Planning and DesignFP&D Manager of SupportUniversity Project MangerDecommissioning Project Manager (DOC)Site Superintendent (DC)DecommissioningCraft Personnel (DC)DecommissioningWork Planner(s)(DC)Decommissioning Safety Manager (DOC)DecommissioningSafety Engineer(s)(DOC)Decommissioning Radiation Protection Manager (DOC)Decommissioning HP Staff (DOC)Director, Environment, Health and Safety ServicesBMRC DirectorAsst. Director EH&S Reactor Engineer BMRC Operations Manager BMRC Site RepresentativeBMRC/UB Radiation Safety OfficerUB Radiation Safety StaffReactor Decommissioning Safety Committee BMRC Decommissioning PlanRevision 0 422.5Training Programs2.5.1General Site TrainingA general training program will be designed and implemented by the DOC and approved by UB to provide orientation to project personnel and meet the requirements of 10 CFR 19, Notices, Instructions, and Reports to Workers: Inspection and Investigations. General site training will be required for personnel assigned on a regular basis to the D&D project. General site training will include but is not limited to:Project orientation, security, and access control -such as BMRC Operating Procedure # 56;BMRC Unescorted Access Training for Non-BMRC PersonnelIntroduction to radiation protectionQuality assuranceIndustrial safetyEmergency proceduresPackaging and transport of radioactive materialsThe following are examples of additional training that may be required:Radiation Worker Training will meet the requirements identified in the BMRC Decommissioning Radiation Protection Plan.Hazardous Waste Operations and Emergency Response (HAZWOPER) training will be required for personnel engaged in hazardous substance removal or other activities that potentially expose them to hazardous substances and health hazards.Respirator Training and Fit Testing will be performed according to the BMRC Decommissioning Respiratory Protection Program.Hazard Communication Training will be provided to personnel exposed to hazardous or potentially hazardous materials.Hearing Conservation Training will be provided on the effects of noise on hearing and the purpose, advantages, disadvantages, and attenuation of various types of hearing protective devices.Permit-Required Confined Space Entry Training will be required for personnel entering confined spaces.Lockout/Tagout Hazardous Energy Control Training for hazardous energy control.Trenching and Excavation Training for the purpose of determining the safety and stability of excavations.For specific tasks that require state licensing or other special qualifications, the qualifications will be reviewed by the DOC PM or Safety Manager. If additional radiation safety training is required, itwill be provided by the site RSO.2.5.2Radiation Worker TrainingThe reactor D&D operations will be managed by the DOC and performed by the DC. As such, the DOC will be responsible for the radiation worker training of BMRC decommissioning contractors and BMRC Decommissioning PlanRevision 0 43subcontractors in accordance with the requirements of 10 CFR 19 with the final approval of qualifications by the RSO. The Decommissioning Radiation Protection Manager (RPM) will be responsible for on-site radiation safety training of workers and verifying pervious training and qualification as approved by the RSO. The DOC's radiation safety training program will be administered by the RPM who will approve, along with the RSO, training materials and qualification of workers. The RSO will provide dose monitoring badges such as thermoluminescent dosimeters (TLD).The minimum radiation safety training provided to any worker will include, but is not limited to the following subjects:Principles of radiation protectionRadiation monitoring techniquesRadiation monitoring instrumentationEmergency proceduresRadiation hazards and controlsConcepts of radiation and contaminationProvisions of 10 CFR 19 and 20NRC license conditions and limitationsReporting requirements for workersBiological effects of radiationRadiation control zone proceduresRadiation Work Permits (RWP)A written exam will be required to demonstrate proficiency with the radiation worker training topics. Radiation worker training will also include a practical factors demonstration and evaluation. This evaluation will include a review of the following:Proper procedures for donning and removing protective clothing and equipment.The ability of the worker to read and interpret self-reading and/or electronic dosimeters (if used).Proper procedures for entering and exiting a controlled area, including proper frisking techniquesPersons who have documented equivalent radiation worker training from another site or employer within the previous twelve (12) months may be waived from taking the training but must take the written and practical factors examinations. Radiation Worker training will be refreshed on an annual basis or at the discretion of the RSO.

BMRC Decommissioning PlanRevision 0 442.6Contractor AssistanceThe UB has already selected a qualified DOC for the design and oversight of the BMRC decommissioning based on a combination of the following items:1.Response and demonstration of prior experience (five years minimum) on the tasks listed in the project scope.i.Project Managementii.Pre-Decommissioning Clean Outiii.Site Characterizationiv.Decommissioning Plan Developmentv.NRC and New York StateRegulatory Interfacevi.Interference Removalvii.Decommissioning Drawings and Specificationsviii.Decommissioning Oversight Activitiesix.Final Status Surveyplanning and implementation2.Prior University Research andTest Reactor Decommissioning Experience3.Experience of Personnel Dedicated to the Project4.State Agency/NRC Experience5.Design / Technical Experience6.Minority Status / StaffingIn addition to the DOC, the UB will select a qualified contractor to perform the physical demolition of the BMRC. In selecting the contractor, the UB will produce a request for proposal, which will define the qualifications and experience necessary for prospective DCs and subcontractors. Prior history and performance of the prospectivecontractor on non-power reactor or similar decommissioning projects will be used to help the UB select a qualified contractor to perform the facility D&D.Qualification and experience requirements that will be used to evaluate the DC are to have at least 5 years prior experience in radiological sitedecontamination. Specific experience in the decontamination and demolition oftest reactors, power reactors, and/or materials licensed sites will be required by the prime contractor.DC submittals of project descriptions, references, and other supporting information will be required prior to contract award.Specific DC project management documentation will be required in the areas of work plan development, training, QA, work management, reactor dismantlement and decontamination, waste packaging, waste shipping, work documentation, and supporting the preparation of the final decommissioning project report.The minimum expectation of the UB for a DC is verification of company experience in these tasks, proof of financial viability, and bonding capacity.The UB will require the selected DC to support the project with an experienced Superintendent, supervisors, and Work Planner(s) with at least fiveyears prior experience in radiological site decontamination and demolitionwith preference in test reactors in a college campus setting.Specific individual experience will be required in the areas of work plan development, training, QA, work BMRC Decommissioning PlanRevision 0 45management, reactor dismantlement and decontamination, waste packaging, waste shipping, work documentation, and supporting the preparation of the final decommissioning project report.The minimum expectation of the UB for a DC is verification of personnel experience in these tasks plus a commitment to provide experienced personnel for the duration of the project.2.7D&D Documents and GuidesThis decommissioning plan was prepared using the guidance and format specified in Chapter 17 of NUREG-1537 (NRC 1996). The radiological criteria for license termination to allow unrestricted use will be as set forth in 10 CFR 20, Subpart E. The decommissioning project will also be administered according to the applicable section of the following regulations and regulatory guidance documents:10 CFR 19Notices, Instructions and Reports to Workers; InspectionsCode of Federal Regulations10 CFR 20Standards for Protection Against Radiation10 CFR 30Rules of General Applicability to Domestic Licensing of Byproduct Material10 CFR 50Domestic Licensing of Production and Utilization Facilities10 CFR 51Licensing and Regulatory Policy and Procedures for Environmental Protection 10 CFR 71Packaging of Radioactive Materials for Transport and Transportation of Radioactive Materials Under Certain Conditions29 CFR 1910Occupational Safety and Health Standards29 CFR 1926Occupation Safety and Health Standards for Construction49 CFR 170-199Department of Transportation Hazardous Materials Regulations1.86Termination of Operating Licenses for Nuclear ReactorsNRC Regulatory Guides1.187Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments8.2Guide for Administrative Practices in Radiation Monitoring8.7Occupational Radiation Exposure Records Systems8.9Acceptable Concepts, Models, Equations and Assumptions for a Bioassay Program8.10Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable8.13Instruction Concerning Prenatal Radiation Exposure8.15Acceptable Programs for Respiratory Protection BMRC Decommissioning PlanRevision 0 461505A Nonparametric Statistical Methodology for the Design and Analysis of Final Status Decommissioning SurveysNUREG-Series Publications1507Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions1549Using Decision Methods for Dose Assessment to Comply with Radiological Criteria for License Termination, Draft1575Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)1640Radiological Assessments for Clearance of Materials From Nuclear Facilities1756Technology, Safety, and Cost of Decommissioning Reference Nuclear Research and Test Reactors1757Consolidated Decommissioning GuidanceAdditional project-specific documents will be developed by the DOC and/or the UB prior to starting the D&D project. Such documents mayinclude:RP and ALARA PlanSite Health and Safety Plan QAPPWaste Management PlanFSS PlanSpecific Task Plans BMRC Decommissioning PlanRevision 0 47 3.03.1Radiation ProtectionPROTECTION OF WORKERS AND THE PUBLICThe RPM, under the direct supervision of the RSO, will administer the Health Physics Program (also referred to as the Radiation Protection Program) specifically developed for the BMRC Decommissioning as described in Section 3.1.2. The DOC will supplement the radiation protection program with detailed plans and procedures specific to the radionuclides listed in Table 3-1. The RSO, the RPM and Decommissioning Health Physics (HP) Staff will be responsible for implementing ALARA principles; providing radiation worker training; establishing administrative-level occupational and public dose limits; monitoring personnel for occupational exposures; controlling exposures; providing and maintaining radiation monitoring equipment; performing radiation surveys and monitoring; and maintaining records and generating reports as necessary to comply with regulatory and licensing requirements.Table 3-1 BMRC Radionuclides of Concern as determined in the Site Characterization ReportRadionuclideHalf Life (yr)EmissionArea(s) of InterestAg-108m4.18E+02Soil; Tank Water;SSCsAm-2414.32E+02Tank sedimentC-145.73E+03Laboratory areasCo-605.27E+00Soil; SSCs; BioshieldCs-1373.01E+01Soil; SSCs; Bioshield

• Eu-1521.36E+01Soil; SSCs; BioshieldEu-1548.59E+00Soil; SSCs; BioshieldH-31.23E+01Soil; Bioshield and Tank WaterNi-631.00E+02Soil; SSCs; BioshieldPu-2388.78E+01Tank sedimentPu-2392.41E+04Tank sedimentPu-2406.60E+03Tank sedimentRa-2261.60E+03Discrete sourcesSr-902.88E+01SSCs; Ventilation systems; Soil

• -137m progeny BMRC Decommissioning PlanRevision 0 483.1.1Ensuring ALARA Radiation ExposuresThe DOC will prepare an RP and ALARA Plan that will incorporate provisions for minimizing occupational and public radiation exposures. This Plan will describe specific administrative and engineering controls that will be put in place during specific D&D project activities. Examples of administrative and engineering controls include limiting access to certain areas, mock-up training, use of remote-handling devices, temporary shielding, containment structures, portable HEPA filtered ventilation, and specialized protective equipment and respiratory protection. 3.1.2Health Physics ProgramThe project Health Physics Program will be implemented under the authority of the RSO with the assistance of the DOC RPM. The Health Physics Program will satisfy the following commitments that should be established by the Radiation Protection Program:Implement the procedures defined in the Radiation Protection and ALARA Plan.Ensure radiological safety of the public, occupationally-exposed personnel, and the environment.Monitor radiation levels and radioactive materials.Control the distribution and release of radioactive materials.Maintain potential exposures to the public and occupational radiation exposure to individual within administrative limits and the regulatory limits of 10 CFR 20 and ALARA.Monitor personnel internal and external exposure in accordance with 10 CFR 20 requirements. 3.1.2.1Project Health Physics Program -General UB has procedures in place that will be implemented during the BMRC Decommissioning Project. Additional Health Physics procedures may be required and will be developed and approved in accordance with UB policy and procedure.UB senior management is readily accessible to ensure timely resolution of difficulties that may need to be addressed prior to regularly scheduled meetings. The RSO, while organizationally independent of the project staff, is a direct reportto the BMRC Director. He also has full authority to act in all aspects of protection of workers and the public from the effects of radiation. Conduct of the BMRC Decommissioning Project HP program will be evaluated according to UB policy.

BMRC Decommissioning PlanRevision 0 493.1.2.2Audits, Inspections, and Management ReviewDuring Decommissioning Project work, aspects of the Project may be assessed and reported by the DOC's Quality Assurance Department, through audits, assessments and inspections of various aspects of decommissioning performance, including HP, as described in Section 1.2.4.3Program Quality Assurance.Audits of the BMRC Health Physics program are conducted in accordance with the requirements of 10CFR 20. These audits will include aspects of the BMRC Decommissioning Project. Additional assessments or management reviews may be performed when deemed appropriate by the EH&S Director.HP equipment and instrumentation suitable to permit ready detection and quantification of radiological hazards to workers and the public will be chosen to ensure the validity of measurements taken during remediation and formal release surveys. The selection of equipment and instrumentation will be based upon detailed knowledge of the radiological contaminants, concentrations, chemical forms and chemical behaviors that are expected to exist as demonstrated during radiological characterization, and as known from process knowledge of the working history of the BMRC. Equipment and instrumentation selection will also takeinto account the working conditions, contamination levels and source terms that are reasonably expected to be encountered during the performance of decommissioning work, as presented in this Plan.The following sections present details of the equipment and instrumentation planned for use during thedecommissioning. It is anticipated that through retirement of worn or damaged equipment/

instrumentation or increase in quantities of available components or instruments, that new technology will permit upgrades or, at minimum, like-for-like replacements. UB is committed to maintaining conformance to minimum performance capabilities stated in this Plan whenever new components or instruments are selected.3.1.2.3Criteria for Selecting Equipment and Instrumentation for Conduct of Radiation and Contamination Surveys and Personnel MonitoringA sufficient inventory and variety of instrumentation will be maintained on site to facilitate effective measurement of radiological conditions and control of worker exposure consistent with ALARA, and to evaluate the suitabilityof materials for release to unrestricted use. Instrumentation and equipment will be capable of measuring the range of dose rates and radioactivity concentrations expected to be encountered during the decontamination and decommissioning activities associated with the BMRC, including implementation of a final status survey.

BMRC Decommissioning PlanRevision 0 50Decommissioning HP staff will select instrumentation that is sensitive to the minimum detection limits for the particular task being performed, but also with sufficient range to ensure that the full spectrum of anticipated conditions for a task or survey can be met by the instrumentation in use.Consumable supplies will conform to manufacturer and/or regulatory recommendation to ensure that measurements meet desired sensitivity and are valid for the intended purpose. 3.1.2.4Storage, Calibration, Testing, and Maintenance of Health Physics Equipment and Instrumentation Survey instruments will be stored in a common location under the control of BMRC Decommissioning HP Staff. A program to identify and remove from service inoperable or out-of-calibration instruments or equipment as described in HP procedures will be adheredto throughout the BMRC Decommissioning Project. Survey instruments, counting equipment, air samplers, air monitors and personnel contamination monitors will be calibrated at license-required intervals, manufacturer-prescribed intervals (if shorter frequency) or prior to use against standards that are traceable to the National Institute of Science and Technology (NIST) in accordance with approved calibration laboratory procedures, HP procedures, or vendor technical manuals. Survey instruments will be operationally checked daily when in use. Counting equipment operability will be verified daily when in use. The personnel contamination monitors are operationally tested on a daily basis when work is being performed.3.1.2.5Specific Health Physics Equipment and Instrumentation Use and CapabilitiesTable 3-2 provides details of typical HP equipment and instrumentation planned for use in the BMRC Decommissioning Project. This list is neither inclusive nor exclusive.Table 3-2 Health Physics InstrumentationInstrumentDetector TypeRadiation DetectedCalibration SourceUseLudlum Model 2221Ludlum Model 43-68 Gas Proportional (126cm 2 Beta area)Tc-99Surface Static Measurements; Beta scan measurementsLudlum Model 2360Ludlum Model 43-68 Gas Proportional (126cm 2Alpha/Beta area)Th-230/Tc-99Alpha/Beta static measurementsLudlum Model 19Internal NaIGammaCs-137General area exposure ratesLudlum Model 3030ELudlum Model 43-10-1 ZnS internal detectorAlpha/BetaTh-230/Tc-99Swipe/smear counting BMRC Decommissioning PlanRevision 0 513.1.2.6Potential Sources of Radiation or Contamination Exposure to Workers and Public as a Result of Decommissioning ActivitiesSources of radiation or contamination exposure were assessed by process knowledge, theHSA, radiological survey data, surveys performed during characterization, previous and current job coverage surveys, or daily, weekly and monthly routine surveys.Worker exposure to significant external deep-dose radiation fields is possible during this project due to the level of activation of reactor components, the reactor bioshield, and the level of radioactive materials in the waste tank systems. Therefore, work precautions and ALARA techniques such as time, distance, shielding, and pre-job planning will be employed. Worker exposure to airborne radioactivity may occur during decontamination operations/work evolutions involvingabrasives or methods that volatilize loose and/or fixed contamination.Exposure of the public to external or internal radiationfrom this Decommissioning Project is possible due to the high dose rates of reactor components and the position of the Tank Farm, however, exposures to the public shall be kept below the limits specified in 10 CFR 20 and will be ALARA by using the Administrative and Engineering controls described in the following paragraphs.The types of exposure controls used will considerthe current state of technology and the economics of improvements in relation to the benefits. Control of potential sources of radiation exposure to workers and public as a result of decommissioning activities will be achieved through, but not limited to, the use of administrative and engineering controls. Administrative controls consist of, but are not limited to:Administrative dose limits that are lower than regulatory limitsTrainingRadiological surveysPhysical barriers such as radiological warning rope/ribbon, in combination with radiological warning tape, lockable doors/gates as well as information signs and flashing lights or other applicable barriers may also be usedEngineering controls may consist of but are not limited to:HEPA ventilation/enclosuresProtective clothing/equipmentContainment(s)

BMRC Decommissioning PlanRevision 0 523.1.2.7Health Physics Policies for Contractor PersonnelContractor personnel will be usedduring the BMRC Decommissioning Project and will be required, at the discretion of the RSO, to:Attend and complete appropriate radiation safety courseProvide required exposure history informationRead and sign an applicable RWP and comply with instructionsFollow special instructions given by the HP3.1.3Dose EstimatesThe total estimated occupational exposure to complete the BMRC Decommissioning Project is 6.7person-rem.The dose estimate for decommissioning of the reactor was prepared using the individual work activity durations and work crew sizes, based upon the results of the characterization results to date and based upon recent experience in performing similar activities at the University of Washington and at the University of Arizona, combined with the DOC'sexperience at numerous other sites. Using these individual work activity durations, and work crew sizes and characterizations results, a dose estimate was generated for each activity. The doses from each activity were categorized and are provided by those categories in Table 3-3.This estimate is provided for planning purposes only. Detailed exposure estimates and exposure controls will be developed in accordance with the requirements of the ALARA program during detailed planning of the decommissioning activities. The primary doses expected to be received by D&D project workers will be from external exposure to activated metals and concrete, with little dose expected from internal exposure. External exposure will be monitored using whole-body and extremity TLDs, and electronic dosimeters. External exposures can be kept ALARA due to the availability of long reach tools, remote handling equipment, and the building's overhead crane. Additionally, there is plenty of floor space in the BMRC to maintain safe distances and to use shielding as necessary to keep exposures ALARA. Air sampling will be performed to assess the potential for airborne contaminants and internal doses will be monitored if they are expected to exceed 10% of the annual dose limits specified in 10 CFR 20. However, the committed effective dose equivalent (CEDE), the sum of the external and internal doses, is expected to be equal to the Deep Dose Equivalent (DDE).The dose estimate to members of the public as a result of decommissioning activities is estimated to be negligible. This is because the area immediately surrounding the facility is under the control of the UB and because the BMRC is not within a high foot-traffic area of the UB South Campus. UB students, BMRC Decommissioning PlanRevision 0 53faculty and staff will be kept at a safe distance from the BMRC during decommissioningactivities using temporary construction fencing.Table 3-3 Project Dose EstimateTaskTask NameTime/ResourcesEst. DoseDaysPeople(person -rem)1Project Planning4070.042Site Mobilization and Training5100.004Removal of the Operating Platform560.015Removal of Reactor Components1582.886Water Removal from the Reactor Tank580.028Removal ofReactor Bio-Shield, Dry Cell, and Hot Cell8082.569Removal of HVAC and other impacted systems5080.1610Tank Farm Removal3080.9611D&Dof Containment Building20100.0212D&Dof Administration Building20100.0213Remediation of Soils and Bedrock20100.0214Perform Final Status Survey2090.0115Backfill and Site Restoration2080.00Total Estimated Project Dose6.703.2Waste ManagementDecommissioning will require the handling of a relatively large volume of radioactive materials to reduce the residual levels of radioactivity to levels that allow for license termination and the release of the site for unrestricted use. Materials that are not decontaminated and/orreleased will be managed as radioactive waste. This sectionof the decommissioning plan presents the programs used to manage and control the management and disposition of solid, liquid and gaseous radioactive waste. Radioactive wastes include neutron-activated materials, contaminated materials remaining in the containment building, tools, and disposable equipment and supplies that become contaminated during dismantling activities. Waste disposal costs are directly related to the activity, volume, and weight of the materials requiring disposal. Strategies for minimizing waste include: source reduction, reuse, decontamination, volume reduction, and waste stream segregation.

BMRC Decommissioning PlanRevision 0 54The DOC will be required to develop and implement a Waste Management Plan for the BMRC Decommissioning project. The Waste Management Plan will include detailed guidance for the characterization, sampling, classification, segregation, handling, packaging, manifesting, transporting and disposal of waste generated by the decommissioning. The plan will be submitted to the RSO and BMRC Director for review and approval prior to the start of any decommissioning work on site that has the potential to generate radioactive waste. Waste volumes will be minimized through the application of industry-proven methodologies to ensure the segregations of contaminated and non-contaminated materials. These methodologies will include the establishment of radiological controls consistent with the health physics program and the implementation of good contamination control practices. Segregation categories may include: uncontaminated waste acceptable for land disposal or reuse, uncontaminated C&D wastes suitable for land disposal or recycle, Class A LLRW, and Class B activated components. Additionally, mixed wastes and non-radiological hazardous waste, if encountered,will be segregated from LLRW. Based on the site characterization and Activation Analysis of the reactor components, Class C radwaste is not present at the BMRC.Except for Class B waste, disposal facility options for contaminatedor activatedmaterialscurrently available to BMRC include land disposal at the Energy Solutions facility in Clive, Utah; and mixed waste treatment by Energy Solutions or another qualified service provider, with subsequent disposal at Energy Solutions. BSFR using a bulk survey and disposal procedure that is specially-permitted in Tennessee is also an option for lightly contaminated materials, especially building materials.Currently, there is no commercial Class B disposal option available for the Old Control Blades. The UBis working with the Nevada National SecuritySite (N2S2) to determine if a nexus exists between BMRC operations and the federal government in order to establish this as a disposal option. The UBshall properly managetheClass B wasteuntil a disposal option is obtained.Transportation of radioactive waste will be performed in accordance with applicable NRC and DOT regulations and the Waste Management Plan. Radioactive waste and material will be shipped either by truck, or by a combination of truck and rail. Shipments will be planned in a practical and efficient manner. Personnel with appropriate training and experience will be used to ensure the shipments comply with the BMRC license, applicable regulations, and the receiving site's license. Packages, packaging, and labeling for radioactive materials and waste shipment will meet applicable regulations and requirements.

Personnel involved in the packaging, preparation for shipment, and transportation of licensed material BMRC Decommissioning PlanRevision 0 55will be required to have training in accordance with 49 CFR 172 Subpart H. The RSO, or designee, shall certify all radioactive waste manifests.3.2.1Fuel RemovalThere is no longer any reactor fuel, used or unused, at the BMRC.As previously stated, the reactor was permanently shutdown in June of 1994.Unused fuel was transferred to North Carolina State University in 1998, and usedfuel was returned to the DOE at INEELin 2005.3.2.2Radioactive Waste Processing Decommissioning of the BMRC reactor will result in the generation of solid and liquid LLRW, mixedwaste, and hazardous waste. Solid radioactive wastes include neutron-activated materials, materials with surface or volumetric residual radioactive materials, and soil. Liquid LLRW includes the water in the reactor pool, waste systems, and the associated piping as well as contaminated water generated during remediation activities. The DP does not contain provisions for gaseous radioactive waste because the reactor has been defueled and has been shut down for over 16 years; therefore, radioactive gases present during operations have long since decayed. Handling, staging, and shipping of packaged radioactive waste will be performed in accordance with applicable regulations, 10 CFR 20.2006, Transfer for Disposal and Manifests; 49 CFR 100-177,Transportation of Hazardous Materials; disposal site waste acceptance criteria; and BMRC licenses and permits. Onsite radioactive waste processing will include waste minimization, volume reduction, segregation, characterization, neutralization, stabilization, solidification, and packaging. Wastes may be shipped to a licensed processing facility for survey and release or decontamination and release, or may be disposed of directly at a licensed facility. Each shipment of radioactive waste will be accompanied by a shipment manifest as specified in Section I of Appendix G to 10 CFR 20, Requirements for Transfers of Low-Level Waste Intended for Disposal at Licensed Land Facilities and Manifests. Radioactive waste generated from BMRC decommissioning activities will be manifest in a manner consistent with its waste classification.3.2.3Radioactive Waste Disposal 3.2.3.1SolidSolid waste generation will primarily be the direct result of the decontamination and dismantlement of the BMRC reactor components, activated and contaminated systems, and structures. The bulk of the radwaste is Class A with approximately 2cubic feet of Class B waste and no Class C wastes based on site BMRC Decommissioning PlanRevision 0 56characterization data and activation analysis data for the reactor. Disposition paths for solid radioactive wastes include decontamination and free release, BSFR, and direct landfill disposal. Wherever possible, volume reduction strategies will be explored to reduce waste disposal handling, exposure, and cost; including offsite processing for volume reduction if appropriate. The Class B Mixed Waste consists of the Old Control Blades made of nickel plated permalloywhich is an alloy consisting of silver, indium and cadmium. Disposal sites licensed to accepted Class B waste are not available to the BMRC atthe time this DP was developed. The UB and DOC are initiating the process with the N2S2to determine if the Class B waste can be accepted for disposal. After determination is made for disposal at N2S2, or another site, the Waste Management Plan is to be revised to incorporate the waste acceptance criteria for thedisposal site.Irradiated reactor hardware may require size reduction to facilitate loading. Depending on the dose rate exhibited by irradiated hardware, it will be shipped either in a shielded Type A container, or it will be loaded into a High Integrity Container (HIC) or liner then placed in an approved, shielded shipping container (Type A or B as dictated by the waste characterization) for transport and subsequent disposal.Contaminated reactor system piping and hardware may be land disposed as LLRW. Pre-disposal volume reduction processing may be performed off site at a subcontracted processing facility if it is determined to be cost effective.Activated or contaminated concrete removed in large sections may be packaged as Low Specific Activity (LSA) material in approved shipping containers for direct shipment to the licensed land disposal facility operated by Energy Solutions at Clive, Utah. Concrete may also be eligible for processing using an option such as the BSFRprogram offered in Tennessee, or potentially N2S2.Mixed waste lead brickswill either be decontaminated and released, or processed to allow for direct land disposal.3.2.3.2LiquidDecommissioning the BMRC reactor involves radioactively contaminated water primarily in the form of low-level radioactively contaminated water in the reactor pool and associated piping. Additional contaminated water may be generated during decommissioning operations (e.g. concrete cutting). These waters will be disposed by discharge to the public sewer system operated by the City of Buffalo; assuming the discharged liquid can be shown to meet the requirements for sewage disposal established by the BMRC license.

BMRC Decommissioning PlanRevision 0 57Pre-discharge treatment may include the use of existing or temporary filtration units or demineralizers, coupled with tanks to store processed water prior to discharge. After it has been verified that the stored processed water meets the allowable discharge limits, the water may be released. In addition to testing the stored water after treatment, effluent monitoring instrumentation may be used to monitor discharges of liquid effluent as required, and to demonstrate compliance with applicable regulations. Contaminated filter media will be disposed as LLRW, after onsite treatment to meet LLRW disposal facility waste acceptance criteria.In the event that discharge to the sanitary sewer or onsite treatment is not feasible, the waters may be treated offsite. There are several licensed radioactive waste processors provide specialized services for volume-reducing or treating radioactive liquid waste, including demineralization, direct incineration, ground application, evaporation, and survey and release. BMRC may elect, or find it necessary, to transfer all or some of the liquid radioactive waste from decommissioning to a licensed waste processor based upon onsite treatment effectiveness, discharge permit limits, stakeholder input, or cost.3.2.4General IndustrialSafety ProgramIndustrial safety and hygiene personnel, such as Certified Safety Professionals or Certified Industrial Hygienists, along with project management personnel, will be responsible for ensuring that the D&D project complies with applicable federal safety requirements and general safe work practices. These personnel will be provided by the DOC, but will report to the UB EH&S department. The DOC will prepare a site specific Health and Safety Plan (HASP) to documentsafety requirements and accidentresponse procedures. All personnel working on the D&D project will receive health and safety training in order to recognize and understand potential hazards and risks. Training requirements for subcontractors will be determined by the Decommissioning Safety Manager based on the specific task the subcontractor is performing.The HASP will be reviewed and approved by theUB EH&S Department. The HASP will direct site activities necessary for ensuring that the reactor D&D project meets occupational safety andhealth requirements for protection of project personnel. The functional responsibility of the HASP will be to ensure compliance with the OSH Act of 1973. New York adopts federal OSHA standards by reference and enforces OSHA standards contained within 29 CFR 1910 and 29 CFR 1926 for General Industry and Construction Industry, respectively. The DOC assists the UB in oversight of the site HASP.

BMRC Decommissioning PlanRevision 0 58As a minimum, the HASP will include the following:Hazards assessmentGeneral site safety proceduresA requirementfor a daily site safety meetingSite inspection proceduresEmergency response proceduresEmergency contact telephone numbersMaterial Safety Data Sheets for hazardous materials present on-siteTraining requirements for specific activities such as permit-required confined space entry or hot workLocal emergency medical information3.3Radiological Accident AnalysesPotential radiological accidents during reactor decommissioning were evaluated by determining reactor components and areas that contain the highest radioactive material inventory. The proposed decommissioning activities and methods in which radioactive material could be released to the work area or environment were considered. Since all special nuclear material has been removed decommissioning, the majority of the accidents discussed in the current license are not applicable. The accident identification process was supplemented by reviewing experiences at other non-power reactor decommissioning projects. The following radiological accidents were considered to present the highest potential consequences:FireSpill liquid radwaste into the environmentRelease airborne contamination to the environmentTransportation accidentThe accidental dropping of an activated reactor component was also considered as apotential accident. However, because the more highly activated components are located under water, the surface contamination on these parts would not be sufficiently high to release significant quantities of radioactive materials during such an incident. Such an incident would most likely result in additional unplanned external exposures. There areno, and will not be,fissile materials located on site that could result in a criticality incident.3.3.1FireThe consequences of a fire during decommissioning of the reactor were considered and are not significantly different than the consequences of a fire during reactor operations. Most materials are metals, concrete, or similar non-combustible materials. Although some torch cutting operations may be BMRC Decommissioning PlanRevision 0 59performed during decommissioning, the likelihood is low that a fire would start or that a fire could become intense enough to release radioactive material. Dry Active Waste (DAW) will be collected and packaged, to limit the volume of DAW available for consumption by fire and lower the potential for a fire to consume additional waste collections. The UB will implement a routine fire loading inspection program during decommissioning activities. DAW would have very low quantities of radioactive materials; therefore, the radioactivity is not high enough to result in a significant release in the case of a fire.3.3.2Spill Contaminated WaterThe consequences of a spill during decommissioning of the reactor were considered and are not significantly different than the consequences of a spill during reactor operations. The spilling of contaminated water could occur during pool water pumping or liquid removal operations from the waste systems. Hoses could leak or break, resulting in an uncontrolled release. To mitigate the extent of such releases, processes involving contaminated liquids will only be operated with personnel present.

Personnel will watch for leaks and spills and respond by shutting down the activity. This will not allow for additional water to leak from the system. In addition to the use of secondary containments or berms, a spill kit will be readily available to respond to any incidents.As evidenced in prior reactor leaks, contaminated water does not infiltrate the subsurface soils or bedrock. Should radioactive liquidsbe spilled, the soils and/or building materials can be remediated with little to no impact to the public or the environment. 3.3.3Release of Airborne ContaminationThe consequences of an airborne contamination event during decommissioning of the reactor were considered and are not significantly different than the consequences of an airborne contamination event during reactor operations. An uncontrolled release of airborne radioactivity could occur during cutting and demolition activities involving contaminatedor activated materials, such as removal and segmentation of reactor components, or removal of tank steel and concrete. The primary method of cutting the activated bioshield is a wet process; therefore, eliminating most if not all of the airborne hazard. Such activities may take place inside temporary containment structures equipped with local HEPA filter ventilation systems. Additionally, non abrasive cutting methods, i.e., hydraulic shears, will be used where possible to limit abrasive dusts and/or activated metal fragments where feasible.

BMRC Decommissioning PlanRevision 0 60Temporary containment systems with local HEPA filter systems will likely vent to the BMRC rooms or tie into existing building ventilation. A failure in the HEPA filter system could result in the uncontrolled release of airborne radioactive materials. A Continuous Air Monitorwill be used to monitor effluent air and will be set to alarm at 10% of the allowable effluent criteria. Operations inside the containment structure will immediately stop and an evaluation conducted to determine the nature of the alarm. While the actual concentrations of airborne radioactive materials are unknown at this time, the scenario is similar to accident analyses contained in the current BMRC Technical Specifications. Safety management operations (standard engineering and administrative controls) are sufficient for protecting against such accidents.3.3.4Transportation AccidentsVarious forms and quantities of radioactive waste will be shipped from the reactor during the D&D project. The dose consequence from transportation accidents could be higher than the contamination accident scenarios described above because high-activity reactor components could be involved. As such, there is a potential for a moderate dose consequence of between 1and 25mrem for the public following a transportation accident. However, adherence to NRC and DOT radioactive material packaging and transportation requirements is considered a sufficient control measure for mitigating transportation-related incidents.Thetransportation accidentrisk isfurtherreduced by using local disposition methods for the concrete, i.e., a local C&D landfill or recycling.

BMRC Decommissioning PlanRevision 0 61 4.0An FSS Plan will be submitted to the NRC for approval following submittal ofthis DP and prior to implementation of the FSS. The following sections describe the methodology and QA requirements to be implemented during the FSS.The DOC is responsible for the planning and implementationof the FSS.PROPOSED FINAL STATUS SURVEY PLAN4.1Survey and Sampling ApproachThe reactor and support facilitieswill be removed prior to site release. Consequently, the Final Status Survey (FSS) will include only the exposed soils and bedrock surfaces in areas covered by license R-77.

The expected condition of the area post remediation will be exposed subsurface soils and bedrock. The non-porous bedrock,beingsimilar to a concrete structure,will be surveyed usingsurvey methodologies for surface release of concrete and the results compared to the NRC surface screening values. Prior to the FSS on bedrock material, the loose dirt and debris is to be removed to ensure there is no interference with the survey measurements. The BMRC Site Characterization report (ENERCON 2011) demonstrates that the subsurface soils are not volumetrically contaminated; therefore, the exposed subsurface soils will be surveyed to surface soil screening criteria to prove that the surface of these exposed soils were not contaminated during the building demolition process. There will be no BMRC buildings or structures that will require a FSS.The FSS will be developed following the guidance provided in NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (NRC 2000) to demonstrate compliance with the release criteria provided in Section 2.2.3. The MARSSIM process emphasizes the use of data quality objectives (DQO), proper classification of survey areas (survey units), a statistically-based survey and sampling plan, and an adequate quality assurance/quality control (QA/QC) program.The FSSwill be performed in accordance with an FSS Plan by trained DOC technicians experienced in performing a MARSSIM FSS. The technicians will follow written procedures regarding surveys and sampling, sample collection and handling, chain-of-custody, and recordkeeping. The FSS Plan will define sampling locations, required analysis, and survey types. Any additional release criteria set forth by the UB or NYS will be contained within the FSS Plan which will direct surveys or sampling efforts required to demonstrate compliance with such criteria.The FSS may include surface gamma surveys using sodium-iodide (NaI) gamma scintillation detectors and gas flow proportional detectors. Surface soil samples will be collected using either a random-start grid pattern or randomly generated locations as appropriate commensurate to the classification of the survey area. Soil samples will be analyzed for contaminants of concern using standard analytical methods BMRC Decommissioning PlanRevision 0 62including liquid scintillation counting for hard-to-detect beta-emitting radionuclides (i.e., Carbon-14 and tritium) and gamma spectroscopy for gamma-emitting radionuclides.4.2Data Quality ObjectivesThe object of the FSS is to demonstrate that the radiological conditions of the reactor site satisfy the decommissioning criteria provided in Section 2.2.3. The DQO's in the MARSSIM survey approach will provide a 95% confidence level for the false negative (Type I error) in demonstrating that the site meets the criteria. Typically, the false positive (Type II error) will also be defined as a 95% confidence level, but may be modified to apply to a specific situation. Therefore, the Type I decision error will be 5-percent. The decision error rates are used in determining the required number of samples necessary in each survey unit aswell as the required minimum number of data points used for the final nonparametric statistical test performed to evaluate contaminant concentrations in the survey units against release criteria. DQOs, will be fully described in the FSS Plan and will include limits on the sensitivities of survey and analytical methods. The QAPP will incorporate standard regulatory and industry measures applicable to the FSS. The QAPP will be reviewed and approved by the Reactor Committee.4.3Identification and Classificationof Survey Units4.3.1Method for ClassificationSurvey units are classified based on contamination potential according to the methods described in the MARSSIM. In general, there are two overall classifications, non-impacted and impacted. Non-Impacted areas haveno reasonable potential for residual contamination because there was no known impact from facility operations.Impacted areas may contain residual radioactivity from facility operations. Based on the levels of residual radioactivity present, impacted areas are further divided into Class 1, Class 2 or Class3 designations.

Class 1 areas have the greatest potential for residual activity while Class 3 areas have the least potential for impacted areas. Each classification will typically be bounded by areas classified one step lower to provide a buffer zone around the higher class. Exceptions occur when an area is surrounded by a significant physical barrier, such as a wall, that would make transport of residual activity unlikely from one area to the adjacent area. In such cases, each area will be classified solely on its own merit using the most reliable information available. The class definitions provided below are from Section 4.4 of the MARSSIM.

BMRC Decommissioning PlanRevision 0 63Areas that have, or had prior to remediation, a potential for radioactive contamination (based on site operating history) or known contamination (based on previous radiological surveys).Examples of Class 1 areas include: 1) site areas previously subjected to remedial actions, 2) locations where leaks or spills are known to have occurred, 3) former burial or disposal sites, 4) waste storage sites, and 5) areas with contaminants in discrete solid pieces of material high specific activity.Note that areas containing contamination in excess of the DCGLClass 1 wprior to remediation should be classified as Class 1 areas.These areas have, or had prior to remediation, a potential for radioactive contamination or known contamination, but are not expected to exceed the DCGLClass 2 w.To justify changing an area's classification from Class 1 to Class 2, the existing data (from the HSA, scoping surveys, or characterization surveys) should provide a high degree of confidence that no individual measurement would exceed the DCGL w.Other justifications for this change in an area's classification may be appropriate based on the outcome of the DQO process.Examples of areas that might be classified as Class 2 for the final status survey include: 1) locations where radioactive materials were present in an unsealed form (e.g.,process facilities), 2) potentially contaminated transport routes, 3) areas downwind from stack release points, 4) upper walls and ceilings of some buildings or rooms subjected to airborne radioactivity, 5) areas where low concentrations of radioactive materials were handled, and 6) areas on the perimeter of former contamination control areas.Any impacted areas that are not expected to contain any residual radioactivity, or are expected to contain levels of residual radioactivity at a small fraction of the DCGLClass 3 wThe size of a survey unit is directly affected by its classification. Section 4.6 of MARSSIM provides suggested sizes for survey units. However, as stated in MARSSIM, the suggested surveyunit sizes were based on a finding of reasonable sample density and consistency with commonly used dose modeling codes. MARSSIM limits the size of a survey unit.

,based on site operating history and previous radiological surveys.Examples of areas that might be classified as Class 3 include buffer zones around Class 1 or Class 2 areas, and areas with very low potential for residual contamination but insufficient information to justify a non-impacted classification.Table 4-1summarizes MARSSIM recommendations for survey unit sizes based on their type and classification.Table 4-1Recommended Survey Unit SizesClassificationMinimum/MaximumBuildingsOpen LandClass 110-m 2/ 100-m100-m 22/ 2,000-mClass 2 2 100-m 2/ 1,000-m2,000-m 22/ 10,000-mClass 3 21,000-m 210,000-m/ No limit 2/ No limit BMRC Decommissioning PlanRevision 0 644.3.2BMRC MARSSIM ClassificationsFollowing remediation and demolition of the buildings, there will be no structures remaining that w ill require FSS. Using the size restrictions in Table 4-1, the exposed bedrock may include only one Class 1 survey unit. The exposed subsurface soils surrounding the Class 1 survey unit will likely be designated as a single Class 2 survey unit to a maximum survey unit size of 10,000 m 24.4Data Collection. The remaining surfacesoils will be designated as a Class 3 survey unit.Survey methods are applied differently depending on the data requirements of a survey area. For example, removable activity measurements provide little, if any, benefit when attempting to assess the radiological conditions in an excavation. Conversely, assessing a building surface via volumetric sampling would provide the necessary data, but at great costs of time and money. This section will discuss the steps necessary to strike a reasonable balance between data needs and ease of survey performance based on the data needs of the survey area.4.4.1Buildings, Equipment, and ComponentsBuildings, equipment, and components are not expected to remain after license termination.4.4.2SoilsTo demonstrate soil areas meet the appropriate release criteria, gamma scans and volumetric samples are required as demonstrated in the following two sections.4.4.2.1Surface Soil ScansSoil areas require gamma scan measurements as part of the FSS process at appropriate coverage rates and speeds that ensure hot spots and/or hot particles are detected.The coverage rates and speeds will be described in the FSS plan and subsequent report to ensure adequate MDCs for hot spots and/or particles.4.4.2.2Volumetric SamplesVolumetric samples are required to demonstrate a soil area meets the appropriate release criteria. In lieu of volumetric samples, soil areas may receive direct measurements using in-situ gamma spectroscopy, as equipment and trained personnel are available. Volumetric sampling differs slightly depending on the situation for which the sample is desired. The required quantityof volumetric samples for an open land survey unit is a calculated value that is discussed in MARSSIM.

BMRC Decommissioning PlanRevision 0 654.4.3BedrockThe Neutron Deck of the BMRC was poured directly on the bedrock with no leveling material (e.g., gravel or sand)utilized between the bedrock and concrete. The bedrock, described in Section 8.0, is non-porous and similar to a concrete slab. Radiological impacts to the bedrock are expected to be limited to the surfaceand after the concrete is removed from the bedrock, loose material such as soiland concrete dust will be removed prior to the FSS. 4.4.4Bedrock Surface ScansThe bedrock surfaces, after cleaning, will be scanned using beta instrumentation such as a gas flow proportional detector. The coverage rates and speeds will be described in the FSS plan and subsequent report to ensure adequate MDCs for hot spots and/or particles.Volumetric samples may be collected to verify residual radioactive materials are only on the surface of the bedrock.4.5Data EvaluationData evaluation is performed on FSSresults for individual survey units to determine whether the survey unit meets the release criteria. Appropriate tests will be used for the statistical evaluation of survey data. Tests such as the Sign test and Wilcoxon Rank-Sum (WRS) test will be implemented using unity rules, surrogate methodologies, or combinations of unity rules and surrogate methodologies, as described in the MARSSIM and NUREG-1505 Chapters 11 and 12.If the contaminant is not in the background or constitutes a small fraction of the DCGL, the Sign test will be used. If background is a significant fraction of the DCGL the WRS test will be used. It is anticipated that the sign test will be the only statistical test applied to the collected data because of the small fraction of the DCGL that background radionuclides will contribute.

BMRC Decommissioning PlanRevision 0 664.6Final Status Survey ReportThe FSS report will provide a summary of the survey results and the overall conclusions todemonstrate that the BMRC site meets the radiological criteria for release. Information such as the number and type of measurements, basic statistical quantities, and statistical analysis results will beincluded in the report. The level of detail is to be sufficient enough to clearly describe the FSS program and to certify the results.

The basic outline of the final report will be similar to the following:Overview of the ResultsDiscussion of Changes to FSSFSS Methodology oSurvey unit sample size oJustification for sample size oSurvey Instrument MDCsFSS Results oNumber of measurements taken oSurvey maps oSample concentrations oStatistical evaluations, including power curves oJudgmental and miscellaneous data sets oElevated Measurement Comparisons (if used)Conclusion for each survey unit BMRC Decommissioning PlanRevision 0 67 5.0This DP is an addendum to Revision 27 of the BMRC Technical Specifications. Revision 27 has been submitted to the NRC via a license amendment request to perform decommissioning activities in accordance with this plan. The Technical Specifications include alicense conditionrequiring an FSS Plan to be submitted and approved by the NRC prior to conduct of license termination surveys.TECHNICAL SPECIFICATIONS BMRC Decommissioning PlanRevision 0 68 6.0The regulations in Section 73.67(c)(1) of Part 73 require facilities to maintain a physical security plan when they possess special nuclear materials of moderate strategic significance or 10 kg or more of special nuclear material of low strategic significance. There is no nuclear fuel remaining at the BMRC; therefore, apart 73 physical security plan is notrequired. PHYSICAL SECURITY PLANA site security plan is maintained to comply with the regulations in Subpart I, Storage and Control of Licensed Material, of 10 CFR 20 are applicable to the remaining radioactive materials possessed by the UB. Licensed materials in storage are secured from unauthorized access or removal. Additionally, licensed materials not in storage will be under the control and constant surveillance of authorized personnel.

BMRC Decommissioning PlanRevision 0 697.0EMERGENCY PLANBMRC ceased operation in 1994, with the used reactor fuel returned to the DOE in 2005 and unusedreactor fuel shipped in 1998. Current activities in this building are minimal, with concentration on maintaining surveillance, monitoring of environmental conditions and security of the facility. During decommissioning of the site, management of significant emergency incidents by the UB will be accomplished through implementation of a response framework as specified by Federal Emergency Management Agency (FEMA) using the Incident Command System (ICS). TheUB is committed to an All Hazard Emergency Management approach, which designates areas of responsibility and defines the administrative framework to respond to all emergency incidents. OverviewThe start of the decommissioning workraises the level of concern regarding response to an incident at the BMRC. Even though research has ended, the fuel returned to the DOE, and the level of risk reduced, the importance of protecting the surrounding community remains a priority to the UB. ActionsWithout research activityora source of fuel, the existing equipment is the highest risk at the BMRC. Access to thefacilityis limited anddaily monitoring of activities atthe BMRC is conducted under the supervision of the UB and DOC project management team, minimizing the riskpotential. This team carefully monitors the status of activities and implements controls to minimizeexposure. The Site Security Plan, along with the UB police monitoring capabilities, maintains a safe environment and protectsthe surrounding community. The UB Communications Department plays an important role in response to any emergency at BMRC, providing accurate information to all media resources. Utilizing the Crisis Communication Plan from the Division of External Affairs, this information flow will maintain community confidence and supporting the UB's response to all incidences at the BMRC.Utilization of the ICS, under FEMA guidelines, will provide a quick response mitigating the incidentsof concern at the BMRC. Unified command under ICS format will afford the UB the opportunity to bring experts from multiple agencies together to mitigateimpactsand allow for a smooth transition back to normal activities at the BMRC until decommissioning.

BMRC Decommissioning PlanRevision 0 70 8.0The Decommissioning ER was prepared in accordance with the guidance provided in Chapter 6.0 of the NRC Office of Nuclear Material and Safety and Safeguards' (NMSS) NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (NRC 2003b). The ER is provided in Appendix Cand is provided foruse by the NRC toconduct its environmental assessment of the potential impacts of this proposed DP in accordance with the National Environmental Policy Act (NEPA) of 1969. NEPA requires Federal agencies, as partof their decision-making process, to consider the environmental impacts of actions under their jurisdiction. The NRC's NEPA requirements are provided in 10 CFR 51.ENVIRONMENTAL REPORT BMRC Decommissioning PlanRevision 0 71 9.0Following NRC review and approval of the DP, the DP will be incorporated as an amendment to license R-77. Minor changes to the DP that do not change the original intent of the DP and which do not involve an unreviewed safety question may be approved by theOperating Committee, a sub-group of the RDSC, as defined in the BMRC Technical Specificationsand this section. The licensee may make changes to the DP without prior NRC approval provided the proposed changes do not:CHANGES TO THE DECOMMISSIONING PLAN i.Require Commission approval pursuant to 10 CFR 50.59;ii.Use a statistical test other than the Sign test or WRS test for evaluation of the FSS;iii.Increase the radioactivity level, relative to the applicable derived concentration guideline level, at which an investigation occurs;iv.Reduce the coveragerequirements for scan measurements;v.Decrease an area classification (i.e., impacted to unimpacted; Class 1 to Class 2; Class 2 to Class 3; or Class 1 to Class 3);vi.Increase the Type I decision error;vii.Increase the DCGLs and related MDCs (for both scan and fixed measurement methods); orviii.Result in significant environmental impacts not previously reviewed.If a significant change to the DP is required, the BMRC RDSC will apply the criteria identified in 10 CFR 50.59 (March 2001) as it applies to non-power reactors in decommissioning. Guidance on implementing the requirements 10 CFR 50.59 is provided in the following documents:NRC Regulatory Guide 1.187 Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and ExperimentsNuclear Energy Institute (NEI) Guidance NEI 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, September 2000NRC Inspection Guidance (Part 9900)If the RDSC determines that the change is significant and could pose a significant increase in potential worker, public, or environmental impacts, NRC approval will be obtained prior to implementing the change. Changes to the DP are to be listed in the Summary of Changes table at the beginning of this DP with special demarcations in the margins next to the revised text. A report ofchanges made to the DP without NRC approval is to be maintained for review by the NRC during routine decommissioning inspections.

Records of all changes to the DP are maintained until license termination.

BMRC Decommissioning PlanRevision 0 72 10.01.Enercon Services, Inc. July 30,2011.BMRC Radiological Characterization Report

.REFERENCES2.WMG, Inc. September 2011. University at Buffalo Activation Analysis and Component Characterization, Revision 2. 3.International Organization for Standardization (ISO). 1988. Evaluation of Surface Contamination-Part 2: Tritium Surface Contamination.ISO 7503-2. August 1.4.U.S. Nuclear Regulatory Commission (NRC) (formerly the U.S. Atomic Energy Commission).

1974.Termination of Operating Licenses for Nuclear Reactors. Regulatory Guide 1.86. June.5.NRC. 1981. Control of Radioactively Contaminated Materials. NRC Office of Inspection and Enforcement (IE). IE Circular 81-07. May 14.6.NRC. 1996. Guidance for Preparing and Reviewing Applications for Licensing of Non-Power Reactors.NUREG-1537, Part 1. February.7.NRC. 2006. Consolidated Decommissioning Guidance. NUREG-17578.NRC. 2000. Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM). NUREG-1575, Revision 1. August.9.NRC. 2003. Radiological Assessments for Clearance of Materials From NuclearFacilities

.NUREG-1640, Volume 1. June.10.NRC. 2003. Environmental Review Guidance for Licensing Actions Associated with NMSS Programs.Office of Nuclear Material and Safety and Safeguards. NUREG-174811.NRC. 2011. Standards for the protection against radiationTitle 10, Part 20, Code of Federal Regulations.

BMRC Decommissioning PlanRevision0APPENDIX A -ACTIVATION ANALYSIS AND COMPONENT CHARACTERIZATION T B U T he ST A U FFALO AN A TE UNI V MATE R A C D COM P V ERSIT Y R IALS R C TIVAT I P ONEN T Report 1 R e M W M 1 Pr e 16 B Peeks k Y of NE W ESEAR C I ON AN A T CHAR 1 0-102D-R E e vision A May 2011 M G Project 1 0-102D epared by: Bank Stree k ill, NY 10 W YOR K C H CE N A LYSIS R ACTER I E-138 t e t 566 K at BU F N TER R E I ZATIO N F FALO E ACTO R N R BMRC A Compo nThis re p The St a plan for under S A ctivation A n ent Chara c p ort summ a ate Univers the Unive UNY Cont r A nalysis an d c terization a rizes the a city of New rsity at Bu f r act T-0004 d F O c tivation a n York (SU N ffalo's Rea01. i O REWORD n alysis wor k N Y) in the cto r. This Repo r k performe d preparatio n work was rt 10-102D

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... 26 P age..... 6 BMRC A Compo n 1.0 I NIn Octo b WMG t o Buffalo prelimin used to product The res have b e results acore pl a and su r evaluat e Based conserv addition of highl y (which signific a conside r in accor The rel e results a CFR P a and ar efinal cla s and con assume A. Th e directly p The an a specific classific require m present e A ctivation A n ent Chara c N TRODUC b e r 2010, T o perform aMaterials ary result s complete content wi tults prese n e en obtain e are consid e a te) the cal rf ace conta e d.on WMG'ative and , surface c y activate d can conta i ant for rea c red prior t o dance with evant acti v are used t o art 61. Th e e used to q ssification usidered fin ad to be fix e e refore, th e p roportion a alysis meth o results i n ation as o m ents for t h e d in Secti o A nalysis an d c terization T ION T he State U a n activatio Research s of WMG'this phas e t hin the act n ted in this e d with ad e e red prelimculated ac t mination, w's extensi v provide a c ontaminati o d reactor c i n activati o ctor compo n o classifica t 10 CFR P a v ation pro d o classify t e activatio n q uantify th e under 10 C al since th e e d and con s e individual a l to the Co ods used f o n terms o o f June 1 he activate d o n 5. d P a University on analysis Center (B s demons t e of work.

ivated rea c report will equately s cinary until a t ivation ac t which cov e v e experi e a reasona b on typicall y c omponent s o n product s nents with tion as Lo w a rt 61. d uct radio n t he activat e n product s e hard-to-dFR Part 61 e ratios of i sistent thr o radionucli

-60 conce n or this proj e o f estimat e , 2011 a r d compone n ge 1 of 28 o f New Yor k and segm e BMRC) rea t rated and The preli m c tor compo n require fu r c aled mea s a ll (includi nivities are e rs the sur f ence, the b le basis f y does not

s. Howev e s, fission relatively l w Level Ra d nuclide co n e d reactor s caling fact o d etect radi

o. The rep ompurities i n oughout th e de conce n n tration.ect are dis c e d activati o r e present e nts are dis c Repo r k at Buffal o entation pl a actor. Thi s approved m inary res u nents. rther norm a surement e n g the con t normalize d faces of t h prelimina r for decomdictate th e er, the su r products aow activat i d ioactive W ncentration s compone n o rs are al s onuclide c o o rted scalin n the initial e compone n ntrations fr o c ussed in S o n activit y e d in Se c cussed in S rt 10-102D

-o (SUNY B u a nning for s report s analytical u lts prese n a lization af t e quipment.t rol rod shr d to measu h e reactor ry activati o missioning e NRC was rface cont a a nd transu i on activiti e Waste (LL R s determi n nts in acco s o present e o ncentratio n g factors amaterial c o nts, as sho o m neutro n Section 2.

T y and 10 ction 3. T Section 4.

-RE-138 R e 05/2 uffalo) eng a the Univer s ummarize s methodol o n t the activ ter final su r The rep oouds and l red dose r componen t o n results planning.te classific aminant a cranics) ca n es and mu s RW) for dis p ned from t rdance wi t ed in this r e n s importare Co-60 b o mposition swn in A pp e n activatio n T he comp oCFR Par The pack a Reference s e v.A 2 011 a ged sity's s the o gies ation rveys o rtedower ates, ts, is are In ation c tivity n be st be posal hese t h 10 e portnt to ased s are e ndix n are onent r t 61 a ging s are BMRC A Compo n Histori c The B Moriginall ywas rec o A ctive approxi m were m o a 6 x 6 a BMRC os. Wa t change d reactor c The faci docume A ctivation A n ent Chara c c al summ a MRC is a li g y fueled wi t o nfigured acore heig mately 16-i n o dified and array of fu e o perated w i ter coolin g d during th e c ore comp o lity operati n nt. Facilit y A nalysis an d c terization ry ght water p t h Material s a nd used A ht is ap p nches abo vre-used d u e l assembli ith relativel y, experim e e operatio n o nents.n g history f y operating d P a p ool type r s Test Rea MF/Hittma n p roximately ve the top f u ring the r ees but did y high rese e ntal facilit y n al history o f orms the b records th r ge 2 of 28 r eactor co nctor (MTR)n/IRM Puls t 24-inche s face of the e configurati onot operat earch react o y , and re a o f the facili t basis for th e r ough June Repo r n structed b) fuel from 1 tar fuel fro m s and co rGrid Plate

.on. The c o e with eac h or flux level actor tank t y without s e activation 1994 are i n rt 10-102D

-b y the Uni v 1961 to 19 6 m 1964 thr o r e mid-pl a. Many re a ore is confi g h grid locat i l s approac h configurat i s ubstantial analysis p n cluded in

-RE-138 R e 05/2 versity that

63. The B M o ugh shutd ane is lo c actor core i gured to a c i on fueled.

h ing 10 13 n/ions were changes t o p resented i n this report.

e v.A 2 011 was M RC own.c atedtems ccept The /cm 2-also o the n this BMRC A Compo n 2.0 N WMG u sof the p material 5) com p A simil a decom m method o provide Several provide dpast. T hHigh Fl u Similar e stated i n method o A ctivation A n ent Chara c N EUTRON T s ed Unive r p rovided n e compositi o p uter progr a a r activati o m issioning ology has b reasonabl e assumpti o d by the U n h e activati o u x Beam R e ffects to a n the sub s o logy. A nalysis an d c terization TRANSP O rsity suppli e eutron flux ons shown a m to perfo r on analysi activities b een refine d e character i ons were m niversity or on analysis R eactor ind a lesser d e sequent se d P a RT AND A e d neutron data is i n in Append i r m activati o s method oat 18 d o d and ben c i zation res u m ade for t h available f and dose icated Co-e g r ee are pctions des ge 3 of 28 A CTIVATIOflux levels n cluded in i x A are us e o n analysis ology has omestic p o chmarked o u lts for the c h e activati o f rom simila profiling at 60 produc t present at t c ribing ea c Repo r N METHO Dat locatio n Section 2.ed as inpu t on individ u been us e ower and o ver the ye a c omponen t o n analysi s a r projects p the Brook h t ion in 60 6 t he BMRC.c h portion rt 10-102D

-DOLOGY ns of intere2. The fl u ts to the O R u al compo n ed by W M research a rs and ha s t s of intere s s , based u p p erformed h aven Nati o 6 1 Aluminu m. These aof the act i-RE-138 R e 05/2 st.A sum u xes and i R IGEN2.2 n ents.MG to su p reactors.s been fou n s t.pon informby WMG i n o nal Labor a m compon ssumption s i vation an a e v.A 2 011mary initial (Ref.p port The n d to ation n the a tory ents.s are alysis BMRC A Compo n 2.1 I n U r e e 2 2 A ctivation A n ent Chara c n put Para m Use of the e actor co m xposure hi s.1.1 Mate Elem com p inclu d were disce Shro u stainl confi r com m type well colu m liner i The i from from react o perfo Mate r Univ e.1.2 Ope r A de t the B on a The c June A n ir r cale n this amaxi m acco u sum m A nalysis an d c terization m eters ORIGEN 2 m ponents i s tories.rial Comp oental mat e puter progr d ed in the lacking, arn materi a uds are fa ess steel f rmed or a s m on 6061 g304. Nic kdocument e mn. The r e i nterior to a initial mat e NUREG C work perf o ors. The Armed at th e rial compo s e rsity, r ating Hist o t ailed oper a BMRC. Th emonthly b a c umulative 1994 was 6 r adiation p o ndar year o analysis. T mum MW s u nted for m arized in T d P a 2 compute r i n terms o o sitions e rial comp o am.A s u appendic e a nd WMG als of con s bricated p r fasteners.

s sumed to g rade Alu m kel clad, sil v ed. Reac t e actor tan k a poured 2 2 e rial comp o C R 3474 (R o rmed for t h A luminum A e Universit y s ition data f ory a ting and p e informati o asis from s tpower pr o 6 8,543.4 M ower histo r o f operatio nhe capacit y s/day (cyc in the o p T able 2-1 b ge 4 of 28 r program of their p h ositions ar e ummary of es. Detail e used dra w struction.

rimarily of Aluminum be fabric a minum. All v e r-indium-tor grade k is constr u 2 5 pcf conc r osition dat a Ref. 6). T h h e Brookh a Alloys 606 1 y of Michig for the Co n power histo r o n was pr o t art-up (Jul o duced ov e M W-hrs.ry was co m n, which is y factor for le 17, 19 p erating helow. Repo r requires a h ysical ch a e required the initial ed drawing wings and The Grid 1100 gra d compone n a ted from l stainless

-cadmium C graphite w ucted of a r ete pit.a for SS30 4 h e graphit e a ven Natio n 1 and 110 0 an and th e n trol Rod Bry was pro v o vided in t e ly 1961) u n e r the lifeti m m piled fro m considere d each "cycl e 987). Sig h istory.T rt 10-102D

-a ccurate m a racteristic s inputs for material cs with ma t technical Plate an d e Aluminu nts outsid e l ess expe n steel was Control R o was used 6061 A lu m 4 and con c e composit n al Labora t 0 are com p e NASA Pl ulades was vided by t h erms of M W n til shutdo w me of the m this infor m d a "cycle e" is deter mnificant d o T he opera-RE-138 R e 05/2 m odeling o f s and ne u the ORI G c ompositio n t erial heat descriptio nd Control m with int e e the core w nsive and m assumed t od material in the th e minum tan k crete are tion is com tories' res e p iled from umbrook fa c provided b y he Universi t W-hrs prod wn (June 1 9 reactor thr o m ation for of operati o m ined usin g o wn times ting histo r e v.A 2 011 f the u tron G EN2 ns is data n s to Rod e gral w ere m ore t o be was ermal k and akenpiled e arch work c ility. y the t y for uced 9 94).o ugh each on" in g the are ry is BMRC A Compo n N 2.2 N A F i r A ctivation A n ent Chara c N otes:Time actu a** M W Cap a N eutron Fl u A summary F igure 2-1 b r radiation f aOrigenPo wYearCycle1961(712)1962 1963 1965 1966 1984 1985 1986 1987 1988 1989 19921994(1 3)1994(6)Survey: A nalysis an d c terization Steps (i.e al operatin g W s/day is n a city Facto r u x Data of the ne u below. Thi s a cilities.w erHistory:Start07/01/61 001/01/62 001/01/63 004/01/65 001/01/66 001/01/84 001/01/85 001/01/86 001/01/87 001/01/88 001/01/8906/01/92 01/01/94 006/01/94 02/24/2011 d P a T BMRC O p., "Cycles

")g history at B ecessary d r= [MWs/d a utron flux d s data repr

" CStopL e 01/01/62 01/01/63 06/30/63 01/01/66 03/31/66 01/01/85 01/01/86 01/01/87 01/01/88 01/01/8911/30/89 12/31/92 03/31/94 06/30/94 ge 5 of 28 T able 2-1 p erating H") are esta b B MRC vs O d ue to the i n a y ---- Cycl e ata used i nesents typi Cycle"De c engthDa y184 365 180 275 89 6366 365 365 365 366 333 213 89 29 6 Repo ristory b lished ba s O rigen co m nconsisten t e (i)] / (Max

.n the activ a i cal therm aTotal cayYear ysMWs413.1,295.641753.3,255.64851,085.10,598.

10,922.

10,117.

11,010.9,894.9149,025.

3663,684.621,580.60830.8 rt 10-102D

-sed on the m puter cod e t Cycle len

g. MWs/day)a tion anal y al and fast fMWsper Cday**32.263.55 04.18 811.84 312.19 028.96 729.93 027.72 430.17 427.03 827.10 617.30 817.760.03-RE-138 R e 05/2 applicabil i e g ths)ysis is sho w flux data f o CapacityFactor0.0740.118 0.139 0.392 0.404 0.960 0.992 0.919 1.000 0.896 0.899 0.573 0.5890.001 e v.A 2 011 ity of w n in o r the B C B MRC Activat i C omponent C h i on Analysis a n h aracterizatio n n d n Univer s P F sity of Buffal o age 6 of 28 F igure 2-1 o Irradiation F Facility Flux D Report 1 D ata 1 0-102D-RE-1 38 Rev. A 05/2011 BMRC A Compo n 2.3 O T a c T l o S S s r e c c

t r p p

c d A ctivation A n ent Chara c O RIGEN 2 N T he ORIGE nd depleti oomponent T able 2-1 u o cation an d S ome r eact S hrouds, a rignificantly esulting in omponent lassificatio n radeoffs a nrimarily c oins that w lassificatio n ifferent ma A nalysis an d c terization N eutron A cN2 compu t on of radi o was irradi a u sing the d the initial mor compo n r e constru c for each different dmaterials.

n and dec o n d difficulti e nstructed o w ould be d n results i n t erial cons t d P a c tivation C ter code, v e onuclides i n a ted based appropriat e m aterial co nent asse m c ted from material a ose rates However, o mmissioni n e s in mat e o f 1100 g r difficult an d n Section t ituents of t h ge 7 of 28 C alculation e rsion 2.2, n compon e on the rea e Universi t mpositions mblies, not amultiple mnd due to and differ e the comp o n g purpos e e rial separ a r ade alumi n d dose int e 3 for suc h h e assemb Repo r n s was used e nts expos e actor opera t ty-supplied

.ably the G r m aterials. the differ ent waste c o nents are es in many ation. For n um, inclu d ensive to h compon e ly. rt 10-102D

-to calcula t ed to neut r ting history d flux for t r id Plate a nNeutron a c r ent materi a c lasses fo rtreated as cases due example, des stainl e remove.ent assem b-RE-138 R e 05/2 t e the activ ron flux.E summariz e t he comp o n d Control c tivation d al compos r the resp e assembli eto the pra c the Grid P e ss steel d Therefore , blies reflec t e v.A 2 011 ation E ach e d in onent Rod iffers s ition, e ctive es for c tical P late, dowel , the t the BMRC A Compo n 3.0 EThis se c Februar yand, as such d a product s 3.1 O T b s

i n a r a t h n e T w e o

c b

e a

d A ctivation A n ent Chara c E STIMATE D c tion prese n y 2011. T stated pre v ata is avail a s only. O verview T he activati ased on O pect ra. T ndividual n u nd nuclide a tes will c h h e compo n ormalizati o xpected to T able 3-1 p w eight, was t stimated a c f June 1, 2 onstructio n y the U n xperience.

nalysis ar e isposal, or A nalysis an d c terization D COMPO N nts the esti These preli m viously in t h able. The aon results O RIGEN o he ORIG E u clide acti vspecific a c h ange the a n ent-specifi on to meas reduce co m p resents a t e volume, ctivity for a 2011. Co m n were det e n iversity, s Please n o e displace m"envelope" d P a N ENT RA D mated acti v minary esti m his report, w activities p rof all rea c output usin g EN output vities are c a ctivity. No a ctivation a c scaling u red dose m ponent to summary total activ a ll reactor c o m ponent w e rmined fro s upplemen t ote that th e ment volu m volumes.ge 8 of 28 D IOACTIVI T v ity for eac mates are will be nor m r esented in c tor comp o g Universi tis in term s a lculated u s rmalization a ctivity for efactors.

Brates at th tal activity.of the pr e ation activit y o mponent s waste weig h m the dra w ted as n e waste vo mes and d This will b e Repo r T Y h reactor c based on malized to m this secti o o nents pre s t y provide d s of speci f s ing the a c n to more a e ach com p Based on e time of a e liminary ry and mat e s should b e h ts, waste w ings, doc u n ecessarylumes incl uo not refl e e addresse d rt 10-102D

-c omponent activation a measured d o n represe n sented in t d flux lev e fic activity c tivated co m a ccurately m ponent but

WMG's p a a ctual dec o results in t erials of co n e less than volumes a u ments an dby WMG uded in thi s ect the "a s d further in

-RE-138 R e 05/2of interest a analysis r e d ose rates w nt the activ this sectio n els and e n(Ci/g) an d mponent w m easured will not ch a ast experi e o mmissioni n t erms of w n struction.

1,200 curi end materi a d data pro v's engine e s section o s-package d Section 4.

0 e v.A 2 011 as of esults w henation n are nergy d the eight dose a nge ence, ng is w aste The es as als of vided e ring o f the d" for 0.

B C B MRC Activat i C omponent C h C Reactor Stru c Components Plenum Flapper Plenum Cham bIon Chamber GFission Cham b Reactor Tank SubtotalsReactor Core Grid Plate Grid Plug (ea)

Fission Cham b Control Eleme n Control Eleme n Control Eleme n Subtotals Experimental Pneumatic Co n Thermal Colu mDry Chamber Isotope Tubes

Vertical Stand p Becquerel Sta n Subtotals i on Analysis a n h aracterizatio n C omponent ctural/Peripher a ber Stand G uide ber (worst case

)Components ber Guide nt (ea, typical) nt Shroud (ea, t nt Drive Shaft (eFacilities nveyo r m n (ea, typical) p ipes (ea, typic a ndpipe Totals nd n C o a l)t ypical) ea, typical) a l)P T Universit y o mponent C h Waste Weight (lbs)54.8 19.0 31.9 7.2 1.5 88.4 2.3 10.8 11.2 87.1 87.1 10.3 3,162.0 1.8 23.5 33.1 age 9 of 28 TABLE 3-1 y at Buffalo B h aracterizatio n Waste Volume (ft 3)0.324 0.113 0.190 0.043 0.009 0.522 0.014 0.063 0.025 0.503 0.503 0.061 22.0 0.011 0.140 0.196 B MRC n Summary TotalActivity (Ci)7.29E-01 2.27E-01 4.41E+00 1.00E+00 1.18E+00<10 7.00E+01 1.67E+00 8.30E+00 5.53E+01 8.85E+01 6.29E+01<1,000 1.43E+00 1.16E+00 1.33E+00 3.27E+00 4.59E+00<50<1100 Report 1 Mate r 6061 Aluminu m 1100 Aluminu m 6061 Aluminu m 6061 Aluminu m 6061 Aluminu m 6061 A luminu m 1100 Aluminu m 6061 Aluminu m 6061 A luminu m Ni clad Ag-In-C 6061 Aluminu m 6061 Aluminu m 6061 Aluminu mRx Grade Gra p 6061 Aluminu m 6061 Aluminu m 6061 Aluminu m 6061 Aluminu m 1 0-102D-RE-1 r ials of Cons t m with 304 SS B m m m m with Uranium m m with 36 SS D o m m C d with Al & 30 4 m with SS Fast e m m p hite & 6061 Al m & Lead Shutt e m m m 38 Rev. A 05/2011 t ruction B olting Loading o well Pins 4 SS fixtures e ners uminum er BMRC A Compo n 3.2 C I n 1 S C p P a d T"s C s w A t o c 3 A ctivation A n ent Chara c C omponen t n dividual c o, 2011. T S tructural/P e C ore Comp lace (Grid P lugs, etc.

)ctivities, th e ose rates m T he radion significant" C ompleting ummary, a w aste in co n Grea t Grea t Grea t A s discuss e o update haracteriz a.2.1 Rea c The r Rea c Plen u The R cons t appr o A 3/4"oper a supp o conc r shiel d Preli m pres e A nalysis an d c terization t Radioact o mponent e he reactor e ripheral C onents. TPlate) or r e). Based e addition a m arginally buclide act iper the gNRC's Un i a radionucl i n centration s t er than 1%t er than 1%t er than 7.

0 e d previous the pre l a tion result s c tor Struct u reactor str u ctor Tank (u m and Fla p R eactor Ta t ruction no m oximately 1

" thick Lin e a tional hist o o rting the r ete aroun d d s j ust o u m inary ac t e nted belo w d Pa givity e stimated a compone n C omponent s The Reacto e side withi n on the e m al effect of s b ut is unlik e ivities pre suidance p r i form Low-L ide is con s s:% of the tot a% of the Cl a 0 Ci/cc for ly, final su r l iminary r s.u ral/Perip h u ctural an d Bioshield C p pe r , and Cnk is a 1/4 i n minally 8 ft 4 ft up fro m er was ins t o ry atop s utank vari e d core ele u tside the tivation an w.g e 10 of 28 a ctivation a nts are divi s, the Exp e r Core Co n the reac t m pirical d a surface co n e ly to chan g sented in r esented i n L evel Radi o s idered si g a l activity o f a ss A limit f o nuclides n rveys of th e esults pr e h eral Com p d peripher a Concrete), C ore Supp o nch thick q uwide at c o m the tank b talled inte r upport stri p e s f rom 2 5vation. T h reactor t aalysis res Repo r activities ar e ded into t h erimental Fmponents tor core (C ata from p n taminants g e waste clthis repo n NUREG/oactive W a gnificant w h f the comp o o r nuclides ot listed in e reactor c e sented h p onents a l compon e A luminum o rt.uasi-hexa g ore elevati o b ottom and rior to the p s/spacers.50 to 150 he BMRC ank at an d ults for s rt 10-102D

-e decay c o h ree group s Facilities a hold the f u ontrol Rod previous d e could incr e assificatio nrt are th o/BR-0204"a ste Manif e hen it is c o o nent listed in 1 010 CFR 61 c omponent s h erein to e nts includ e Reactor T gonal 6061 on increasi n d approxim a Reactor T. The Bio pcf with also has d above c elected c o-RE-138 R e 05/2 o rrected to s: the Re and the Re a u el eleme n Shrouds, e commissi o e ase comp o n.ose consi d"Instruction s e st" (Ref. 7 o ntained i n 0 CFCR 61.55 s are nece s provide e the Con c Tank and L plate alum ng to 14 ft ately 29 ft d Tank durin g shield con cheavy 25 0 moveable c ore elev a o mponents e v.A 2 011 June a ctor actor nts in Core o ning o nent d ered s for ). In n the .55 s sary final c rete L ine r ,inum wide d eep.g the crete 0 pcf lead a tion.are BMRC A Compo n A ctivation A n ent Chara c Plen u The P core fabri c com p abun d belo w C W W C C S T T A nalysis an d c terization u m Comp o Plenum, a n a nd suppo r c ated from ponents w dances an d w.C omponentDescription W aste Wei g W aste Volu m H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g o nents n d Plenum r ted the co r 3/8" thic k w ith stainl e d scaling f C ID P C h g ht m e Fr a A b u 1.0 1.5 1.

9.4 3.5 4.

1.9 3.8 2.3 1.0 g e 11 of 28 Chamber S r e while fa c k 6061 al e ss steel f actors are Ta b Plenu m C haracteri z 03a P lenum h ambe r 54.82 0.324 actional u ndance 0 2E-04 5 1E-03 11E-02 4 0E-01 5 2E-04 7 4E-02 9 9E-14 8 6E-05 3 5E-07 0 0E+00 Repo r S tand are l c ilitating couminum a fasteners summariz e b le 3-2 m Chambe r z ation Re s lbs ft^3 Co-60 SF 1.08E-04 1.61E-03 1.18E-02 1.00E+00 3.75E-04 5.05E-02 2.12E-14 4.11E-05 2.50E-07 rt 10-102D

-ocated be n o olant flow.

and interfa

c. Com p ed in Tabl e r s ults 2.49E+0 4 9.16E+0 3 NRC Fr a T1 0.02 0.00 0.15 0.00 0.17-RE-138 R e 05/2 n eath the a The Plen u ces with o ponent is o es 3-2an d 4 g 3 cc Class A a ctions T2 0.00 0.00 0.11 0.11 0.00 0.22 e v.A 2 011 a ctive um is o ther o tope d 3-3 BMRC A Compo n A ctivation A n ent Chara c A nalysis an d c terization ComponentDescription Waste Wei g Waste Volu H-3 C-14 Fe-55 Co-60 Ni-59 Ni-63 Sr-90 Nb-94 Tc-99 Total d Pa g Pl e C h ID P C h S g ht m e Fr A b u 1.3.1.

9.

2.

3.

1.

2.

5.1.0 g e 12 of 28 Tabl e e num Cha h aracteriza 03c P lenum h amber S tand 31.93 0.190 actional u ndance 22E-11 00E-03 38E-02 52E-01 49E-04 08E-02 09E-15 25E-05 77E-10 0 0E+00 Repo r e 3-3 a mber Sta n a tion Resu l lbs ft^3 Co-60 SF 1.28E-11 3.15E-03 1.45E-02 1.00E+00 2.62E-04 3.23E-02 1.14E-15 2.37E-05 6.06E-10 rt 10-102D

-n d l ts 1.45E+0 4 5.37E+0 NR C Fr a T1 0.31 0.01 0.93 0.00 1.24-RE-138 R e 05/2 4 g 3 cc C Class A a ctions T2 0.00 0.02 1.12 0.72 0.00 1.86 e v.A 2 011 BMRC A Compo n A ctivation A n ent Chara c Flap p The F durin g thick stainl facto r A nalysis an d c terization p er Flapper is g forced c o componen tess steel h rs are sum m Component IDDescription Waste Wei g WasteVolume H-3 C-14 Fe-55 Co-60 Ni-59 Ni-63 Sr-90 Nb-94 Tc-99 Total d Pa g a hinged a onvection a t was fabri c h inge parts m arized in T C h 0 Fl a g ht Fra c A bu n 4.8 9 1.4 9 5.5 4 9.7 7 1.1 0 1.5 4 1.2 5 3.8 4 5.5 2 1.0 0 g e 13 of 28 and count e a nd open d c ated from . Compon Table 3-4 b Tabl e Fla p h aracteriza 0 3b a ppe r19.00l 0.113 f ctional n dance 9 E-12 9 E-03 4 E-03 7 E-01 0 E-04 4 E-02 5 E-14 4 E-05 2 E-09 0 E+00 Repo r e rbalanced d uring nat u 1100 grad eent isotop e below. e 3-4 p per a tion Resu l bs f t^3 Co-60 SF 5.00E-12 1.53E-03 5.67E-03 1.00E+00 1.13E-04 1.58E-02 1.28E-14 3.93E-05 5.65E-09 rt 10-102D

-plate that u ral circul a e aluminu m e abundan c l ts 8.62E+0 3 3.19E+0 3 NR C Fr a T1 0.01 0.00 0.14 0.00 0.15-RE-138 R e 05/2was shut d ation. The m with som e ces and s c 3 g 3 cc C Class A a ctions T2 0.00 0.00 0.10 0.03 0.00 0.13 e v.A 2 011 d ung inch e 304 c aling BMRC A Compo n A ctivation A n ent Chara c Ion C The i o abov e cha m sum m C W W V C C S T T A nalysis an d c terization C hamber G o n chamb e e the Grid mbers. C o m arized in T C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g Guide e r guide is t Plate bol t o mponent Table 3-5b C h ID Ion Ch g ht F r Ab 1 3 1 9

2 3

1 2

6 1.g e 14 of 28 t he frame w ted to the isotope a below. Tabl e Ion Cham b h aracteriza 04amber Guid 7.21 0.0 4 ractional b undance.61E-11.29E-03.37E-02

.49E-01

.72E-04

.32E-02

.30E-15

.47E-05

.33E-10.00E+00 Repo r work of 2 in cPlenum t o b undances e 3-5 b er Guide a tion Resu l d e5lbs 43ft^3 Co-6 0 SF 1.70E-3.46E-1.45E-1.00E+2.87E-3.50E-1.37E-2.60E-6.67E-rt 10-102D

-ch, 6061 a l o flange to and scali l ts 3.27E 1.21E 0 N R T111 03 0.302 +00 04 0.002 15 05 1.0 10 0.0 1.3-RE-138 R e 05/2 luminum a n locate th e ng factor s E+03 g E+03 cc RC Class A Fractions T 2 0.0 4 0.0 1.1 1 0.7 0.0 2 0 7 1.9 e v.A 2 011 n gles e ion s are 2 0 2 2 8 0 2 BMRC A Compo n 3 A ctivation A n ent Chara c Fissi The F and wis si z Despis no t durin g facto r C W W V C C S T T.2.2 Rea c Thes e cons e com p Guid e and l o A nalysis an d c terization on Cham b F ission Ch a w ithdrawn f r zed to fit iite it's rela t t expected g power o rs are sum m C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal c tor Core C e compon e equently t ponents co n e & Fissio n o wer porti o d Pa g b er amber is a r om the co rnside it's g tively light to drive w a operation.

m arized in T C h ID Fissi o g ht F r Ab 7 3 1 9

2 3

1 2

8 1.C omponen t e nts are s he most nsist of the n Chambe r o ns of the C g e 15 of 28 moveable re during p o g uide and weight, t r a a ste class b Compone n Table 3-6 b Tabl e Fission C h aracteriza 05a on Chambe r 1.0.0 0 ractional b undance.25E-10.59E-03.49E-02

.48E-01

.31E-04

.34E-02

.50E-14

.71E-05

.57E-10.00E+00 t s s ubject to activated Grid Plat e r , Control E C ontrol Ele m Repo r compone n o wer oper ais fabrica t ansmutatio n b ecause th e n t isotope below. e 3-6 C hamber a tion Resu l r.5lbs 09ft^3 Co-6 0 SF 7.65E-3.79E-1.58E-1.00E+2.44E-3.52E-1.58E-2.86E-9.04E-the great e compone n e , Grid Plat E lements, C m ent Drive S rt 10-102D

-n t located a a tion. The f t ed from 6 n of Uraniu e chamber abundanc l ts 6.80E 2.55E 0 N R T110 03 2.002 +00 04 0.002 14 05 6.2 10 0.0 8.3 est neutro n nts. Th e e Plugs, F i Control El e Shafts.-RE-138 R e 05/2 at a core c o f ission cha m 6 061 alumi nm to Plutowas withdes and s c E+02 g E+02 cc RC Class A Fractions T 2 0.0 6 0.1 6.2 5 4.3 0.0 0 0 1 10.6 n flux and e reactor i ssion Cha m ement Shr o e v.A 2 011 orner mber num. nium rawn c aling 2 0 0 0 7 0 6 7 are core m ber ouds, BMRC A Compo n A ctivation A n ent Chara c Grid The G array fittin g Shro u the u Com p Tabl e C W W V C C S T T A nalysis an d c terization Plate G rid Plate i sof 2.4" di a gs. 25 3/4" h ud locating upper fac e ponent iso t e 3-7belo w C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g s a 5 inch t a meter ho l holes are a l studs. 1/4" d e near ea t ope abun d w.C ID G g ht F r Ab 4 3 2

8 5

7 9

2 1 1.g e 16 of 28 t hick slab o les milled t lso milled t diameter s tch fuel h o dances an d Ta b Gri d C haracteri z 01 rid Plate 88.3 0.5 2 ractional b undance.71E-05.44E-03.06E-02

.98E-01

.37E-04

.72E-02

.31E-14

.40E-05

.37E-08.00E+00 Repo r o f 1100 gra d t o accom m o accomm o tainless st e ole to ori e d scaling f a b le 3-7 d Plate z ation Re s 36lbs 22ft^3 Co-6 0 SF 5.25E-3.83E-2.29E-1.00E+5.98E-8.60E-1.04E-2.67E-1.53E-rt 10-102D

-de aluminu m odate the odate the C e el dowel p ent the f u a ctors are s ults 4.01E 1.48E 0 N R T105 03 2.002 +00 04 0.102 13 05 5.6 08 0.0 7.8-RE-138 R e 05/2 um with a 6 lower fuel C ontrol Ele mins are fix e uel assem b summariz e E+04 g E+04 cc RC Class A Fractions T 2 0.0 4 0.1 6.0 2 10.4 0.0 8 0 3 16.6 e v.A 2 011by 6 end ment e d on blies. e d in 2 0 4 7 4 3 0 6 4 BMRC A Compo n A ctivation A n ent Chara c GridGrid expe r plug s abun d C W W V C C S T T A nalysis an d c terization Plate Plu g Plate hole s r iments w e s are fa b d ances an d C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g g s and We e s not occu p ere filled w b ricated f r d scaling f a C ID Singl g ht F r Ab 7 3 1

9 2

3 4

2 5 1.g e 17 of 28 e p Hole Pl u pied by fu e w ith Plugs.

rom 6061 a ctors are s Ta b Grid P C haracteri z 02 e Grid Plug 2.31 0.01 ractional b undance.36E-10.72E-03.55E-02

.46E-01

.38E-04

.44E-02

.00E-15

.61E-05

.20E-10.00E+00 Repo r u gs el, Control WMG co Aluminuummarize d b le 3-8 Plate Plug z ation Re s5lbs 4ft^3 Co-6 0 SF 7.77E-3.93E-1.64E-1.00E+2.52E-3.63E-4.23E-2.76E-5.49E-rt 10-102D

-Element S nservativel ym. Com p d in Table 3 s ults 1.05E 3.89E 0 N R T110 03 2.002 +00 04 0.002 15 05 5.6 10 0.0 7.6-RE-138 R e 05/2 S hroud stu d y assume d ponent is o 3-8below.E+03 g E+02 cc RC Class A Fractions T 2 0.0 0 0.1 5.8 5 4.2 0.0 1 0 5 10.1 e v.A 2 011 d s or d the o tope 2 0 0 1 2 0 1 3 BMRC A Compo n A ctivation A n ent Chara c Fissi The alum i core Com p Tabl e C W W V C C S T T A nalysis an d c terization on Cham bFission C h inum tube corner an d ponent iso t e 3-9belo w C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g b er Guide hamber G u with a fue l d is used t o t ope abun d w.C ID Fissi o g ht F r Ab 7 3 1

9 2

3 1

2 8 1.g e 18 of 28 uide is a 7 l assembly o guide th e dances an d Ta b Fission C h C haracteri z 05a on Chambe r Guide 11.0 0.0 6 ractional b undance.25E-10.59E-03.49E-02

.48E-01

.31E-04

.34E-02

.50E-14

.71E-05

.57E-10.00E+00 Repo r 71/2 foot lo nlower en d e elevatio n d scaling f a b le 3-9 h amber G u z ation Re s r 03lbs 65ft^3 Co-6 0 SF 7.65E-3.79E-1.58E-1.00E+2.44E-3.52E-1.58E-2.86E-9.04E-rt 10-102D

-n g 3 inch d fitting. It n of the Fi s a ctors are u ide s ults 5.00E 1.85E 0 N R T110 03 2.002 +00 04 0.002 14 05 6.2 10 0.0 8.3-RE-138 R e 05/2 diameter 6is located s sion Cha m summariz e E+03 g E+03 cc RC Class A Fractions T 2 0.0 6 0.1 6.2 5 4.3 0.0 0 0 1 10.6 e v.A 2 011 6 061at a m ber.e d in 2 0 0 0 7 0 6 7 BMRC A Compo n A ctivation A n ent Chara c Cont The Elem 80%

is us e diam e plati n rivet s steel.the R Cont r the t h the a parti c seve r facto r C W W V C C S T A A T A nalysis an d c terization rol Eleme n neutron r eents. The silver - 15

%ed to cou p e ter Drive ng) by 4.8 5 s attaching Two set s R eactor Ta r ol Elemen t hin nickel c a ctivated C cularly the red from th rs are sum m C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 A g-108m A g-108 T otal d Pa g n ts eaction is 0.18Contr o% indium -ple the pla tShaft. Th e 5 inches wi the transi t s of Contro lnk having t waste cla s c ladding.A C ontrol El efirst set of

e absorbe r m arized in T C ID Sin g E g ht F r Ab 5 1 1 9

7 8

1 8

5 1.1.1.g e 19 of 28 controlled o l Element s- 5% cadm t e-like Con t e absorber de by 29 i tion to th e l Elements a shorter ss is most h Also, cad m e ments s h Control E l r. Compo n T able 3-10 Ta b Contr o C haracteri z 14a g le Control E lement 11.1 5 0.0 2 ractional b undance.64E-05.17E-04.13E-02

.47E-02

.05E-03

.87E-01

.11E-14

.89E-07

.93E-09.46E+01.30E+00.00E+00 Repo r d by the s are fabri c ium alloy.

trol Eleme nis only 0.

1nches tall.

e absorber exist with exposure heavily infl u mium is co n h ould be clements, w nent isotop e below.b le 3-10 o l Element z ation Re s 50lbs 25ft^3 Co-6 0 SF 5.95E-1.24E-1.20E-1.00E+7.44E-9.36E+1.17E-9.38E-6.26E-1.54E+1.37E+rt 10-102D

-elevation c ated from A flat alu m n t absorb e 1 8 inches t WMG a s are made the set cu r history th a u enced by t n sidered a considered whose flat t e abundan c s ults 5.06E 7.10E 0 N R T104 03 0.001 +00 02 1.4+00 13 06 0.2 08 0.0+02 +01 1.7-RE-138 R e 05/2of the C oa nickel-p minum tran s e r with a 1 thick (excl u s sumed th e from stai n rrently stor e a n the firs t the activati o toxic wast emixed w t ransitions w ces and s c E+03 g E+02 cc RC Class A Fractions T 2 0.0 7 0.0 0.6 7 116.0.0 0 0 5 117.e v.A 2 011 o ntrol lated sition inch u ding e five nless e d in t set. on of e , so aste, w ere c aling 2 0 7 2 48 0 18 BMRC A Compo n A ctivation A n ent Chara c Cont Cont r Shro u The C 0.30 5 and f assu m abun d C W W V C C S T T A nalysis an d c terization rol Eleme n r ol Eleme n uds which C ontrol Ele 5 inches th f asteners a med to be d ances an d C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g n t Shroud s n t location act as a gment Shro u ick and ar e r e stainles s made fro m d scaling f a C C ID Cont S g ht F r Ab 1 2 3 7

1 1

2 1

4 1.g e 20 of 28 sis facilita t uide for th e uds have a e approxi m s steel whil m 1100 gr a a ctors are s Ta b C ontrol El e C haracteri z 14b rol Element S hroud 87.1 0.5 0 ractional b undance.48E-04.80E-03.60E-02

.91E-01

.18E-03

.69E-01

.84E-13

.93E-05

.18E-08.00E+00 Repo rted by fr a e absorbe r a rectangul a mately 6 fe e e the rem a a de alumi nummarize d b le 3-11 e ment Sh r z ation Re s2lbs 03ft^3 Co-6 0 SF 1.87E-3.54E-4.56E-1.00E+1.49E-2.14E-3.59E-2.44E-5.28E-rt 10-102D

-a me-like C r s regardle s ar cavity 5 et tall. Th e ainder of th num. Co m d in Table 3 r oud s ults 3.95E 1.42E 0 N R T104 03 2.102 +00 03 0.301 13 05 5.9 08 0.0 8.4-RE-138 R e 05/2 C ontrol Ele mss of elev ainches wi d e locating s e compon e mponent is o 3-11below.E+04 g E+04 cc RC Class A Fractions T 2 0.0 7 0.3 7.0 3 30.0 0.0 8 0 9 37.3 e v.A 2 011 m ent ation. de by s tuds ent is o tope 2 0 2 2 0 2 0 3 6 BMRC A Compo n A ctivation A n ent Chara c Cont Cont r Elem lowe r activ a lowe r C W W V C C S T T A nalysis an d c terization rol Eleme n r ol Elemen tent Drive rmost part ated. Co m r shaft are s C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g n t Drive S h t elevation Shafts ar eis activa t mponent i s summarize d C o C ID Cont D r g ht F r Ab 7 3 1 9

2 3

4 2

5 1.g e 21 of 28 h aftsis facilitat e e 1 inch d ted. The sotope abu d in Table 3 Ta b o ntrol Ele m C haracteri z 14c rol Element r ive Shaft 1.1 0.0 0 ractional b undance.36E-10.72E-03.55E-02

.46E-01

.38E-04

.44E-02

.00E-15

.61E-05

.20E-10.00E+00 Repo r ed by the D diameter 6 upper po rndances a 3-12below b le 3-12 m ent Drive z ation Re s7lbs 07ft^3 Co-6 0 SF 7.77E-3.93E-1.64E-1.00E+2.52E-3.63E-4.23E-2.76E-5.49E-rt 10-102D

-Drive Shaft 6 061 alum i rtion of t h a nd scaling

.Shaft s ults 5.30E 1.94E 0 N R T110 03 2.002 +00 04 0.002 15 05 5.6 10 0.0 7.6-RE-138 R e 05/2 ts. The C o inum tube , h e shaft i s factors fo E+02 g E+02 cc RC Class A Fractions T 2 0.0 0 0.1 5.8 5 4.2 0.0 1 0 6 10.1 e v.A 2 011 o ntrol , the s not r the 2 0 0 1 2 0 1 3 BMRC A Compo n 3 A ctivation A n ent Chara c.2.3 Exp e Spec radio i arou n assu m mate r Colu m the B discu Pne u The asse m adja c Only abun d Tabl e C W W V C C S T T A nalysis an d c terization e rimental F ial neutro n isotopes a n n d and adj a med to be p rial. Exper mn, Dry C h B ecquerel S ssed sepa r u matic Co n Pneumati c mblies tha t cent to the the sectio n dances an e 3-13belo w C omponentDescription W aste Wei g W aste Volume H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g F acilities n irradiatio n n d material acent to th e p urged of a i mental fac h amber, Is o S tandpipe.

r ately belo w nveyors c Convey o t could m ocore in the n s closest d scaling f w.C ID Singl e C g ht F r Ab 1 3 1 9

2 3

1 2

5 1.g e 22 of 28 n facilities s testing.

e active co any experi milities inclu d o tope Tub e The resu l w.o rs are d o ove materi a horizontal to the cor e f actors for Ta b Pneuma t C haracteri z 07 e Pneumati conveyo r 10.3 0.0 6 ractional b undance.22E-11.00E-03.38E-02

.52E-01

.49E-04

.08E-02

.09E-15

.25E-05

.77E-10.00E+00 Repo r are provi d Experimenre. These m ental mat e d e the Pne u es, movabl e lts for eac h o uble 606 als from th plane usi n e are activ a the lower b le 3-13 t ic Conve y z ation Re s c 34lbs 61ft^3 Co-6 0 SF 1.28E-3.15E-1.45E-1.00E+2.62E-3.23E-1.14E-2.37E-6.06E-rt 10-102D

-d ed for th e tal facilitie sexperime n erials or iso u matic Co n e Vertical S h experim e 1 aluminue hot cell n g different ated. Co m shaft are yor s ults 4.69E 1.74E 0 N R T111 03 0.302 +00 04 0.002 15 05 0.9 10 0.0 1.2-RE-138 R e 05/2 e producti o s are locat e n tal facilitie stope produ nveyor, Th e S tandpipes , ental facilit y m tube rto immedi ial air pres s mponent is o summariz e E+03 g E+03 cc RC Class A Fractions T 2 0.0 1 0.0 1.1 1 0.7 0.0 3 0 4 1.8 e v.A 2 011 on of ed in, s are ction e rmal , and y are r abbit ately s ure.o tope e d in 2 0 2 2 2 0 6 BMRC A Compo n A ctivation A n ent Chara c Ther m The nose p neutr alum i grap h core scali n belo w C W W C C S T TDry C Opp o expe r had a A ddit Cha m A nalysis an d c terization m al Colu m Thermal C p iece imm eons to a inum bails h ite blocks is substa n n g factors w.C omponentDescription W aste Wei g W aste Volu m H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal Chamber osite the r imental s p a similar n o ional oper a m ber comp o d Pa g m n C olumn us e ediately a dlarge exp e and rod s in the exp e ntially acti vfor the ac t C ID The r g ht m e F Ab 1 1 4 9 1 1 0 8 4 1 Thermal p ace that w osepiece, b u a tional his t onents oth e g e 23 of 28 ed a 606 1 djacent to e rimental s s facilitate d e rimental s p vated. C o t ivated se c Ta b Therm a C haracteri z 08 r mal Colum n 3162.21.9 Fractional b undance.51E-07.57E-03 4.03E-02 9.46E-01.07E-04

.25E-02.00E+00 8.22E-06 4.34E-11.00E+00Column w was not fill e u t had a la r t ory inform a e r than the Repo r 1 aluminu m the active s pace ben e d placem e pace. Onl y o mponent c tion are s u b le 3-14 al Column z ation Re s n.0lbs 98ft^3 Co-6 0 SF 1.60E-1.66E-4.26E-1.00E+1.13E-1.32E-0.00E+8.70E-4.59E-was a si m ed with gr a rge lead s h ation is n e nosepiece.

rt 10-102D

-m exterior, core to p e ath the h ent of the y the secti o isotope a b ummarize d s ults 1.43E 6.22E 0 N R T107 03 0.002 +00 04 0.002 +00 06 0.0 11 0.0 0.0 milar but aphite. Th e hield close t eeded to c h-RE-138 R e 05/2 graphite p rovide th e hot cell.

6 reactor g on closest t o bundances d in Table E+06 g E+05 cc RC Class A Fractions T 2 0.0 0 0.0 0.0 0 0.0 0.0 0 0 0 0.0slightly l a e Dry Cha m t o the tank h aracteriz e e v.A 2 011filled e rmal 6 061 g rade o the and 3-14 2 0 0 0 0 0 0 a rger mber wall.e Dry BMRC A Compo n A ctivation A n ent Chara c Isot o Strai g used chan g core for th C W W C C S T T A nalysis an d c terization o pe Tubes, ght and c u for experi m g ed relativ e are activa t e activated C omponentDescription W aste Wei g W aste Volu m H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g Vertical S u rved 6061 m ental pur p e to the co r ted. Com p sections a C ID Is o g ht m e F A 7 3 1 9 2 3 6 2 6 1 g e 24 of 28 S tandpipes aluminu m poses. S o re. Only th ponent isot o a re summa r Ta b Isot o C haracteri z 10 otope Tube 1.8 0.01 Fractional bundance 7.29E-10 3.69E-03 1.53E-02 9.47E-01 2.36E-04 3.41E-02 6.15E-15 2.64E-05 6.09E-10 1.00E+00 Repo r , and the B m tubes of ome of the e portions o pe abund a r ized in Ta b b le 3-15 o pe Tube z ation Re s 81lbs 1ft^3 Co-6 0 SF 7.70E-3.89E-1.62E-1.00E+2.50E-3.60E-6.50E-2.78E-6.43E-rt 10-102D

-B ecquerel different d tubes' loc aof the tub eances and b les 3-15 t o s ults 8.20E 3.04E 0 N R T110 03 2.002 +00 04 0.002 15 05 5.7 10 0.0 7.8-RE-138 R e 05/2 Standpip e diameters w ations coul e s closest t o scaling fa o 3-17belo w E+02 g E+02 cc RC Class A Fractions T 2 0.0 1 0.1 5.9 5 4.2 0.0 6 0 2 10.2 e v.A 2 011 e w ere d be o the ctors w.2 0 0 1 6 0 2 7 BMRC A Compo n A ctivation A n ent Chara c A nalysis an d c terization Compone n Descriptio n Waste We i Waste Vol u H-3 C-14 Fe-55 Co-60 Ni-59 Ni-63 Sr-90 Nb-94 Tc-99 Total d Pa g C n t ID n S ght ume A g e 25 of 28 Ta b V ertica l C haracteri z 11ingle Vertic a Standpipe 2 3 0.1 Fractional A bundance 1.61E-11 3.29E-03 1.37E-02 9.49E-01 2.72E-04 3.32E-02 1.30E-15 2.47E-05 6.33E-10 1.00E+00 Repo r b le 3-16 l Standpip e z ation Re s a l 3.5lbs 40ft^3 Co-6 S F 1.70 E 3.46 E 1.45 E 1.00E 2.87 E 3.50 E 1.37 E 2.60 E 6.67 E rt 10-102D

-e s ults 1.07 E 3.96 E 6 0 N F T E-11 E-03 0.3 E-02+00 E-04 0.0 E-02 E-15 E-05 1.0 E-10 0.0 1.3-RE-138 R e 05/2 E+04 g E+03 cc N RC Class A Fractions T 1 T 0.0 3 4 0.0 1.0 1 0.7 0.0 0 2 0 0 3 7 1.9 e v.A 2 011 A T 2 0 0 0 2 12 7 8 0 0 9 2 BMRC A Compo n A ctivation A n ent Chara c C W W C C S T T A nalysis an d c terization C omponentDescription W aste Wei g W aste Volu m H-3 C-14 Fe-55 C o-60 Ni-59 Ni-63 Sr-90 Nb-94 T c-99 T otal d Pa g C ID B S g ht m e F A 1 3 1 9 2 3 1 2 6 1 g e 26 of 28 Ta b Isot o C haracteri z 12 B equerel S tandpipe 33.0 0.1 9 Fractional bundance 1.61E-11 3.29E-03 1.37E-02 9.49E-01 2.72E-04 3.32E-02 1.30E-15 2.47E-05 6.33E-10 1.00E+00 Repo r b le 3-17 o pe Tube z ation Re s 08lbs 96ft^3 Co-6 0 SF 1.70E-3.46E-1.45E-1.00E+2.87E-3.50E-1.37E-2.60E-6.67E-rt 10-102D

-s ults 1.50E 5.56E 0 N R T111 03 0.302 +00 04 0.002 15 05 1.0 10 0.0 1.3-RE-138 R e 05/2 E+04 g E+03 cc RC Class A Fractions T 2 0.0 4 0.0 1.1 1 0.7 0.0 2 0 7 1.9 e v.A 2 011 2 0 2 2 8 0 2 BMRC A Compo n 4.0 C Detaile d present e activate dwas ha m compon compon compon The Co n BMRC.results n exceed s rates t o concent is curre n had a v e disposa l NTS is govern m Prelimi n Elemen t necessi t sufficie n segmen activate d compon disposa lto acco m packagi n (waste v compon The m experim material upon th e reactor Howev e hotspot s compon A ctivation A n ent Chara c C OMPON E d radiation e d in this a d compon e m pered by ents. In a ents whic h ents for tr a n trol Elem e NRC Cla s not yet no r s that acc e o be obtai ration coul d n tly availab e ry similar l of non-D eshowing a m ent entitie s n ary curie e t Shrouds, t ating tran s n t volume ttation. Th d compon eents, redu c l. Tubing s m modate t h n g efficien c v olume / lents and c ainimally a ental facili

t. Disposa e detailed rtank and o er, the acti v s will not ents, nor a A nalysis an d c terization E NT PACK A surveys analysis.

O ents closes tdetector sddition, th e h need to nsport and ent results a s s A mixed r malized t o eptable at tned in M a d still exce e le for disp o predicame n e partment a nexus o s.e stimation s may excee sport in an N t o accom m e shieldin g ents. The l a c ing the ti m sections an d h e internal cy of the a c iner intern a reful pack ctivated c ties can b e l line r/cont a r adiation s u other mini m v ation level s change t h pproach a n d Pa g A GING REmust be p O f particul a t to the acti aturation w e radiation be take ndisposal.

a nd discus swaste can o measure dhe Clive d a y 2011 o e d NRC Cl o sal of suc h n t that, aft eof Energy of waste r e s indicate t d the defin i N RC licen s m odate all t g afforded b a rge paylo a m e and d o d other ite mheight of c tivated co m al volume)aging. .

c omponent s e package aine r and t u rveys obt a mally activ a s in these c h e ove r all n y regulato r g e 27 of 28 QUIREME N p erformed a r importan cve core.

F w hen appr o surveys id e n into con s s ion are lik e be dispos e d dose rat eisposal sit e o f a repreass A limit h mixed wa s e r regulato r mixed wa s e sponsibilit the Grid P ition of Lo w sed Type B t he highly by the 8-1 2 a d capacit y ose necess m s exceedi the dispos a mponents.

) can be a s of the d for disp o t ransportat a ined durin g a ted comp o c omponent s approach r y limits.Repo r N TSto finaliz ece is to o b F ebruary 2 0 oaching th e entify any sideration ely to driv e ed at Clive es, the Co n e. Even a f e sentatives. Only th e s te. The P r y effort, di d ste. Key t o t y betwee nlate, Cont r w Specific A B cask. A sactivated 20 is also s y of and 8-sary to pa cng 5 feet l o a l liner an d A packagi a chieved w reactor s osal as L o ion packa g g decommi s onents ma ys are low eto remov a rt 10-102D

-e the prel btain surve y 011 compo n e the highl y"hot spots "during pa c e packagin g, UT. Ho w n trol Elem e f ter normaControl El e Nevada Tlum Brook d result in a o regulator y n the BM R r ol Elemen t A ctivity [II] (s ingle 8-12 0 componen t sufficient f o120 minimi c kage the c o ng need t o d furtherm ong efficien c w ith segm e s tructure, o w Specifi c g e selectio n ssioning.

A y have loc a e nough su c a l and dis-RE-138 R e 05/2iminary r e ys of the h nent surve y y activated

" on the re a ckaging o f g options f o wever, bas e ent waste c lization to ement, n u Test Site (N Reactor F a a cceptanc e y acceptan c R C and fe d ts, and C oLSA II) ma t 0 cask line r t s with mi n o r all the h i zes handli n c omponent o be segm e ore, to incr cy of up to e ntation of periphery c Activity (L n will be b Activation o alized hots ch that loc aposal of t e v.A 2 011 esults highly y use core a ctor f the or the e d on class dose uclide NTS) acility e and c e at d eral o ntrolterial r has n imal highly n g of s for e nted ease 15%long andLSA) ased of the pots.alized hese BMRC A Compo n 5.0 R A ctivation A n ent Chara c R EFEREN C1. ORN L Tran s Labo r2. DLC-Secti o Vess eShiel d3. ORN L Matri x4. Evan Rea c5. NUR E Radi o A nalysis an d c terization C ES L CCC-25 4 s port Code r atory, Apri 185, BUG L o n Library d el Dosimet r d ing Infor m L/CCC-371 x Exponen t s, J.C., et a c tor Materia E G/BR-02 0 o active Wa s d Pa g 4 , ANISN-O with Aniso tl 1991. LE-96, Cou d erived fro m r y Applicati m ation Cent e , ORIGEN t ial Method a l., NURE G ls, Pacific N 0 4, Instructi s te Manife s g e 28 of 28 O RNL One-D tropic Scat t pled, 47-N e m ENDF/B-ons, Oak R e r, July 19 9 2.2, Isoto p, Oak Ridg e G 3474, Lo n N orthwest L ons for Co m s t, July 19 9 Repo r D imension a t ering, Oa k e utron, 20 G-VI for LW R R idge Natio 9 9.p e Generati e National n g-Lived A c L aboratori e m pleting N 9 8.rt 10-102D

-al Discrete k Ridge Na t Gamma-R a R Shielding nal Labora t on and De p laboratory, c tivation Pr o e s, August 1 RC's Unifo

-RE-138 R e 05/2 Ordinates t ional a y Cross and Press t ory Radia t p letion Co d May 2002.o ducts in 1 984.rm Low-Le v e v.A 2 011 ure t ion d e,.v el BMRC A Compo n A ctivation A n ent Chara c A nalysis c terization O R P AP R IGEN Ma t P age A 1 PENDIX A terial Com p Repo rpositions rt 10-102D

--RE-138 R e 05/2 e v.A 2 011 BMRC A Compo n 3 A ctivation A n ent Chara c 304 Stainle D Av e E A nalysis c terization ss Steel (N ensity = 8.

0 e rage NUR E Element R S Nu Li 3 0 N 7 0 Na 11Al 13Cl 17K 19 Ca 20Sc 21Ti 22V 23Cr 24Mn 25Fe 26 Co 27Ni 28 Cu 29Zn 30Ga 31As 33Se 34Br 35 Rb 37 P NUREG 34 7 0 3 3 cm g , 5 0 EG 3474 3 0 SICC mber Wei g Frac t(g/g 0000 1.30 E 0000 4.52 E0000 9.70 E0000 1.00 E0000 7.00 E0000 3.00 E0000 1.90 E0000 3.00 E0000 6.00 E0000 4.56 E0000 1.84 E0000 1.53 E0000 7.06 E0000 1.41 E0000 1.00 E0000 3.08 E0000 4.57 E0000 1.29 E0000 1.94 E0000 3.50 E0000 2.00 E0000 1.00 E P age A 2 7 4)0 1 3 ft lbs 04 Stainle s ght tion g) Eleme n E-07Sr E-04Y E-06Zr E-04Nb E-05Mo E-06Ag E-05Sb E-08Cs E-04Ba E-04La E-01Ce E-02Sm E-01Eu E-03Tb E-01Dy E-03Ho E-04Yb E-04Lu E-04Hf E-05W E-06Pb E-05Th U Repo r s s Steel C o n t RSICC Number380000 390000 400000 410000 420000 470000 510000 550000 560000 570000 580000 620000 630000 650000 660000 670000 700000 710000 720000 740000 820000 900000 920000 rt 10-102D

-ompositio n Weight Fraction (g/g) 2.00E-07 5.00E-06 1.00E-05 8.90E-05 2.60E-03 2.00E-06 1.23E-05 3.00E-07 5.00E-04 2.00E-07 3.71E-04 1.00E-07 2.00E-08 4.70E-07 1.00E-06 1.00E-06 2.00E-06 8.00E-07 2.00E-06 1.86E-04 6.70E-05 1.00E-06 2.00E-06 -RE-138 R e 05/2 n e v.A 2 011 BMRC A Compo n C A ctivation A n ent Chara c C arbon St e D A E* T h 4 5 in A nalysis c terization eel (NURE G ensity = 7.

8 A verage N U Element R S Nu Li 3 0 N 7 0 C* 8 0 Na 11Al 13Cl 17K 19 Ca 20Sc 21Ti 22V 23Cr 24Mn 25Fe 26 Co 27Ni 28 Cu 29Zn 30Ga 31As 33Se 34Br 35 Rb 37 h e carbon 50], for typi NUREG 3 4 P G 3474)8 7 3 cm g , 4 9 UREG 347 4 SICC mber Wei g Frac t(g/g 0000 3.00 E 0000 8.40 E 0000 2.90 E0000 2.30 E0000 3.30 E0000 4.00 E0000 1.20 E0000 1.40 E0000 2.60 E0000 2.00 E0000 8.00 E0000 1.70 E0000 1.02 E0000 9.80 E0000 1.22 E0000 6.60 E0000 1.27 E0000 1.00 E0000 8.00 E0000 5.32 E0000 7.00 E0000 8.50 E0000 4.80 Eweight pe r cal pressu r 474. P age A 3 9 1 3 ft lbs 4 Carbon S ght tion g) Eleme n E-07Sr E-05Y E-03Zr E-05Nb E-04Mo E-05Ag E-05Sb E-05Cs E-07Ba E-06La E-05Ce E-03Sm E-02Eu E-01Tb E-04Ho E-03Yb E-03Lu E-04Hf E-05Ta E-04W E-07Pb E-07Th E-05U rcent is ta k r e vessel s t Repo r Steel Com p n t RSICC Number380000 390000 400000 410000 420000 470000 510000 550000 560000 570000 580000 620000 630000 650000 670000 700000 710000 720000 730000 740000 820000 900000 920000 ken from P t eel becau s rt 10-102D

-p osition Weight Fraction (g/g) 1.50E-07 2.00E-05 1.00E-05 1.88E-05 5.60E-07 2.00E-06 1.10E-05 2.00E-07 2.73E-04 1.00E-07 1.00E-06 1.70E-08 3.10E-08 4.50E-07 8.00E-07 1.00E-06 2.00E-07 2.10E-07 1.30E-07 5.50E-06 8.20E-04 1.80E-07 2.00E-07 Page 2, G r se there is n-RE-138 R e 05/2 rade 65 [G no carbon l i e v.A 2 011rade isted BMRC A Compo n B A ctivation A n ent Chara c B ioshield C o D Av e E* Th e nu c A nalysis c terization oncrete (N U ensity = 2.

3 e rage NUR E Element R S Nu H 1 0 Li 3 0 B 5 0 N 7 0O* 8 0 Na 11Mg* 12Al 13Si 14P 15 S 1 6Cl 17K 19 Ca 20Sc 21Ti 22V 23Cr 24Mn 25Fe 26 Co 27Ni 28 Cu 29Zn 30Ga 31As 33Se 34Br 35 e oxygen a n clides are e x P UREG 347 4 3 0 3 cm g , 1 4 EG 3474 B SICC mber Wei g Frac t(g/g 0000 6.10 E 0000 2.00 E 0000 2.00 E 0000 1.20 E 0000 5.02 E0000 7.39 E0000 2.46 E0000 3.10 E0000 1.68 E0000 5.00 E 6000 3.10 E0000 4.50 E0000 7.50 E0000 1.83 E0000 6.50 E0000 2.12 E0000 1.03 E0000 1.09 E0000 3.77 E0000 3.90 E0000 9.80 E0000 3.80 E0000 2.50 E0000 7.50 E0000 8.80 E0000 7.90 E0000 9.20 E0000 2.40 E nd magnes xcluded fr o P age A 4 4)4 4 3 ft lbsioshield C o ght tion g) Eleme n E-3 Rb E-5 Sr E-5 Y E-4 Zr E-1 Nb E-3 Mo E-3 Pd E-2 Ag E-1 Cd E-3 Sn E-3 Sb E-5 Cs E-3 Ba E-1 La E-6 Ce E-3 Sm E-4 Eu E-4 Tb E-4 Dy E-2 Ho E-6 Yb E-5 Lu E-5 Hf E-5 Ta E-6 W E-6 Pb E-7 Th E-6 U ium weight o m NUREG Repo r oncrete C o n t RSICC Number370000 380000 390000 400000 410000 420000 460000 470000 480000 500000 510000 550000 560000 570000 580000 620000 630000 650000 660000 670000 700000 710000 720000 730000 740000 820000 900000 920000 percents a 3474. rt 10-102D

-ompositio n Weight Fraction (g/g) 3.50E-5 4.38E-4 1.82E-5 7.10E-5 4.30E-6 1.03E-5 3.00E-6 2.00E-7 3.00E-7 7.00E-6 1.80E-6 1.30E-6 9.50E-4 1.30E-5 2.43E-5 2.00E-6 5.55E-7 4.10E-7 2.30E-6 9.00E-7 1.40E-6 2.70E-7 2.20E-6 4.40E-7 1.40E-6 6.10E-5 3.50E-6 2.70E-5 a re calculat e-RE-138 R e 05/2 n e d since th e e v.A 2 011 e se BMRC A Compo n A G A ctivation A n ent Chara c A luminum 6 D E G raphite D E A nalysis c terization 6061 ensity = 2.

7 Aver alement R S Nu m B 5 0 N 7 0Mg 12 0Al 13 0Si 14 0Ti 22 0Cr 24 0Mn 25 0 ensity = 1.

7 A vlement R S Nu m H 1 0 B 5 0 C 6 0 O 8 0 F 9 0Na 11 0 P 7 3 cm g, 16 9 a ge Alumi n S ICC mber Wei gFract(g/g 0000 8.43 E 0000 1.37 E 0000 1.00 E 0000 9.66 E 0000 6.00 E 0000 1.50 E 0000 1.95 E 0000 1.50 E 7 3 cm g, 10 6 verage Gr a S ICC mber Wei gFract(g/g 0000 3.89 E 0000 5.00 E 0000 9.89 E 0000 1.29 E 0000 2.50 E 0000 1.00 E P age A 5 9 3 ft lbs num 6061 C g htion g) Eleme n E-7 Fe E-4 Co E-2 Ni E-1 Cu E-3 Zn E-3 Nb E-3 Mo E-3 6 3 ft lbs aphite Co m g htion g) Eleme n E-5 Mg E-7 Cl E-1 Ti E-3 Fe E-5 Co E-4 Cu Repo r C ompositi o n t RSICC Number260000270000280000290000300000410000 420000 mposition n t RSICC Number120000170000220000260000270000290000 rt 10-102D

-o nWeight Fraction (g/g) 7.00E-3 1.72E-4 4.04E-4 2.75E-3 2.50E-3 3.40E-5 5.60E-7 Weight Fraction (g/g) 1.00E-4 2.50E-5 1.00E-3 8.00E-3 5.00E-5 1.00E-4 -RE-138 R e 05/2 e v.A 2 011 BMRC Decommissioning PlanRevision0APPENDIX B -SITE CHARACTERIZATION REPORT Site Characterization ReportBuffalo Materials Research CenterPrepared for:Buffalo Material Research CenterOffice of Environment, Health, and Safety ServicesCompleted by:

4490 Old William Penn HwyMurrysville, PA 15668July 30, 2011 BMRCCharacterization ReportRevision 0 ivSummary of ChangesRevisions to the BMRC Characterization Reportwill be tracked when revisions are issued. Changed sections will be identified by special demarcation in the margin. A summary description of each revision will be noted in the following table.

Revision NumberDateDescription of Change0July 30,2011Initial Issue BMRCCharacterization ReportRevision 0 ivTable of ContentsACRONYMS AND ABBREVIATIONS.......................................................................................ii1.EXECUTIVE

SUMMARY

.................................................................................................1 2.SCOPE AND BACKGROUND..........................................................................................32.1SCOPE..................................................................................................................................32.2FACILITY BACKGROUND.....................................................................................................33.

SUMMARY

OF TECHNICALAPPROACH.....................................................................93.1RADIONUCLIDES OF C ONCERN............................................................................................93.2RELEASE CRITERIA...........................................................................................................123.2.1Soils.......................................................................................................................123.2.2Surfaces.................................................................................................................1 33.3SURVEY DESIGN................................................................................................................143.4SURVEY PACKAGE IDENTIFICATION.................................................................................153.5SURVEY INSTRUMENTATION.............................................................................................163.6M INIMUM DETECTABLE ACTIVITY...................................................................................163.7PRELIMINARY SURVEY UNITS AND CLASSIFICATIONS.....................................................174.CURRENT RADIOLOGICALCONDITIONS................................................................214.1ADMINISTRATIVE W ING....................................................................................................214.1.1Control Deck.........................................................................................................214.1.2Gamma Deck.........................................................................................................224.2S UB-BASEMENT................................................................................................................234.3CONTAINMENT WING........................................................................................................234.3.1Control Deck.........................................................................................................234.3.2Gamma Deck.........................................................................................................254.3.3Neutron Deck........................................................................................................264.4CONCRETE C ORES.............................................................................................................264.4.1Floor Cores............................................................................................................274.4.2Bioshield Cores.....................................................................................................304.5EXTERIOR SOILS AND BUILDING SURFACES.....................................................................334.5.1Sub-Surface Borings.............................................................................................334.5.2Surface Water and Groundwater Samples.............................................................344.5.3Gamma Radiation Scan.........................................................................................384.5.4BMRC Rooftops....................................................................................................394.5.5Tritium and Carbon-14 Smears.............................................................................394.6TANK FARM......................................................................................................................404.7VENTILATION....................................................................................................................434.8MISCELLANEOUS SAMPLE AREAS....................................................................................434.8.1N16 Tank Vault.....................................................................................................434.8.21K Tank.................................................................................................................455.HAZARDOUS MATERIALS...........................................................................................466.QUALITY ASSURANCE AND QUALITY CONTROL.................................................476.1GENERAL PROVISIONS......................................................................................................476.1.1Written Procedures................................................................................................476.1.2Instrumentation Selection, Calibration, and Use...................................................476.1.3Chain of Custody...................................................................................................48 BMRCCharacterization ReportRevision 0 iv6.1.4Independent Review of Survey Results.................................................................486.2TRAINING..........................................................................................................................486.3SAMPLE ANALYSIS............................................................................................................487.LIMITATIONS..................................................................................................................

497.1H IGH BACKGROUND AREAS.............................................................................................497.2INTERNAL ACTIVITY.........................................................................................................498.REFERENCES..................................................................................................................5 0List of TablesTable 3-1Radionuclides of Concern..............................................................................................

9 Table 3-2 Site-Specific Radionuclides of Concern at BMRC......................................................11 Table 3-3NRCSurface Soil Screening Levels.............................................................................12 Table 3-4NRCRegulatory Guide 1.86 Levels for Surfaces........................................................13 Table 3-5NRCScreening Levels for Building Surfaces..............................................................14 Table 3-6 Survey Instrumentation................................................................................................16 Table 3-7 Instrumentation MDA..................................................................................................

17 Table 3-8 Survey Unit Summary..................................................................................................

19 Table 4-1 Administrative Wing Control Deck Survey Results Summary....................................22 Table 4-2 Administrative Wing Gamma Deck Survey Results Summary...................................22 Table 4-3 Sub-Basement Survey Results Summary.....................................................................23 Table 4-4 Containment Wing Control Deck Survey Results Summary.......................................24 Table 4-5 Containment Wing Gamma Deck Survey Results Summary.......................................25 Table 4-6 Containment Wing Neutron Deck Survey Results Summary......................................26 Table 4-7 Concrete Floor Cores Analytical Results Summary.....................................................29 Table 4-8 Bioshield Cores Analytical Results Summary.............................................................32 Table 4-9 Soil Borings Analytical Results Summary...................................................................35 Table 4-10 Tank Farm AnalyticalSample Results Summary......................................................42 Table 4-11 Ventilation Systems Survey Results Summary..........................................................43 Table 4-12 N16 Tank Vault Analytical Results Summary...........................................................44 Table 4-13 1K Tank Analytical Results Summary.......................................................................45

BMRCCharacterization ReportRevision 0 ivList of FiguresFigure 1: University of Buffalo South Campus..............................................................................4 Figure 2: Control Deck Layout.......................................................................................................6 Figure 3: Gamma Deck Layout.......................................................................................................7 Figure 4: Neutron Deck Layout......................................................................................................8 Figure 5: Floor Core Locations.....................................................................................................28 Figure 6: Bioshield Core Locations..............................................................................................30 Figure 7: Soil Bore Locations.......................................................................................................33 Figure 8: Gamma Walkover..........................................................................................................38 Figure 9: Tank Farm Layout.........................................................................................................41 Figure 10: N16 Tank Vault Sample Locations.............................................................................44 List of AppendicesAppendix A -BMRC Characterization Photographs BMRCCharacterization ReportRevision 0 vList of Acronyms and AbbreviationsAECAtomic Energy CommissionACMAsbestos Containing Material BFBioshield Face BMRCBuffalo Materials Research Center D&DDecontamination and Dismantlement DCGLDerived Concentration Guideline Level DPDecommissioning Plan DPMDisintegrations per Minute DQOData Quality Objectives FSSFinal Status Survey HSAHistorical Site Assessment MARSSIMMulti-Agency Radiation Survey and Site Investigation Manual MDAMinimum Detectable Activity MDCMinimum Detectable Concentration

MW tMegawatt ThermalNaISodium Iodide NISTNational Institute for Standards and Testing NRCNuclear Regulatory Commission NUREGNuclear Regulatory Guide PULSTARPulse Training and Reactor R-77Reactor License Number 77 RFPRequest For Proposal RSORadiation Safety Officer SSCsSystemsStructures Components SUNYState University of New York UBUniversity of Buffalo BMRCCharacterization ReportRevision 0 1 1.EXECUTIVE

SUMMARY

This report describes the current radiological status of the facility to support the development of the Buffalo Materials Research Center (BMRC) Decommissioning Plan (DP). The sections that follow describe the scope, background, and technical approach used during the characterization of the BMRC. The BMRC contains a 2-Megawatt Thermal (MW t)pool-type research reactor licensed by the United States Nuclear Regulatory Commission (NRC) under reactor license number 77 (R-77) and is located on the South Campus of the State University of New York (SUNY) at Buffalo, NY.The data collected during this characterization will be utilized to support the development of a DP inaccordance with the following NRC regulatory guidance documents: 1) NUREG-1537, Part 1, Chapter 17, Guidelines for Preparing and Reviewing Applications for Licensing of Non-Power Reactors; 2) NUREG-1757,Consolidated NMSS Decommissioning Guidance; and 3) NUREG-1575,Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)

.The data will specifically assist in the development of radiation safety protocols and project dose estimates; estimation ofexpected radiological waste volumes; methodologies for removal and packaging of radiological waste; and disposal options for radioactively impacted materials generated during decommissioning activities conducted under NRC License R-77. This data will also be incorporated into the decision making process for the development of Final Status Survey (FSS) Data Quality Objectives (DQO's) described in MARSSIM. The FSS provides the closeout documentation required by the NRC in order to terminate the BMRC Reactor License.For the characterization effort, ENERCON developed a Characterization Plan to establish the measurement and sampling technical approach along with the project quality assurance requirements. This plan was reviewed and approved by the BMRC Operating Committee. Radiological work permits were issued by the University's Radiation Safety Officer (RSO) for all survey areas, as necessary. The BMRC facility was separated into survey units with survey instructions for each unit. The survey instructions were implemented by a qualified Health Physics technician and the data was documented on a radiological survey. This report only contains a summary of the survey results. All completed survey packages are stored at the BMRC for future reference.

BMRCCharacterization ReportRevision 0 2Radiological measurements indicate that levels of residual materials on the building surfaces are less than release criteria established bythe NRC in Regulatory Guide 1.86.

Soil samples indicate that remediation of soils will not be required outside of the facility; however, radionuclides above the release criteria were detected in the N16 Vault which does not have a concrete floor coveringthe bedrock. Residual radioactive materials were only found in areas indicated by the Historical Site Assessment. The structures and components that contain the majority of the residual radioactive materials are the activated reactor components and bioshield, the former and current liquid waste tanks, and the reactor water cooling system. Residual radioactive materials were also identified in the Hot Cell and laboratory fume hoods.

BMRCCharacterization ReportRevision 0 3 2.SCOPE AND BACKGROUND 2.1 ScopeThe BMRC characterization scope was to determine the nature and extent of residual radioactive materials and was accomplished through the following methods:Radiological measurements on building surfaces and structuresConcrete cores on the reactor bioshield to determine concrete activationExterior sub-surface soil boringsInterior concrete floor coresLiquid samples from legacy and current waste holding tanksThe activation analysis of reactor components andpool liner is not included in this characterization report. The Component Activation Analysis scope of work was contracted by the University to WMG, Inc. of Fishkill, NY. The Component Activation Analysis Report, along with this characterization report,will be appended to the BMRC DP for approval by the NRC.2.2Facility BackgroundThe UBis licensed by NRC to possess radioactive materials within the BMRC. The BMRC reactor is located on the South Campus of the University at Buffalo (UB) in the city of Buffalo, New York, as shown in Figure 1.The reactor was defueled in 2005 and is beginning the Decontamination and Dismantlement (D&D) process to decommission the facility for eventual termination of the NRC license. This Characterization Report is in support of a DP developed in accordance with Chapter 17 of the Nuclear Regulatory Commission (NUREG -1537) Part 1 Guidance for Preparing and Reviewing Applications for Licensing of Non-Power Reactors (NRC 1996). This report describes the purpose, scope and technical approach used forthe characterization of the BMRC. The purpose of the characterization is to assess the current radiological status of the facility for the development of the Decommissioning Plan. This data is also incorporated into the decision-making process for development of FSS DQOs described in MARSSIM.

BMRCCharacterization ReportRevision 0 4Figure 1:University of Buffalo South CampusThe BMRC building is comprised of an administrative/laboratory wing (administrative wing) and a vapor containment building (containment building) with three levels in each. The three levels are: neutron deck (lowest level, i.e. sub-grade), gamma deck (2 ndlevel, i.e. middle level), and control deck (top floor). The neutron deck of the administrative wing (a.k.a. sub-basement) houses numerous systems, structures, and components (SSCs) that support operation of the reactor. The remainder of the administrative wing contains 20 rooms which are a mixture of offices, laboratories, utility rooms, and classrooms.See Figures2, 3,and 4 at the end of this section.The facility was constructed in 1959, went into operation on March 24, 1960, and was operated by The Western New York Nuclear Research Center, Inc, a subsidiary of the State University of New York, under Atomic Energy Commission (AEC) license number R-77. The facility BMRCCharacterization ReportRevision 0 5licensee was changed to the Nuclear Science and Technology Center followed by a change to the Buffalo Materials Research Center in 1973 and 1985, respectively. The licensed power was one MW twithout forced convection cooling and up to two MW tpossible for short times. In 1991, the reactor was retrofitted with a 0.75 inch thick aluminum liner. This new liner supplements the original 0.25 inch thick aluminum liner and there isa 0.75 inch air gap between the twoliners.The reactor core is located in a pool-type tank that is 29 feet deep with horizontal dimensions of 13 feet by 7 feet, located in the containment building of the BMRC. The tank contains approximately 13,700 gallons of demineralized water.The reactor fuel consisted of standard zircalloyclad Pulse Training and Reactor (PULSTAR) typefuel elements. Several events have occurred at the BMRC during its operational history that has led to the determination that the buildings, structures, andimmediate surrounding soils are impacted from historical operations at BMRC.The following events are documented in the BMRC Historical Site Assessment (HSA).In 1975, and again in 1989, a leak developed in the primary cooling piping at the point where the pipe penetrates the reactor pool tank. The leakage is thought to have traversed the primary piping exterior to a point where it emerged from the foundation concrete in Room N16 and then to the sumps associated with the Cooling Water Equipment Room (Room N03). In 1993, the Primary Coolant Heat Exchanger located in Room N02 of the Laboratory Wing lower level, developed a primary to secondary leak that permitted small amounts of coolant to transfer to the water cascading in the cooling tower. The cooling tower and its above grade concrete structure have since been removed. The concrete basin was left in place and backfilled to grade.In the Laboratory Wing, the drains in the Vertical Accelerator Room (Room 115) are posted as contaminated as a result of drains backing up during operation. Events were discussed during interviews that relate to airborne contamination events withinthe Containment Building. These events resulted in areas or levels of the Containment Building being designated in whole or part as contaminated. One event was an airborne release of Co 60to the entire NeutronDeck. Decontamination occurred in all areas of the Containment Building except for areas near the ceiling and the ceiling. The second event was a release of Sr 90that contaminated areas of Room 202. The walls adjacent to the California hood in this room have plexiglassmounted to provide shielding from the strontium. There was also one event where H 3was released in the Control Deck Upper Airlock and Upper Fuel Vault.

BMRCCharacterization ReportRevision 0 6Figure 2: Control Deck Layout BMRCCharacterization ReportRevision 0 7Figure 3: Gamma Deck Layout BMRCCharacterization ReportRevision 0 8Figure 4: Neutron Deck Layout BMRCCharacterization ReportRevision 0 9 3.

SUMMARY

OF TECHNICALAPPROACHRadiological characterization surveys were performed to establish the current radiological status of the BMRC. The site characterization survey includedradiological surface measurements on building surfaces and equipment in addition to volumetric measurements on surrounding soils, floors, and the reactor bioshield. The characterization surveys were designed, performed, evaluated, and documented in accordance with the following sections.The technical approach for the characterization of the building surfaces of the BMRC was developed to meet MARSSIMcriteria for FSS. A minimum quantity of survey locations for each survey unit was defined to meet a 95% certainty of detection using nonparametric statistical analyses contained in MARSSIM. Survey locations within the building were selected in Visual Sample Plan Version 6.0 using either a random or systematic triangular grid placement method. Survey technicians were also instructed to use professional judgment in identifying additional biased locations(i.e., fume hoods, elevated measurements, lab benches)to assure that the nature and extent of any residual radioactive materials present were adequately defined.The technical approach for exterior soils was developed using MARSSIMguidance to determine the impacts, if any, to surface water and groundwater.

3.1Radionuclides of ConcernBased upon facility operating history and historical radiological analyses, bothalpha and beta/gamma emitting radionuclides may be present in the BMRC. Evaluation of radionuclides of concern identified in NUREG/CR-3474, NUREG/CR-4289, and those detected via laboratory analyses from samples collected at the facility yields a substantial list of 60radionuclides. This list is presented in Table 3-1.Table 3-1Radionuclides of ConcernNuclideHalf Life (yr)Citation SourceDetected at BMRCAc-2287.00E-04N/AYesAg-108m4.18E+02NUREG/CR-3474YesAg-110m6.84E-01NUREG/CR-3474NoAm-2414.32E+02NUREG/CR-4289NoAr-392.69E+02NUREG/CR-3474No BMRCCharacterization ReportRevision 0 10NuclideHalf Life (yr)Citation SourceDetected at BMRCBa-1331.05E+01NUREG/CR-3474NoC-145.73E+03NUREG/CR-3474YesCa-411.03E+05NUREG/CR-3474NoCe-1418.90E-02NUREG/CR-3474NoCl-363.01E+05NUREG/CR-3474NoCm-2441.81E+01NUREG/CR-4289NoCo-577.44E-01N/AYesCo-581.94E-01NUREG/CR-3474YesCo-605.27E+00NUREG/CR-3474NUREG/CR-4289 YesCr-517.58E-02NUREG/CR-3474NoCs-1342.06E+00NUREG/CR-3474NoCs1352.30E+06NUREG/CR-3474NoCs-1373.02E+01NUREG/CR-3474NUREG/CR-4289 YesEu-1521.36E+01NUREG/CR-3474NUREG/CR-4289 YesEu-1548.59E+00NUREG/CR-3474NUREG/CR-4289 YesEu-1554.96E+00NUREG/CR-3474NoFe-552.70E+00NUREG/CR-3474NoFe-591.22E-01NUREG/CR-3474NoH-31.23E+01NUREG/CR-3474NUREG/CR-4289 YesHf-178m3.00E+01NUREG/CR-3474NoHo-166m1.20E+03NUREG/CR-3474NoI-1291.57E+07NUREG/CR-3474NUREG/CR-4289 NoKr-812.10E+05NUREG/CR-3474NoKr-851.07E+01NUREG/CR-3474NoMn-533.70E+06NUREG/CR-3474NoMn-548.56E-01NUREG/CR-3474NoMo-933.50E+00NUREG/CR-3474NoNb-92m2.78E-02NUREG/CR-3474NoNb-942.03E+04NUREG/CR-3474NUREG/CR-4289 NoNi-597.50E+04NUREG/CR-3474NUREG/CR-4289 NoNi-631.00E+02NUREG/CR-3474NUREG/CR-4289 YesNp-2372.14E+06NUREG/CR-4289NoPb-2051.51E+07NUREG/CR-3474NoPm-1451.77E+01NUREG/CR-3474NoPu-2388.78E+01NUREG/CR-4289YesPu-2392.41E+04NUREG/CR-3474NUREG/CR-4289 YesPu-2406.60E+03NUREG/CR-4289YesRa-2261.60E+03N/AYesSb-1241.65E-01NUREG/CR-3474No BMRCCharacterization ReportRevision 0 11NuclideHalf Life (yr)Citation SourceDetected at BMRCSc-462.29E-01NUREG/CR-3474NoSe-796.50E+04NUREG/CR-3474NoSm-1461.00E+08NUREG/CR-3474NoSm-1519.30E+01NUREG/CR-3474NoSn-121m5.00E+00NUREG/CR-3474NoSr-891.38E-01N/AYesSr-902.88E+01NUREG/CR-3474NUREG/CR-4289 YesTb-1581.50E+02NUREG/CR-3474NoTc-992.13E+05NUREG/CR-3474NUREG/CR-4289 NoTh-2281.91E+00N/AYesTh-2321.41E+10N/AYesU-2331.59E+05NUREG/CR-3474NoU-2342.46E+05N/AYesU-2384.47E+9N/AYesZn-656.69E-01NUREG/CR-3474NoZr-931.53E+06NUREG/CR-3474NoThirty-six (36) of the 60 listed radionuclides have not been detected in samples collected from the facility. Removing those radionuclides which have not been detected; radionuclides with a half-life less than one (1) year; and, naturally occurring radionuclides which have been detected only at background concentrations pares this list down to a site-specific list of fourteen (14) radionuclides as presented in Table 3-2.Table 3-2Site-Specific Radionuclides of Concern at BMRCRadionuclideHalf Life (yr)EmissionArea(s) of InterestAg-108m4.18E+02Soil; SSCsAm-2414.32E+02Tank sedimentC-145.73E+03Laboratory areasCo-605.27E+00Soil; SSCs; BioshieldCs-1373.02E+01*Soil; SSCs; BioshieldEu-1521.36E+01Soil; SSCs; BioshieldEu-1548.59E+00Soil; SSCs; BioshieldH-31.23E+01Soil; SSCs, BioshieldNi-631.00E+02Soil; SSCs; BioshieldPu-2388.78E+01Tank sedimentPu-2392.41E+04Tank sedimentPu-2406.60E+03Tank sedimentRa-2261.60E+03Discrete sourcesSr-902.88E+01SSCs; Ventilation systems; Soil

• emission from Ba-137m progeny BMRCCharacterization ReportRevision 0 12 3.2Release CriteriaThe BMRC characterization effort included evaluation of SSCs and of soils surrounding the facility. While release criteria are not required for the characterization process, consideration of likelycriteria in selecting field instrumentation and determining action levels is important. Two sets of criteria were considered; one set for surface soils, and one for SSCs.

3.2.1 SoilsNRC License Termination Screening Levels contained in Appendix H of NUREG-1757Volume 2 for surface soils were considered during the characterization process at BMRC. These criteria,listed in Table 3-3,provide a point of comparison for the soil data collectedaround the BMRC.In addition to the NRC Screening Value, a second screening value column has been added to compare the NRC values at 25 mrem/year to the State of New York's 10 mrem/year dose release criteria established in Radioactive Materials Guidance Document,DSHM-RAD-05-01, Cleanup Guidelines for Soils Contaminated with Radioactive Materials, issued by the Department of Environmental Conservation.Of the site-specific radionuclides of interest, surface soil screening levels are available for all but Ag-108m. Additional evaluation of criteria for this radionuclide will berequiredin the DP for the FSS.Table 3-3NRC Surface Soil Screening LevelsRadionuclideNRC Screening Value for Surface Soils (pCi/g)Screening Value Scaled for NY State

• (pCi/g)Ag-108mNoneNoneAm-241NoneNoneC-1412 4.8Co-603.81.52Cs-13711 4.4Eu-1528.73.48Eu-1548 3.2H-3110 44Ni-632,100 840Pu-2382.5 1Pu-2392.30.92Pu-240NoneNoneRa-2260.70.28Sr-901.70.68*New York State dose requirement is 10 mrem/yr(40% of the NRC Values)

BMRCCharacterization ReportRevision 0 13 3.2.2SurfacesFor the BMRC characterization effort, unrestricted release of material and equipment prior to a final status survey considers criteria from NRC Regulatory Guide 1.86. Thesecriteriawereconsidered in calculating the instrumentation counting sensitivities in Section 3.1.6. The Regulatory Guide 1.86 criteria aremore conservative than the NRC screening levels for building surfaces presented in Appendix H of NUREG-1757 Volume 2and are listed in Table 3-4. Final Status Survey criteria, if needed, will use those criteria in NUREG-1757 presented inTable 3-5.Table 3-4NRCRegulatory Guide 1.86 Levels for SurfacesRadionuclideAverage a b c d pm/100 cmMaximum 2 b d d pm/100 cmRemovable 2 b e d pm/100 cmU-nat, U-235, U-238 and associated decay products 25,00015,0001,000Transuranics, Ra-226, Ra-228, Th-230, Th-228, Pa-231, Ac-227, I-125, I-12910030020Th-nat, Th-232, Sr-90, Ra-223, Ra-224, U-232, I-126, I-131, I-1331,0003,000200Beta-gamma emitters (nuclides with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above.5,00015,0001,000 aWhere surface contamination by both alpha and beta-gamma emitting nuclides exists, the limits established for alpha-and beta-gamma-emitting nuclides should apply independently.

bAs used in this table, dpm(disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

c Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each object.

dThe maximum contamination level applies to an area of not more than 100 cm 2.e The amount of removable radioactive material per 100 cm 2of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface.

BMRCCharacterization ReportRevision 0 14Table 3-5NRCScreening Levels for Building SurfacesRadionuclideNRC Screening Value for Building Surfaces (DPM/100cm 2)Ag-108mNoneAm-241NoneC-143,700,000Co-607,100Cs-13728,000Eu-152NoneEu-154NoneH-3120,000,000Ni-631,800,000Pu-238NonePu-239NonePu-240NoneRa-226NoneSr-908,700Consideration ofthe release criteria for building surfaces is important when selectingremediation strategies and for developing the final status survey. The release criteriafor material and equipment are alsoimportant whenestimating the quantity of material and equipment that will be disposed as radioactive waste.

3.3Survey DesignCharacterization surveys were designed to determine the presence of residual radioactive materials at the BMRC. In each area, professional judgment was used in conjunction with a systematic or random survey design for selection of locations that may have increased potential for residual radioactive materials. These locations were then surveyed for total alpha, total beta, removable alpha, and removable beta and general area gamma radiation dose rates.In the survey design, interior surfaces of the administrative wing wereinitially considered a minimum of MARSSIMClass 3. The entire containment wing was considered MARSSIM Class1 with the exception of the containment ceiling, which was considered Class 2. At a minimum, 29 survey locations were identified per survey package. Survey packages couldconsist of more than one room and a survey unit couldcontain more than one survey package. Additional survey locations were sometimesidentified by the survey technician during the BMRCCharacterization ReportRevision 0 15survey for collection of biased survey data. As such, a minimum of 29 survey locations were identified per survey package.The identified survey locations within a survey package receiveda static total alpha/beta measurement, an alpha/beta removable wipe sample, and a beta/gamma scan of the 1 square meter area surrounding the location. Gamma dose rate measurements were performed 1-meter above identified floor locations.Background measurements were collected in air within the selected room, or alternately,during the source check in the established technician staging area (Room 210/212).The status of these rooms at the time of the survey is documented in the photographs in Appendix A.

3.4Survey Package IdentificationDuring the investigation, a consistent identification system was used to ensure both the uniqueness and clarity in evaluation location and an identification of data collected. This section describes the protocol that was employed in naming the evaluation locations. Each location was assigned a unique identifier that included: Class (1, 2, or 3)Building Level oC for the control deck level oG for the gamma deck level oN for the neutron deck levelSurvey unit number -sequential number relative to the class and building levelRoom identifier as historically identified This resulted in a unique identifier for each survey package. For example, the survey package 2C1-215 represents Room 215 as being survey Class 2 on the control deck in survey unit 1. In this case, adjacent Room 213 is also part of survey unit 1 and is included in the survey package 2C1-213.

BMRCCharacterization ReportRevision 0 16 3.5Survey InstrumentationRadiological survey instrumentation was selected to ensure that sensitivities were sufficient to detect the expected radionuclides at the minimum detection requirements. The instrumentation was calibrated in accordance with approved procedures to National Institue of Science and Technology (NIST)traceable standards. The calibration was checked daily using Th-230 and Tc-99 for alpha and beta/gamma measurements, respectively. A list of the survey instrumentation, along with the type of radiation detected, calibration sources, and the instrument use, is provided in Table 3-6.Table 3-6Survey InstrumentationInstrumentDetector T yp eRadiation DetectedCalibration SourceUseLudlum Model 2221Ludlum Model 43-68 Gas Proportional (126 cm 2 area)Beta/GamaTc-99Surface Static Measurements; Beta/Gamma scan measurementsLudlum Model 2360Ludlum Model 43-89 ZnS coated Plastic Scintillator (126 cm 2 area)Alpha/BetaTh-230/Tc-99Alpha static measurementsLudlum Model 19Internal NaIGammaCs-137General area exposure ratesLudlum Model 3030ELudlum Model 43-10-1ZnS internal detectorAlpha/BetaTh-230/Tc-99Swipe/smear counting 3.6Minimum Detectable Activity The minimum detectable activity (MDA), also referred to minimum detectable concentration (MDC)is the concentration of radioactivity that an instrument can be expected to detect at a 95 percent confidence level. For instruments performing direct measurements and for laboratory analyses, the MDA goal was 10-50% of applicable release criteria. For static (direct) surface measurements, with conventional detectors, the MDA was calculated using the formula:

MDA (dpm/100cm

2) = t s b s s b T T T T R/1 29.3 3 Variables:

b R= Background count rate (cpm) b T= Background count time (min) s T= Sample Count Time (min) t= Total Instrument Efficiency (MARSSIMsection 6.6.1)

BMRCCharacterization ReportRevision 0 17The data used to calculate the MDA for the instrumentation used during the BMRC characterization are shown on the survey records in stored at the BMRC. The typical a priori MDA is listed in Table 3-7.Table 3-7Instrumentation MDAInstrumentDetector T ypeRadiation DetectedAverage MDA (d pm/100 cm 2)Ludlum Model 2360Ludlum Model 43-89Alpha47Beta612Ludlum Model 2360Ludlum Model 43-68Alpha59Beta393Ludlum Model 3030ELudlum Model 43-10-1Alpha12Beta159Ludlum Model 2221Ludlum Model 43-68Beta271 3.7Preliminary Survey Units and ClassificationsThe BMRC was segmented into logical areas of similar history and/or construction as survey units. Utilizing guidance available in the MARSSIM,an initial classification of either impacted or non-impacted was assigned to each survey unit.Non-impacted areas are areas where historical information and/or process knowledge does not indicate the existence of residual radioactive material, and does not indicateany reason to suspect the presence of residual radioactive materials. Impacted areas are areas where historical information and/or process knowledge indicates a potential presence of residual radioactive materials. During the characterization phase of the BMRC, all areas within the building were considered as impacted. Based on the levels of potential residual radioactive materials, impacted areas are further divided into Class 1, Class 2 or Class 3 designations. Class1 areas have the greatest potential for residual activity while Class 3 areas have the least potential for impacted areas. Each classification will typically be bounded by areas classified one step lower to provide a buffer zone around the higher class. Exceptions occur when an area is surrounded by a significant physical barrier that would make transport of residual activity unlikely from one area to the adjacent area. In such cases, each area is classified solely on its own merit using the most reliable information available. The class definitions provided below are from Section 4.4 of the MARSSIM.

BMRCCharacterization ReportRevision 0 18 Class 1"Areas that have, or had prior to remediation, a potential for radioactive contamination (based on site operating history) or known contamination (based on previous radiological surveys). Examples of Class 1 areas include: 1) site areas previously subjected to remedial actions, 2) locations where leaks or spills are known to have occurred, 3) former burial or disposal sites, 4) waste storage sites, and 5) areas with contaminants in discrete solid pieces of material high specific activity. Note that areas containing contamination in excess of the DCGL wprior to remediation should be classified as Class 1 areas."

Class 2"These areas have, or had prior to remediation, a potential for radioactive contamination or known contamination, but are not expected to exceed the DCGL w. To justify changing an area's classification from Class 1 to Class 2, the existing data (from the HSA, scoping surveys, or characterization surveys) should provide a high degree of confidence that no individual measurement would exceed the DCGL

w. Other justifications for this change in an area's classification may be appropriate based on the outcome of the DQO process. Examples of areas that might be classified as Class 2 for the final status survey include: 1) locations where radioactive materials were present in an unsealed form (e.g., process facilities), 2) potentially contaminated transport routes, 3) areas downwind from stack release points, 4) upper walls and ceilings of some buildings or rooms subjected to airborne radioactivity, 5) areas where low concentrations of radioactive materials were handled, and 6) areas on the perimeter of former contamination control areas."

Class 3"Any impacted areas that are not expected to contain any residual radioactivity, or are expected to contain levels of residual radioactivity at a small fraction of the DCGL w, based on site operating history and previous radiological surveys. Examples of areas that might be classified as Class 3 include buffer zones around Class 1 or Class 2 areas, and areas with very low potential for residual contamination but insufficient information to justify a non-impacted

classification."The preliminary list of survey units is presented inTable 3-8.

BMRCCharacterization ReportRevision 0 19Table 3-8Survey Unit SummaryClassDeckSurvey UnitRoom IDRoom Descri ption1C1200Electronics shop1C2201NWControl Deck Northwest quadrant1C3202Laboratory1C4203Laboratory1C5204Fan Room1C6205Reactor Control1C7206Office1C8207Superintendent Office1C9201AFuel Storage Vault1C9201BAirlock1C10201NEControl Deck Northeast quadrant1C11201SEControl Deck Southeast quadrant1C12201SWControl Deck Southwest quadrant1C12S242Stairs from Gamma Level to Control Level1C13201HCHot Cell Roof1C14201UArea above airlock1C15203UArea above rooms 202/2031C16204UArea above room 2041C17205UArea above room 2051C18206UArea above room 2061C19207UArea above room 2072C1213Laboratory2C1215Laboratory2C2CeilingContainment ceiling3C1208General Manager's Office3C1209Men's Locker and Change Area3C1210Conference Room3C1212Conference Room(cont)3C1214Secretary Office3C1216Directors Office3C1221Women's Rest Area3C1208AReception Area3C1208BGeneral Manager Closet3C1209AJanitor's Closet3C1209BMen's Toilet Room3C1214ASecretary Office Closet3C1216ADirectors Office Closet3C1221AWomen's Toilet Area3C1C241Corridor3C1OTBVertical Accelerator upper3C1S240Stairs Hall1G1101Airlock1G1101AJanitor's Closet1G2102NWGamma Deck1G2S123Stairs BMRCCharacterization ReportRevision 0 20ClassDeckSurvey UnitRoom IDRoom Description1G3103Chemistry Lab1G4104Medical Lab1G5105Work Room1G6106Change Room1G7107Hot Cell Service Room1G8108Hot Chemistry Lab1G9109Storage Area1G10113Shop1G11115Laboratory1G12114Health Physics/Counting Room 1G13115AVertical Accelerator lower1G14102NEGamma Deck NE area1G15102EGamma Deck East area1G16102SGamma Deck South area1G17HotcellHot Cell1G18102WGamma Deck West area2G1117Classroom2G1118Horizontal Accelerator3G1110Electrical Room3G1111Air Conditioning Equipment Room 3G1111AJanitor's Closet3G1S121, S122, & C119Stair Hall1N1N01 -ANeutron Deck1N2N16N16 tank room1N3SN07Stairs1N4N02AIRAir shaft to exterior1N5N03Cooling Water Equipment Room1N6N03PIT1000 gal tank pit1N7N02-NorthAir Conditioning Equipment Room -North section1N8N02-SouthAir Conditioning Equipment Room -South section1N9N01-BNeutron Deck1N10N01-CNeutron Deck1N11N01-DNeutron Deck1N12N01-ENeutron Deck1N13N01-FNeutron Deck1N14N01-GNeutron Deck2N110K10,000 gal Tank Room3N1N04Air Conditioning Equipment Room3N1N05Air Plenum3N1SN06Stair Hall BMRCCharacterization ReportRevision 0 21 4.CURRENT RADIOLOGICALCONDITIONSThe following sections summarize the results of the radiological characterization effort. Per MARSSIMguidance all measurement results, whether positive, negative, or less than MDA, were included in the calculations of the mean, maximum, and standard deviation. The results are summarized by survey unit. The completed survey packages have been retainedfor future reference,but not included in this report.

4.1Administrative WingSeveral rooms in the administrative wing have radioactive materials stored in them. Due to elevated backgroundfrom the radioactive material, it was difficult to determine the presence of residual radioactive materials. It is ENERCON's belief that these areas do not have residual radioactive materials present and after the stored radioactive material is packaged and shipped off site, these measurements will be verified. The rooms were surveyed for total alpha, total beta, removable alpha, and removable beta. Twenty-nine (29) building surface locations were selected in each room. In addition, biased locations were selected(e.g. fume hoods, drains, and sinks)at the discretion of the survey technician.Each subsection below contains a table which summarizes characterization survey results for that area.4.1.1Control DeckThe following rooms on the control deck of the administrative wing show no elevated measurements of residual radioactive materials:Locker Rooms (Rooms 209, 221 and 221A)Conference Room (Room 212)Offices (Rooms 208, 210, 214 and 216)Reception Area (Room 208A)Men's ToiletRoom (Room 209B)Janitor Closet (Room 209A)Two labs (Rooms 213 and 215)

BMRCCharacterization ReportRevision 0 22Table 4-1Administrative Wing Control Deck Survey Results SummaryRemovable Alpha Measurement Results (DPM/100cm 2)Removable Beta Measurement Results(DPM/100cm 2)Static Alpha Measurement Results(DPM/100cm 2)Static Beta Measurement Results(DPM/100cm 2)Survey Unit#MeanMax StdDevMeanMax StdDevMeanMax StdDevMeanMax Std Dev2C11721153111012319671621815373413C14410618901717139282584310673 4.1.2Gamma DeckThe following rooms on the gamma deck of the administrative/laboratory wing show no elevated measurements of residual radioactive materials:Electrical Servi ce Room (Room 110)Mechanical Room (Room 111) Machine Shop (Room 113)Several rooms on the gamma deck of the administrative/laboratory wing contain radioactive materials. These rooms are:Horizontal Accelerator (Room 118) with an adjacent cave area Class Room (Room 114)Health Physicist Office (Room 117)Vertical Accelerator Room (Rooms 115 and 115A)Table 4-2Administrative Wing Gamma Deck Survey Results SummaryRemovable Alpha Measurement Results (DPM/100cm 2)Removable Beta Measurement Results (DPM/100cm 2)Static Alpha Measurement Results (DPM/100cm 2)Static Beta Measurement Results (DPM/100cm 2)Survey Unit#MeanMax Std DevMeanMax Std DevMeanMax Std DevMeanMax Std Dev1G107616146411278917896591751G1176112222153767192009792101G12780312376238417619443610721G13760318591531751910191715930072G11440611296241850132429602723G1174061348102758141001330217 BMRCCharacterization ReportRevision 0 23 4.2Sub-BasementThe sub-basement, located below the gamma deck of the administrative/laboratory wing includes rooms that house the Holdup Tank Cubicle (Room N16), the Cooling Water Equipment Room and the Facility Sumps (Room N03), the lower Air Conditioning Equipment Room (Room N02), the Air Handling Duct Room (Room N04) and access to the 10K tank enclosure (Room N05). Room NO3 houses a 1000 gallon tank. This tank contains approximately 6 inches of sludge with elevated levels of radioactivematerials. Room N16 houses a 5,000 gallon N16 decay tank which is internally contaminated with radioactive materials. Table 4-3Sub-Basement Survey Results SummaryRemovable Alpha Measurement Results (DPM/100cm 2)Removable Beta Measurement Results (DPM/100cm 2)Static Alpha Measurement Results (DPM/100cm 2)Static Beta Measurement Results (DPM/100cm 2)SurveyUnit#MeanMax Std DevMeanMax Std DevMeanMax Std DevMeanMax Std Dev1N229162471122762584664694110761N433162232727671824774916388231N5381315481227581735691614735111N62713213213414108239924499364513741581N7331621632458247520547255469125421N83413112158501224110562722N1300004314935215015No DataNo DataNo Data3N19316236411769142993463577 4.3Containment WingThe containment wing of the BMRC is accessible via airlocks from the administrative wing control and gamma deck levels. Exterior access is viaa truck door on the gamma deck.

4.3.1Control DeckThe Control Deck (top level) houses a dual-hook over head crane with one 10-ton and one 2-ton hook on tracks at the ceiling level. Crane access to the lower levels is via a floor plate on the Control Deck and awebbing cover on a floor penetration from the Gamma Deck to the Neutron Deck. In addition to the reactor pool, the Control Deck houses: Reactor Control Room (Room 205)Superintendent's Office (Room 207)

BMRCCharacterization ReportRevision 0 24Two labs (Rooms 202 and 203)Fan Room (Room 204)Office (Room 206)Airlock (Room 201B) for access to the upper or First Floor of the Administrative WingNew Fuel Storage Room (Room 201A) located within the doors of the airlockMost of these rooms were beingused to storelegacy radioactive wasteswhen surveys were performed. The elevated backgroundfrom the radioactive material storage areas madeit difficult to determine the presence of residual radioactive materials on building surfaces in these areas.The limited radiological measurements collected in these areas did not identify removableor fixed radiological activity;therefore, the building surfaces are not believed to be contaminated. Following the removal of these legacy materials for offsite disposal, additional measurements will be collected in these areas. Room 202 was the location of a release of Sr-90that contaminated the walls adjacent to the California hood. These walls are affixedwith Plexiglas coveringsas a mitigating measure to provide beta shielding.Table 4-4Containment Wing Control Deck Survey Results SummaryRemovable Alpha Measurement Results (DPM/100cm 2)Removable Beta Measurement Results (DPM/100cm 2)Static Alpha Measurement Results (DPM/100cm 2)Static Beta Measurement Results (DPM/100cm 2)Survey Unit#MeanMax StdDevMeanMax StdDevMeanMax StdDevMeanMax Std Dev1C130131764151262386023120845081C2401318741680179372007042411C3412934113836641493912226241518421251C438112321962341139348320013551C538162187421122218542256491961C6381622396241092484614814702651C73821232817036101188374761301620941C8451616481284218552207042121C929418514802053112803201090471732172431C103411231096211112084547026924771C113829211591795407951276971771C12684184659121115758117333248446191C14261924371017226738110120503621C152816233710554097939312703311C1629162532117222662102831228211C172931233531214993620973332678281C182941541169211812594884916673771C19250314329211326508321177200 BMRCCharacterization ReportRevision 0 25 4.3.2Gamma DeckThe middle level or Gamma Deck houses:Hot CellHot Cell Work Room (Room105)Locker Room (Room 106)Hot Chemical Lab (Room 108)Medium Chemical Lab (Room 104)Activation Analysis Lab (Room109)Lower Fuel Vault (Room 101A)Chemical Lab (Room 103)Airlock (Room 101) foraccess between the administrative wing and containmentThis level also has a Truck Lock thatprovidesvehicular and equipment access to the outside.Prior to 1979, this level housed the waste compaction system. Wastesgenerated at BMRC and under the site-wide radiological program were collected and compacted for volume reduction in this system. Most rooms on the Gamma Deck werebeing used to store radioactive materialwhich makes it difficult to determine the presence of residual radioactive materialsonbuilding surfacesAdditional measurements will be collected on building surfaces in these areas following waste removal to verify residual radioactivity levels.All items inside the Hot Cell, including the Hot Cell, should be considered radioactive waste.Table 4-5Containment Wing Gamma Deck Survey Results SummaryRemovable Alpha Measurement Results (DPM/100cm 2)Removable Beta Measurement Results (DPM/100cm 2)Static Alpha Measurement Results (DPM/100cm 2)Static Beta Measurement Results (DPM/100cm 2)Survey Unit#MeanMax Std DevMeanMax Std DevMeanMax Std DevMeanMax Std Dev1G144293221596208421884071251G230292259116213433694307410681G33826376416501693520429475181G438162643137601548513370668621G538315434391241923432420114071G64021237641415525945180238499421G73826211692056209511124776316321G83931542016539912174467273254080221G9422123227693167371022715121725043 BMRCCharacterization ReportRevision 0 26 4.3.3Neutron DeckTheNeutron Deck (lower level) is divided by caging into two sections. The open area includes access to the Patient Treatment Room which is lined with wood. The Patient Treatment Room was included in the original design of the BMRC to be a location to provideneutron treatments to cancer patients. There have been no indications that it was ever used for this purpose. The enclosed area includes the rerouted Primary Coolant Piping and access to the seven Beam Storage Tubes. The Beam Storage Tubes extend 10 feet through the Containment Building wall into the surrounding soil. They were used as storage-for-decay of high dose reactor components or experiments. At the point where they exit the containment building wall, they are approximately 10 feet underground. Thebalance of the neutron deck is open area. The Neutron Deck is the area where the majority of radioactive waste materials awaiting disposal were being stored. No removable radioactive material was found during the characterization survey. Upon removal of the stored radioactive materials, a more detailed investigation will be performed.Table 4-6Containment Wing Neutron Deck Survey Results SummaryRemovable Alpha Measurement Results (DPM/100cm 2)Removable Beta Measurement Results (DPM/100cm 2)Static Alpha Measurement Results (DPM/100cm 2)Static Beta Measurement Results (DPM/100cm 2)Survey Unit#MeanMax Std DevMeanMax Std DevMeanMax Std DevMeanMax Std Dev1N1191621248181393348720921448833891N935293853143365938911993167287354971N1038061221600021152200489458081N1113000152110319260518884205124821N124151541812229861985318118014291N1338162748132584437932162226246831N14381621712227109308686743202962 4.4Concrete CoresConcrete core samples were collected to assess volumetric activity in the neutron deck floor and the bioshield. In addition, the concrete cores in the neutron deck were used to determine if a preferential pathway existed between the neutron deck floor and the bedrock. The concrete cores were field scanned for gross gamma radioactivity prior to beingcutinto approximate 1 inch thick BMRCCharacterization ReportRevision 0 27cross-sectionsfor radioanalysis. Cross-sectionsthat exhibited elevated count rates were sent offsite for analysis. If no elevated count rate was detectedat any cross-sectional location in the core, at a minimum, the end cross-sectionwas submitted.

4.4.1Floor CoresSix (6) locations on the Neutron Deck floor were chosen to collect 3-inch diameter concrete cores. The locations areshown in Figure 5. Field scans of the cores indicated no residual radioactive materials were present. Floor core #1 was collected through the proposed elevator pit and was therefore not as thick as the remaining floor cores. Locations#5 through #6 were cored through the concrete floor to the bedrock. During construction, the concrete floor of the neutron deck was poured directly on the excavated bedrock to an approximate depth of 30 inches. The concrete cores proved that the concretewas poured directly on the bedrock because no sand or gravel bedding layer was found in any location. Therefore a preferential pathway for radioactive materials does not existbetween the concrete floor and the bedrock.The analytical results indicate essentially background activities for the evaluated radionuclides. A summary of the laboratory analytical results for the floor cores is included in Table 4-7.

BMRCCharacterization ReportRevision 0 28Figure 5: Floor Core Locations BMRCCharacterization ReportRevision 0 29Table 4-7Concrete Floor Cores Analytical Results Summary Core ID>FLOOR 1FLOOR 2FLOOR 3FLOOR 4FLOOR 5FLOOR 6RadionuclideMax Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Ag-110M-0.030.040.010.060.000.02-0.010.02-0.020.05-0.010.05Co-58-0.040.06-0.040.06-0.010.020.000.030.000.06-0.020.06Co-600.090.060.000.070.010.030.000.02-0.010.050.000.05Cs-134-0.030.050.010.060.000.030.000.030.020.050.000.05Cs-1370.010.060.000.060.000.020.000.030.010.060.000.06Eu-1520.080.15-0.030.130.000.070.030.090.050.14-0.080.15Eu-1540.020.09-0.020.080.010.030.010.040.020.08-0.030.09H-33.120.533.640.512.570.512.080.535.550.572.370.54K-405.990.256.090.533.470.283.650.204.460.452.810.55La-140-0.120.12-0.040.20-0.060.07-0.010.11-0.010.18-0.010.20Mn-540.040.06-0.010.050.010.030.000.03-0.020.05-0.020.06Ra-2261.661.022.020.432.021.02Sb-1240.000.06-0.010.070.000.030.020.040.000.07-0.020.07Th-2280.280.110.220.080.120.040.140.050.210.080.170.09Th-2320.370.170.290.190.200.08Note: Blank field indicates no reported result BMRCCharacterization ReportRevision 0 30 4.4.2Bioshield CoresSix (6) locations along two (2) wallsof the bioshield face (BF)on the neutron deck were chosen for core samplesas shown inFigure 6.Three (3) cores were advanced in-line with the beam tubes until contact was made with the original 1/4 inch aluminum liner at the inner surface of the bioshield. This resulted in a total length for each core of approximately 70 inches. Evaluation of the data for the bioshield core samples indicates measureable activity in certain areas exceeds 12 inches in depth. The charts below show the Co-60 analytical results of the two sets of bioshield core data in a graphical manner of depth vs. activity. The Co-60 results are used as being representative of the overall results. Chart 1 presents Co-60 results vs. depth from the liner for the bioshield core samples on wall 4 and Chart 2presents the data for bioshield core sampleson wall 5.A summary of the bioshield core analytical results is presented in Table 4-8.Figure 6: Bioshield Core Locations BMRCCharacterization ReportRevision 0 31Chart 1:Bioshield Cores Wall 4Chart 2:Bioshield Cores Wall 5 BMRCCharacterization ReportRevision 0 32Table 4-8Bioshield Cores Analytical Results Summary Core ID>BF1-1BF1-2BF1-3BF2-1BF2-2BF2-3RadionuclideMax Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Ag-110M0.020.240.080.280.060.160.000.050.030.18-0.010.04Co-580.100.350.230.420.010.240.030.080.060.270.000.06Co-60104.900.30175.900.3250.080.186.680.0769.100.224.410.05Cs-1340.030.210.020.250.060.150.000.050.050.160.010.04Cs-1370.100.250.190.300.050.170.010.060.060.200.010.05Eu-1525.010.5310.750.633.890.370.310.134.500.420.290.11Eu-1542.950.353.850.391.780.250.170.081.940.280.050.06H-3141.002.37290.003.70154.002.478.011.18110.002.0319.700.97K-400.610.291.090.350.700.21La-1400.110.410.060.560.080.33-0.020.130.070.340.010.10Mn-540.120.310.170.360.010.210.020.070.040.240.000.05Ra-226Sb-1240.110.270.080.330.070.190.000.060.080.210.000.05Th-228Th-232Note: Blank field indicates no reported result BMRCCharacterization ReportRevision 0 33 4.5Exterior Soils and Building Surfaces 4.5.1Sub-Surface BoringsA total of 19 sub-surface soil boring locations were identified in the immediate vicinity of the building exterior including the area surrounding the liquid waste tanksas shown in Figure 7.One location (BMRC-018) was excluded because of its proximity to buried utilities.Figure 7:Soil Bore LocationsBorings were advanced by a split spoon sampler until refusal. Samples were collected in 2-foot intervals. All samples were field scanned at the time of collection for gross gamma radioactivity. At a minimum the first (surface) and last (refusal) samples from each boring were sent for laboratory analysis.None of the collected samples indicated presence of groundwater.The soil boring identified as BMRC-019 was advanced at the location of the former cooling tower which was known to have leaked low levels of radioactive liquids. The analyzed sample results only show the presence of naturally occurring radioactive materials.

BMRCCharacterization ReportRevision 0 34Examining the analytical data for the soil samples shows three (3) radionuclides as detectable. These radionuclides are Cs-137, H-3, and Ni-63. Of these radionuclides, Ni-63 appears in the highest concentration with a maximum value of 11.9 pCi/g which is less than 1% of the NRC screening level and approximately 1.4% of the scaled NY State screening level. In terms of percent of screening level, H-3 appears in one sample at approximately 4% of the NRC screening level which is approximately 9% of the scaled NY State screening level. A summary of the analytical results is provided in Table 4-9on the following page.

4.5.2Surface Water and Groundwater SamplesNo surface water or groundwater samples were collected during characterization. As identified in the NRC's Safety Evaluation Report, the SUNY UB campus is covered with a dense glacial clay overburden that is generally 10 to 20 meters thick. Below the overburden is bedrock consisting of a combination of two limestone formations above five dolomite formations on top of a shale layer. The bedrock layers are approximately 1000 feet in total depth. Additionally, the NRC Safety Evaluation Report for the BMRC describes the water movement in the overburden as extremely slow with percolation only in the top foot of soil. During the characterization effort, borings advanced to the upper surface of bedrock returned no groundwater. The sample analyses showed only low levels of radionuclide concentrations which may be attributable to the facility.There are no surface water features in the immediate vicinity of the reactor. The nearest surface water feature is a small pond 0.6 miles south of the BMRC located in McCarthy Park.

BMRCCharacterization ReportRevision 0 35Table 4-9Soil Borings Analytical Results SummaryBore ID>BMRC-001BMRC-002BMRC-003BMRC-004BMRC-005BMRC-006RadionuclideMax Activity (pCi/g)Max MDC (pCi/g)Max Activity (pCi/g)Max MDC (pCi/g)Max Activity (pCi/g)Max MDC (pCi/g)Max Activity (pCi/g)Max MDC (pCi/g)Max Activity (pCi/g)Max MDC (pCi/g)MaxActivity (pCi/g)Max MDC (pCi/g)Ac-2283.230.201.470.202.070.241.650.192.080.17Ag-108M0.010.040.020.050.000.040.000.040.020.100.000.04Ag-110M0.000.07-0.010.080.030.080.010.070.020.16-0.010.06Co-580.010.16-0.030.21-0.040.200.010.18-0.020.380.040.17Co-600.030.060.020.060.030.070.020.060.020.11-0.010.04Cs-1370.090.060.080.070.070.080.030.06-0.010.120.070.05Eu-1520.040.160.000.150.040.160.100.140.080.300.060.13Eu-1540.030.100.030.10-0.020.100.010.080.050.140.000.07H-30.090.892.910.89-0.310.883.720.88-0.390.86-0.690.89K-4019.460.3917.550.4615.920.4717.770.4019.731.2515.460.40La-14010.0667.0810.8163.5440.8490.5827.1987.0510.64202.108.3974.83Mn-540.020.070.030.08-0.010.080.010.070.030.150.030.07Ni-639.170.8311.900.920.250.600.340.66-0.150.870.050.89Ra-2262.241.081.991.181.220.731.821.021.631.171.940.89Sb-1240.020.230.050.25-0.010.250.010.22-0.020.510.100.20Th-2280.990.100.790.110.850.100.980.080.650.170.810.08Th-2320.730.190.720.220.620.230.730.170.670.230.660.16GR-A7.274.898.464.305.884.294.833.8711.504.959.432.85GR-B40.003.0036.802.9234.702.9128.602.6435.603.0038.002.86Note: Blank field indicates no reported result BMRCCharacterization ReportRevision 0 36Table 4-9Soil Borings Analytical Results Summary(Cont.)

Bore ID>BMRC-007BMRC-007ABMRC-008BMRC-009BMRC-010BMRC-011BMRC-012RadionuclideMax Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Ac-2281.000.121.980.172.730.521.540.141.190.18Ag-108M0.010.030.000.050.030.120.010.040.010.050.000.050.000.05Ag-110M0.020.050.030.080.020.200.030.070.020.080.030.070.000.07Co-580.020.120.020.240.020.470.020.170.020.18-0.040.18-0.030.20Co-600.000.040.030.070.020.110.020.050.040.060.030.060.000.06Cs-1370.000.04-0.020.070.090.160.050.050.080.060.050.060.040.06Eu-1520.030.090.000.180.100.390.060.130.050.170.010.140.040.16Eu-1540.010.060.000.090.030.210.000.070.040.10-0.010.090.010.10H-3-0.460.784.120.88-0.180.86-0.240.81-0.580.83-0.550.84-0.400.87K-4014.850.2715.100.6517.931.4017.130.4315.220.4619.140.4515.870.50La-140-23.6053.965.54115.0028.14283.9013.3385.3119.1379.09-0.65107.00-11.0699.19Mn-540.020.050.010.090.040.190.010.070.000.080.030.080.030.08Ni-631.670.930.460.650.180.660.250.680.360.660.510.700.600.71Ra-2261.700.931.410.841.701.101.951.12Sb-1240.100.160.040.30-0.020.660.090.200.000.250.140.280.040.26Th-2280.590.060.750.100.920.280.810.080.760.100.880.100.800.11Th-2320.520.120.610.230.680.160.690.170.620.180.730.180.790.21GR-A4.922.817.562.715.482.727.603.065.552.897.722.919.773.27GR-B30.002.8636.202.8225.202.8234.302.8827.302.8735.202.8727.002.88Note: Blank field indicates no reported resultNote: BMRC-007 was moved due to concrete wall of N-16 tank room, the new hole was labeled BMRC-007A BMRCCharacterization ReportRevision 0 37Table 4-9Soil Borings Analytical Results Summary(Cont.)Bore ID>BMRC-013BMRC-014BMRC-015BMRC-016BMRC-017BMRC-019RadionuclideMax Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)Max Activity (p Ci/g)Max MDC (p Ci/g)AC-2281.480.212.590.211.840.212.580.221.440.211.310.17AG-108M0.020.050.010.040.020.05-0.010.04-0.010.050.010.05AG-110M0.060.070.030.070.020.070.010.080.020.07-0.010.06CO-58-0.030.18-0.040.180.000.18-0.010.180.010.190.010.15CO-600.010.050.020.060.020.06-0.010.050.020.070.010.05CS-1370.070.070.010.060.070.070.100.060.080.060.010.05EU-1520.020.15-0.010.150.030.150.060.150.000.150.070.14EU-1540.020.090.020.09-0.010.090.010.090.010.090.020.08H-3-0.480.830.380.970.170.990.190.970.290.950.161.07K-4016.270.4615.370.4117.760.4015.340.4018.290.5018.380.38LA-14040.73110.3046.4699.359.8785.15-8.2776.3312.8879.4615.0375.23MN-540.020.070.030.070.010.070.010.070.020.070.020.06NI-630.310.66-0.121.53-0.391.530.001.55-0.211.60-0.241.57RA-2262.171.062.170.931.680.882.231.101.690.77SB-1240.020.240.010.240.030.24-0.020.240.080.250.170.23TH-2280.790.090.750.130.850.100.910.090.860.100.730.09TH-2320.590.200.700.190.860.190.660.200.780.200.630.16GR-A5.983.126.212.868.142.887.593.457.293.238.623.01GR-B31.102.8829.902.8737.502.8735.102.8829.902.8828.902.88Note: Blank field indicates no reported resultNote: BMRC-018 was excluded due to proximity to buried utilities BMRCCharacterization ReportRevision 0 38 4.5.3Gamma Radiation ScanA Gamma Radiation Scan was performed on the surface soils immediately surrounding the BMRC using a 2x2 Sodium Iodide (NaI)detector connected to a Ludlum Model 2221. The ratemeter reading was paired with its latitude/longitude coordinate and logged using a Trimble GPS unit. Additionally, an area several hundred yards to the northeast was selected for background radiation scans. The average background reading was 6384 cpm with a maximum reading of 7311 cpm. The average reading for the surface soils nearthe BMRC was 6998 cpm with a maximum reading of 8909 cpm. The highest measurements recorded are adjacent to the current Vertical 10K Storage Tank and next to the northeast corner of the building. The elevated readings can be attributed to background interference from the Vertical 10K tank and the Cs-137 calibration source in Room 115A, respectively.Figure 8: Gamma WalkoverData Value>12768 5000 5500 6000 6500 7000 7500 8000 8500 9000 9500 10000 10500 11000 11500 12000 12500STEAM M.H.

BMRCCharacterization ReportRevision 0 39 4.5.4BMRC RooftopsThe rooftop of the BMRC Containment Building and the Administrative Wing were surveyedfor loose alpha/beta, fixed beta and loose beta. Additionally, the fixtures of the building exhaust systems were surveyed. Fourteen (14) random locations were plotted using the VSP software and an additional 6 locations were chosen based on professional judgment which included the Containment Exhaust Vent, the Tank Farm Vent pipe, and four vents from the Administrative Wing.All smear results were less than MDC. The static Beta measurements, without material specific background subtraction, had anaverage of1369 dpm/100cm 2, with a maximum result of 2403 dpm/100cm 2 and a standard deviation of 456 dpm/100cm 2.4.5.5Tritium and Carbon-14 SmearsA tritium and Carbon-14 smearwas collected from every room, sink, and hoodthroughout the BMRC Administrative Wingand Containment Buildings. A total of 83smears (60 floor locations, 11 hoods, and 12 sinks) were analyzed by the offsite laboratory for loose tritium and loose C-14 with an MDC values at approximately 9 dpm/100cm 2 and 6 dpm/100 cm 2 ,respectively. All locationsin the Administrative Wingwere less than MDC for both radionuclides. Eight (8)locations in the Containment Buildingindicated a potential presence of tritiumwith an average result of 30 dpm/100 cm 2and a maximum value of 100 dpm/100 cm 2.Additionally, three (3) locations indicated the potential presence of C-14 with a maximum result of 35 dpm/100cm 2.When compared to the NRC Building Surfaces screening values for tritium and C-14, the maximum results are approximately 0.00005% and 0.0009% of the screening values,respectively.

BMRCCharacterization ReportRevision 0 40 4.6Tank FarmThe Tank Farm lies in the subsurface adjacent to the containment building and extends towards the southwest of the containment building. The Tank Farm consists of two 250-gallon stainless steel tanks (Tanks 4 and 5)and two 600-gallon stainless steel tanks (Tanks 2 and 3) in connected concrete enclosures. There is also a 10,000-gallon carbon steel tank (Tank 1) in a separateenclosure to the southeast as shown in the HSA. The 250-gallon tanks were connected to the Isotope Processing Labs and the Hot Cell. The 600-gallon tanks supported the drains from the lower level labs and the floor drains. The tanks were interconnected by a manifold and pump system that allowed any combination of water transfer. The normal movement was to pump the small tanks to the 10,000-gallon tank for blending prior to discharges into the sewer system. Samples from the all of the tanks were taken and sent for analysis. The results are contained inTable 4-10 and Figure 9provides the orientation of the tanks in the tank farm.As discussed in the HSA, the tanks were placed in wet layup by pumping them at least half-full of water to minimize oxygen degradation in 1985. This method of storage was recommended by personnel at the DOE's Hanford Site.Sampling ports known as Tell-Tale sampling ports were installed in the original configuration to sample any liquids that may have entered the enclosures and concrete berm to verify tank and piping integrity. BMRC personnel collect samples on a quarterlybasis and no indications of loss of integrity have been detected.

BMRCCharacterization ReportRevision 0 41Figure 9:Tank Farm Layout BMRCCharacterization ReportRevision 0 42Table 4-10Tank Farm Analytical Sample Results SummaryBMRC-TF-001BMRC-TF-002BMRC-TF-003BMRC-TF-004BMRC-TF-005RadionuclideMax Activity (p Ci/L)Max MDC (p Ci/L)Max Activity (p Ci/L)Max MDC (p Ci/L)Max Activity (p Ci/L)Max MDC (p Ci/L)Max Activity (p Ci/L)Max MDC (p Ci/L)Max Activity (p Ci/L)Max MDC (p Ci/L)Ag-108M116324561824485976609Ag-110M2337727-191928Am-241 (AS)00C-144223615102510302587298519Cm-242 (AS)00Cm-243/244 (AS)00Co-5803-428-112-512311Co-601283104901416548235879437Cs-134-13119-5828-78Cs-137803437222211013091059Eu-15219-5351-1025021-325Eu-15416-824-514-410613Fe-550216GR-A11383933323GR-B1050021478015541016318012224010H-34320355058103580426035603880362039703610I-129-3077La-14006-425-1314-218316Mn-5413-226310211-210Ni-59-4773Ni-63388141040013255001316501346713Pu-238 (AS)00Pu-239/240 (AS)00Pu-2416669Sb-12404-822-510-510210Sr-891380069422064543062372063296070Sr-9043101813301623001511501689512Tc-99418U-233/234 (AS)10U-235 (AS)00U-238 (AS)00Note: Blank field indicates no reported result. (AS) = Alpha Spectroscopy.

BMRCCharacterization ReportRevision 0 43 4.7VentilationSurveys of the ventilation systems consisted of removable activity surveys at select access points and were performed in the course of the characterization surveys and are reported for the survey unit to which the system is associated. Table 4-11provides a summary of the ventilation systems by survey unit.Table 4-11Ventilation Systems Survey Results SummaryRemovable Alpha Activity (DPM/100cm 2)Removable Beta activity (DPM/100cm 2)Survey UnitAverage MaxAverage Max1C33343741G1200001G8612351G9009272C11327902G1031274 4.8Miscellaneous Sample AreasAdditional samples have been collected from the N16 tank room soil and from the sediment material in the 1K tank located in Room N03.

4.8.1N16 Tank VaultThe N16 tank is located in a vault in the sub-basement accessible through a wall hatch in Room N03. This room is unfinished and has concrete walls and a dirt floor. The tank is mounted on concrete piers. Piping exits the neutron level of containmen t and passes into this room. Four (4) soil samples were collected as part of the characterizationas shown in Figure 10.The results indicate impacts greater than the NRCand NYS Screening values for Co-60. Additionally, Ag-108m was elevated and has a high potential to be greater than the release criteriadeveloped as part of the DP. A summary of the analytical sample results is presented in Table 4-12on the following page.

BMRCCharacterization ReportRevision 0 44Figure 10: N16 Tank VaultSample LocationsTable 4-12N16 Tank VaultAnalytical Results SummaryRadionuclideMaximum Activity (pCi/g)Maximum MDC (pCi/g)RadionuclideMaximum Activity (pCi/g)Maximum MDC (pCi/g)Ac-2283.95E+004.71E-01Fe-552.61E+009.81E+00 A g-108M9.99E+011.94E-01H-37.19E+001.18E+00Ag-110M5.98E-011.42E-01K-401.12E+014.60E-01Co-579.13E-011.04E-01La-1401.84E-012.52E-01Co-582.84E-021.60E-01Mn-542.31E-021.29E-01Co-601.26E+017.03E-02Ni-637.69E+016.26E-01Cs-1343.03E-021.46E-01Sb-1242.50E-021.95E-01Cs-1374.65E+001.42E-01Sr-895.66E-021.79E-01Eu-1522.00E+005.65E-01Sr-903.61E-016.76E-02Eu-1549.50E-012.94E-01Th-2285.38E-013.28E-01GR-A8.36E+002.64E+00Th-2326.12E-014.82E-01GR-B8.27E+012.60E+00 BMRCCharacterization ReportRevision 0 45 4.8.21K TankThe 1K tank is located in a pit in Room N03. Water is collected in this tank from all sumps and drains in the containment building prior to entering the 10K tank and ultimately being discharged through the NPDES permitted sanitary system.The tank sediments were sampled and contained elevated levels of the site specific ROCs with the primary radionuclides being Co-60, Ag-108m, Ni-63, and Sr-90. The sediment sample collected from the tankhad a dose rate of 1.5 mR/hr on contact. The water in the tanks was sampled and contained only Ni-63.Table 4-13on the following page provides a summary of the analytical results of the tank sediment.Table 4-131K Tank Analytical Results SummaryRadionuclideSedimentsLiquidActivity (pCi/g)Uncertainty 2 Sigma (pCi/g)Activity (pCi/l)Uncertainty 2 Sigma (pCi/l)C-142.23E+016.70E+00<MDC<MDCNi-591.76E+021.03E+02<MDC<MDCNi-639.92E+039.94E+012.96E+034.29E+02Sr-891.38E+022.03E+01<MDC<MDCSr-901.99E+021.37E+01<MDC<MDCAg-108m1.03E+045.97E+01<MDC<MDCCo-601.51E+033.57E+01<MDC<MDCCs-1374.90E+013.12E+01<MDC<MDCAm-2413.90E+009.07E-01<MDC<MDCPu-2381.71E+004.28E-01<MDC<MDCPu-239/2405.74E+008.30E-01<MDC<MDCU-233/2341.74E+004.80E-01<MDC<MDCU-2381.09E+003.51E-01<MDC<MDC BMRCCharacterization ReportRevision 0 46 5.HAZARDOUS MATERIALSAs part of the facility characterization, a hazardous materials assessment was also performed. The goal of the assessment was to identify known and potential hazardous materials present at the facility. The assessment was based on site observations and document reviews.During the on-site characterization, several potential hazardous materials were identified. These included caustics and acids (water treatment chemicals) and lubricating oils. There appeared to be no evidence of spill or leaks of these materials that would have impacted the facility. Because the facility housed many experiments, there may also be containers of laboratory chemicals stored about the facility that were not observed during the radiological site characterization activities. It is expected that containers of hazardous materials will be disposed of according to current practices and procedures prior to radiological decontamination and demolition.UB does not have a site asbestos management plan, however, the facility has been surveyed for Asbestos Containing Materials (ACM)with ACM locations identified on piping. The floor tile in the administration wing is also known to be ACM. There is a high potential that the mastic under the tile is also ACM. The University plans on issuing a request for proposal (RFP) for asbestos removal in the second half of 2011. A new ACM survey will be performed before an RFP is issued for the ACM interference removal project.Lead is present throughout the facility in the form of lead bricks and lead sheets. The University is in the process of issuing a contract to dispose of all loose legacy materials in the facility which includes all lead bricks and sheets. While a lead paint survey was not conducted, because of the age of the facility, it is expected that lead-based paints potentially were used throughout the facility. A lead paint survey will either be conducted at the sametime a new ACM survey is conducted or will be conducted prior to an RFP being developed for building remediation and demolition.Mercury chloride was used in the activation analysis lab on the gamma deck in the containment wing. The University required mercury monitoring during radiological surveys in the lab. Additionally, the fluorescent light ballasts and any old thermostats will likely contain hazardous materials.

BMRCCharacterization ReportRevision 0 47 6.QUALITY ASSURANCE AND QUALITY CONTROLENERCON ensured that quality and regulatory requirements were satisfiedduring the characterization effort.Activities were controlled by procedures and the Site Characterization Plan. These documents includedthe following Quality Control (QC) measures as an integral part of the survey process.

6.1General Provisions 6.1.1Written ProceduresSurvey tasks were controlledby characterization survey instructions contained in each survey package, ENERCON procedures, and the BMRC Characterization Plan. The followingprocedures were used and referenced in the characterization survey instruction during the characterization project: TS 5.4.6, Chain of Custody TS 5.4.7, Documentation of Radiological Surveys TS 5.4.8, Instrument Source and Response Check TS 5.4.10, Sampling Materials for Radiological Characterization TS 5.4.11, Sample Handling TS 5.4.12, Radiological Scans and Measurements TS 5.4.13, Technician Training and QualificationSUNY-OP-01,BMRC Reactor Bioshield Core SamplingSUNY-OP-02,Neutron Deck Coring and Subgrade SamplingSUNY-OP-03,Concrete Core Sample ProcessingSUNY-OP-04,Soil Sampling 6.1.2Instrumentation Selection, Calibration, and UseENERCON selected instruments that are proven to reliably detect the radionuclidespresent at the BMRC. Instruments were calibrated by qualified vendors under approved procedures using calibration sourcestraceable to the National Institute of Standards and Technology (NIST). Alldetectors were subject to daily response checks when in use per guidance established in American National Standard Institute (ANSI) standard ANSIN323-1997.

BMRCCharacterization ReportRevision 0 48 6.1.3Chain of CustodyThe Chain of Custody procedure established responsibility for the custody of samples from thetime of collection until results were obtained. All samples shipped off sitefor analysis were accompanied by a chain-of-custody record to track eachsample.

6.1.4Independent Review of Survey ResultsThe survey package and survey data from each area received an independentreview to verify all documentation is complete and accurate.

6.2TrainingAll project personnel received site specific training to identify the specific hazards present in the survey areasin addition to the characterization process.The training included a briefing and review of the BMRC Characterization Plan, ENERCON procedures, and the Site Safety and Health Plan.Personnel were also required to read each document. Copies of all training records were maintained on site through the duration of the onsite activities.

6.3 Sample AnalysisENERCON utilized a third party vendor, Teledyne Brown Engineering (TBE) in Knoxville, TN, for all radioanalytical servicesduring the characterization project. All samples sent to TBE were accompanied by a Chain of Custody with their receipt acknowledge via email. TBE isused extensively in the nuclear industry for environmental, bioassay, and waste characterization analyses. TBE provides QC with all laboratory reports includingblanks, spikes and duplicates.

BMRCCharacterization ReportRevision 0 49 7.LIMITATIONS 7.1High Background AreasAs noted throughout this report, there were several areas where the background radiation was elevated due to the presence of stored radioactive materials.The status of these rooms at the time of the survey is documented in the photographs in Appendix A. In these areas, surveys may not be complete, but will be verified following the pre-decommissioning cleanout of loose legacy materials. Following the disposal campaign, radiological surveys will be performed in the areas and the results documented. The results will be analyzed to ensure the information submitted in the DP remains valid. A revised DP will be submitted to the NRCif a revision is required.

7.2 Internal ActivityThe internal surfaces of various components potentially containing radioactive materials were not surveyed. These include the primary coolant pipes, the nitrogen-16 decay tanks, the primary coolant pump, the vertical 10K taste tank, and the reactor tank. However, external dose rates were measured for these items and were documented in the radiation surveys. A dose rate survey was conducted in the reactor tanks near all activated components. This information was used by WMG for the Component Activation Analysis report.

BMRCCharacterization ReportRevision 0 508.REFERENCES8.1BMRC Historical Site Assessment, Rev. 0, March 17 2010, ENERCON8.2BMRC Characterization Plan, November 24, 2010, ENERCON8.3BMRC Site Health and Safety Plan for the SUNY-UB Characterization, November 30, 2010, ENERCON8.4NUREG-1537, Part 1, Chapter 17, Guidelines for Preparing and Reviewing Applications for Licensing of Non-Power Reactors8.5NUREG-1757,Consolidated Decommissioning Guidance8.6NUREG-1575,Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).8.710CFR20, Standards for the protection against Radiation8.8DSHM-RAD-05-01, Cleanup Guidelines for Soils Contaminated with Radioactive Materials, New York State Department of Environmental Conservation.8.9ANSI N323-1997,Radiation Protection Instrumentation Test and Calibration, Portable Survey Instruments

,American National Standard Institute (ANSI) Standard 8.10NUREG-0982,Safety Evaluation Reportrelated to the renewal of the operating license for the Research Reactor at the State University of New York at Buffalo, May 1983, NRC8.11NUREG/CR-3474,Long-Lived Activation Products in Reactor Materials

.8.12NUREG/CR-4289, Residual Radionuclide Contamination Within and Around Commercial Nuclear Power Plants

.

BMRCCharacterization ReportRevision 0 51 Appendix ABMRC Characterization Photographs BMRCCharacterization ReportRevision 0 52Administrative Wing -Control Deck LevelPhotograph 1Building Exterior Main EntrancePhotograph 2OTB (Vertical AcceleratorRoom)Photograph 3Room 215Photograph 4Room 213Photograph 5Stairwell (S240)Photograph6Room 221 (Women's Restroom)

BMRCCharacterization ReportRevision 0 53Photograph 7Main Control Deck Hallway (C241)Photograph 8Room 209 (Men's Restroom)Photograph 9Room 216Photograph 10Room 214Photograph 11Room 210/212Photograph 12Room 208 BMRCCharacterization ReportRevision 0 54Photograph13Room 208A BMRCCharacterization ReportRevision 0 55Administrative Wing -Gamma Deck LevelPhotograph 14Room 115A (Vertical Accelerator Target)Photograph 15Room 115Photograph 16Stairwell (S122)Photograph 17Room 113 (Machine Shop)Photograph 18Room 111Photograph 19Main Gamma Deck (C119)

BMRCCharacterization ReportRevision 0 56Photograph 20Room 118Photograph 21Room 117Photograph 22Room 114Photograph 23Room 110 BMRCCharacterization ReportRevision 0 57Administrative Wing -Neutron Deck Level (Sub-Basement)Photograph 2410K Tank RoomPhotograph 25Room N05Photograph 26Room SN06 (Stairwell)Photograph 27Room N02Photograph 28Room N04Photograph 29Room N03 BMRCCharacterization ReportRevision 0 58Photograph 30Room N03 1K Tank PitPhotograph 31N16 Tank Room BMRCCharacterization ReportRevision 0 59Containment Wing -Control Deck LevelPhotograph 32Room 201APhotograph 33Room 202Photograph 34Room 203Photograph 35Room 204 (Fan Room)Photograph 36Room 205 (Control Room)Photograph 37Room 206 BMRCCharacterization ReportRevision 0 60Photograph 38Room 207Photograph 39Room 200Photograph 40Main Floor Control DeckPhotograph 41Main Floor Control DeckPhotograph 42Main Floor Control DeckPhotograph 43Main Floor Control Deck BMRCCharacterization ReportRevision 0 61Containment Wing -Gamma Deck LevelPhotograph 44Room 101Photograph 45Room 103Photograph 46Room 104Photograph 47Room 109Photograph 48Room 108Photograph 49Room 107 BMRCCharacterization ReportRevision 0 62Photograph 50Room 106Photograph 51Room 105Photograph 52HotcellPhotograph 53Main Floor Gamma DeckPhotograph 54Main Floor Gamma DeckPhotograph 55Main Floor Gamma Deck BMRCCharacterization ReportRevision 0 63Photograph 56Main Floor Gamma DeckPhotograph 57Main Floor Gamma Deck BMRCCharacterization ReportRevision 0 64Containment Wing -Neutron Deck LevelPhotograph 58Main Floor Neutron LevelPhotograph 59Main Floor Neutron LevelPhotograph 60Main Floor Neutron LevelPhotograph 61Main Floor Neutron LevelPhotograph 62Main Floor Neutron LevelPhotograph 63Main Floor Neutron Level BMRCCharacterization ReportRevision 0 65Photograph 64Main Floor Neutron LevelPhotograph 65Beam Port Storage TubesPhotograph 66High Radiation Area Neutron LevelPhotograph 67Thermal ColumnPhotograph 68Trench System BMRC Decommissioning PlanRevision0APPENDIX C -DECOMMISSIONING ENVIRONMENTAL REPORT Decommissioning En vironmental ReportBuffalo Materials Research CenterPrepared for:Buffalo Material Research CenterOffice of Environment, Health, and Safety ServicesCompleted by:4490 Old William Penn HighwayMurrysville, PA 15668December 2011 BMRC Decommissioning Environmental Report Revision 0 Prepared By: Date: 11/4/2011 Wyatt Grant, P.E. Senior Technical Specialist Prepared By: Date: 11/4/2011 Glenn Hargrove, PG Technical Specialist Reviewed By: Date: 11/4/2011 Robert D. Sanders Senior Technical Specialist Approved By: Date: 12/22/2011 Dustin G. Miller, CHP Decommissioning Project Manager BMRCDecommissioning Environmental ReportRevision 0 iTABLE OF CONTENTS

1.0INTRODUCTION

.............................................................................................................................11.1Purpose and Need for Action.........................................................................................................11.2The Proposed Action......................................................................................................................21.3Applicable Regulatory Requirements, Permits, and Required Consultations................................21.3.1Federal Requirements..............................................................................................................21.3.2State of New York...................................................................................................................42.0FACILITY DESCRIPTION...............................................................................................................63.0ALTERNATIVES............................................................................................................................133.1.1SAFSTOR Alternative..........................................................................................................133.1.2ENTOMB Alternative...........................................................................................................133.1.3DECON-AAlternative..........................................................................................................133.1.4DECON-BAlternative..........................................................................................................143.2Decommissioning of the Reactor, License Termination, and Site Reuse.....................................143.2.1Decommissioning of the Reactor..........................................................................................143.2.2Licenses.................................................................................................................................153.2.3Reuse of Site.........................................................................................................................153.3Cumulative Effects.......................................................................................................................163.4Comparison of the Predicted Environmental Effects...................................................................164.0DESCRIPTION OF THE AFFECTED ENVIRONMENT.............................................................174.1Land Use.......................................................................................................................................174.2Transportation..............................................................................................................................184.3Geology and Soils.........................................................................................................................184.4Water Resources...........................................................................................................................194.5Ecological Resources....................................................................................................................204.6Meteorology, Climatology, and Air Quality................................................................................20 4.7Noise.............................................................................................................................................214.8Cultural and Historical Resources................................................................................................224.9Visual/Scenic Resources..............................................................................................................234.10Socioeconomic..........................................................................................................................234.11Public and Occupational Health................................................................................................244.12Waste Management...................................................................................................................285.0ENVIRONMENTAL IMPACTS.....................................................................................................295.1Land Use Impacts.........................................................................................................................29 BMRCDecommissioning Environmental ReportRevision 0 ii5.2Transportation Impacts.................................................................................................................295.3Geology and Soils Impacts...........................................................................................................305.4Water Resources Impacts.............................................................................................................305.5Ecological Resource Impacts.......................................................................................................305.6Air Quality Impacts......................................................................................................................305.7Noise Impacts...............................................................................................................................315.8Historical and Cultural Resources Impacts..................................................................................3 15.9Visual/Scenic Resource Impacts..................................................................................................315.10Socioeconomic Impacts............................................................................................................315.11Environmental Justice...............................................................................................................325.12Public and Occupational Health Impacts..................................................................................325.12.1Nonradiological Impacts.......................................................................................................325.12.2Radiological Impacts.............................................................................................................325.13Waste Management Impacts.....................................................................................................335.13.1Radiological Impacts.............................................................................................................356.0MITIGATION MEASURES...........................................................................................................367.0ENVIRONMENTAL MONITORING AND MEASUREMENT PROGRAMS............................377.1Radiological Monitoring..............................................................................................................377.2Physiochemical Monitoring..........................................................................................................37 7.3Ecological Monitoring..................................................................................................................378.0COST BENEFIT ANALYSIS.........................................................................................................389.0

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES...........................................................39

10.0REFERENCES

.............................................................................................................................40 LIST OF FIGURESFigure 1: The BMRC and Adjacent Buildings

..............................................................................................6Figure 2: Control Deck Layout

.....................................................................................................................9Figure 3: Gamma Deck Layout

...................................................................................................................10Figure 4: Neutron Deck Layout

..................................................................................................................11Figure 5: Decommissioning Boundary

.......................................................................................................34 BMRCDecommissioning Environmental ReportRevision 0 iiiAcronyms and AbbreviationsACMAsbestos Containing MaterialASTaboveground storage tankBLMBureau of Land Management BMRCBuffalo Materials Research CenterBSFRBulk Survey for ReleaseCAMContinuous Air MonitorCFRCode of Federal RegulationsD&DDecontamination and Decommissioning DCGLDerived Concentration Guideline LevelsDECDepartment of Environmental Conservation (State of New York)DECON-Acomplete decontamination and structure demolition optionDECON-Bcomplete decontamination and release of the structure optionDOCDesign and Oversight Contractor DOEUnited States Department of EnergyDOTDepartment of TransportationECLEnvironmental Conservation LawEH&SEnvironment,Health and Safety ENTOMBEntombment optionEPAEnvironmental Protection AgencyEREnvironmental ReportFFahrenheitFSSFinal Status SurveyHEPAHigh-efficiency particulate airHSAHistorical Site AssessmentLLRWLow-level radioactive waste MARSSIMMulti-Agency Radiation Survey and Site Investigation ManualMGDMillion Gallons per DaymremMilliremMTRMaterials Testing ReactorMWMegawatt MWtMegawatt thermalN-16Nitrogen 16NEPANational Environmental Policy Act BMRCDecommissioning Environmental ReportRevision 0 ivNMSSNRC Office of Nuclear Material Safety and SafeguardsNRCNuclear Regulatory CommissionNSTCNuclear Science and Technology CenterNYCRRNew York State Codes, Rules, and RegulationsNYSNew York StateNYSDOHNew York State Department of Health PuBePlutonium-BerylliumPULSTARPulse Training Assembled ReactorRCRAResource Conservation and Recovery ActRFTresilient floor tileSAFSTORNo-Action Alternative SCRSite Characterization Report (ENERCON initial draft)SNMSpecial Nuclear MaterialSr-90Strontium-90SUNYState University of New YorkTLDThermoluminescent dosimeterUBUniversity at BuffaloUSTunderground storage tankWMPWaste Management Plan BMRCDecommissioning Environmental ReportRevision 0

11.0INTRODUCTION

This Environmental Report (ER) describes the environmental effects related to the decommissioning of the University at Buffalo (UB) Material Research Center (BMRC) Research and Test Reactor Facility.

The ER was prepared in accordance with the guidance provided in Chapter 6.0 of the U.S. Nuclear Regulatory Commission (NRC) Office of Nuclear Material Safety and Safeguards (NMSS) NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (NRC 2003b). This ER is designed to be used by the NRC in conducting its environmental assessment in accordance with the National Environmental Policy Act (NEPA) of 1969. NEPA requires federal agencies, as part of their decision-making process, to consider the environmental impacts of actions under their jurisdiction. The NRC's NEPA requirements are provided in Title 10 Code of Federal Regulations (CFR) Part 51.1.1Purpose and Need for ActionThe reactor at the BMRC wasoperated from 1961 to 1963 in support of training and education for the university and other national users. In 1964, the reactor was shut down and the core and control systems were modified so that the reactor could operate with Pulse Training Assembled Reactor (PULSTAR)-type fuel at power levels up to 2 megawatts thermal (MWt). The BMRC continued in support of training and education for the university from 1964 until reactor activities were suspended in 1994. During the period of operation, the BMRC has had multiple uses including:Training and educationTransient fuel performance testingMaterials radiation damage researchIsotope productionNeutron interrogation through activation analysis, radiography and delayed fission assayThe unit has been in Possession Only status since June 6, 1997. All of the unused fuel was shipped to North Carolina State University in 1998 and all the spent fuel was removed from the site in 2005 and shipped to Idaho National Engineering and Environmental Laboratory. The BMRC administrative/laboratory wing (administrative wing) is currently used infrequently for two purposes. One purpose is an ion chamber calibration facility that is located in the basement of the administrative wing. The second purpose is for training of the State University of New York (SUNY) at Buffalo (UB) maintenance staff in the proper care and cleaning of asbestos-containing resilient floor tile (RFT). The top BMRCDecommissioning Environmental ReportRevision 0 2floor of the administrative wing has been determined to contain asbestos-containing RFT. Certain regulatory statutes mandate a standard of care for maintenance and custodial workers when activities affect asbestos-containing RFT. The UB Maintenance Department utilizes this space to train personnel on how to properly strip and wax the RFT. The containment building is only accessed for routine Technical Specification inspections.1.2The Proposed ActionUB has already removed the BMRC from service and now plans to dismantle the reactor and its ancillary support systems, remove all residual radioactive material from the BMRC facility, and demolish the entire facility. Radioactivity levels will be reduced to levels that will permit release of the licensed area for unrestricted use and allow termination of NRC Possession License OnlyR-77.1.3Applicable Regulatory Requirements, Permits, and Required ConsultationsDecommissioning of the BMRC requires adherence to numerous federal, state, regional, local, and UB regulations. Guidance for determining many of the applicable federal, state, regional, and local requirements is identified in the following subsections. The information provided below is intended as a broad overview of applicable regulations and is not intended to be all-inclusive. The licensee or owner, UB in this case, is ultimately responsible for compliance with applicable federal, state, local, and internal regulations and is responsible for the costs associated with acquiring applicable permits and for the costs of implementing the necessary compliance programs during decommissioning activities.1.3.1Federal RequirementsDecommissioning activities that are subject to federal regulations, permits, licenses, notifications, approvals, or acknowledgements include:Handling, packaging, and shipment of radioactive wasteWorker radiation protectionLicense termination and final site releaseWorker, contractor, and the general public's health and safetyLiquid effluent releasesHazardous waste generation and dispositionHandling, removal, and proper disposal of asbestos-containing materialsHandling, removal, and proper disposal of lead-containing paintand lead-based paintHandling, removal and proper disposal of underground and aboveground storage tanks (UST and AST, respectively)

BMRCDecommissioning Environmental ReportRevision 0 3The majority of radiological activities fall under Title 10 CFR and are administered by the NRC. Applicable portions of Title 10 regulations are included within the following parts:Nuclear Regulatory CommissionPart 20 -"Standards for Protection Against Radiation"Part 50 -"Domestic Licensing of Production and Utilization Facilities" including decommissioning activitiesPart 51 -"Environmental Protection Regulations For Domestic Licensing and Related Regulatory Functions"Part 61 -"Licensing Requirements for Land Disposal of Radioactive Waste"Part 71 -"Packaging and Transportation of Radioactive Material"Many of the decommissioning requirements that involve activities for site control, characterization, and final status surveys (FSS) are found within the following parts of Title 10 of the CFR and are administered by the NRC. The parts include:Part 20.1401 -"General provisions and scope"Part 20.1402 -"Radiological criteria for unrestricted use"Part 20.1403 -"Criteria for license termination under restricted conditions"Part 20.1404 -"Alternate criteria for license termination"Part 20.1405 -"Public notification andpublic participation"Part 20.1406 -"Minimization of contamination"Part 20 Subpart F -"Surveys and Monitoring" Part 30.36 -"Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas"Part 40.42 -"Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas"Part 70.38 -"Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas"Part 72.54 -"Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas"Radioactive material transportation activities fall under Title 49 of the CFR and are administered by the Department of Transportation (DOT). Applicable portions of Title 49 regulations are included within the following parts:Department of TransportationSubtitle B -"Other Regulations Relating to Transportation," Parts 100 to 185 -as applicable BMRCDecommissioning Environmental ReportRevision 0 4The Environmental Protection Agency (EPA) provides the federal environmental requirements. The State of New York is under the jurisdiction of the EPA Region II office. The EPA regulations outlined in Title 40 of the CFR apply as follows:Environmental Protection AgencyPart 61 -"National Emission Standards for HazardousAir Pollutants"Part 61 Subpart M -"National Emission Standard for Asbestos" pertaining to asbestos handling, removal, and disposalPart 129 to 132 -Clean Water ActPart 190 -"Environmental Radiation Protection Standards for Nuclear Power Operations"Parts 260-272-Hazardous waste disposal and solid waste disposal as included in the Resource Conservation and Recovery Act (RCRA)1.3.2State of New YorkEnvironmental regulations and policies in the State of New York are codified by the New York State Legislature under Environmental Conservation Law (ECL) and enforced by the Department of Environmental Conservation (DEC). Portions of the ECL may apply as follows:Article 1-General Provisions oTitle 1-Declaration of PolicyArticle 3 -Department of Environmental Conservation; General Functions, Powers, Duties, and Jurisdiction Article 15 -Water Resources oTitle 1 -Short Title; Statement of Policy; Definitions; General Provisions oTitle 5 -Protection of Water oTitle 19 -Drainage oTitle 31 -Groundwater Protectionand Remediation ProgramArticle 17 -Water Pollution Control oTitle 1 -General Provisions and Public Policy oTitle 5 -Prohibitions oTitle 7 -Permits and Certificates oTitle 8 -State Pollution Discharge Elimination System oTitle 14 -Nonpoint Source Water Pollution ControlArticle 19 -Air Pollution Control oShort Title; Declarations of Policy and Purpose; DefinitionsArticle 27 -Collection, Treatment and Disposal of Refuse and Other Solid Waste BMRCDecommissioning Environmental ReportRevision 0 5 oTitle 1 -Solid and Hazardous Waste Management Policy and Planning oTitle 3 -Waste Transporter PermitsPart 364 Waste Transporter Permits oTitle 7 -Solid Waste Management and Resource Recovery Facilities oTitle 9 -Industrial Hazardous Waste Management oTitle 17 -Lead-Acid Battery Recycling oTitle 24 -Environmental Tests Reporting RequirementsArticle 28 -Pollution PreventionArticle 37 -Substances Hazardous or Acutely Hazardous to Public Health, Safety, or the Environment oTitle 1 -Substances Hazardous to the Environment oTitle 2 -Hazardous PackingArticle 54 -Environmental Protection Act oTitle 1 -General ProvisionsArticle 72 -Environmental Regulatory Program Fees oTitle 1 -Declaration of Policy; Definitions oTitle 4 -Hazardous Waste Program FeeWorker protection laws in the State of New York are regulated and enforced by the State of New York Department of Labor. Portions of 12 New York State Codes, Rules, and Regulations (NYCRR) may apply as follows:Asbestos -Part 56 of Title 12 of the Official Compilation of Codes, Rules, and Regulations of the State of New York (cited as 12 NYCRR Part 56)

BMRCDecommissioning Environmental ReportRevision 0 62.0FACILITY DESCRIPTIONThe BMRC is owned by UB and is located on the south edge of the South Campus of UB in the City of Buffalo, New York. See Figure 2.1 for the location of the BMRC as it is positioned on the UB campus.

Thefacility consists of a cylindrical vapor containment building and the attached rectangular administrative wing that is oriented on the long axis to the northeast of the containment building. The reactor is housed within the containment building. The containment building is only accessed for routine technical specification inspections. An ion chamber calibration facility is located in the basement of the administrative wing and the top floor of the administrative wing is utilized as an area for training of UB maintenance and custodial staff.Figure 1: The BMRC and Adjacent Buildings BMRCDecommissioning Environmental ReportRevision 0 7The ReactorThe Containment BuildingThe containment building is a poured reinforced concrete right cylinder, 70 feet in diameter and 52 feet in height. The reinforced concretewalls and roof (supported by concrete beams) are 2feet thick and 0.33 feet thick, respectively. The building walls and the first level are laid on bedrock. The containment building is attached to a laboratory complex formerly dedicated primarily to nuclear science-related research and instruction. The reactor pool is a reinforced high density concrete structure located mostly below grade. The reactor facility, including the control and safety systems, was designed and built by American Machine and Foundry. The reactor first began operation in June 1961 and was originally referred to as the Western New York Nuclear Research Center and subsequently the Nuclear Science and Technology Center (NSTC) of SUNY UB. The reactor was originally fueled with materials-testing-reactor (MTR)-

type fuel elements operating at a maximum steady state power level of 1 MWt. The reactor operated in this mode from 1961 to 1964. The reactor was shut down in 1964 so that core and control systems could be modified. After the modification, the reactor operated with PULSTAR-type fuel at power levels up to 2MWt. The original core grid plate was retained and the MTR fuel elements were replaced with PULSTAR pin-type fuel clusters which were designed to utilize the existing grid space. On May 12, 1965, the reactor was additionally licensed to operate in the pulse mode with a routine energy per pulse of up to 35 MW per second and a maximum size pulse of 44 MW per second. The BMRC operated with PULSTAR fuel since 1965, with one major re-fueling in 1978.The reactor is a PULSTAR heterogeneous open-pool type water-cooled reactor using solid 6percent enriched uranium fuel similar to nuclear power reactor fuel. The core was cooled by forced convective cooling at high power levels and by natural convection at lower power levels. The coolant/moderator is light water, and the reflector may be either water or graphite. The core is immersed in a 13,000-gallon, aluminum-lined reinforced concrete pool. The coolant was circulated through external systems for heat removal and for purification. Former reactor experimental facilities included in-core irradiation positions, a thermal column, beam tubes, pneumatic sample transport systems, a dry gamma chamber, and a gamma irradiation facility.The core was immersed in a 13,000-gallon, aluminum lined tank pool surrounded by both high density and normal density concrete. It was cooled by a 5,000-gallon circulating water system exiting from the reactor pool bottom via pumps to a subsurface 5,000-gallon hold-up tankfor N-16decay. The water then went through a heat exchanger connected to an external cooling tower located on the southeast side of the BMRCDecommissioning Environmental ReportRevision 0 8administrative wing. The cooled water was then circulated back to the top of the pool. After a leak was detected in 1977 where the coolant piping penetrated the bottom of the reactor pool, modifications were made to the cavity lower liner and the piping was rerouted to exit out of the side of the pool and through the lower wall of the Neutron Deck of the containment building. After a leak was detected in 1989 in the liner, a new liner was installed over the original liner in the lower section of the tank. All the spent and unused fuel has been shipped off-site. The reactor and all its associated components remain in the pool in the normal operational configuration as they were during operation.

BMRCDecommissioning Environmental ReportRevision 0 9The Control DeckThe Control Deck (top level) houses a dual-hook overhead crane with a ten-ton and a two-ton hook on tracks at the ceiling level. Crane access to the lower levelswas via floor plates on the Control Deck and a webbing cover on a floor penetration from the Gamma Deck to the Neutron Deck. In addition to the reactor pool, the Control Deck houses the Reactor Control Room (Room 205), the Superintendent's Office (Room 207), two labs (Rooms 202 and 203), the Fan Room (Room 204), another office (Room 206), and an airlock (Room 201B) for access to the upper or first floor of the administrative wing. The New Fuel Storage Room (Room 201A) is located between the inner and outerdoor of the airlock. Figure 2 below provides the layout of the Control Deck.Figure 2: Control Deck Layout BMRCDecommissioning Environmental ReportRevision 0 10The Gamma DeckThe middle level of the Containment Building is called the Gamma Deck. A plan view of the Gamma Deck is shown on Figure 1-4. The Hot Cell, Hot Cell Work Room (Room 105), Locker Room (Room 106), Room 107, Hot Chemical Lab (Room 108), Medium Chemical Lab (Room 104), Activation Analysis Lab (Room 109), Lower Fuel Vault Room (Room 101A), and Chemical Lab (Room 103) are located on the Gamma Deck. This level also has an Airlock (Room 101) for access to the bottom level of the Administration Building and a truck door for access to the asphalt drive located on the southern side of the Containment Building. The Truck Door provides vehicular and equipment access to the outside. Prior to 1979, the Truck Door area housed a waste compaction system. Wastes generated at the BMRC (NSTC at the time) and under the site-wide radiological program were collected and compacted for volume reduction in this system. Figure 3 provides the layout of the Gamma Deck.Figure 3: Gamma Deck Layout BMRCDecommissioning Environmental ReportRevision 0 11The Neutron DeckThe Neutron Deck (lower level) is divided by caging into two sections. The open area includes access to the "Patient Treatment Room" which is lined with wood. The Patient Treatment Room was included in the original design of the BMRC to be a location to provide neutron treatments to cancer patients. No history that it was ever used for this purpose was found. The enclosed area includes the rerouted Primary Coolant Piping and access to the seven Beam Storage Tubes. The Beam Storage Tubes extend 10 feet through the containment building wall into the surrounding soil. They were originally designed to hold the beam tube plugs but were used as storage for decay of high dose reactor components or experiments.

At the point where they exit the containment building wall, they are approximately 10 feet underground.

The balance of the Neutron Deck is open area where the majority of radioactive contaminated materials awaiting disposal are being stored. Figure 4 provides the Neutron Deck layout.Figure 4: Neutron Deck Layout BMRCDecommissioning Environmental ReportRevision 0 12The Upper FloorThe Administrative/Laboratory Wing The administrative wing housed the Locker Rooms (Rooms 209, 221, and 221A), Conference Room (Room 212), offices (Rooms 208, 210, 214, and 216), the Reception Area (Room 208A), Upper Air Conditioning Equipment Room (Room 209B), the Janitors Closet (Room 209A) and two low level labs (Rooms 213 and 215) on the upper floor. The Basement FloorOn the lower or basement floor there was a Horizontal Accelerator (Room 118) with an adjacent cave area. This area has supported multiple functions; including a lab, a Class Room (Room114), a Health Physicist Office (Room 117), Counting Room, The Vertical Accelerator Room (Rooms 115 and 115A), and a Machine Shop (Room 113). The Electrical Service Room (Room 110) is also located on this level.

There is a tunnel off the Electrical Service Room (Room 110) that connects to the Campus Service Tunnel system and is locked to prevent access.

SubbasementThe space below the basement floor level is the area designated as the subbasement. This area has rooms housing the N16 Vault (Room N16), the Cooling Water Equipment Room and the Facility Sumps (Room N03), the lower Air Conditioning Equipment Room (Room N02), the Air Handling Duct Room (Room N04), and access to the 10,000-gallon tank enclosure (Room N05). These rooms house the decay, filtration, and cooling systems for the reactor. Room N03 also contains the 1,000-gallon waste holding tank.

BMRCDecommissioning Environmental ReportRevision 0 133.0ALTERNATIVESThere are four alternatives available to, and considered by, the UB: 1) the No-Action alternative (SAFSTOR); 2) the entombment option (ENTOMB); 3) complete decontamination and structure demolition (DECON-A); and 4) complete decontamination and release of the structure (DECON-B). The DECON options are recommended by the NRC for non-power reactors. The selected alternative is DECON-A. The four alternatives are summarized in the following sections.3.1.1SAFSTOR AlternativeThe SAFSTOR alternative would involve the same potential risks and environmental impacts as the proposed action, but for a much greater time period. The alternative would require that the UB maintain current radiological controls, site security, required licensing, a reactor administrator, and the utilities until the DECON option was implemented. The UB will have to incur all of the expenses associated with maintaining the facility. This alternative would require that the UB apply for and obtain an extension to thecurrent NRC operating license. The SAFSTOR alternative would leave the site as unusable space that will delay the beneficial reuse and the potential for environmental contamination would still exist. This alternative is not environmentally preferable. 3.1.2ENTOMB AlternativeThe ENTOMB alternative would require the same as the SAFSTOR alternative with the additional requirement that the radioactive material is placed in a long-lived structure, i.e., concrete, or the current structure proven adequate for long-term storage. This alternative delays the impacts of the proposed action and the potential for environmental contamination would continue to exist. This alternative is not environmentally preferable.3.1.3DECON-AAlternativeThe facility records and current facility characterization reveal minimal facility contamination from past reactor operations. This alternative requires the site to be released and restored for unrestricted use. The reactor, the containment building, and the administrative building under thisoption will be disassembled and the radioactive material removed to meet the release criteria. The BMRC facility is located in the center of a growing university and the land area could be reused for future construction; therefore, complete decontamination and demolition (D&D) of the BMRC facility, DECON-A, is the preferred option. This alternative poses minimal risk and impacts to the environment as described in Section 8.0.

BMRCDecommissioning Environmental ReportRevision 0 143.1.4DECON-BAlternativeThe DECON-B alternative is similar to DECON-A, however, the structure would not be removed after remediation. The risk and impacts to the environment are the same as DECON-A for this alternative, but the UB has determined that the reuse of the building is not in its best interests. Additionally, a final status survey of the soils and bed rock is more complicated and requires a significantly greater level of surveying and sampling than releasing an open excavation. This alternative is not preferred by the UB.3.2Decommissioning of the Reactor, License Termination, and Site Reuse3.2.1Decommissioning of the Reactor UB plans to decommission the reactor which will require the removal of all radioactive materials from the BMRC facility; dismantling the reactor, the reactor peripheral support systems, and support buildings; and removal of the UST and associated piping, materials associated with the previously demolished cooling tower, and any legacy waste.Some of the reactor components and systems are either activated or contaminated and will need to be segregated from non-radiological components and surfaces. Components and systems that are designated as activated or impacted will be disposed of as low-level radioactive waste (LLRW). Building materials, such as the reactor tanks, will need to be evaluated for radiological activityand removed and disposed of according to their radiological status, as necessary.The following are decommissioning tasks, which are necessary for site release. The sequence in which these tasks occur may vary:Pre-Decommissioning Cleanout -removal of loose legacy equipment and materials Isolation and removal of inactive systemsRemoval of hazardous materials (i.e., lead) and abatement of asbestos containing material (ACM) Perform supplementary characterization Installation of temporary systems and preparation of the facility for decommissioning operations Removal of the irradiated reactor componentsRemoval of and disposition of water in the reactorRemoval of and disposition of the reactor linerDecontamination of concrete associated with reactor, bioshield, and hot and dry cellRemoval of the reactor, bioshield, and hot and dry cellSegregation, packaging and shipment of materials according to radioactivity levelsRemoval of auxiliary systems (rabbit system, water purification, ventilation)Decontamination of building surfacesInterior release survey using Reg Guide 1.86 limitsDemolition of the BMRC facility Perform the FSS on BMRC footprint BMRCDecommissioning Environmental ReportRevision 0 15Submit required reports that demonstrates to the NRC that the facility meets the release requirementsRequest license R-77 terminationRestore the site by backfilling the void created by removing below grade structures for future use by UB.The BMRC has been in Possession Only status since June 1997 and the spent fuel was removed from the site in 2005. The on-sitedecommissioning tasks are expected to start date in the second half of 2012.The FSS will be developed by the Design and Oversight Contractor (DOC) using the criteria provided in NUREG-1575,Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (NRC 2000)

.Radiological measurements identified in the Characterization Report indicated that the typical levels of residual radioactive materials on the building surfaces are less than release criteria established by the NRC in Regulatory Guide 1.86. Residual radioactive materials were only found in areas indicated by the Historical Site Assessment. Soil samples indicated that only limited remediation of soils will be required outside of the facility. Radionuclides above derived concentration guideline levels (DCGL) were detected in the N-16Vault, which does not have a concrete floor covering the bedrock. The N16 Vault is identified on Figure 4. The structures and components that contain the majority of the residual radioactive materials are the activated reactor components and bioshield, the former and current liquid waste tanks, and the reactor water cooling system. Residual radioactive materials were also identified in the Hot Cell and laboratory fume hoods. Since all BMRC structures, systems, andcomponents will be removed from the site, the FSS will only need to cover the exposed surface soils. 3.2.2LicensesThe BMRCmaintains NRC license No. R-77 for Possession Only. Recently in 2011, the BMRC'sSpecial Nuclear Material (SNM) License No. SNM-273, for possession of a Plutonium-Beryllium (PuBe) neutron sourcewas terminated and the PuBe source transferred to the University's New York State Department of Health (NYSDOH) radioactive material license, No. 1051. The scope of the NYSDOH license is for possession of sources and for decommissioning.The R-77 license is to be terminated as part of the decommissioning. The MARSSIM NUREG-1575provides guidance to assemble a statistically accurate FSS plan to support the termination of the NRC license. The NYSDOH license will have all sources transferred to another NYSDOH license at UB. The SNM license will have a request for license termination submitted after the NYSDOH license is amended in order to transfer the PuBe source.3.2.3Reuse of SiteThe site is expected to be reused as either green space or a future road.

BMRCDecommissioning Environmental ReportRevision 0 163.3Cumulative EffectsThe cumulative effects of the implementation of the proposed action will result in short-term cumulative impacts as discussed in Section 5.0 of this ER.3.4Comparison of the Predicted Environmental EffectsThe following table provides the predicted environmental effects and impacts of the alternatives that were evaluated for this ER. More detailed information on the expected impacts can be found in Section 5.0 of this ER.Affected EnvironmentNo ActionProposed ActionLand UsePossible ImpactPossible ImpactTransportationNo ImpactsPossible ImpactGeology and SoilsPossible ImpactPossible ImpactWater ResourcesNo ImpactsNo ImpactsEcological ResourcesNo ImpactsNo ImpactsMeteorology, Climatology and Air QualityNo ImpactsPossible ImpactNoiseNo ImpactsPossible ImpactCultural and Historic ResourcesNo ImpactsNo ImpactsVisual/Scenic ResourcesNo ImpactsNo ImpactsSocioeconomicNo ImpactsNo ImpactsEnvironmental JusticeNo ImpactsNo ImpactsPublic and Occupational HealthNo ImpactsPossible ImpactWaste ManagementNo ImpactsPossible Impact BMRCDecommissioning Environmental ReportRevision 0 174.0DESCRIPTION OF THE AFFECTED ENVIRONMENTThe following sections describe specific areas of the environment that may be affected because of the decommissioning activities.4.1Land Use The BMRC is a stand-alone structure located on the south edge of the South Campus of UB. The structure is comprised of two distinctively different architectural components, the containment building and the attached administrative wing. The containment building is a three-story right cylinder constructed of concrete, 70 feet in diameter with a height of 52feet. The reactor is located within the three-story cylindrical building. The former core was immersed in a 13,000-gallon, aluminum-lined tank pool surrounded by both high density and normal concrete. The cylindrical building walls and the lower level of the containment building rest directly on bedrock, the exterior walls are poured concrete finished with paint, and the roof of the cylindrical building is four-inch thick reinforced concrete supported by concrete beams. Interior floors are poured concrete with the Neutron Deck formed of two courses of concrete with a finish course of about 1.25 inch thickness, and the Gamma and Control Decks are monolithic. Select floors in the administrative building are formed of terrazzo, mosaic tile, or resilient floor tiles. Ceilings in select areas may be formed of acoustic tiles of varying sizes resting on ametal grid system suspended with metal hangers. The administrative wing is comprised of three levels, the Upper Floor, the Basement Floor, and the Foundation Level. The administrative wing was originally constructed for office, laboratory, utility rooms,and classrooms for activities conducted with and/or for the reactor. The exterior walls are formed of load-bearing concrete masonry blocks and are finished with a brick façade. Interior floors primarily consist of nine-inch by nine-inch vinyl asbestos floor tiles adhered to the slab with adhesive. Walls are formed of painted masonry block and finished with paint. The Tank Farm lies in the subsurface area south of the containment building and extends towards the southeast of the containment building. The Tank Farm consists of two 250-gallon stainless steel tanks and two 600-gallon stainless steel tanks in connected concrete enclosures. There is also a 10,000-gallon carbon steel tank outside of the enclosures to the east. The 250-gallon tanks were connected to the Isotope Processing Labs and the Hot Cell and the 600-gallon tanks supported the drains from the lower level labs and the floor drains. The tanks were interconnected by a manifold and pump system that allowed any The Tank Farm BMRCDecommissioning Environmental ReportRevision 0 18combination of water transfer. The normal movement was to pump the small tanks to the 10,000-gallon tank prior to discharging to the sewer system. The 10,000-gallon tank sits on concrete saddles inside a concrete bermed area. The enclosure and the 10,000-gallon tank are beneath3-4 feet of soil.4.2Transportation The BMRC is located in a relatively moderate to high traffic area in the northeastern section of the city limits of Buffalo, New York. Surrounding areas are largely residential. A recent traffic congestion study by INRIX,as reported by a local Buffalo television station, indicated that while traffic congestion in Buffalo is better than the national average, it has increased from 2009 to 2010 faster than the national average. In Section 3.0, Highway System Profile of a Niagara Frontier Urban Area Freight Transportation Truck study indicated that the region has a total of 3,675 miles of highway network, including major interstates, state routes, and local arterial roads. The major interstate highways that service Erie and Niagara counties included Interstate 90, Interstate 190, Interstate 290, and Interstate 990. The local streets will be utilized to transport radioactive waste and construction debris associated with the decommissioning and demolition of the BMRC. Interstates90 and 190 are less than five miles from the site and will likely be utilized as transport routes to the eventual disposal destinations.4.3Geology and SoilsThe City of Buffalo is located within the Niagara Region, a section of a great plain that extends north to southfrom the Laurentian Highlands (Canadian Shield) approximately 161 kilometers north of Toronto, Ontario to the Southern Allegheny Plateau. This plain is a small portion of the Great Lakes low lands within which all of the Great Lakes are located. Within the Niagara Region is located the Niagara Escarpment, the weathered edge of an ancient sea bottom extending roughly from Watertown, New York westerly through Illinois and Wisconsin. The Escarpment is neither a fault line nor a rift line, but is instead an erosional feature classified as a cuesta, a ridge with a gentle slope on one side and a cliff on the other.(NUREG-0982)A smaller escarpment, the Onondaga Escarpment, often referred to as the Onondaga Cuesta, trends east to west located along the northern shore of Lake Erie. The escarpment is capped with the Onondaga limestone. The SUNY campus is located on the extreme edge of the Onondaga Cuesta. The cuesta faces the northwest and has a local relief of 80 feet. The southeastern portion of the campus is located on the dip slope of the cuesta. In general, the area within which the City of Buffalo is located is very flat with the exception of the Onondaga Cuesta. As a result, local streams are slow moving and widely spaced.

(NUREG-0982)

BMRCDecommissioning Environmental ReportRevision 0 19The bedrock of the area consists of Silurian and Middle Devonian marine shale, dolomite and limestone with a southerly drop of 50 feet per mile. The rock formation is a joint system consisting of two joint sets arranged in a north-south east-west configuration intersecting at approximately 90 degrees. This is underlain by a similar marine series of Ordovician and Cambrian age to a depth of 3,000 feet that rests on a pre-Cambrian deposition. (NUREG-0982)The overburden from the bedrock to the surface averages about 15 feet in the area of the BMRC. The soil proper occupies the first 14 inches with subsoil, which is made of dense boulder and clay extending uniformly to the bedrock. The soil from the surface to a depth of nine inches consists of moderately compacted, brown-gray, heavy, silty clay loam. Beneath this is a roughly five-inch stratum of compact dull yellowish-brown silty clay with a considerable amount of fine pebbles. The layer below this is made up of dull brown clastic, heavily compacted, silty clay containingcrystalline pebbles dispersed throughout. This clay material extends to bedrock without any significant change. (NUREG-0982)The data in this section was collected during initial licensing and design of the BMRC. The primary sources of information for this section is the reactor's Safety Analysis Report and NUREG-0982,Safety Evaluation Report related to the renewal of the operating license for the Research Reactor at the State University of New York at Buffalo.More recent drilling on the south campus in 2008 and 2009, supports the above description of the area geology and soils.4.4Water ResourcesThe City of Buffalo is located along the eastern end of Lake Erie. Water comes from Lake Erie into an intakeout in the lake and flows through a 12-foot by 12-foot conduit to the Colonel Ward WaterTreatment Plant and out to the city through 800 miles of pipe controlled by 25,000 valves. The system supplies an average of 99 million gallons per day to 82,000 service connections and 7,600 fire hydrants. A peak supply of 127.8 MGD was reached in 2001. This capacity is adequate to satisfy foreseeable future demands. Water quality is good andcomplies with all regulations. Four miles east of the campus at Williamsville is Elliot Creek, which flows north to an unnamed creek that has its headwaters approximately two miles north of UB campus. There are no other streams in close proximity to the BMRC. The nearest water access is Lake Erie, which is five miles to the southwest of the BMRC site. The Niagara River, on which Niagara Falls lie, is 4.6 miles to the southwest while Lake Ontario is approximately 30 miles from the facility. These bodies of water are not anticipated to be impacted by any activities at the BMRC.The UB campus is located along the edge of the Onondaga Cuesta, which trends from the southwest to the northeast. The southeastern portion of the campus is positioned on the down slope side of the cuesta.

BMRCDecommissioning Environmental ReportRevision 0 20With the exception of the cuesta, the general area is relatively flat. As a result, streams are slow moving and widely spaced apart. In the immediate area of the BMRC, stormwater run-off flows generally towards the south where it is collected by a stormwater management system and eventually routed to the sewage treatment plant on campus. There are no streams in the immediate vicinity of the BMRC. The slope of the adjoining land and the drainage path near the building will not permit accumulation of water around the building. There are no credible paths for reactor pool water to get into the campus water system, however surface water run-off is routed towards the UB sanitary sewer system. There are no surface water features in the immediate vicinity of the reactor. The nearest surface water feature is a small pond 0.6 miles south of the BMRC located in McCarthy Park.The density of the clay soils does not allow percolation of water into the sub-surface. For all practical purposes, surface water penetration ceases below a depth of 13 inches. Water will move through the saturated and undisturbed material in the first eight inches of topsoil at an average rate of 0.02 to 0.2 inches per hour. In the next five-inch layer, the penetration decreases sharply to zero. The underlying Onondaga and substrata are not known to contain water in the immediate vicinity, but it is notimpervious. Based on observations several miles east of the campus, the water was presumed to move to the escarpment edge. Water movement within the overburden including the soil proper is extremely slow.

Only within the first 13 inches water percolation takes place very slowly, 0.2 inches per hour. In the next 15 feet, permeability ceases for all practical purposes. Surface water flows in a southerly direction into established storm drains.(NUREG-0982)4.5Ecological ResourcesThe BMRC is located within a well-developed area where virtually all flora consist of species introduced for landscaping of residential, commercial, and educational facilities. The likelihood of endangered native species of plants is very small. Any native fauna would consist primarily of small, nocturnal animals not likely to appear on any endangered species list. The DEC website for endangered species did not list any insects as endangered or threatened in Buffalo, New York.4.6Meteorology, Climatology, and Air QualityBuffalo experiencesa fairly humid, continental-type climate, but with a definite "maritime" flavor due to strong modification from the Great Lakes. Lake Erie lies to the southwest of the facility and functions to moderate the temperatures. The average temperatures measuredat the Buffalo International Airport range from 18degrees to 80 degrees Fahrenheit (F) with extremes recorded of -20 degrees and 99 degrees F. Annual rainfall averages 38.5 inches in the Buffalo area and snowfall averages 93.3 inches per year.

BMRCDecommissioning Environmental ReportRevision 0 21Winters inWestern New York are generally cloudy, cold, and snowy but are changeable and include frequent thaws and rain as well. Over half of the annual snowfall comes from the "lake-effect" process and is localized. Due to the prevailing winds, areas south of Buffalo receive much more lake-effect snow than locations to the north. As the prevailing airflow is mostly southwesterly, areas near the lake are often as much as 20 degrees colder than inland locations. The cool lake waters act as a strong stabilizing influence, so areas near the lakeshore, which includes the City of Buffalo, experience more sunshine and fewer thunderstorms than inland areas. Summer is also influenced by the stabilizing effect of Lake Erie. It inhibits thunderstorms and enhances sunshine inthe immediate Buffalo area. The lake also modifies the extreme heat that approaches from the Ohio Valley. Tornados are rare in Buffalo; the Weather Channel website reports that only 19 tornados have struck the vicinity of Buffalo from the period 1950 to 2009.4.7NoiseThe BMRC is located within an academic setting and noise is typically at a low level. At the time of the drafting of this document, renovation activities were occurring at a nearby structure. The Environment,Health and Safety Department (EH&S) of UB SUNY has issued guidance for noise in their Contractor Safety Guidebook, Document Number SA-023-A, August 25, 2009. Section 9.0 instructs contractors to keep work areas as quiet as possible when the work is proximal to buildings within which class activities are occurring. The UB SUNY project manager or the EH&S can temporarily halt work activities that cause noise at a level that affects classrooms activities.The Common Council of the City of Buffalo has issued an ordinance to regulate the level of noise within the city under Chapter 293, Noise, August 13, 1990. Section 293-4 states the following regarding construction:I.Construction activity.(1) The performance or engagement in construction work, building, excavating, hoisting, grading, demolishing, dredging or pneumatic hammering within the limits of the city between the hours of 9:00 p.m. and 7:00 a.m. that causes sound which annoys or disturbs a reasonable person of normal sensitivities in a residential real property zone, except for emergency work of public service utilities or as otherwise provided in Subsection I(b) herein[is prohibited].

BMRCDecommissioning Environmental ReportRevision 0 224.8Cultural and Historical ResourcesThe Buffalo Preservation Board maintains a website with detailed information on various historic districts within the City of Buffalo. The Board is an agency of the City of Buffalo and is administered by the City of Buffalo Office of Strategic Planning. Nine historic districts are listed as either Certified Local Preservation District or National Register Historic Districts. Maps for each of the districts are available for viewing on the website. After viewing the maps, it was determined that the UB South Campus is not located in any of the historic districts. The nearest historic district was the Hamlin Park Local Preservation District.The historic district known as Hamlin Park is located approximately two miles south-southwest of the BMRC. Hamlin Park developed during the first 25 years of the 19 thSeveral buildings of historical significance are located within the city limits of Buffalo. A select few worthy of mention include Buffalo's City Hall which opened in 1931; St. Paul's Episcopal Cathedral, originally built in the mid-19century as a textbook zone of emergence. The name of the area is derived from a former horse racing park, Hamlin's Driving Park, which opened in 1858. The owner of the track, Cicero Hamlin, once touted a race as the Kentucky Derby of the North. Following Cicero Hamlin's death in 1905, Hamlin's racing park lay dormant. After several fires and years of neglect, this three hundred acre parcelof scruffy and largely vacant land lay empty and unused until 1912, when it was bought by a Toronto real estate developer. Homes were developed for the middle class and quickly sold. By the late1950's and early 60's, Hamlin Park had changed. A transition had occurred as middle-class African-Americans moved in and in the process created the best and the nicest African-American neighborhood in Buffalo. In 1999, the area was officially designated as a Historic District.

thThe UB South Campus, also known as the Main Street campus, is the former grounds of the Erie County Almshouse and Insane Asylum, of which four buildings remain (Hayes Hall, the former insane asylum; Wende Hall, a former maternity hospital; Hayes D; and Townsend Hall, a former nurses' quarters). The four buildings were constructed during the mid to late 1880s. The college was designed by architect E.B.

Green in 1910 and was originally intended to resemble Trinity College in Dublin, Ireland. Although these century and re-built 40 years later after a fire; and the Theodore Roosevelt National Historic Site, the site of the emergency swearing in as president of Theodore Roosevelt following the assassination of President William McKinley in Buffalo in 1901.The Buffalo Preservation Board lists 89 local Buffalo Landmarks, and 77 state and regional registers within the Buffalo city limits.

There were no sites listed that correlated with addresses or buildings located on or near the South Campus BMRCDecommissioning Environmental ReportRevision 0 23structures are ofa sufficient age and historical significance, they are not listed on any documents for local, state, or national historical recognition.4.9Visual/Scenic ResourcesThe BMRC is located in the southeastern section of the UB South Campus. The campus is within an area of heavy residential neighborhood to the south, west, and north. The Veterans Administration Hospital is to the southeast and a golf course is located to the northeast. Some commercial development is present north of the South Campus.The BMRC is located within what would be classified as a foreground-middle ground zone by the BLM Visual Resource Inventory and Evaluation System. Local residents would rarely glimpse the structure as it is positioned such that the view from the south, southwest, and southeast is obscured by other campus buildings. The population most likely to view the BMRC on a regular basis is the student population. It is unlikely that most students would feel a negative aesthetic impact during the demolition of the BMRC or after thestructure is removed.4.10SocioeconomicBuffalo is the second most populous city in New YorkStatewith an estimated 261,310 residents (2010 Census). The city has seen a steady decline in population numbers since peaking at around 580,132 residents in 1950. The decline has come about because of the loss of industrial base but researchers of the population indicate that the population decline may have finally stabilized. Based on the 2005-2007 American Community Survey Estimates, the population was 53% white, 41% black or African American, 1% American Indian and Alaska Native, 2% Asian, 4.5% of another race and 2.5% from two or more races. Buffalo has sizeable populations of Irish, Italian, Polish, German, Jewish, Greek, Arab, African American, Indian, and Puerto Rican descent.The nearest private residences that are not under UB control are approximately 450 feet south of the BMRC. The nearest private residences in the direction of the prevailing southwest to northeast winds that are not under UB control are approximately 3,700 feet northeast of the BMRC. There are no heavy industrial facilities near the South Campus. The nearest airport, Buffalo Niagara International Airport is approximately 4.5 miles east-southeast of the campus. The intersection of Interstates290 and 90, major highways in the area, are approximately 2.5 miles east of the campus. An Amtrak passenger station is located approximately 5 miles south-southwest of the BMRC. Freight by rail is offered by CSX, Norfolk Southern, Canadian Pacific, and Canadian National in the Buffalo area. The United States Coast Guard BMRCDecommissioning Environmental ReportRevision 0 24Auxiliary, Flotilla 3-3, 9 thA May 1983Safety Evaluation Report related to the renewal of the operating license for the Research Reactor at the State University of New York at Buffalo drafted by the United States Nuclear Regulatory Commission was reviewed as part of this report. The Report indicated that no heavy industry, heavy air or ground traffic would constitute an external threat to the integrity of the reactor facility. The report concluded that there was no significant risk from accidents to the reactor because of activities related to the military, industry, or heavy transportation traffic. Since the drafting of the 1983 report, the major interstates I-90 and I-290 have been added to the region to the east, northeast, and southeast of the BMRC. No other significant changes have occurredsince 1983 that would alter the conclusions of the report. The addition of the interstates to the area is not considered a significant risk to the reactor at the BMRC.District, Eastern Region is located 6.25 miles southwest of the campus. There are no other major military bases or facilities in the Buffalo region. 4.11Public and Occupational HealthPublic and Occupational Health activities associated with the current operations of the BMRC include the following:All of the spent fuel was shipped to the Department of Energy (DOE) in September 2005 and the unused fuel was sent to North Carolina State University in July 1998. Radiation exposures from the former reactor core are reduced to acceptable levels by water and concrete shielding. The Primary Coolant heat exchanger was removed and disposed of as radioactive waste in 1994. The containment building hadasignificant amount of legacy waste on all three levelsuntil the Pre-decommissioning Cleanout project in the summer of 2011. All of the reactor components remain in the pool and the components from the 1991 reactor rebuild werestored under shielding on the Neutron Deck of the buildinguntil they were sent for burial at the EnergySolutions' facility in Clive, UT during the Pre-decommissioning Cleanout Project.

There are no regularly scheduled activities within the containment building.Containment Building/ReactorENERCON conducted a Historical Site Assessment (HSA), and released a report with findings on March 17, 2010. The HSA reported that events and operations have transpired that have impacted the containment building. The roof, interior and all the systems and structures in the building are designated as Impacted Areas. These areas and/or components have been designated as impacted due to elevated levels of residual radioactive materials or the potential for the presence of residual radioactive materials and are expected to require, in part or whole, remediation and/or disposal at an NRC licensed disposal BMRCDecommissioning Environmental ReportRevision 0 25facility. The HSA reported that the primary contaminants of concern for the entire BMRC site were H 3 , C 14 , Mn 54 , Co 58 , Co 60 , Eu 152 , Eu 154, Ag108m, Ag110m, Sb 124 , La 140, and Ni 63. Since the plant has been shutdown since June 23, 1994, the Co 58 , Sb 124, Ag110mand the La 140ENERCON conducted a site characterization study and released a Site Characterization Report (SCR), on May 30, 2011. The study did not include the activation of reactor components and the pool liner. The SCR offered the following findings:have decayed significantly due to their short half-life. The HSA concluded with a recommendation that scoping/characterization surveys be conducted for the containment building.Control Deck:

oMany areaswere being used to store legacy radioactive wastes. The elevated background from the radioactive material storage areas made it difficult to determine the presence of residual radioactive materials on building surfaces in these areas. However, the limited radiological measurements collected in the areas of the Control Deck did not identify removal or fixed radiological activity. Therefore, it seems reasonable to conclude that the building surfaces in these areas are not contaminated. Additional testing for confirmation of this conclusion will be performed when all legacy radioactive wastes are removed from the area.

oRoom 202 was the location of a strontium-90 (Sr-90)release that contaminated areas of the walls adjacent to the California hood. Sections of Plexiglas have been affixed to the walls to afford temporary shielding from the strontium.Gamma Deck oMost rooms on the Gamma Deck are currently being used to store radioactive waste, making characterization of building surfaces difficult. Additional testing of building surfaces will be performed subsequent to the removal of all items from the area. All items inside the Hot Cell, including the Hot Cell, should be considered radioactive waste.Neutron Deck oThe Neutron Deck is the area where the majority ofradioactive waste materials awaiting disposal are currently stored. Subsequent to the removal of all radioactive material, a more detailed investigation of the building surfaces will be performed.

oConcrete cores of the floor were collected at six locations. Coring confirmed that the concrete was originally poured directly onto bedrock. Because a sand or gravel layer was not placed on top of the bedrock prior to pouring of the concrete, no preferential pathway exists between the Neutron Deck and the bedrock. The analytical results of the testing indicated background levels for the evaluated radionuclides.

oConcrete cores of the bioshield were collected at six locations. The data from the testing indicates measureable radioactivity due to neutron activation incertain areas exceeds 12 inches in depth.

BMRCDecommissioning Environmental ReportRevision 0 26The administrative wing also has radioactive materials stored in various areas. In addition, the UB radiological instrument calibration facility is located in the Laboratory Wing. The administrative wing is used infrequently for two purposes. One purpose is an ion chamber calibration facility that is located in the basement of the administrative wing. Secondly, the top floor has asbestos-containing floor tile in some areas. The UB Maintenance Department uses this floor to train maintenance and custodial personnel how to safely strip and wax this type of floor tile.Administrative/Laboratory WingBased on the HSA, dated March 17, 2010, events and operations have transpired that have impacted the administrative wing. The roof, interior and portions of the systems and structures in the building are designated as Impacted Areas. These areas and/or components have been designated as Impacted due to elevated levels of residual radioactive materials or the potential for thepresence of residual radioactive materials and limited portions are expected to require remediation and/or disposal at an NRC licensed disposal facility.The ENERCON SCR offered the following findings:Control Deck oRooms 208, 208A, 209, 209A, 209B, 210, 212, 213, 214, 215, and 216 showed no elevated measurements of residual radioactive materials. Gamma Deck oRooms 110, 111, and 113 showed no elevated measurements of residual radioactive materials.

oRooms 114, 115, 115A, 117, and 118 contain radioactive materials. These spaces may receive additional surveyssubsequent to the removal of radioactive materials.Sub-Basement oRoom NO3 contains a 1,000-gallon tank containing six inches of sludge with elevated levels of radioactive materials.

oRoom N16 contains a 10,000-gallon tank internally contaminated with radioactive materials.Soil samples characterized for radionuclides outside the facility indicated that remediation of soil willnot be necessary.Exterior Sub-Surface BMRCDecommissioning Environmental ReportRevision 0 27The laboratory analysis of samples collected from each of the five tanks indicated that elevated levels of radionuclides are present in the waste tanks. The liquids will require proper handling to ensure radioactive materials are not released to the environment. The water volume in each tank is 75-100% of their maximum capacity.Tank FarmThe tank farm has sample tubes that extend down outside of the tank to the bottom of the enclosure and the bottom of the concrete berm. These sample tubes, known as "tell-tale" samples, have not indicated any major leaks from the tanks.Testing of dirt and debris on the bedrock in the N16 Tank room indicated impacts greater than the NRC and New York State (NYS) screening values for Co-60. Ag-108m was elevated and has a high potential to be greater than the DCGL's stated inthe decommissioning plan.N 16 Tank VaultWater and sediments were collected for characterization from the 1,000-gallon tank located in Room N03. The tank sediments contained elevated levels of the radionuclides Co-60, Ag-108m, Ni-63, and Sr-90. The water sample contained Ni-63.1,000 Gallon TankSources of radiation within the BMRC wereassociated primarily with legacy wastes stored in a variety of areas in both the administrative wing and the containment Building. The reactor is inoperable and all fuel and spent fuel have been shipped from the site. There are currently no regularly scheduled activities within the BMRC except for occasional training and routine inspection. UB has developed written policies that ensure that authorized persons only are allowed into the BMRC. An intrusion alarm system has been installed and is operational any time the BMRC is unoccupied. The alarm system is checked on a weekly basis. Extraneous SourcesUB has developed a written monthly and quarterly check sheet to ensure that failsafe systems are operational within the BMRC. Systems inspected and calibrated include, but are not necessarily limited to, the Building Gas electronics, Building Particulate electronics, the Control Deck Continuous Air Monitor (CAM), and theemergency damper closure time in response to a manual damper scram.

Groundwater samples are collected from the underground wastewater vaults on a monthly basis to test for radionuclides.

BMRCDecommissioning Environmental ReportRevision 0 28According to UB EH&Sstaff, approximately ten totwelve UB employees are required to wear personalThermoluminescent dosimeters (TLD) during activities in the BMRC. The personnel badges are analyzed on a quarterly basis. The EH&Sstaff report that personal exposures are less than the minimum reportable dose of 10 mremper sampling period. TLDs are also placed at various interior and exterior locations to monitor the general areasof the BMRC. The TLDs are submitted to a testing laboratory for analysis on a monthlybasis. The exterior TLDsread0 to 4 mrem abovebackground levelsper reporting period. The analytical results of the interior TLDs typically range from 0to 2 mremper month, however,the TLD positioned on the bridge over the reactor poolyieldsthe highest readings of 3to 7 mremperperiod.Routine MonitoringA1963 report on Environmental Monitoring Program for Western New York Nuclear Research Center Inc. and UB was available for review. The report detailed environmental monitoring of the former BMRC and surrounding area beginning on March 1, 1961. Sampling for radioactivity was performed on surface water, soil, vegetation, air, and atmospheric fallout. The report concluded that activities at the nuclear research facility had not caused any detectable increase in the radiation background of the environment.4.12Waste ManagementA Waste Management Plan (WMP) will be implemented for the disposal of the waste generated during the BMRC D&Dproject. The WMP will include detailed guidance for the characterization, sampling, classification, segregation, handling, packaging, manifesting, transporting and disposal of all waste categories.ENERCON performed a waste study for the BMRC of the legacy waste items and released a report dated December 2009, Study to Determine Quantities, Types, and Disposition of Waste at the Buffalo Materials Research Center. The waste study divided all of the materials that will eventually require disposal into five potential treatment categories. These are as follows:Items for on-site survey and unrestricted release (free release)Bulk Survey forRelease (BSFR)Off-site ProcessingLead ProcessingDirect DisposalThe waste study discusses the five potential treatment categories in depth and the reader of this report is referred to the waste study for additional detail, if needed. The legacy waste was removed during the Pre-Decommissioning Cleanout. The R-77 license authorizes the licensee to ship radioactive material.

BMRCDecommissioning Environmental ReportRevision 0 295.0ENVIRONMENTAL IMPACTSThe following sections describe the potential environmental impacts that may result from the decommissioning activities of the BMRC.5.1Land Use ImpactsLand use impacts are expected to be significant during the decommissioning activities. The construction activities involved during decommissioning will require the removal of all radioactive materials from the BMRC,dismantling the reactor and any peripheral support systems, removal of UST and associated piping, removal of materials associated with the previously demolished cooling tower, demolition of both wings and removal of any waste. Following the decommissioning, the site will be returned to usable space by backfilling the void created to match the normal grade of the surrounding areas. Any further land use impacts are expected to be minimal. 5.2Transportation ImpactsThe primary project impacts to the environment from transportation would occur when various forms and quantities of radioactive, nonradioactive, and hazardous wastes are shipped from the BMRC facility during decommissioning activities. During transport, all materials are to be effectively packaged toprevent significant radiation or other impacts external to the truck. Thus, the primary impacts are accident risk and emissions/noise from the trucks themselves. The dose consequence from transportation accidents occurring with radioactive waste could be higher than the contamination accident scenarios described in Section 5.6 and Section 5.12.2 because high-activity reactor components could be involved. As such, there is a potential for a moderate dose consequence of between one and 25 mrem for the public following a transportation accident. However, adherence to NRC and DOT radioactive material packaging and transportation requirements is considered a sufficient control measure for mitigating transportation-related incidents. Local streets will be utilized initially to transport radioactive waste and construction debris associated with the decommissioning and demolition of the BMRC. Interstates 90 and 190 are less than five miles from the site and will likely be utilized as transport routes to the eventual disposal destinations. Therefore, it is expected that there will be minimal transportation impacts due to increased trucking activity during the decommissioning activities.

BMRCDecommissioning Environmental ReportRevision 0 305.3Geology and Soils ImpactsBased on the Site Characterization results three (3) samples collected from the N16 room in the sub-basement indicated impacts greater than the NRC Screening values for Co-60. Additionally, Ag-108m was elevated and has a high potential to be greater than the DCGL developed as part of the Decommissioning Plan. The impacted dirt and debris will be removed during the decommissioning activities. Therefore, it is expected that there will be no geology or soil impacts as a result of decommissioning of the BMRC.5.4Water Resources ImpactsENERCON anticipates that therewill be no impact to water resources as a result of decommissioning of the BMRC. All water generated as a result of the decommissioning of the BMRC will be contained and disposed of in accordance with all UB, federal, state and local regulations. No waterother than water mist for dust controlwill be introduced to the subsurface environment or into the natural environment outside of the facility. No water will be discharged to the stormwater system, unless it has been sampled to verify it is within regulatory limits. 5.5Ecological Resource ImpactsNo ecological resource impacts are expected, as all work will be performed within the BMRC. Potential lay down areas for equipment will only be placed in developed areas. Decommissioning the reactor would have no impact on amphibians, reptiles, birds, fish, mammals or threatened species. 5.6Air Quality Impacts The decommissioning activities could minimally impact the air quality near the BMRC from both stationary and mobile source emissions. A small increase in mobile source emissions, such as carbon monoxide and nitrogen oxides, could be released from contractor's trucks and cars. Due to the temporary nature of the decommissioning activities, effects from mobile source emissions would be low. Stationary emissions from the decommissioning activities could occur during demolition and soil remediation activities. The emissions from the building demolition, subsurface material excavations and general construction work are expected to be minimal. All applicable dust control measures will be implemented as part of the decommissioning construction activities. Standard asbestos abatement procedures implemented by a contractor licensed by the State of New York will be used to remove any BMRCDecommissioning Environmental ReportRevision 0 31asbestos-containing materials. Site workers would be protected during decommissioning activities through air monitoring and the use of air purifying respirators when required. An uncontrolled release of airborne radioactivity could occur during cutting and demolition activities involving activated materials. Such activities may take place inside temporary containment structures equipped with high-efficiency particulate air (HEPA) filter ventilation systems or other systems, if applicable. The failure of a containment structure could result in the release of airborne radioactive materials into environment. Therefore, an alarming CAM will be used in the work areas to warn against the release of airborne radioactivity.While the actual concentrations of airborne radioactive materials are unknown at this time, the doseconsequence of an uncontrolled release is expected to be low (<1 mrem off-site impact and < 25mrem to on-site workers). As such, safety management operations (standard engineering and administrative controls) are sufficient for protection against such accidents. 5.7Noise Impacts Noise impacts during the decommissioning of the BMRC are expected to be those associated with normal construction activities. The UB project manager or the EH&Scan temporarily halt work activities that cause noise at a level that affects classrooms activities. The construction activities will take place between 7:00 am and 9:00 pm to ensure compliance with the City of Buffalo noise regulations.5.8Historical and Cultural Resources ImpactsThe decommissioning and demolition of the reactor and support facilities is not expected to have any historical or cultural impacts.5.9Visual/Scenic Resource ImpactsVisual/Scenic Resource impacts associated with decommissioning are primarily visual and relate to the structures andvisual attributes of the decommissioning site. The impact of decommissioning on site aesthetics (e.g., truck traffic, demolition, noise) is limited in duration. Therefore, any impacts are temporary and are expected to be minimal.5.10Socioeconomic ImpactsNo socioeconomic impacts are expected from the decommissioning of the BMRC.

BMRCDecommissioning Environmental ReportRevision 0 325.11Environmental JusticeHigh and adverse health, economic or environmental effects to local low-income and minority populations characterize environmental justice. There is no reason tobelieve that low-income or minority populations would be affected by BMRC decommissioning.5.12Public and Occupational Health Impacts Nonradiological and radiological impacts from decommissioning activities are expected to be minimal. The work associated with nonradiological and radiological controls will be conducted within approximately 150 feet of the UB property boundary and within 450 feet of the nearest residential area.

Figure 5, on the next page, identifies the BMRC location in association with the property boundary and the nearest fulltime resident.The following sections describe the potential nonradiological and radiological impacts associated with the decommissioning activities.5.12.1Nonradiological ImpactsAs part of the decommissioning process nonradiological impacts will be associated with the removal of any general building materials and asbestos in the decommissioning area. The removal of asbestos containing materials will be conducted in accordance with applicable state and federal regulations.

Removal of general building materials and debris will be conducted utilizing industry standard controls and applicable state guidelines. 5.12.2Radiological ImpactsThere is a potential for radiological accidents during the BMRC facility decommissioning project resulting from the uncontrolled release of radioactive materials to the work area or the environment.

These releases are most likely associated with the mismanagement of contaminated liquids in the waste tanks. Uncontrolled releases of airborne contamination could also occur during the demolition of the reactor tank and segmentation of the activated bioshield. An uncontrolled release of radioactive material could also occur during a transportation accident.The proper handling of the waste liquids by draining the tanks prior to moving them is deemed adequate to prevent uncontrolled release. The demolition of the reactor tank and the segmentation of the bioshield shouldbe conducted inside containmentwith HEPA filtration to help prevent an unplanned release to the environment. The accidental dropping of an activated reactor component was also considered as a potential accident. However, because the more highly activated components are located under water and the water is BMRCDecommissioning Environmental ReportRevision 0 33purified, the surface contamination on these parts is minimal and would not release significant quantities of radioactive materials during such an incident. Such an incident would most likely result in additional external exposures. The airborne release fraction from dropped metal or soil removal is relatively low.

Very minimal amounts of soil are expected to require remediation and removal from the site.A fire is another possible source of an uncontrolled release of radioactive materials. However, the majority of the combustibles that will be present onsite will be clean materials. Potentially contaminated combustibles may include dry active waste such as personal protective clothing, rags and towels used for site cleanup and decontamination. The radioactivity contained in these materials would not be high enough to result in a significant release during such an incident. There will be no fissile materials located on the site that could result in a criticality incident because all nuclear fuel has been removed. 5.13Waste Management ImpactsThe BMRCdecommissioning will generate soil LLRW, mixed waste (i.e., contaminated lead and cadmium), hazardous waste (i.e. ACM, oils and fluid drained from equipment). These wastes will be handled, stored and disposed of according to applicable state and federal regulations. The DOC will coordinate with the waste disposal site(s) regarding the site's waste acceptance criteria and pre-shipment processing requirements.Waste processing may include volume reduction through compaction or segmentation, neutralizati on, stabilization or solidification. Due to the limited size of the facility and work area, concrete rubblization beyond that required for demolition is not expected to occur on-site. Complying with written procedures, standard work practices and operating withthe limits of the NRC license will ensure safe waste processing. The decisions as to the type and degree of waste processing will primarily be based on economics that weigh the costs of additional handling and processing compared to transferring the material off-site for treatment and/or disposal.After the characterization surveys and sampling are complete, wastes will be wrapped, bagged and/or containerized and staged in the appropriate designated area. Items and containers will be properly labeled as Radioactive Material and the label will indicate the external dose rate from the material. Radioactive wastes will be stored in properly secured radioactive materials storage areas. Waste material logs will be maintained for materials placed in disposal and shipping containers.

BMRCDecommissioning Environmental ReportRevision 0 34Figure 5: Decommissioning Boundary BMRCDecommissioning Environmental ReportRevision 0 355.13.1Radiological ImpactsPrior to disposal, all waste streams will be properly characterized according to the requirements of the disposal facility. This characterization will include quantification of primary radionuclides of concern as well as hard-to-detect radionuclides. Additionally, those radionuclides that have specific limits for Class A waste will be directly quantified or estimated based on ratios to concentrations of other radionuclides.All waste will be shipped to an acceptable waste disposal site in accordance with applicable NRC, DOT, and NYS regulations regarding waste packaging, labeling and placarding. Each LLRW shipment will be accompanied by a shipping manifest as specified in Section I of Appendix F to 10 CFR 20, "Requirements for Low-Level Waste Transfer for Disposal at Land Facilities and Manifests." The waste will be manifested consistent with its classification. Only licensed transporters will be used to transport wastes from the BMRC facility.Mixed wastes may be shipped to an NRC licensed processing facility or directly to an NRC licensed land disposal facility depending on the nature of the waste and the treatment options available.The consequence levels discussed in this section are described in more detail in the DOE Standard DOE-STD-1120-2005, "Integration of Environment, Safety and Health Into Facility Disposition Activities" (DOE 2005)

BMRCDecommissioning Environmental ReportRevision 0 366.0MITIGATION MEASURESThe following table identifies the areas that may be impacted by the decommissioning of the BMRC and the mitigation measures:Land UseTransportationGeology and SoilsMeteorology, Climatology and Air QualityNoisePublic and Occupational HealthWaste ManagementMitigation measures that will be used to reduce potential impacts in these areas will include:Affected EnvironmentMitigation MeasuresLand UseFollowing strict site demolition and restoration procedures. TransportationProper loading and shipping of containers and/or materials going off-site.Geology and SoilsProper removal and disposal of soils impacted above regulatory levels.Meteorology, Climatology and Air QualityBuild negative air pressure tents (when feasible) around work areas so that potential air contaminants are contained within work areas. Using water sprays to minimize the amount of dust generated. Following applicable construction and abatement procedures.NoiseLimiting the time of increased noises to daylight hours, with a schedule that takes account of the UB academic calendar.Public and Occupational HealthConstant radiological and air monitoring during decommissioning activities will ensure that the public and the occupational workers are safe. Waste ManagementProper decontamination and segregation of waste will ensure that wastes are disposed of properly.

BMRCDecommissioning Environmental ReportRevision 0 377.0ENVIRONMENTAL MONITORING AND MEASUREMENT PROGRAMSThis section describes the environmental monitoring and measurement programs that will be used during the decommissioning of the BMRC.7.1Radiological MonitoringFrequent radiological monitoring will be performed during the BMRC decommissioning activities. CAMs will be used to monitor the air during selected decommissioning activities. Survey stations will be set up to monitor personnel and equipment. All packaged waste materials willbe surveyed prior to leaving the facility for disposal.7.2Physiochemical MonitoringMonitoring for chemical/hazardous constituents such as asbestos, lead, cadmium and mercury will be performed as needed during the BMRC decommissioning activities. A thoroughasbestos inspection will be performed prior to decommissioning activities and all materials suspect to contain asbestos will be characterized. Asbestos-containing materials will be removed by a trained and licensed New York Department of Labor Asbestos Abatement Contractor prior to the eventual demolition of the facility.7.3Ecological MonitoringNo ecological monitoring is required during the decommissioning of the BMRC.

BMRCDecommissioning Environmental ReportRevision 0 388.0COST BENEFIT ANALYSISDetailed cost estimates for the completion of the BMRC decommissioning activities are included in the Decommissioning Plan. The following are some of the benefits associated with completion of the decommissioning of the BMRC.Increased public health and safety;Decreased operating and maintenance costs;Free release thesite for reuse;Termination of the NRC licenses.

BMRCDecommissioning Environmental ReportRevision 0 399.0

SUMMARY

OF ENVIRONMENTAL CONSEQUENCESThe following is a summary of the environmental consequences related to the implementation of the proposed action:Affected EnvironmentEnvironmental ConsequencesLand UseShort Term Impacts -Construction and demolition of the BMRC buildings, excavation and removal of all associated tanks and piping and removal of all subsurface materials. Following demolition conducting site restoration to usable space. TransportationShort Term Impacts -Hazardous, solid, and radioactive waste transportationGeology and SoilsSoils will be impacted by removal of structures and tanks. Fill will be introduced to the site as necessary and the area will be restored to grade.Water ResourcesNo ImpactsEcological ResourcesNo ImpactsMeteorology, Climatology, and Air QualityShort Term Impacts -Possible air quality issues associated with construction activities.NoiseShort Term Impact -Noise from heavy equipment and demolition of the structures.Cultural and Historic ResourcesNo ImpactsSocioeconomicNo ImpactsPublic and Occupational HealthShort Term Impact -Possible radiological exposure, possible asbestos fiber exposure, and dust above background.Waste ManagementShortTerm Impact -Disposal of solid, hazardous, and radioactive waste.There will be no adverse or long-term environmental impacts as a result of the implementation of the proposed action.

BMRCDecommissioning Environmental ReportRevision 0 40

10.0REFERENCES

1.NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (NRC 2003b).

2.10CFR20, Standards for the protection against Radiation 3.2006 New York State Low-Level Radioactive Waste Transportation Report, March 2008, New York State Department of Environmental Conservation Division ofSolid & Hazardous Materials 4.2035 Long Range Transportation Plan Update, May 2010, Greater Buffalo-Niagara Regional Transportation Council 5.BMRC Historical Site Assessment, Rev. 0, March 17 2010, ENERCON 6.BMRC Study to Determine Quantities, Types, and Disposition of Waste at the Buffalo Materials Research Center, December 2009, ENERCON 7.BMRC Historical Site Assessment, Rev. 0, March 17 2010, ENERCON 8.BMRC Characterization Plan, November 30, 2010, ENERCON 9.Chapter 293, Noise, City of Buffalo City Ordinances, August 13, 1990, Common Council of the City of Buffalo 10.Custom Soil Resource Report for Erie County, New York, BMRC at SUNY, May 2, 2011, United States Department of Agriculture Natural Resources Conservation Service 11.Issuance of Amendment No. 26, To Facility Operating License No. R-77-University of New York Buffalo [Buffalo Materials Research Center (BMRC) Research Reactor] (TAD No. MC3050), May 4, 2005, NRC 12.Landmarks in Buffalo, New York, Buffalo as an Architectural Museum, <http:buffaloah.com/a/landmks/landmks6.html>, May 5, 2011, Landmarks and Historic Districts in Buffalo 13.Niagara Frontier Urban Area Freight Transportation Study, Technical Memorandum No. 2, Freight Transportation System Profiles, Project No. 06 Freight, February 20, 2008, Wilbur Smith Associates 14.NUREG-0982, Safety Evaluation Report related to the renewal of the operating license for the Research Reactor at the State University of New York at Buffalo, May 1983, NRC BMRCDecommissioning Environmental ReportRevision 0 41 15.NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, Final Report, August 2003, NRC 16.Report On Environmental Monitoring Program For Western New York Nuclear Research Center Inc., and the University of Buffalo, 1963, The University of Buffalo and the Western New York Nuclear Research Center, Inc.

17.Specifications for Nuclear Research Center for the University of Buffalo, Buffalo, New York, Contract No. 1, General Construction, June 6, 1959, Office of J. Fruchtbaum 18.University at Buffalo R-77, Operating Procedure #59, Operation of the Intrusion Alarm System, Revision Date January 9, 2009, UB EH&S 19.University at Buffalo R-77, Operating Procedure #77, Quarterly Checks, Revision Date January 9, 2009, UB EH&S 20.Visual Resource Management, BLM Manual 8400, US Department of Interior, Washington, D.C.,

April <http:www.blm.gov:80nstc/VRM/8400.html>, May 3, 2011, Bureau of Land Management