ML20214K802

Responds to 861106 Request for Addl Info Re Application to Amend License R-78.Safety Analysis of Change to possession- Only Status,Summary of Disassembly Activities,Inventory of Remaining Activated Matls,Tech Specs & Related Info Encl

ML20214K802
Person / Time
Site:	05000148
Issue date:	11/24/1986
From:	Rosson H KANSAS, UNIV. OF, LAWRENCE, KS
To:	Berkow H Office of Nuclear Reactor Regulation
Shared Package
ML20214K803	List: ML20214K802 ML20214K823
References
NUDOCS 8612020470
Download: ML20214K802 (10)

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THE UNIVERSITY OF KANSAS LAWRENCE, KANSAS 66045-2223 DEPARTMENT OF CHEMICAL AND PETROLEUM ENGINEERING Ydf!4Es November 24, 1986 Mr. Herbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ,

Washington, D.C. 20555 Re Docket No. 50-148 NRC Review of University of Kansas Possession-Only Ammendment j

Application Dear Mr. Berkows f In response to your letter of November 6 requesting additional information,

! we submit the following documents (Item numbers refer to those in the

! enclosure to >our letter):

l Item 1 Safety Analysis of Changing the University of Kansas Reactor Facility to " Possession Only" Status l

Item 2 Sumnary of Disassembly Activities and Inventory of Remaining l Activated Materials Item 3 Processing and Disposal of Activated and Contaminated Reactor j Components (RSS-1 Project 1)

Exposure ALARA Considerations for RSS-1 Project 1 Radiation Safety Service Permit Application, Permit No. RSS-1 Item 4 Included in response to Item 2 Item 5 Proposed Appendix A. Technical Specifications for the Nuclear fleactor Facility License R-78, Revised November,1986 We hope trat these responses will permit you to complete your review and evaluation of our amendment request.

Sin cere .. y ,

/ p Harold F. Rosson Reactor Director

Enclosures:

As stated Copy W/ enclosures: Carl E. Locke Q Y 8612020470 061124 PER ADOCK 05000148 i P PDR

r SAFETY ANALYSIS OF CHANGING THE UNIVERSITY OF KANSAS REACTOR FACILITY TO " POSSESSION ONLY" STATUS

.lovember, 1986 All nuclear fuel has been removed from the facility. Criticality cannot be achieved and hence does not constitute a safety hazard.

All remaining radioactivity either is contained in certain parts that have been removed from the reactor tank (control rods and sheaths, grid plates, aluminum angle pieces, and assorted bolts) or is within the reactor shielding (the aluminum tank, the concrete biological shield, the graphite thermal column, and the beam port plugs).

The parts that have been removed total 45 pounds and have been assayed to contain 0.96 mci of co-60. They are stored in one of the shielded vaults in the hot lab and are accessible only by trained Radiation Safety Service personnel. The exposure rate from the parts is 1.75 mR/hr at 1 meter. They

, represent no hazard to the general public and only a minor hazard to I

operating personnel.

The radioactivity contained in the shielding results in a maximum exposure l rate inside and at the bottom of the empty tank of < 30 mR/hr. However, a l cover has been locked to the top of the tank to prevent unauthorized access.

l The exposure rate directly above the cover is 40 pR/hr, around the top catwalk it is 5 pR/hr, and at the surface of the shield waist-high above floor level it is < 5 uR/hr, all measured above background. This represents no hazard to the general public and only a negligible hazard to operating personnel. In fact, given the very small occupancy factor of the area around the top of the reactor (< 15 min /wk), the reactor room might qualify for unrestricted use.

There are no sources of 11gulds, sludges, or gases which might be released.

We can conceive of no credible accident which would release significant amounts of any radioactive contaminant to the environment.

The Technical Specifications specify procedures to be followed to maintain the facility in a safe condition. Adherence to these procedures shall insure safety.

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SUMMARY

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

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

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

The following activated components have been removed from the tank and are stored in a shielded vault in the hot lab Description Activity (mCl) Weight (1bs)

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

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

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

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

No other material has been removed or shipped off site.

PROCESSING AND DISPOSAL OF ACTIVATED AND CONTAMINATED REACTOR COMPONENTS RSS-1 Project 1 Approved by majority vote of Radiation Sources Committee March 17, 1986 I. Introduction It is proposed that all remaining contaminated components of the reactor, exclusive of the structural shielding, be appropriately processed for officient packaging and disposal as radioactive waste under our usual procedures.

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

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

Protective clothing will be worn in disassembling the components.

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

Pocket chambers will be worn.

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

If components need to be cut or sawed, drop cloths will be used and work will be carried out in a draft-free environment. Face masks with particulate filters will be used with eyes protected. All filings and other materials will be disposed of as radioactive.

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

Estimates of activity will be made from radiation levels. Analysis of spectra may be used, as appropriate, for identification of products.

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

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

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

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lPcrait No. RSS-1 l l Effective Date l l completed by RSS l Radiation Safety Service PA-RLap Permit Application

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

Radiation Safety Service '

gg Benjamin S. Friesen l Assistant RSO Director and Radiation Safety Officer of fice - 217 Nuclear Reactor Center home phone 841-8260 i

office phone 864-4089 Judith deChamplain g

home phone 843-4373 Radiation Protection Specialist l home phono 842-3180

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(b) Roosa where r$dio$ctive e$teriaIs~wIli be u$ed or etored."

NRC - rooms 207, 210A, 203, 218, 111, 112, 132, 126, 125, 142 llawor th 904, 906, 10-1 Nicholn 142 (n11 n t her noornveri Inhorntorien)

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

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

3. Isotopee

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

Radioactive l Compound (s) l Stock Storage l Requested l Possession Limit footope l and/or Fore l Location l Possession Limit l (completed by RSS) l I I I I I I I Any listed In forms listed 203, til NRC At levels listed'g At levels listed in Radioactive  ! ni 38-C019-01, in 38-C019-01. i Materials License I Waste and  ! n 38-C019-01.

I I 38-C019-01 I Scaled Saurces!

(copy cttached)  !

ggg gg g3 (cppropriate portfor s) l 207, 210A, NRC l l l l 904, 906, 10-1l l l l Ilavo rt h l l

! I I g

142 Nichols g l

I I I l l I I l

4. Claes of Laboratory (Circle appropriate clase.)

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

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5. Training of Laboratory Supervisor duration of on the

- fo rmal Type of training training job course (a) Principles and practices of radiation protection, See c iclosed vitae. yes no yes no (b) Radioactivity measurements, monitoring techniques, instrument capabilities, yes no yes no standardizations, (c) Mathematics and calculations f basic to the use and measurement yes no yes no j of radioactivity, (d) Biological ef fects of radiation including estimates of risk. yes no yes no

6. Experience of Laboratory Supervisor where experience duration of isotope maximum amount type of use was gained experience See enclosed vitae.

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

888 efficiency (average) type of instrument radiation detected m nitoring, surveying or sensitivity measuring See appropriate por tions of License Nun ber 38-C019-01.

8. Method, f requency, and standards (sources) used in calibrating and checking proper ,

operation of instruments listed above.

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RSS-1 Application cont. PA-RSSI.386

9. The TR-TD1 is enclosed.

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

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

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

12. Radiation Protection Program

a. General:

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

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

The procedures covered are summarized below:

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

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

XI. Training XII. Waste Disposal

b. Specific Items

1. Possession:

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

materials either in stock form or in waste form for users for variable lengths of time. The RSS, for itself, may need reference sources, classroom materials, and calibretions sources. All items are so stored that unrestricted areas will not exceed applicable IOCFR20 regulations.

2. Approach to non-routine projects:

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

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

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

time limitations are established.

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

IV. From analysis of operations to be accomplished, necessary shielding

. arrangements are calculated and installed.

V. All appropriate safety precautions are followed:

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

May include respirators, hooded garments, and bootles.

2. Protective drop cloths are used if radioactive materials might

• be spread.

3. Hoods or dry boxes are used as required.

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

5. Film badges are worn.

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

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

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

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

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

IV.

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

V.

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

4.

Any major project will be submitted for review and approval on a one time basis.

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