ML20151P378

Forwards Addl Info Re Planned Decommissioning of Facility. Licensee Fully Prepared to Cover Costs Associated W/ Decommissioning & Will Adjust Transfers to Escrow Account According to Approved Plan & Schedule

ML20151P378
Person / Time
Site:	05000199
Issue date:	07/21/1998
From:	Jackson W MANHATTAN COLLEGE, RIVERDALE, NY
To:	Michaels T NRC (Affiliation Not Assigned)
Shared Package
ML20151P383	List: ML20151P378 ML20151P384 ML20151P387
References
NUDOCS 9808030132
Download: ML20151P378 (11)

Text

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! , MANHATTAN COEEGE Riverdale, N.Y.10471

) g l A Inenillan CathoHc CoHege Since 1853

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16 July 21,1998 Mr. Theodore S. Michaels Senior Project Manager Non-Power Reactor Program Management Office of Nudear Reactor Regulation U.S. Nudear Reguhtory Commission Washington, D.C. 20555-0001 Subject AdditionalInformation Decomrmssion Plan for Manhattan College Zero Power Reactor Dear Mr. Michaels-As requested in your letter of 20 May 19998, I am endosing additional infonnation regarding the planned decomnussioning of the Manhattan College Zero Power Reactor (MCZPR).

I am providing answers to the questions induded in your letter and a revised Decomnussioning Plan incorporating these answers.

Please be advised that an escrow account for the decommissioning fund has been established with Citibank (D 1925774). The current balance is $30,000. An additional $30,000 will be transferred to this account within the next 90 days. We are budgeting $30,000 each yen to cc,ver the costs associated with the decommissioning of the Zero Power Reactor. We are fully prepared to cover the costs associated with the decommissioning and will adjust our transfers to the escrow account according to the approved plan and schedule.

Should you require further infonnation to complete your review and approve the Decommissioning Plan, please let me know and I will provide it immediately.

Sincerely, N.-n}wl km {

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MCZPR 7/98 ADDITIONAL INFORMATION REQUESTED FOR MANHATTAN COLLEGE ZERO POWER REACTOR (MCZPR)

DECOMMISSIONING Ouestion Resoonse Banari Pace 1 Manhattan College is requesting a Possession 1 Only (PO) license followed by decommissioning l after the decommissioning plan is approved. Once fuel and the PuBe source is removed and all I decommissioning actions are completed, we request termination of Reactor License No. R-94.

2 The April 24, 1997 letter (W. Jackson to T. NA Michaels) contained the estimated cost ($134,500) to decommission both the MCZPR and two subcritical facilities located adjacent to the reactor. The

$65,000 estimate in the Decommissioning Plan refers only to the MCZPR. The cost of consultants is l l

included in the decommissioning costs. Details of the funding mechanism are included as Attachment 1.

3 Planning, dismantling, radiological survey and 6 material shipments will all be performed in accordance with written procedures by trained personnel. Procedures will be reviewed by the Campus Radiation Safety Committee prior to implementation.

All procedures will comply with all pertinent regulatory requirements including those for transportation. Each step of the decommissioning program and confirmatory surveys will be documented, to develop a stand-alone record of the decommissioning process that will be suitable for internal audit and regulatory review.

4 The Dean of Engineering, not Dr. Berlin, will 6 oversee the contractors, maintenance personnel and students performing the actual tasks. Dr. Berlin will provide an independent QA oversight function 1

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MCZPR 7/98 reporting to the Dean of Engineering.

5 Despite anticipated limited occupancy of the 8 laboratory the calculation of the TEDE release criteria is based on continuous, unrestricted use of the facility.

6 The PuBe source has been placed in storage in its 9 original shipping container and is stored within the Controlled Access Area (CAA) in accordance with the provisions of the existing MCZPR Security Plan.

To maintain doses due to the presence of these sources ALARA, it is requested that the requirement for periodic leak testing be amended to conform to that in SNM license # 1892. That is, that leak testing will not be required during storage but will be performed when the source is removed from storage and prepared for shipment.

7 Camera-ready copies of Figures 2-1 and 2-1 have been 10 incorporated into the revised Decommissi.oning Plan. 11 1

8 The radiation levels in Figure 2-2 are illustrative 9 of the fact that even when fuel and the PuBe source were present there was no major radiation source in the MCZPR room. The presence of the " metal rods" was noted as the only other identifiable radiation source in the room. It is expected that they will be trans-ferred as low level radioactive waste (LLRW) during decommissioning. Radiation levels in the building remote from the reactor facility represent ' background" levels for purposes of decontamination.

9 The interim survey discussed in Section 2.3.1, 12 Item 2, is the same one described on page 12 of the original DP.

10 The discussion in Section 2.3.1, Item 2, explains 13 Manhattan College's intent to use procedures for the interim survey that meet all the requirements for the final survey. Because our facility is essentially dealing with sealed sources (e.g.,

clad fuel and sealed neutron source) it is possible, and expected, that no subsequent contamination would occur in some areas after the interim survey is performed. Only the results of a survey performed 2

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MCZPR 7/98 after all radioactive material is removed from an i area, and any necessary decommissioning actions have  !

been completed, will be used to support the requested license termination. l 11 ~The following sentence has been added to Section 13 l 2.3.1, Item 3. " Operating procedures will be l prepared and approved by the Radiation Safety Committee for all decommissioning tasks not previously performed."

12 The following sentence has been added to Section 13 2.3.1, Items 5 and 6. "The used storage containers 14 will be surveyed prior to release of the fuel (source, to the transport company for shipment as an additicnal verification that the fuel (source) is intact.

13 Section 2.3.1, Item 8 has been amended to state 14 i

the material packaged and shipped for disposal will i meet "all applicable NRC and DOT regulations."

L 14 The last paragraph of Section 2.3.1 has been 15 revised as follows: "No materials or procedures l will be used during decommissioning without ,

appropriate procedures and changes in the fire I protection, ventilation and Technical Specifications, l if needed."

l 15 The purpose of the discussion of use of the interim 16 l survey results in the final survey when appropriate was to indicate Manhattan College's intent to complete this project as expeditiously as possible.

, Our first commitment is to achieving and documenting

! a facility eligible for release for unrestricted use and the surveys performed will support this commitment.

16 Section 2.6 has been revised to indicate that both 17 Dr. Berlin and Mr. Luckett have been contracted independently to provide Quality Assurance and Health Physics support, respectively. They will be responsible to the Dean of Engineering as will Mrs.

, Stanton and will perform their tasks in consultation i with the campus Radiation Safety Committee.

i f 17 Mrs. Stanton, Dr. Berlin and Mr. Luckett all have 17 1

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MCZPR 7/98 the expertise described in the second paragraph of Section 2.5 and documented in Appendix A to the Decommissioning Plan. Any other decommission-ing personnel (e.g., maintenance staff and student assistents) will be given basic radiation protection and general safety instruction using existing training materials and procedures.

18 The apparent inconsistency has been resolved with NA the revision to p. 6. The discussion here that all contractors will report to the Dean of Engineering is correct.

19 The last paragraph of Section 3.1.1 has been 20 revised to indicate that the campus RSO is responsible for ALARA.

20 The RSO is a member of the Radiation Safety 20 Committee. The reference to Figure 1-4, which does not refer to the RSO, has been deleted.

21 Radiation protection during decommissioning will 20 be the responsibility of the campus RSO. The principles and procedures in the existing radiation safety program for the MCZPR (Appendix B to the SAR and this Decommissioning Plan) will be used to supplement general requirements applicable to other radioactive material uses at Manhattan College.

Mrs. Stanton will provide day to day oversight of radiation safety in cooperation with the campus RSO. The Health Physicist will continue to be available for consultation as needed. Health Physicist concurrence on regulatory compliance is required prior to release of radioactive material from the facility.

22 Prior to shipment, fuel will be removed from the 21 storage container. Each element will be wipe tested to determine the level of removable contam-ination. The wipes will be counted for alpha and beta / gamma activity. Similar measurements will be made of wipes of the storage containers to document that no radioactive material exceeding the limits for unrestricted release is present. Surveys to date - of facility and fuel surfaces and reactor water - have indicated no radioactive material distinguishable from background.

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i MCZPR 7/98 23 We recognize that preparation and packaging of 23 fuel for shipment is the shipper's respon-sibility. However, because of DOE ownership of the fuel the Department will be involved in supporting this transfer. The first sentence l of the sixth paragraph of Section 3.4 has been i amended to read as follows: " Transportation of the fuel elements to the designated receipt point will be in casks specified and provided by DOE and in conformance with all regulatory requirements and approved procedures."

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24 The second sentence of the third paragraph of 24 Section 4 has been revised to read as follows: i

" Residual activity will be sufficiently low to comply with the criteria for unrestricted release in 10 CFR 20.1402."

25 The fourth sentence of Section 8.2 has been 26 revised to read as follows: " Shipments will be in compliance with all applicable NRC and DOT regulations."

26 Based on facility experience and the absence to 26 date of any contamination exceeding Regulatory Guide 1.86 levels for unrestricted release, it is considered unlikely that any liquid radioactive waste will be generated. However, since such a possibility cannot be ruled out a priori, the first sentence of the second paragraph of Section 8.2 has been revised by deleting reference to liquid waste. The environmental impact of LLRW shipments is covered in the discussion in the first paragraph of this section.

27 The last paragraph of Section 8.2 has been revised 27 include an estimate of public and occupational i

exposure due to decommissioning. The calculation of this exposure has been attached to this package l for information.

l l 28 The following sentence has been added to the end of 27 Section 9: "Any changes in the Decommissioning Plan

which involve unreviewed safety questions or l Technical Specification changes will be submitted to the Nuclear Regulatory Commission for review

before implementation."

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MCZPR 7/98 l 29 All references to the Reactor Operations Committee i have been revised to read the Radiation Safety Committee.

30 The Radiation Safety Committee members have direct NA I

[ expertise in radiation safety as documented in their qualifications supplied in Appendix A. Special-ized knowledge for handling and shipment of the fuel and the source are provided by Mrs. Stanton and Mr. Luckett. They will work in cooperation and consultation with the Radiation Safety Committee.

31 The Chief Reactor Supervisor has been requested NA to perform the duties of the Acting Reactor Administrator as defined in this Decommissioning '

Plan.

32 With the exception of some editorial changes such as from Reactor Operations Committee to Radiation Safety Committee, the radiation protection program has been essentially unchanged from the operating phase to the decommissioning phase. No conditions are anticipated during decommissioning that would l differ substantially in the need for radiation '

protection from those during operation. For example, fuel has been packaged and shipped, sources have  ;

been moved to storage, and reactor internals were ,

handled during the tank renovation. Therefore no  !

additional radiation protection requirements were i identified for decommissioning. Manhattan College's  !

philosophy continues to be that this is a opportunity l to instill good practice in those working on the {

project, even if the requirements exceed those  ;

required under the regulations.

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33 (not included in letter) 34 TL.c Technical Specifications (?S) definitions have 1-1 been reviewed as requested.

35 Saft. : 3 Limit specifications have been added as 2-1 recommended.

36 Limitint, Conditions for Operation have been added 3-1 as recommended.

37 Section 4.1.3.E has been revised to state that the 4-1 6

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• MCZPR 7/98 source will be leak tested semi-annually "unless it is in storage and is not being used. However, when it is removed from storage for use or transfer to another person and has not been tested within the required leak test interval, it shall be tested before use or transfer. Under no condition will the source be stored for a period of more than 10 years without being tested for leakage and/or contamination."

Section 4.1.4 has been revised to indicate that 4-2 specification 4.1.3.E will maintain exposures ALARA while verifying radiation protection. The language

used is identical to that used in license #SNM-1892 i for non-alpha emitting sealed sources

! 38 The physical inspection frequency used in this 4-3 i specification coincides with the inventory fre-l quency required for material accountability j records. Complying with both requirements simul-taneously maintains personnel exposure ALARA and The requirements are consistent with those used at the Catholic University of America and at the University of Kansas during Possession Only status.

39 The description of the duties of the Quality NA Assurance Manager are correct as stated on p. 6-3.

The apparently inconsistent description on p. 6 has been revised.

40 The relationship between the reactor RSO and 20 Campus RSO has been described on p. 20 of the 6-3 DP and in Section 6 of the TS.

41 Section 6-7, Records, has been revised as suggested.6-8 42 Page 6-11 was erroneously included in the original document and has been removed as not applicable to decommissioning.

43 The requested changes to the reporting addresses 6-7 have been incorporated and the TS have been repagineted.

44' The agreement with St. Joseph Hospital is confirmed NA annually be telephone call to the hospital as part of the verification of the emergency call out roster. No other written record is available.

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. 'y MCZPR 7/98 CALCULATION OF TOTAL PERSON-REM EXPOSURE FROM DECOMMISSIONING Occupational Exposure On Site (estimate based on prior experience) 10 workers at 100 mrem / worker 1 person-rem No general public exposure estimated on site.

Transportation (estimate based on Incident-Free Unit Risk Factors for transportation using the methodology of Radtran 4 and reported in Table H-5 of the DEIS for Closure or Long-Term Management of Facilities at the Western New York Nuclear Service Center -

DOE /EIS-0226-D, January 1996)

Assuming 2 truck trips of fuel to Oak Ridge, one truck trip of LLRW to Barnwell, South Carolina - 2250 truck miles (3600 truck km) and one truck trip to Los Alamos (2000 miles or 3200 km). Risk factors separately address occupational exposure and both on-link (sharing tie road) and off-link (within 800 feet) exposure to the general public. They further distinguish between different types of communities since there will be different population densities in urban, suburban and rural areas. Shipments from Manhattan College will enter the Interstate highway system within three blocks of the College. For purposes of this analysis, we have assumed that the routes can be approximated as 50% suburban and 50% rural.

The fuel and LLRW shipments were assumed to have radiation levels of 1 mrem /hr at 1 m from the shipping container even though these are approximately the surface radiation levels from the unpackaged material. The radiation level for the source shipment was assumed to be the regulatory limit of 10 mrem /hr at 1 m from the shipping container.

Based on these conservative assumptions, the occupational transportation radiological impact is estimated to be 2.4 person-rem. The general public is estimated to receive 1.8 person-rem from transportation. Over 90% of this exposure is due to the es'timated shipment of the PuBe source to Los Alamos.

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