ML14310A588
| ML14310A588 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 04/02/2015 |
| From: | Persinko A Reactor Decommissioning Branch |
| To: | Alexander T University of Michigan |
| References | |
| Download: ML14310A588 (6) | |
Text
April 2, 2015 Mr. Terrance G. Alexander, Executive Director Occupational Safety & Environmental Health University of Michigan Campus Safety Services Building 1239 Kipke Drive Ann Arbor, Michigan 48109-1010
SUBJECT:
TERMINATION OF FACILITY OPERATING LICENSE NO. R-28 FOR THE UNIVERSITY OF MICHIGAN FORD NUCLEAR REACTOR
Dear Mr. Alexander:
On June 23, 2004, you submitted a Decommissioning Plan (DP), (Agencywide Documents Access and Management System (ADAMS) Package No. ML041810586), for the University of Michigans (UM) Ford Nuclear Reactor (FNR). On January 10, 2006, you submitted a revised DP (ADAMS Package No. ML060180411). The U.S. Nuclear Regulatory Commission (NRC) approved the Universitys revised DP by Amendment No. 50, dated June 26, 2006 (ADAMS Accession No. ML061220260).
Decommissioning activities included remediation, dismantlement, and demolition of various systems, structures and components followed by final status surveys (FSS) based on the guidance in NUREG-1757, Consolidated Decommissioning Guidance, and the methodology in NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).
Finally, several FNR systems and components were transferred to the UM Broad Scope license No. 21-00215-04, in accordance with your approved DP.
In letters dated April 8, 2011, July 12, 2011, January 20, 2012, June 1, 2012, July 13, 2012, and September 17, 2012 (ADAMS Accession Nos. ML11119A004, ML11199A009, ML12025A125, ML12157A266, ML12199A018, and ML12264A562, respectively), you requested approval of a partial FSS Plan. Additional site characterization information for the FNR was provided as part of submittals on February 14, 2012, and September 18, 2012 (ADAMS Package No. ML120950629 and ADAMS Accession No. ML12264A064).
By letter dated October 25, 2012 (ADAMS Accession No. ML12293A302), the NRC reviewed the FSS Plan and determined that after a change to one paragraph, it was acceptable and consistent with the guidance in NUREG-1757 and NUREG-1575. The UM provided the modified FSS Plan with the revised paragraph on November 2, 2012 (ADAMS Accession No. ML12312A130). The modification required an additional FSS Report for three special areas of the FNR. The UM conducted FSSs from November 26 to December 12, 2012. The NRC performed confirmatory surveys from December 3 to 6, 2012.
T. Alexander 2 The UM provided a FSS Report which included information on the three special FSS areas in a letter dated July 11, 2013 (ADAMS Package ML13205A152), followed by a corrected background count rate for the FSS Report on August 18, 2013 (ADAMS Accession No. ML13235A009).
In a February 26, 2014, letter (ADAMS Accession No. ML14063A207), the UM confirmed that FNR systems and components had been transferred to the UM Broad Scope license No.
21-00215-04 by amendment No. 102, in accordance with the approved DP, and requested termination of the FNR license. The amendment No. 102 transfer was approved by the NRC, with a correction, on February 19, 2014 (ADAMS Accession No. ML14055A189). On June 23, 2014, the NRC inspectors confirmed that site conditions were acceptable for license termination (ADAMS Accession No. ML14197A232). Additionally, the NRC staff has reviewed the FNR FSS Report of July 11, 2013. The FNR FSS Report states that the criteria for termination set forth in FNRs license (R-2), and as established in its decommissioning plan (DP) and FSS plan have been satisfied.
As stated in the FNR FSS Report, the facility was divided into 73 individual survey units (SUs). A total of 1,337 direct beta contamination measurements and 1,337 smear samples for removable beta contamination were taken on structural surfaces and remaining equipment. The FSS Report states that no elevated activity was detected during the beta or gamma scan surveys with the exception of one sample in one of the three special FSS areas. Additionally, all the removable activity measurements were well below 10% of the DPs derived concentration guideline levels (DCGLs).
The elevated measurement was taken in the cavity area under the facility basement floor, directly below the FNR roll-up door, adjacent to an inaccessible expansion joint between subgrade building footers. While not part of the MARSSIM statistical analysis, inclusion of the data from this elevated activity would not have caused that SU to fail the MARSSIM statistical test.
Additionally, all soil was removed from the cavity as part of site remediation, and a sample analyzed for the FSS Report (Appendix F). The sample analysis results are below the FNR DP soil DCGL.
The building expansion joint contamination within the under slab cavity area, the beam port storage area, and the foundation drain areas are addressed by separate analysis in section 6 of the FSS Report, which provides documentation that these special areas are in compliance with NRCs criteria for unrestricted use. The NRC staff has reviewed section 6 of the FSS Report, and the associated appendices containing soil sampling data, computer modeling analysis, and direct measurement. Based on this staff review, the NRC concludes these areas are in compliance with the NRC dose criteria for unrestricted release.
On August 9 through 11, 2011, NRC conducted an on-site inspection of decommissioning activities at the FNR (ADAMS Accession No. ML11299A076). The NRC inspector evaluated decommissioning performance and conducted independent radiation surveys and soil sampling, with soil sample evaluation of the NRC samples by the Oak Ridge Associated Universities (ORAU). At the conclusion of the on-site inspection, the inspector discussed the interim inspection results with members of the FNR staff. As a result of this inspection, a Notice of Violation was issued to the UM for failing to independently monitor or audit either decommissioning operations or the quality assurance program annually as required. This violation has been resolved by the UM reinitiating audits and quality assurance reviews as part of semi-annual Decommissioning Review Committee meetings, as documented in an October 10,
T. Alexander 3 2012, NRC inspection report (ADAMS Accession No. ML12284A282). The final report from ORAU of the results of the soil sample analysis was provided to the NRC on August 30, 2011 (ADAMS Accession No. ML112420852). One of the soil samples exceeded the FNR DPs soil DCGL for Cobalt-60, which was addressed by the UM subsequently remediating all the soil from the cavity area, and resampling as part of the FSS.
ORAU and NRC staff performed confirmatory surveys and measurement at FNR to compare with the final status surveys results. Surface scans identified elevated activity in an area which was remediated to background levels. All surface activity values were less than the corresponding gross beta DCGL. Laboratory analysis of the soil shows that the radiological contaminant concentrations are less than their respective DCGL values, and all of the samples meet the DP criteria without need to apply MARSSIM statistical analysis.
At the request of NRC staff, on January 16, 2015 (ADAMS Accession No. ML15020A725), UM provided the results of eight additional soil samples, taken to a depth of thirteen feet in the area where stockpiled soils were reused to refill the excavation in the former storage ports area of the FNR. The results demonstrate that the reused stockpiled soils are acceptable for unrestricted release. Additionally, three split samples were sent to ORAU for laboratory analysis. (ADAMS Accession No. ML15030A311). The resulting analytical report are consistent with UMs sampling.
Additionally, all the radioactive wastes have been removed from the facility, and documentation regarding their removal disposition is provided in the FSS Report.
Based on its review and evaluation of the FSS Report and associated documentation, and on the results of NRC inspections and confirmatory surveys, the NRC staff has concluded that the survey was conducted in accordance with the guidelines and recommendation in NUREG-1757 and NUREG-1575, that decommissioning pursuant to the approved DP is finished, and that the site meets the unrestricted release criteria for license termination in 10 CFR Part 20, Subpart E.
Accordingly, pursuant to 10 CFR 50.82(b)(6), Facility Operating License No. R-2 is hereby terminated.
In connection with the license termination, we are enclosing two copies of Amendment No. 12 to Indemnity Agreement No. E-24. Please sign and return one copy to Mr. Eric Olvera in the Financial Analysis and International Projects Branch, U.S. NRC, Mail Stop O-7C2A, 20555, and include the U.S. NRC Document Control Desk, and Mr. Theodore Smith, Reactor Decommissioning Branch, U.S. NRC, Mailstop T-8F5, 20555.
Also enclosed is a copy of the Notice of License Termination, which is being sent to the Office of the Federal Register for publication.
T. Alexander 4 In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions concerning this matter, please contact Theodore Smith at (301) 415-6721.
Sincerely,
/RA/
Andrew Persinko, Deputy Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No.: 50-2
Enclosures:
- 1. Amendment No. 12 to Indemnity Agreement No. E-24
- 2. Federal Register Notice cc: Docket Service List
T. Alexander 4 In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions concerning this matter, please contact Theodore Smith at (301) 415-6721.
Sincerely,
/RA/
Andrew Persinko, Deputy Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No.: 50-2
Enclosures:
- 1. Amendment No. 12 to Indemnity Agreement No. E-24
- 2. Federal Register Notice cc: Docket Service List DISTRIBUTION RidsOgcMailCenter RidsAcrsAcnwMailCenter RidsRgn3MailCenter RidsFsmeOd TSmith ROrlikowski, RIIII ML14310A571 OFFICE NMSS NMSS NMSS NMSS NAME TSmith SAchten SGiebel BWatson DATE 11/04/2014 11/07/2014 11/13/2014 11/14/2014 OFFICE NRR/IFAIB OGC NMSS NAME ABowers MCarpentier APersinko DATE 3/26/ 2015 3/19/2015 (by email) 4/2/ 2015 OFFICIAL RECORD COPY
University of Michigan - Ford Nuclear Reactor Service List cc:
Mr. Mark L. Driscoll, Radiation Safety Officer Occupational Safety & Environmental Health University of Michigan Campus Safety Services Building 1239 Kipke Drive Ann Arbor, Michigan 48109-1010 Dr. Mark M. Banaszak Holl, Ph.D., Associate Vice President Office of Vice President for Research, Natural Science and Engineering Fleming Building / Room 4079 503 Thompson Ann Arbor, Michigan 48109-1340 Mr. Curt W. Smitka, Director Budget & Administration Office of Vice President for Research Fleming Building / Room 4056 503 Thompson Ann Arbor, Michigan 48109-1340 Mr. Robert B. Blackburn, Manager Ford Nuclear Reactor - Decommissioning Project Phoenix Memorial Laboratory / Room 3034 2301 Bonisteel Boulevard Ann Arbor, Michigan 48109-2100 Special Assistant to the Governor Office of the Governor Room 1 - State Capitol Lansing, MI 48909 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Hazardous Waste and Radiological Protection Section Nuclear Facilities Unit, 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611