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Submittal of Final Status Survey Report for the University Of Q UN I V ER SIT Y OF ENVIRONMENTAL HEALTH AND SAFETY 1ITWASLHLI1N1GTON 201 Hall Health Center Box 354400 * Seattle, Washington 98195-4400 Phone 206.543.0463 FAX 206.543.3351 www.ehs.washington.edu February 26, 2007 Alexander Adams US Nuclear Regulatory Commission Mail Stop O - 12 - G -15 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Re: Termination of NRC License # R-73 Dear Alexander: The University is pleased to submit the revised Final Status Survey Report for the University of Washington More Hall Annex Decommissioning Project. We believe the enclosed controlled copy demonstrates that the conditions and requirements of 10CFR 50.82 B6 have been met, and addresses the NRC Request for Additional Information dated February 7, 2007. The responses to your questions of February 7, 2007, along with necessary back-up documentation, are attached to this letter and, where appropriate, corresponding changes to the Final Status Survey are indicated with a vertical bar in the left hand margin. We believe the final status survey process has established that the More Hall Annex is now suitable for release from radiological controls. The enclosed revised Final Status Survey Report provides the necessary documentation demonstrating the radiological condition of the facility and responds to the NRC review comments. This document also supports the conclusion that the University of Washington has complied with NRC decommissioning requirements. Based on this, the University of Washington is now requesting termination of United States Nuclear Commission License number R-73. Please contact me with any questions about this request. Sincerely, Stanley J. Addison, M.S. UW Radiation Safety Officer I declare under penalty of perjury that, to the best of my knowledge, the forgoing is true and correct. Executed 2/26/07 Copy: Marty Howlett, Project Manager, Capital Projects Office Jeff Angeley, Associate Construction Manager, Capital Projects Office REQUEST FOR ADDITIONAL INFORMATION UNIVERSITY OF WASHINGTON RESEARCH REACTOR FINAL STATUS SURVEY REPORT DOCKET NO. 50-139 1. The cited nominal efficiency values for Alpha Gas Proportional detectors in Tables 5-1 and 5-2 and the text in Section 5.3.1.1 are inconsistent. The nominal efficiency values should be consistent in the document, and the associated Minimum Detectable Activities (and Probabilities of Detection) should be calculated using the same efficiency value for a given instrument combination/measurement type. Please update this information to be consistent. 2. Section 5.3.2, Instrument Calibration, does not include a discussion of calibration sources (isotope, material, and geometry) and source-to-detector distance for each type of radiation measurement (alpha, beta, gamma). Please provide this information. 3. Section 7.1.3.3 describes the use of a 50 cm 2 air proportional detector for assessing total alpha activity inside the fuel storage tubes (10 cm diameter). Table 7-2 describes three elevated alpha activity results and the associated weighted average. Please provide the source-to-detector distance and the method of determining the net results in dpm/100 cm2 (e.g., was the measurement result doubled since the detector is 50 cm 2 in area?). Discuss if the source-to-detector distance results in an underestimation or overestimation in the efficiency and results. 4. Section 4.3.2 of the Decommissioning Plan states that "For direct methods of surface monitoring, the scanning speed will be slow enough to ensure a source detectionr probability of at least 25% of the guideline level." The calculated scan MDC for beta surface activity, as specified in Table 3-3 of the Final Site Survey Plan (FSSP), is less than 25% of the release criteria for gas proportional detectors, but is not less than 25% of the release criteria for beta friskers. Furthermore, the scan MDC for alpha surface activity specified in Table 3-3 of the FSSP is 160 dpm/100 cm 2, which is not less than 25% of the release criteria. Standard final site survey instrumentation is typically not capable of detecting radioactivity at 25% of the Regulatory Guide 1.86 release criteria when utilized for scanning, nor is there a regulatory requirement that scanning instrumentation should be capable of detecting radioactivity at these levels. Please develop and submit a technical basis to justify the deviation from the requirements of the DP or revise the DP accordingly. If you revise the DP, please submit a copy of the revision paperwork. 5. Because of your revision to release criteria that occurred after NRC's site visit to account for tritium, please collect and submit additional measurements around two locations of interest on the bioshield floor (grid location B, 1) and bioshield interior south wall (grid location E,-1), to verify that the square-meter average is less than the modified average beta contamination limit of 1,700 dpm/100 cm 2. The individual measurement results for these locations were 3,700 and 1,800 dpm/100 cm 2, respectively. ) UW More Hall Annex Decommissioning Project Document Comments Form F Services, Inc. Document Final Status Survey Report Document No.: UW-MCP-OP-13 Rev. 1 Commenter(s) NRC Docket # 50-139 RAI (February 7, 2007) Document Date: December 6, 2006 Project Number 10492 Comment Section/ Comments Responses No. Page 1 5.3.1.1 The cited nominal efficiencies for Alpha Gas Proportional The text contained in Section 5.3.1.1 has been detectors in Tables 5-1 and 5-2 and the text in Section 5.3.1.1 modified to provide a consistent instrument efficiency are inconsistent. The nominal efficiency values should be and a discussion of the probability of detection consistent in the document, and the associated Minimum formula from the MARSSIM. Detectable Activities (and Probabilities of Detection) should be calculated using the same efficiency value for a given instrument combination/measurement type. 2 5.3.2 ORISE recommends the section 5.3.2, Instrument Calibration, A short description of the daily response checks and include a discussion of calibration sources (isotope, material, the associated sources has been added to Section and geometry) and source-to-detector distance for each type of 5.3.2 of the FSS report. radiation measurement (alpha, beta, gamma). 3 7.1.3.3 Section 7.1.3.3 describes the use of a 50 cm' air proportional A discussion has been added to Section 7.1.3.3 of the detector for assessing total alpha activity inside the fuel FSSR on the use of the 50-cm2 detector in the fuel storage tubes (10 cm diameter). Table 7-2 describes three storage tubes. elevated alpha activity results and the associated weighted average. ORISE recommends including additional information Section 6.2 of the FSSR details the data conversion in the report that describes 1) the source-to-detector distance process which includes detector area correction for all and 2) the method of determining net results in dpm/100 cm2 measurements based upon the detector utilized. (e.g. was the measurement result doubled since the detector is 50 cm2 in area?). The additional information should support the premise that the source-to-detector distance did not result in an overestimation in the efficiency, and therefore underestimation of the result. I Document I Final Status Survey Report Document No.: UW-MCP-OP-13 Rev. 1 Commenter(s) NRC Docket # 50-139 RAI (February 7, 2007) Document Date: December 6, 2006 ___Project Number 10492 Comment Section/ Comments Responses No. Page 4 DP Section 4.3.2 of the Decommissioning Plan states that "For A 50.59-type change has been drafted ,reviewed and direct methods of surface monitoring, the scanning speed will approved by the University Technical Safety be slow enough to ensure a source detection probability of at committee to modify the Decommissioning Plan least 25% of the guideline level." The calculated scan MDC requirement of alpha scan MDC's below 25% of the for beta surface activity, as specified in Table 3-3 of the Final guideline levels. A copy of this change request has Site Survey Plan (FSSP), is less than 25% of the release been included as an attachment to this Project criteria for gas proportional detectors, but is not less than 25% Document Comment Form. The requirement has of the release criteria for beta friskers. Furthermore, the scan been modified to ensure that alpha scans be MDC for alpha surface activity specified in Table 3-3 of the performed slow enough to ensure that the scan MDC FSSP is 160 dpm/100cm2, which is not less than 25% of the is below the EMC criteria, in this case 300 release criteria. Standard final site survey instrumentation is dpm/1 00cm 2. typically not capable of detecting radioactivity at 25% of the Regulatory Guide 1.86 release criteria when utilized for Beta frisker instrumentation was used to collect FSS scanning, nor is there a regulatory requirement that scanning evaluated data in localized areas where gas instrumentation should be capable of detecting radioactivity at proportional probes were to large. In all cases, the these levels. Please develop and submit a technical basis to beta scan MDC was below the EMC value of 15,000 justify the deviation from the requirements of the DP or revise dpm/1 00cm2.2 the DP accordingly. If you revise the DP, please submit a copy of the revision paperwork. 5 N/A Because your revision to the release criteria that occurred after Material was collected from these two locations the NRC's site visit to account for tritium, please collect and immediately following the completion of the final submit additional measurements around two locations of NRC site inspection. This material was sampled and interest on the bioshield floor (grid location B,1) and bioshield analyzed to develop the Hard To Detect nuclide interior south wall (grid location E, -1), to verify that the fraction and revised release criteria.
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