ML18019A201
| ML18019A201 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/17/2018 |
| From: | Travis Tate Framatome |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| CAC L33364, TJT:18:008 | |
| Download: ML18019A201 (73) | |
Text
framatome January 17, 2018 T JT:18:008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards 11555 Rockville Pike One White Flint North Rockville, MD 20852 Gentlemen:
Subject:
Triennial Update to Decommissioning Funding Plan (DFP) for the Framatome Inc. Richland Nuclear Fuel Fabrication Facility (License No. SNM-1227; Docket No. 70-1257)
Ref. 1. Letter, T. J. Tate to USNRC Document Control Desk; "Triennial Update to Decommissioning Funding Plan (DFP) for AREVA NP lnc.'s (AREVA's) Richland Fuel Fabrication Facility (License No. SNM-1227, Docket No. 70-1257)"; January 29, 2015.
Ref. 2. Letter, N. Baker to T. J. Tate; "Approval of Decommissioning Funding Plan (Cost Activity Code L33364), August 30, 2016.
The purpose of this correspondence to convey an updated DFP for Framatome's Richland nuclear fuel fabrication facility. NRC regulations at 10 CFR 70.25(e) require that decommissioning cost estimates be adjusted at intervals not exceeding three years.
Framatome's last triennial DFP update was submitted via Reference 1 and ultimately approved by the NRC via Reference 2. The Reference 1 DFP provided estimated decommissioning costs as of December 2011. The DFP being submitted at this time provides estimated costs as of December 2014.
The total decommissioning cost estimate is substantially increased over the previous triennial estimate. A portion of that increase is due to expected increases in labor rates, waste disposal costs, and costs of purchased materials and services relative to the actual demolition and decontamination (D&D) tasks. A full listing of noteworthy changes to the DFP and its associated cost estimate is provided in the Nature of Changes section of the document.
The increased cost estimate will necessitate an increase in Framatome's financial assurance coverage. You will note that the financial assurance certification and instruments provided in Sections 7.0 and 8.0 respectively of the DFP have not been Framatome Inc.
2101 Horn Rapids Road Richland, WA 99354 Tel: (509) 375-8100 www.framatome.com J
Document Control Desk January 17, 2018 TJT:18:008 Page 2 included. Framatome's intention is to await the NRC's review and eventual approval of the revised DFP and cost estimate, at which time we will take the necessary actions to revise and fully execute these items. Finalized financial assurance instruments will be incorporated into the finalized DFP for re-submittal to the NRC at that time. This is consistent with the approach utilized in the last completed triennial update cycle.
If you have questions or require additional information, please feel free to contact me at 509-3 7 5-8550.
Very truly yours, T. J. Tate, Manager Environmental, Health, Safety & Licensing
Document Control Desk January 17, 2018 c:
Kevin Ramsey US Nuclear Regulatory Commission Two White Flint North Mail Stop 4 A60 11545 Rockville Pike Rockville, MD 20852-2738
/mah T JT:18:008 Page 3
EHS&L Document E06-04-007 Version 7.0 Page i Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Item
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Paraqraph Document Rewrite EHS&L Document Decommissioning Funding Plan Nature of Changes Description Editorial/technical revisions and updates Justification Triennial update List Below any Documents, including Forms & Operator Aids which must be issued concurrently with this document revision:
This Document contains a total of 70 pages excluding the signature page.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page ii DOCUMENT REVIEW/APPROVAL/DELETION CHECKLIST All new and/or revised procedures shall be approved by the change author, cognizant manager(s) of areas affected by the changes, and by applicable manager(s) of any function that approved the previous revision of the document unless responsibility for such approval has been transferred to another organization. Also, the procedure shall be approved by manager(s) of functional organizations that provide technical reviews with the exception of the Training Department. Finally, Document Control shall verify that the required approvals have been properly obtained and that any documents that must be issued concurrently are ready to be issued.
Document Reviews Document Approvals Specify Reviewer(s)
(Check (Check Purpose/Function of Review (Optional except for all that Title of Approver all that change author) apply)
Apply)
Document Control (Automatic)
[8]
Document Control (Automatic)
[8]
Change Author CD Mannino
[8]
Author
[8]
Independent Technical Review LKim
[8]
Operability Review(s)
Mqr, Richland Operations(1l 0
Conversion 0
Mgr, Uranium Conversion &
0 Recovery 0
Recovery Operations(1l Ceramics 0
Mqr, Ceramic Operations(1l 0
Rods 0
Mgr, Rods & Bundles(1) 0 Bundles 0
Components 0
Mgr, Component Fabrication(1l 0
Maintenance Review 0
Mqr, Maintenance(1l
[8]
Lab Review 0
Mqr, Production Suooort (1l 0
Transportation 0
Mgr, Ops Strategy & Supply Chain 0
EHS&L Review(s)
",i.? ::~ **~:: *:1rr>:; *. *.. :, *.. \\.<
,..* Mgr, EHS&L(2l
[8]
Criticality 0
Mgr, Nuclear Safeti2l 0
Radiation Protection YR Sakach
[8]
Safety 0
Mor, Safetyl"J 0
Security/Emergency Prep.
0 Mgr, Security & Emergency 0
Fire Safety 0
Preparedness(2l MC&A 0
Transportation 0
Mgr, Licensing & Compliance(2l 0
Environmental JB Perryman
[8]
Mechanics Richland Review 0
Mgr, Mechanics Richland 0
Mechanics Lynchburq Review 0
Thermal-Hydraulics Richland Review 0
Mgr, Thermal-Hydraulics Richland 0
Thermal-Mechanics Richland Review 0
Mqr, Materials & Therm-Mechs 0
Project & Reliability Review 0
Mor, Project & Reliability Eno.
0 Quality Review 0
Mgr, Richland Site Quality 0
Purchasinq Review 0
Mgr, PP&CPC 0
Others:
0 Mor, Richland Site/Other
[8]
Document Control 0
Richland Records Management 0
Trainino & Employee Dev.: (3) 0 Traininq & Employee Dev.
0 (1lNote:
(2lNote:
(3lNote:
If approvals include 2 or more product center managers, the Operations manager can be substituted for the applicable product center managers.
If approvals include 2 or more EHS&L functional managers, the EHS&L manager can be substituted for the applicable EHS&L functional managers.
Training department review is required for all procedures that require or affect a Learning Plan and if additional training materials or curriculum must be revised before issuing procedure.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page iii 23371 Rev. 000 12/29/2016 EHS&L CHAN GE IMPACT EVALUATION FORM The scope and content of this document have been determined by EHS&L to not impact the safety disciplines checked below. Future revisions do not require review by those EHS&L component(s) unless the scope changes such that a previously excluded safety discipline may be impacted.
D Criticality D Radiation Protection O Safety/Security O Emergency Preparedness O MC&A O Transportation O Environmental DOCUMENT VERSION:
I EHS&L REVIEW COMPONENT: I EVALUATION DATE:
I CHANGE EVALUATOR*:
2" 0 PARTY APPROVAL*:
The scope and content of this document have been determined by EHS&L to not directly impact the safe handling of D
licensed materials (enriched uranium). Future revisions to this document do not require the 10CFR 70.72 change evaluation unless the scope of the document changes such that it directly impacts the handling of licensed materials.
DOCUMENT/ ECN No**: E06-04-007 I EVALUATION DATE: 1/16/ 18 I CHANGE EVALUATOR: CD MANNING Does the change potentially impact Criticality Alarm System (CAS) coverage?
DYES [3l No EVALUATION OF NRC PRE-APPROVAL:
IS NRC PRE-APPROVAL ( LICENSE AMENDMENT) NEEDED?
~
Based on "YES" answer to any of five questions below.
DYES [3l No
~
Based on "NO" answer to all five questions below.
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Does the change create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 (create high or intermediate consequence events)
DYES [3l No and that have not previously been described in AREVA lnc.'s !SA Summary?
- 2.
Does the change use new processes, technologies, or control systems for which AREVA Inc. has no prior DYES [3l No experience?
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Does the change remove, without at least an equivalent replacem ent of the safety function, an item relied DYES [3l No on for safety (IROFS) that is listed in the !SA Summary?
- 4.
Does the change alter any item relied on for safety, listed in the ISA Summary, that is the sole item DYES [3l No preventing or mitigating an accident sequence of high or intermediate consequences?
- 5.
Does the change qualify as a change specifically prohibited by NRC regulation, order or license condition?
DYES [3l No Evaluation of Actions Required PRIOR TO OR CONCURRENT with Change Implementation:
- 6.
Modification / Addition to CAS system or system coverage documentation DYES [3l No
- 7.
Acquire NRC pre-approval (LICENSE AMENDMENT)
DYES [3l No
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Conduct/modify !SA DYES [3l No
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Modify /
181 None 0 ISA Database 0 NCSA 0 NCSP 0 RHA 0 ChHA update the D Other 0 Red-Line Drawings/P&ID 0 NCSS 0 PHA 0 FHA 0 Procedures following:
Evaluation of Actions Required SUBSEQ.UENTTO Change Implementation:
- 10. Modify/
181 None 0 ISA Database 0 NCSA 0 NCSP 0 RHA 0 ChHA update the 0 Other 0 AS-Built Drawings/P&ID 0 NCSS 0 PHA 0 FHA 0 Procedures following:
Justification Section for "YES" preceding Questions 1-8 or other for 9, 10:
(*)
Only required if one or more of the boxes to exclude a particular safety discipline review is checked.
(**)
If this form exists as a part of a document, the document number is not required.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table of Contents E06-04-007 Version 7.0 Page iv 1.0 Introduction and Summary.............................................................................................. 1 2.0 Decommissioning Criteria................................................................................................ 3 2.1 Uncontaminated Facilities.................................................................................... 3 2.2 Residual Radiation Levels................................................................................... 3 2.3 Records............................................................................................................... 3 2.4 Financial Provisions............................................................................................. 3 3.0 Key Assumptions............................................................................................................. 3 4.0 Facility Description Summary.......................................................................................... 4 4.1 NRC License....................................................................................................... 4 4.2 Authorized Radioactive Materials......................................................................... 5 4.3 Usage of Licensed Materials................................................................................ 5 4.4 Description of Facilities Utilizing Special Nuclear Material................................... 5 4.5 Pre-Shipment/Disposal Waste Accumulations..................................................... 6 5.0 Closure Procedures and Cost Estimates......................................................................... 7 5.1 Production and Production Support Facilities....................................................... 7 5.1.1 Dry Conversion Facility.......................................................................... 7 5.1.2 U02 Building.......................................................................................... 8 5.1.3 Specialty Fuels Building......................................................................... 9 5.1.4 Production Support (Ancillary) Facilities................................................. 9 5.2 Containerized Waste Storage Pads and Inventories.......................................... 25 5.2.1 Container Storage Pad Structures....................................................... 25 5.2.2 Containerized LLRW Inventory............................................................ 34 5.2.3 Containerized Mixed Waste Inventory.................................................. 34 5.3 Environmental Remediation............................................................................... 36 5.3.1 Legacy Surface lmpoundment System................................................. 36 5.3.2 Historic Spills and Releases (Documented)......................................... 37 5.3.3 Potential Soil Contamination Areas...................................................... 37 6.0 Adjustment of Cost Estimates and Funding Level.......................................................... 50 7.0 Certification of Financial Assurance.............................................................................. 51 8.0 Financial Assurance Instruments................................................................................... 52
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan List of Tables E06-04-007 Version 7.0 Page v Table 1 Decommissioning Cost Estimate Summary................................................................... 2 Table 2 Total Dimensions of Facility Components - Production and Production Support Facilities........................................................................................................... 12 Table 3 Planning and Preparation - Production and Production Support Facilities (Work Days).................................................................................................................. 13 Table 4 Decontamination or Dismantling of Radioactive Facility Components -
Production and Production Support Facilities (Work Days)............................................ 14 Table 5 Final Radiation Survey - Production and Production Support Facilities (Work Days).................................................................................................................. 17 Table 6 Total Work Days by Labor Category - Production and Production Support Facilities........................................................................................................... 18 Table 7 Worker Unit Cost Schedule......................................................................................... 19 Table 8 Total Labor Costs by Major Decommissioning Task - Production and Production Support Facilities......................................................................................... 20 Table 9 Shipping and Disposal of Radioactive Wastes - Production and Production Support Facilities (Excluding Labor Costs).................................................. 21 Table 10 Equipment/Supply Costs - Production and Production Support Facilities................... 22 Table 11 Laboratory Costs - Production and Production Support Facilities.............................. 22 Table 12 Miscellaneous Costs - Production and Production Support Facilities......................... 23 Table 13 Total Decommissioning Costs - Production and Production Support Facilities........................................................................................................................ 24 Table 14 Number and Dimensions of Facility Components - Storage Areas............................ 27 Table 15 Planning and Preparation - Storage Areas (Work Days)............................................ 28 Table 16 Decontamination or Dismantling of Radioactive Facility Components -
Storage Areas (Work Days)........................................................................................... 29 Table 17 Restoration of Contaminated Areas on Facility Grounds - Storage Areas (Work Days)........................................................................................................ 29 Table 18 Final Radiation Survey - Storage Areas (Work Days)................................................ 29 Table 19 Total Work Days by Labor Category - Storage Areas................................................ 30 Table 20 Total Labor Costs by Major Decommissioning Task - Storage Areas........................ 31 Table 21 Packaging, Shipping, and Disposal of Radioactive Wastes - Storage Areas (Excluding Labor Costs)...................................................................................... 31 Table 22 Equipment/Supply Costs - Storage Areas (Excluding Containers)............................. 32 Table 23 Laboratory Costs - Storage Areas............................................................................. 32 Table 24 Miscellaneous Costs - Storage Areas........................................................................ 32 Table 25 Total Decommissioning Costs - Storage Areas......................................................... 33 Table 26 Containerized Waste Inventory Costs....................................................................... 35
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 27 Residual Labor Requirements for Final Release of Former Surface E06-04-007 Version 7.0 Page vi lmpoundment Area (Work Days)................................................................................... 39 Table 28 Total Labor Costs for Final Release of Former Surface lmpoundment Area.............................................................................................................................. 39 Table 29 Laboratory and Miscellaneous Costs - Final Release of Former Surface lmpoundment Area........................................................................................................ 40 Table 30 Total Decommissioning Costs - Final Release of Former Surface lmpoundment Area........................................................................................................ 40 Table 31 Labor Requirements - Historic Spills/Releases (Work Days)....................................40 Table 32 Total Labor Costs for Historic Spills/Releases........................................................... 41 Table 33 Laboratory and Miscellaneous Costs - Historic Spills/Releases................................ 41 Table 34 Total Costs - Environmental Remediation for Historic Spills/Releases...................... 41 Table 35 DimensionalNolume Assumptions for Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.................................................. 42 Table 36 Planning and Preparation - Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.............................................................................. 43 Table 37 Environmental Investigation/Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.............................................................................. 44 Table 38 Total Work Days by Labor Category - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping...................................................................................................... 45 Table 39 Total Labor Costs by Major Decommissioning Task - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.............................................................................. 46 Table 40 Packaging, Shipping and Disposal of Radioactive Wastes - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.................................................................... 47 Table 41 Laboratory and Miscellaneous Costs - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping...................................................................................................... 48 Table 42 Total Decommissioning Costs - Potential Soil Contamination Areas -
Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping...................................................................................................... 49
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan List of Exhibits E06-04-007 Version 7.0 Page vii Exhibit 1 - Irrevocable Standby Letter of Credit......................................................................... 52 Exhibit 2 - Standby Trust Agreement........................................................................................ 56
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 1.0 Introduction and Summary E06-04-007 Version 7.0 Page 1 This Decommissioning Funding Plan (DFP) is submitted by AREVA Inc. (AREVA) in compliance with 10 CFR 70.25(c) (2) and contains the information required by 10 CFR 70.25(e).
Furthermore it provides the required [10 CFR 70.25(e)] triennial adjustment of the decommissioning cost estimate, last conveyed to the NRC via Version 6.0 of this plan (January 2015). The DFP was developed using the guidance provided in NUREG-1757, Volume 3, Rev.
1, "Consolidated Decommissioning Guidance".
The DFP establishes decommissioning criteria and key assumptions and outlines the major technical approaches in the decommissioning of all facilities on the AREVA Richland site with a potential for radioactive contamination. This includes the major production facilities, production support facilities, containerized waste storage areas, and contaminated environmental media (soil). Certain portions of the containerized waste storage areas manage wastes that are classified as mixed wastes, i.e., wastes that are radiologically contaminated and also contain chemical constituents that cause them to be designated as dangerous wastes under the State of Washington Dangerous Waste Regulations. The decommissioning/closure procedures and provision of financial assurance for these mixed waste areas are, therefore, intended to meet the pertinent requirements of both the NRC and the Washington State Department of Ecology (Ecology).
The DFP also provides associated decommissioning/closure cost estimates, a commitment for periodic (minimum triennial) cost estimate adjustments, and appropriate evidence of financial assurance via a Financial Assurance Instruments section. The total consolidated decommissioning/closure cost estimate addresses all required costs relative to NRC licensed materials for both the NRC and Ecology and is summarized in Table 1. The Table 1 costs are effective as of December 2017.
The major components of the cost estimate are described in Sections 5.1, Production and Production Support Facilities; 5.2, Containerized Waste Storage Pads, and 5.3, Environmental Remediation. Section 5.1 is further broken down into the major production facilities and production support (ancillary) facilities. Decommissioning the waste storage pads involves decommissioning the pad structures and disposing of the containerized mixed and low level radioactive wastes stored on the pads. Environmental remediation will entail any activities and associated costs to address any environmental contamination that will require remediation during decommissioning to meet the unrestricted use criteria of 10 CFR 20.1402.
Each of the major cost estimate components is presented via a set of tables, as similar as practicable to those in NUREG-1757, which support the estimates. In some cases, e.g.,
dispositioning of the containerized waste inventories, the NUREG-1757 tables are not easily applied; in those cases alternate or modified tables better suited to communicate the pertinent cost data have been used.
A certification that AREVA has obtained financial assurance in an amount sufficient to meet the decommissioning cost estimate is provided in Section 7.0. Evidence of that financial assurance utilizing the letter of credit/standby trust method is provided in Section 8.0.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 2 Table 1 Decommissioning Cost Estimate Summary CateQory Cost Estimate, $
- 1. Production and Production Support Facilities (Table 13) i48,033,688
- 2. Containerized Waste Storage Pads and Inventories A
Storage Area (Pad) Structures (Table 25) 69,757.
B.
LLRW Inventory Disposal (Table 26) 2,924,292 C.
Mixed Waste Inventory Disposal (Table 26) 592,176
- 3. Environmental Remediation A
Legacy Surface lmpoundment Area (Table 30) 265,885 B.
Historic Spills/Releases (Table 34) 14,110 C.
Potential Soil Contamination Areas (Table 42) 1,240,732 Subtotal 53,140,640 25% ContinQency 13,285,160 TOTAL 66,425,800
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 2.0 Decommissioning Criteria E06-04-007 Version 7.0 Page 3 This DFP and associated decommissioning cost estimate for AREVA's Richland Facility, located at 2101 Horn Rapids Road, Richland, Washington (License SNM-1227, Docket 70-1257) have been prepared per the requirements of 10 CFR 70.25 and guidance provided in NUREG-1757, "Consolidated NMSS Decommissioning Guidance, Volume 3", Rev. 1, February 2012.
2.1 Uncontaminated Facilities The disposition of uncontaminated equipment and facilities is not within the scope of this plan, provided that such facilities are verified to be uncontaminated in accordance with approved radiation survey procedures.
2.2 Residual Radiation Levels In accordance with 10 CFR 20.1402, the residual radioactive contamination distinguishable from background radiation for the decontaminated Richland facility shall result in dose levels of less than 25 mrem/yr to the average member of the critical group. Any equipment or facility which cannot be decontaminated to acceptable levels will be demolished, packaged, and disposed of at a licensed low-level radioactive waste (LLRW) or mixed waste disposal site, or alternatively, could be transferred to another licensed facility. Residual environmental contamination will be remediated to levels consistent with the 25 mrem/yr unrestricted use criterion.
2.3 Records Records of the decommissioning procedures and results will be preserved for at least five years, or as required by then-current regulations.
2.4 Financial Provisions Decommissioning of the AREVA Richland facility will be conducted at no cost to the public.
AREVA's provisions for funding of the decommissioning activities are provided in Section 7.0 of this plan.
3.0 Key Assumptions The following key assumptions were used in the preparation of the DFP and cost estimate for the decommissioning of the licensed facilities at AREVA's Richland Facility.
- 1. This DFP assumes the availability of LLRW and mixed waste disposal facilities at reasonable cost and the application of packaging and transportation requirements consistent with existing regulations.
- 2. Prior to the start of final site decommissioning, a detailed decommissioning plan consistent with NRC guidance, including a proposed closeout survey plan, will be submitted to the NRC for approval. The results of the closeout survey shall be approved by the NRC prior to release of equipment or grounds to unrestricted use.
- 3. All work will be performed in compliance with procedures written specifically for the decommissioning activity in conjunction with the detailed decommissioning plan.
- 4. All work inside contaminated areas will be performed using approved radiation work procedures.
- 5. The typical costs associated with decontamination of process equipment and ventilation ductwork for free release are expected to be greater than their salvage value, as well as in
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 4 excess of the cost savings realized by disposal at a non-radioactive waste disposal site. In general, therefore, no attempt at decontamination for this purpose will be made except in special cases when it may be warranted. Contaminated process equipment and ductwork along with other decommissioning-related wastes will typically be disposed of by burial in LLRW disposal sites, and only the facility will be decontaminated.
- 6. The facilities themselves, i.e., the buildings housing activities utilizing licensed materials, will be decontaminated via a combination of physical processes (steamcleaning, sandblasting, scarification, etc.) such that their demolition will not be required to meet the 25 mrem unrestricted use criteria.
- 7. All LLRW generated in the decontamination and/or dismantling of site facilities will be containerized and staged to allow shipment to the U.S. Ecology-operated Northwest Compact LLRW Disposal Site over a two calendar year period. The site operator is limited to a maximum allowable total revenue collection from all facility users over a one year period; this limit is currently at $6.230M as set by the Washington Utilities and Transportation Commission. The disposal cost estimate [(see Table 9b)] conservatively assumes application of the entire disposal site fee for the two year period to AREVA.
- 8. The cost estimate does not take credit for any salvage value that may be realized from the sale of potential assets (e.g., recovered materials or decontaminated equipment) during or after decommissioning.
- 9. The cost estimate does not take credit for reduced taxes that might result from payment of decommissioning costs or site control and maintenance costs.
- 10. The site's uranium inventory is owned by its utility customers and is not considered to be a decommissioning liability. It is AREVA's plan that this inventory will be processed into product and/or returned to the customer prior to processing, in either case prior to the initiation of the decommissioning process. If for unforeseen circumstances there is still customer-owned uranium inventory present at the initiation of decommissioning, this inventory will be reclaimed by its owners at no cost to AREVA.
- 11. For the sake of this DFP and associated cost estimate, the limit for free release of materials, e.g., soil, in which the radioactive contamination is distributed throughout the material matrix, is assumed to be 30 pCi/gram.
- 12. The DFP assumes that the site and associated facilities will be decommissioned via decontamination activities and materials removal/disposal in a manner that will not necessitate stabilization and long-term surveillance programs.
4.0 Facility Description Summary This section provides a facility description as called for in the Facility Description section of Volume 3, Rev. 1, of NUREG-1757. The information supplements the facility description on record (Docket 70-1257) as part of AREVA's NRC special nuclear materials license (SNM-1227) for the Richland site.
4.1 NRC License The AREVA Richland nuclear fuel fabrication facility is operated in accordance with an NRC special materials license issued under 10 CFR Part 70. The license, SNM-1227, is docketed under NRC Docket No. 70-1257 for the Richland site.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 4.2 Authorized Radioactive Materials E06-04-007 Version 7.0 Page 5 NRC License SNM-1227 authorizes AREVA to possess up to 75,000 kg (75 metric tons) of U-235 present in uranium enriched up to 5 wt. % U-235; only 350 g U-235 may be possessed in uranium U-235 enrichments exceeding 5 wt. %. In addition to this NRC license, AREVA has a Radioactive Materials license with the State of Washington, WN-1062-1. The disposal costs associated with the material authorized in this license, other than the sealed sources, is included in this Decommissioning Funding Plan.
4.3 Usage of Licensed Materials The AREVA Richland nuclear fuel fabrication facility utilizes enriched uranium (~5 wt. % U-235) for the production of enriched uranium nuclear fuel for use in commercial light water reactors, both domestically and internationally. Finished fuel assemblies (bundles) are supplied to nuclear utilities for direct usage as fuel in their nuclear power reactors; however intermediate products such as enriched uranium powder or pellets are also produced on behalf of other nuclear fuel cycle facilities.
The typical feed material to the plant is uranium hexafluoride (UF6) received in 30-inch diameter steel cylinders, each containing approximately 1500 kilograms of enriched uranium. Some feed material is Urania or UN solutions received in licensed shipping packages which are unloaded and eventually processed through the appropriate process stream(s). The UF6. UN, and Urania are chemically converted to ceramic grade uranium dioxide (U02) powder. The resultant owders pressed into fuel pellets, which are then sintered and subsequently loaded into fuel rods. These loaded fuel rods, in conjunction with other supporting hardware (tie plates and grid spacers), are assembled into a variety of fuel bundle designs, depending on customer-specific requirements. The fuel products - powder, pellets, or fuel bundles (assemblies) - are loaded for shipment into specially designed shipping containers licensed by the NRC and/or the U.S.
Department of Transportation.
4.4 Description of Facilities Utilizing Special Nuclear Material The AREVA Richland nuclear fuel fabrication plant is located at 2101 Horn Rapids Road just within the northern limits of the City of Richland in Benton County, Washington. More specifically, the facility is located in the approximate center of the more easterly of two adjacent quarter sections (160 acres each) of land owned by AREVA. All facilities storing or processing special nuclear material are located within an approximately 53 acre fenced, secured area; the remainder of the surrounding AREVA property is either devoted to vehicle parking areas, is undeveloped, or is leased for agricultural usage.
The primary production activities involving special nuclear material and state licensed material are conducted in three major facilities - the Dry Conversion Facility; the Uranium Dioxide (U02)
Building, which includes the Blended Low-Enriched Uranium (BLEU) addition; and the Specialty Fuels (SF) Building. The specific functions of these facilities, the general approach to their decommissioning, and the associated decommissioning cost tables are provided in Section 5.1, Production and Production Support Facilities, of this DFP.
The primary production facilities are supported by a number of ancillary support facilities that also entail the storage or handling of SNM or SNM-containing materials. These facilities are most typically involved with materials storage (feed materials, product intermediates, or finished product) or waste processing functions but also provide a number of other miscellaneous production support functions, e.g., purification of contaminated fuel scrap, laundering of contaminated clothing, and recertification of UF6 shipping cylinders. A listing of these facilities and their functions, the general assumptions/approach pertinent to their decommissioning, and the associated decommissioning cost tables are also provided in Section 5.1 of this DFP.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 6 The major containerized solid waste storage pads consist of two asphalted areas managing currently generated and legacy containerized (barreled or boxed) wastes. These facilities are distinguished by their large spatial size and the fact that they may manage mixed wastes, i.e.,
wastes that are both radiologically contaminated and chemically hazardous. These facilities are therefore simultaneously subject to the decommissioning requirements of the NRC and, for those portions managing chemically hazardous wastes, the closure requirements of the Washington State Department of Ecology. The inventory disposition and closure approach pertinent to the containerized waste pads are addressed in Section 5.2 of this DFP.
In addition to the facilities themselves as discussed above, operation of the site offers the potential for contamination of the land (soil) below and/or around those facilities. That contamination may have resulted from releases from the facilities or from releases/spills associated with the transfer of licensed materials between facilities, e.g., piping leaks, container spills, etc.
The most significant area of known soil contamination on the AREVA Richland site was the area associated with operation of the legacy surface impoundment system. Known liquid releases from at least three of the six impoundments in the 1970s - early 1980s resulted in contamination of the soils underlying these units with uranium as well as certain chemicals (fluorides, nitrates, ammonia). The surface impoundment system has been removed and associated radiological and non-radiological soil contamination remediated to meet Washington Department of Ecology (Ecology) soil cleanup levels for uranium and regulated chemical constituents. Additional soil remediation to meet NRC radiological decommissioning criteria is not anticipated to be necessary.
Less significant instances of soil contamination with licensed materials have occurred from documented spills/releases over the course of the plant's operating history. These contamination incidents have typically been small and remediated at the time of occurrence but in some cases the potential for residual contamination (detected or undetected) remains. These areas are documented in decommissioning records maintained by AREVA in accordance with 10 CFR 70.25(g).
Also addressed are two potential soil contamination areas that have not been characterized but that may, based on operating history, impose soil contamination levels requiring remediation.
The two areas are the soil underlying current and historic wet chemical processing areas within the U02 Building and soil underlying current and historic underground piping carrying uranium-bearing solutions.
Decommissioning obligations and associated costs relative to environmental remediation are discussed in Section 5.3. These include residual decommissioning-related final survey costs associated with the remediated surface impoundment area, potential characterization/
remediation costs associated with certain spills/releases documented in required decommissioning records, and estimated characterization/remediation costs postulated for the two uncharacterized potential soil contamination areas discussed above.
4.5 Pre-Shipment/Disposal Waste Accumulations With the elimination of the site's historic surface impoundment system, current liquid waste processing is very closely coupled to production, using relatively small volume tanks.
Temporary accumulation of liquid SNM-containing wastes from production activities is very limited with respect to time and volume and an insignificant contributor to the overall plant decommissioning liability.
Current inventories of containerized solid wastes (low-level radioactive and mixed) and their associated disposition costs are provided in Table 26. Based on the site's continued progress
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 7 in working down its legacy backlog of stored wastes, current inventories are no longer necessarily higher than possible maximum foreseeable inventories in the future. Therefore in addition to current inventories, Table 26 provides estimates of maximum anticipated volumes in each solid waste category. These higher inventory volumes have been conservatively utilized to estimate disposal cost liabilities.
Accumulated volumes of low-level radioactive waste (LLRW) generated by the actual decommissioning activities will be dispositioned to LLRW disposal and/or recycle facilities.
These waste volumes are presented in Table 9. Disposal volumes related to postulated environmental remediation activities are included in Table 40. As noted in Section 3.0, Key Assumptions, No. 7, the waste volumes set forth in Tables 9 and 40 will be containerized and staged over the course of the decommissioning/remediation activities and then all shipped to the LLRW disposal site over a two year period.
5.0 Closure Procedures and Cost Estimates This section outlines the major technical approaches involved in the decontamination and decommissioning of each major facility with a significant potential for radiological contamination.
In the case of the containerized waste storage areas, the DFP also extends to the onsite waste inventory associated with these units. Minor ancillary facilities such as external docks, grounds, and warehouses, where contamination is not anticipated but may be found, will be decontaminated in a similar fashion as the known-contaminated facilities described herein.
Certain portions of the containerized waste storage areas may manage mixed wastes, i.e.,
wastes that are radiologically contaminated and also contain chemical constituents that cause them to be designated as dangerous wastes under the State of Washington Dangerous Waste Regulations. These wastes are dually regulated by the NRC and Ecology and the units are subject to the decommissioning requirements of the NRC (10 CFR 70.25) and the closure requirements of Ecology (WAC 173-303-610 and 650). Detailed decommissioning procedures written pursuant to this DFP and closure plans/procedures developed pursuant to Ecology's regulations will jointly address the requirements of both regulatory agencies with respect to the mixed waste areas.
Environmental remediation costs apart from costs associated with the decommissioning of site structures are not anticipated to be significant by comparison. Environmental remediation-related approaches and costs are discussed in Section 5.3.
5.1 Production and Production Support Facilities The production activities at the AREVA Richland facility encompass the full scale of nuclear fuel fabrication, i.e., chemical conversion of UF6 to U02 powder, U02 pellet production, rod loading, and fuel bundle assembly. These activities occur in three major production facilities, namely the Dry Conversion Facility; the U02 Building, including the Blended Low Enriched Uranium (BLEU) addition; and the Specialty Fuels Building. The major production activities are supported by a number of production support, or ancillary, facilities. The general approach to decommissioning these facilities, along with the associated costs, is described below. The associated cost estimates are shown in Tables 2 through 13.
5.1.1 Dry Conversion Facility The Dry Conversion Facility (DCF) houses the head-end processes for the Richland plant's nuclear fuel fabrication activities, namely the vaporization of UF6 out of Model 30-8 cylinders using electrically-heated autoclaves, the conversion of the UF6 vapor to dry U02 powder in fluidized bed reactors, final defluoridation of the powder in calciners, and the physical
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 8 preparation (milling, compacting, etc.) of the powder for subsequent pellet pressing. Major aspects of the decommissioning of the DCF are as follows:
- 1. All process equipment in the various contaminated areas of the building will be surveyed to determine the degree of contamination. Equipment with contamination which is below acceptable release levels can be disposed of on a commercial basis at non-radiological disposal facilities. Equipment which is contaminated to levels above such release levels will be decontaminated if warranted, and packaged for shipment. Such equipment contaminated above free release levels will be shipped to an appropriate low-level radioactive waste disposal site or alternatively, could be transferred to another licensed facility.
Liquid effluent systems exiting radiation zones will be treated in the same manner as process equipment in the contaminated areas.
Sufficient radiation surveys of process equipment outside the contaminated areas will be made to assure that unacceptable levels of contamination have not spread outside the contaminated operating areas. Non-contaminated process equipment outside the contaminated areas can be disposed of on a commercial basis at non-radiological disposal facilities or can be left in place to support the mission of associated decontaminated facilities.
- 2. All contaminated exhaust ductwork will be treated in a manner similar to the contaminated process equipment as described in item 1 above. The final filter bank of the ventilation system will also be disposed of by burial.
- 3. After removal of all process equipment, ancillary equipment, and exhaust ducting, the facility ceiling and walls will be cleaned as necessary. The cost estimate for this work is based on sandblasting. The typical wall materials (painted concrete and painted cement block) and ceiling materials (metal panels) are amenable to coating removal and decontamination via sandblasting. Porous, non-durable wall coverings such as gypsum wallboard are uncommon and are present in noteworthy quantities only within two production facilities (U02 and Specialty Fuels Buildings) and a single production support facility (ELO Building).
The total packed disposal volume for the potentially radioactively contaminated portion of this material is relatively small (~2,500 ft3) and is included in the packed disposal volumes provided in Table 2.
- 4. The floors of the controlled areas will be stripped of all protective coatings and appropriately cleaned. Solvents, if used, will be selected such that they will not cause materials to be designated as dangerous wastes under the State of Washington Dangerous Waste Regulations. The cost estimates for floor decontamination assume the utilization of mechanical scarification. Due to the fact that the floors are in most cases coated with some type of sealant, less aggressive surface decontamination techniques may suffice for large areas of the facility, making scarification a conservative assumption.
- 5. A radiation survey described in the decommissioning plan will be completed to verify that areas are successfully decontaminated.
- 6. After NRC approval of the radiation survey results, the entire affected area may be resurfaced as appropriate.
5.1.2 U02 Building The U02 Building houses the majority of AREVA's nuclear fuel fabrication process downstream of the Dry Conversion Facility, i.e., pellet pressing to final fuel bundle assembly. The building also houses the Richland plant's one remaining "wet" chemical conversion (ammonium
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 9 diuranate) production line, now utilized strictly for uranium scrap recovery. The activities (excluding the ADU conversion-related activities) are broadly grouped into two categories as follows:
Ceramics, including additive blending, pellet pressing, pellet sintering, pellet grinding and pellet inspection; and Rod Fabrication/Bundle Assembly, including rod loading; rod welding, leak checking, assaying, and x-raying; rod inspection; bundle assembly; and bundle inspection, cleaning, and packaging.
These ceramics and rod fabrication/bundle assembly activities include those performed in the traditional portions of the U02 Building as well as those more recently added (2004) to accommodate processing of BLEU material.
Other miscellaneous support facilities located within the U02 Building include the U308 Facility, Powder Storage Facility, Powder Dissolution Facility, Pellet Dissolution Facility, Miscellaneous Uranium Recovery (MURS) Facility, Powder Characterization Facility, UF6 cylinder wash facility,
, Quality Control Analytical/Testing Laboratories, Waste Volume Reduction Facility (VRF), and "hot" maintenance facilities.
Decontamination and decommissioning of the U02 Building will be accomplished via an approach consistent with that described for the Dry Conversion Facility with one exception. The cost estimate includes enhanced approaches to address potential floor contamination in historic and current wet chemical processing areas, including deeper floor scarification or concrete removal.
5.1.3 Specialty Fuels Building The Specialty Fuels (SF) Building houses fuel fabrication activities related to the production of fuel containing gadolinia (Gd203) as a neutron poison. The activities include the blending of U02 powder, produced in the Dry Conversion Facility or U02 Building, with purchased Gd203; powder preparation and additive blending; pellet pressing; pellet sintering; and pellet grinding. Loading of gadolinia-containing pellets into rods occurs in the U02 Building. Also located in the SF Building is the Solid Waste Uranium Recovery (SWUR) Incinerator Facility.
Decontamination and decommissioning of the SF Building will be accomplished via an approach consistent with that described for the Dry Conversion Facility and U02 Building.
5.1.4 Production Support (Ancillary) Facilities In addition to the Dry Conversion Facility and the U02 and SF Buildings, a number of other facilities are involved with enriched uranium handling and processing in varying degrees, and will, therefore, require decontamination/decommissioning efforts commensurate with those activities. The facilities, along with a brief summary of their associated enriched uranium/
radionuclide-handling activities, are as follows:
- 1. Engineering Laboratory Operations (ELO) Building - process development laboratories, Gadolinia Scrap Uranium Recovery (GSUR) Facility (fuel scrap dissolution and solvent extraction activities), decontamination area, and hot maintenance area.
- 2. Contaminated Clothing Laundry - laundering of contaminated protective clothing.
- 3. Fuels Storage Warehouse (Warehouse 4) - storage of packaged special nuclear material in various compounds and forms.
- 4. UNH Drum Storage Warehouse - storage of closed drums of uranyl nitrate liquid awaiting processing.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 10
- 5. Uranium Storage Warehouse (Warehouse 6) - past storage of packaged special nuclear material in various compounds and forms; currently devoted to non-SNM processing/storage activities.
- 6. Operations Scrap Warehouse (Warehouse 7) - storage of closed containers of uranium-containing feed materials, product, or scrap awaiting processing.
- 7. Product Development Test Facility (PDTF) - LOCA heat transfer, seismic, and coolant flow testing of nuclear fuel assemblies.
- 9. Lagoon Uranium Recovery (LUR) Facility - past recovery of uranium from liquid process wastes; no current SNM-related activities.
- 10. Solids Processing Facility (SPF) - an addition to LUR containing equipment for recovery of uranium from contaminated sludges.
- 11. Silicon Removal Process (SRP) - equipment housed at LUR/SPF to remove silicon from low-U liquid effluents before treatment in the Ammonia Recovery Facility.
- 12. Modular Extraction Recovery Facility (MERF) - recovery of uranium from certain solid phase low-level radioactive and mixed wastes.
- 13. Wastewater Treatment Facility - includes the traditional Ammonia Recovery Facility (ARF) for the recovery of ammonium hydroxide from high-ammonia-content liquid process wastes; the filtration and ion exchange (IX) systems for removal of trace levels of uranium from the plant's final sewered effluent, including equipment to flush and regenerate these systems; and wastewater tanks for interim management of the site's contaminated liquid effluents.
- 14. Fuel Services Facility (Building 9) - disassembly of contaminated fuel bundles; waste handling/packaging activities; miscellaneous production-support activities.
- 15. Cylinder Recertification Facility (CRF) - testing and recertification of UF6 cylinders.
- 16. Warehouse 2 - storage/loading of packaged special nuclear material in various compounds and forms.
- 17. Uranyl Nitrate Building (UNB) - receipt of uranyl nitrate (UN) solution from offsite sources (download from shipping containers) and onsite sources (pipeline transfer) with subsequent storage of the UN in tanks while awaiting transfer to the U02 Building for conversion to U02.
The same basic plan as outlined above for the major production facilities will be implemented, as necessary, in the decontamination and decommissioning of these ancillary facilities.
Assumptions specific to ancillary facilities are as follows:
- 1. The following facilities contain contaminated equipment to be disposed of and, based on the nature of their operations, will likely require decontamination of the facility and supporting structures prior to release.
ELO (process areas)
LUR/SPF/SRP MERF Fuel Services Building (Building 9) process area WWTF (ARF process sump areas only)
Laundry
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 11
- 2. The following facilities contain contaminated equipment to be disposed of, but no significant contamination of the facilities themselves is anticipated because the radioactive material was well contained in equipment or in closed containers:
WWTF (exclusive of ARF process sump areas)
Cylinder Recertification Facility Uranyl Nitrate Building
- 3. The following facilities contain neither contaminated equipment requiring disposal nor significant levels of structural contamination because they contain, or previously contained, radioactive material exclusively in closed containers.
Operations Scrap Warehouse (Warehouse 7)
UNH Drum Storage Warehouse Boron Pellet Production Facility (a.k.a. Warehouse 6, this building was formerly used for Uranium Oxide Storage in inner shipping_packages, 5-gallon buckets and 45-gallon powder storage drums.)
PDTF Fuels Storage Warehouse (Warehouse 4)
UF6 Receiving and Storage Facility Warehouse 2
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 12 Table 2 Total Dimensions of Facility Components - Production and Production Support Facilities Level of Contamination: <2000 dpm/100 cm 2
Production Facilities Components Total Dimensions Dry Conversion Floors 17,818ff Facility Walls 46,179 ft2 Ceilings 20,611 ft2 Equipment/Components/Wallboard 4,301 ft 3 (packaged for disposal)
U02 Building, Floors 116,269 ftL including BLEU
- Walls 268,606 ft2 Ceilings 135,355 ft2 Equipment/Components/Wallboard 20,786 ft3 (packaqed for disposal)
Specialty Fuels Floors 13,540 ftL Building
- Walls 52,804 ft2 Ceilings 15,825 ft2 Equipment/Components/Wallboard 6,929 ft3 (packaqed for disposal)
Production Support Components Total Dimensions Facilities WWTF (ARF Sumps Floors 527 ff Only)
LUR/SPF/SRP Floors 6,165 ffl Building
- Walls 25,823 ft2 Ceilings 6,673 ft2 ELO Building Floors 8,772 ft2 (process areas)
Walls 19,743 ft2 Ceilings 8,770 ft2 MERF Floors 2,045 ft2
- Walls 5,091 ft2 Ceilings 2,045 ft2 Fuel Services Floors 5,305 ft2 Building (Building 9)
- Walls 10,361 ft2 (process area)
Ceilings 5,455 ft2 Laundry Floors 299 ft.!
Walls 690 ft2 Ceilings 299 ft2 All Production EquipmenUcomponents/wallboard 10,323 ft 3
Support Facilities from all production support facilities (packaged for disposal)
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 13 Table 3 Planning and Preparation - Production and Production Support Facilities (Work Days)
Estimate of the number of work days, by specific labor category, that will be required to I
I d
f f T compete panning an prepara 10n ac 1v1 1es.
Safety Health and Engineer Safety NRC Crafts Laborer -
Activity Engineer Work Technician Work Work Work Work Days Days Work Days Days Days Days Preparation of Documentation for 181 Regulatory Agencies Submittal of Decommissioning Plan to NRC when required 27 25 by 10 CFR 30.36(g)(1),
40.42(g)(1 ), or 70.38(q)(1)
Development of Work 44 Plans Procurement of Special 44 Equipment/Services Staff Training 10 20 40 40 Characterization of Radiological Condition of the Facility (including sampling, soil and 482 tailings analysis, or groundwater analysis if applicable)
TOTALS 218 88 502 25 40 40
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 14 Table 4 Decontamination or Dismantling of Radioactive Facility Components - Production and Production Support Facilities (Work Days)
Estimate of the number of workdays, by specified labor category that will be required to complete the specified decontamination and/or dismantling activities.
Name of room, laboratory, or area: Dry Conversion Facility Level of Contamination: <2000 dpm/100 cm2 Health and Component Decon.
Engineer Crafts Laborer Safety Method Work Days Work Days Work Days Technician Work Days Preparation/
56 Mobilization Equipment/
Component 478 478 Removal Floors Scarification
$47,330 (See Table 12)
Walls/
Sandblast Estimated @$4.16/ft2 (See Table 12) = $277,847 Ceilings Remedial Radiation 208 Surveys QNQC 25 TOTALS 25 478 534 208
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 15 Table 4 Decontamination or Dismantling of Radioactive Facility Components - Production and Production Support Facilities (Work Days) (cont.)
Estimate of the number of workdays, by specified labor category that will be required to complete the specified decontamination and/or dismantling activities.
Name of room, laboratory, or area: U02 Building, including BLEU Level of Contamination: <2000 dpm/100 cm 2 Health and Component Decon.
Engineer Crafts Laborer Safety Method Work Days Work Days Work Days Technician Work Days Preparation/
276 Mobilization Equipment/
Component 1,766 1,766 Removal Floors Scarification
$485,090 (See Table 12)
Walls/
Sandblast Estimated@ $4.16/ft2 (See Table 12) = $1,680,479 Ceilings Remedial Radiation 1,098 Surveys QA/QC 129 TOTALS 129 1,766 2,042 1,098
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 16 Table 4 Decontamination or Dismantling of Radioactive Facility Components - Production and Production Support Facilities (Work Days) (cont.)
Estimate of the number of workdays, by specified labor category that will be required to complete the specified decontamination and/or dismantling activities.
Name of room, laboratory, or area: Specialty Fuels Building Level of Contamination: <2000 dpm/100 cm2 Health and Component Decon.
Engineer Crafts Laborer Safety Method Work Days Work Days Work Days Technician Work Days Preparation/
103 Mobilization Equipment/
Component 873 873 Removal Floors Scarification
$35,966 (See Table 12)
Walls/
Sandblast Estimated @ $4.16/ft2 (See Table 12) = $285,497 Ceilings Remedial Radiation 510 Surveys QA/QC 30 TOTALS 30 873 976 510
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 17 Table 4 Decontamination or Dismantling of Radioactive Facility Components - Production and Production Support Facilities (Work Days) (cont.)
Estimate of the number of workdays, by specified labor category that will be required to complete the specified decontamination and/or dismantling activities.
Name of room, laboratory, or area: Production Support (Ancillary) Facilities Level of Contamination: <2000 dpm/100 cm 2
Health and Component Decon.
Engineer Crafts Laborer Safety Method Work Days Work Days Work Days Technician Work Days Preparation/
157 Mobilization Equipment/
Component 927 927 Removal Floors Scarification
$105,422 (See Table 12)
Walls/
Sandblast Estimated @ $4.16/ft2 (See Table 12) = $353,394 Ceilings Remedial Radiation 276 Surveys QA/QC 43 TOTALS 43 927 1,084 276 Table 5 Final Radiation Survey - Production and Production Support Facilities (Work Days)
Estimate of the number of work days, by specific labor category that will be required to conduct a final radiation survey.
Activity Health and Safety Technician Work Days Final Survey 628 TOTAL 628
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 6 Total Work Days by Labor Category - Production and Production Support Facilities E06-04-007 Version 7.0 Page 18 Total work days estimated for each specific labor category from the applicable tables above (i.e., from Tables 3 through 5) plus total work days associated with overall project support functions (non-task-specific).
Safety Senior Engineer Health and Clerical Crafts Laborer NRC Support Health Activity Project Engineer Engineer Work Safety Work Work Work Work Technician Physicist Manager Work Work Days Technician Days Days Days Days Work Days Work Days Days Work Days Days Planning and Preparation (TOTALS 218 88 502 40 40 25 from Table 3)
Decontamination and/or Dismantling of Radioactive Facility 227 2,092 4,044 4,636 Components (Sum of TOTALS from Table 4)
Operation of Waste Volume Reduction 4,680 Facility Final Radiation Survey 628 (TOTAL from Table 5)
Project Administration 1,040 1,040 1,040 1,040 1,040 1,040 (6 FTE)
Craft Support - Plant 2,340 Operations (3 FTE)
Technician Support -
Plant Operations (4 3,120 FTE)
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 7 Worker Unit Cost Schedule E06-04-007 Version 7.0 Page 19 Fully burdened billing rates (wages, benefits, overheads, and profits) from State of Washington-based third party contractors (with exception of NRC).
Labor Category Labor Rate, $/hr.
Labor Rate, $/day*
Project Manager 119.32 955 Senior Engineer 102.40 819 Engineer 76.80 614 Health and Safety Technician (HST) 48.00 384 Health Physicist 111.18 889 Safety Engineer 72.40 579 Crafts (D&D) 93.47 748 Crafts - Plant Operations Support 88.92 711 Equipment Operator 57.91 463 Laborer 53.09 425 Technician - Plant Operations Support 53.15 425 Clerical 38.30 306 NRC 279.00 2,232
- Eight hour day; rounded to the nearest dollar.
~
EHS&L Document E06-04-007 Environmental Protection - Miscellaneous Reports Version 7.0 Decommissioning Funding Plan Page 20 Table 8 Total Labor Costs by Major Decommissioning Task - Production and Production Support Facilities Estimated work days for each specific labor category (from Table 6) multiplied by the total cost per work day for the corresponding labor category (from Table 7). Costs for Craft Support - Plant Operations and Technician Support - Plant Operations based on full time equivalent staffing (FTE) as indicated and composite labor rates reflecting staffing mix.
Health Technician Project Safety Senior Engineer and Health Clerical Crafts Laborer Plant NRC Total Labor Task Manager Engineer Engineer Cost, $
Safety Physicist Cost, $
(Avg.)
Cost, $
- Support, Cost, Cost, $
Cost, $
Cost, $
Cost, $
Tech.
Cost, $
Cost, $
Cost, $
Cost$
Planning and 126,222 54,067 192,768 29,910 16,989 55,860 475,816 Preparation Decontaminati on or Dismantling of 139,468 803,328 3,023,941 1,970,300 5,937,037 Radioactive Facility Components Operation of Waste Volume 1,989,000 1,989,000 Reduction Facility Final Radiation 241,152 241,152 Survey Project Administration 993,200 602,160 851,760 638,560 925,018 318,656 4,329,3564 (6 FTE)
Craft Support -
Plant 1,664,582 1,664,582 Operations (3 FTE)
Technician Support - Plant 1,451,424 1,451,424 Operations (4 FTE)
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 21 Table 9 Shipping and Disposal of Radioactive Wastes - Production and Production Support Facilities (Excluding Labor Costs)
Note: Labor costs for waste packaging included in Table 8 under Operation of Waste Volume Reduction Facility. Labor costs for shipping activities are included in Table 12 under Logistics/
Shipping Support.
(a) Packing Material Costs Estimate of the types and volumes of waste expected to be generated, along with the number and types of containers required for packing the waste.
Number of Type of Unit Cost of Total Waste Type Volume (ft3)
Packaging Containers Container Container, $
Costs, $
Bldg. Waste 42,338 455 93 ft3 Box 1,810 823,550 Boron spider 1,418 16 28,960 drums (compacted)
Contaminated shipping 400 5
9,050 container (compacted) components TOTAL 44,156 476 861,560 (b) Shipping and Disposition Costs Estimate of the volume of waste to be disposed and the shipping and disposal costs.
Waste Type Disposition Volume or Disposition Costs, $
Shipping Cost, $
Weight (as indicated)
Containerized Waste 44,156 ft3 12,460,000*
568,000**
for Burial 30-B Cylinders (melt, 478,800 lbs.
1,661,436 186,000**
reuse TOTAL 14,121,436 754,000
- Assumes all wastes accumulated/staged for disposal over two calendar year period at maximum allowed waste site revenue collection of $6,230,000/yr. (see Section 3.0, Key Assumptions)
- This is for total cost, actual transport plus TN labor of about $6,500 per truck to support the shipments.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 22 Table 10 Equipment/Supply Costs - Production and Production Support Facilities (Excluding Containers)
Estimate of the quantity of equipment and supplies required for decommissioning.
Equipment/Supplies Total Equipment/Supply Cost, $
Miscellaneous Decommissioning-Related 420,200 Tools/Equipment/Consumable Supplies TOTAL 420,200 Table 11 Laboratory Costs - Production and Production Support Facilities Estimate of costs for analyses to be performed by an independent third-party laboratory.
Activity Total Cost, $
Lab analysis costs 180,960 TOTAL 180,960
' \\
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 23 Table 12 Miscellaneous Costs - Production and Production Support Facilities Estimate of any other applicable costs.
Cost Item Total Cost, $
State/Local Regulatory Fees 77,000/yr x 3 yr. = 231,000 Insurance 1, 144,000/yr x 3 yr. = 3,432,000 Taxes 1,994,000 NRC Inspections 90,000/yr x 3 yr. = 270,000 Sandblasting Walls/Ceilings 2,597,216 Scarifying Floors 673,808*
Certification Survey 115,000 Logistics/Shipping Support 298,200 Security 965, 120/yr. x 3 yr. = 2,895,360 Utilities (electricity, water, sewer) 975,000 X 3 yr. = 2,925,000 IT Support 175,581 TOTAL 15,607,165 Totals from Table 4.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 24 Table 13 Total Decommissioning Costs - Production and Production Support Facilities Total of the reported costs in Tables 8, 9, 10, 11 and 12.
Task/Component Cost, $
Planning and Preparation 475,816 (TOTAL from Table 8)
Decontamination and/or Dismantling of Radioactive Facility Components 5,937,037 (TOTAL from Table 8)
Operation of Waste Volume Reduction Facility 1,989,000 (TOTAL from Table 8)
Final Radiation Survey 241, 15 (TOT AL from Table 8)
Project Administration Costs 4,329,356 (TOTAL from Table 8)
Craft Support - Plant Operations Costs 1,664,582 (TOTAL from Table 8)
Technician Support - Plant Operations Costs 1,451,424 (TOTAL from Table 8)
Packing Material Costs 861,560 (TOTAL from Table 9a)
Shipping 754,000and Disposition Costs (14,121,436) 14,875,436 (TOTAL from Table 9b)
Equipment/Supply Costs 420,200 (TOTAL from Table 10)
Laboratory Costs 180,960 (TOTAL from Table 11)
Miscellaneous Costs 15,607,165 (TOTAL from Table 12)
TOTAL - Production and Production Support Facilities 48,033,688
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 5.2 Containerized Waste Storage Pads and Inventories E06-04-007 Version 7.0 Page 25 Containerized (barreled or boxed) operational wastes are managed on an ongoing basis at two significant container storage areas at the Richland facility - an uncovered asphalt pad located in the central portion of the site, often referred to as the "old" or "historic" dangerous waste storage pad; and a newer, partially covered asphalt pad, located in the southeast corner of the site, and referred to as the Dangerous Waste Storage Facility (DWSF). Both pads manage containerized low-level radioactive waste (LLRW) and also manage, or have managed, LLRW that also designates as chemically dangerous per Ecology's Dangerous Waste Regulations (WAC 173-303), i.e., mixed wastes. As such, these waste management units, all or in part, are subject to both the NRC's decommissioning requirements and Ecology's closure requirements, as well as the financial assurance requirements of both agencies.
The decommissioning/closure of the containerized waste storage pads will involve disposition of the containerized inventories followed by decommissioning/closure of the physical structures.
Current plans call for utilization of both pads for the management of LLRW until time of plant closure, meaning that NRC decommissioning will not occur before then. With respect to mixed waste management, nearly all of the historic dangerous waste pad has been closed per Ecology regulations now that AREVA has completed its disposition of the large volume of legacy containerized mixed wastes once stored on the historic pad. Management of LLRW and mixed wastes on the newer DWSF will continue until time of plant closure, at which time AREVA will pursue Ecology closure of the DWSF plus the small unclosed portion of the historic pad. At that time, decommissioning of both pads will also be pursued per NRC requirements.
5.2.1 Container Storage Pad Structures Physical structures associated with the container storage pads (historic pad and DWSF) consist of the blacktop pads at both locations, a limited number of double containment storage pallets, and the roofed three-sided storage building at the DWSF. Contamination levels (radiological or chemical) are expected to be minimal at both locations based on the fact that the pads manage for the most part solid phase wastes in securely closed strong-tight containers. Outside surfaces of the containers have undergone appropriate radiological release surveys.
Furthermore, the containers are subject to routine operational inspections. The need for remediation of surrounding or underlying soil to any significant extent is also not anticipated but soil status will be verified via appropriate screening/sampling protocols. Prior (September 2004) closure of a significant portion of the historic waste pad under Ecology regulations confirmed the lack of surface and soil contamination associated with this longstanding operation.
Major aspects of the decommissioning/closure of the container storage pads and associated equipment/facilities are as follows:
radiological surface screening measurements at a detection sensitivity sufficient to detect past releases from containers to the blacktop or surrounding peripheral soils; removal of any asphalt with evidence of radiological contamination to allow similar screening of underlying soil; chemical constituent sampling of any underlying or peripheral soils found to be radiologically contaminated; removal/disposal of contaminated blacktop and/or soils in accordance with NRG/Ecology cleanup criteria; surveying/decontamination/release of double containment pallets, and; replacement of removed asphalt with non-contaminated material.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 26 Final release of the pad structures will be subject to the final release survey requirements of both the NRC and Ecology. Costs associated with closure/decommissioning of the waste storage pad structures are summarized in Tables 14-25.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 27 Table 14 Number and Dimensions of Facility Components - Storage Areas N
f I b ame o room, a oratory, or area: 0 td u oor C t.
. d W t St on a1nenze as e orage A reas Component Number of Dimensions of Total Dimensions, ft2 Components Components Asphalt Pad - Old 1
72' x 133 ' + 45' x 169' 17,181 Asphalt Pad - DWSF 1
120' X 170' 20,400 Double Containment 20 4' x4' 320 Pallets
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 15 Planning and Preparation - Storage Areas (Work Days)
E06-04-007 Version 7.0 Page 28 Estimate of the number of work days, by specific labor category, that will be required to It I
d f
fT comp e e panning an prepara 10n ac 1v1 1es.
Safety Health and Activity Engineer Engineer Safety Laborer Work Days Work Days Technician Work Days Work Days Preparation and Submittal of Documentation for Regulatory Agencies Submittal of Decommissioning Plan to NRC when required by 10 CFR 30.36(g)(1 ),
40.42(g)(1 ), or 70.38(g)(1)
Development of Work 2
Plans/Safety Plans Procurement of Special 2
Equipment Staff Training 1
1 1
Characterization of Radiological Condition of the Facility (including sampling, 4
10 4
soil and tailings analysis, or groundwater analysis if applicable)
Other (specify)
TOTALS 3
6 11 5
Labor costs relative to NRC licensed materials included in Decommissioning Plan for Production and Production Support Facilities (Table 3). Closure plan for Ecology-regulated areas already on file with Ecology.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 29 Table 16 Decontamination or Dismantling of Radioactive Facility Components - Storage Areas (Work Days)
Estimate of the number of workdays, by specified labor category that will be required to complete decontamination and/or dismantling activities for each facility component.
Name o f I b room, a oratory, or area: w aste s torage A reas Component Health and Safety Technician Laborer Work Days Work Days Asphalt Pads 1
2 Double Containment Pallets 5
TOTALS 6
2 Table 17 Restoration of Contaminated Areas on Facility Grounds - Storage Areas (Work Days)
Estimate of the number of work days, by specific labor category that will be required to restore t
t d f
Tt d
con am1na e areas on ac1 1 ty groun S.
Activity Laborer Work Days Waste Storage Areas 3
TOTAL 3
Table 18 Final Radiation Survey - Storage Areas (Work Days)
Estimate of the number of work days, by specific labor category that will be required to conduct f
I
- d. r a ina ra 1a 10n survey.
Engineer Health and Safety Laborer Activity Work Days Technician Work Days Work Days Survey 30 Sampling Labor 2
2 TOTALS 2
30 2
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 19 Total Work Days by Labor Category - Storage Areas E06-04-007 Version 7.0 Page 30 Total work days estimated for each specific labor category from the applicable tables above (i.e., from Tables 15 through 18).
Safety Health and Engineer Safety Laborer Activity Engineer Work Days Technician Work Days Work Days Work Days Planning and Preparation 3
6 11 5
(TOTALS from Table 15)
Decontamination and/or Dismantling of Radioactive Facility 6
2 Components (Sum of TOTALS from Table 16)
Restoration of Contaminated Areas on 3
Facility Grounds (TOTAL from Table 17)
Final Radiation Survey 2
30 2
(TOTALS from Table 18)
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 31 Table 20 Total Labor Costs by Major Decommissioning Task - Storage Areas Estimated work days for each specific labor category (from Table 19) multiplied by the total cost per work day for the corresponding labor category (from Table 7).
Safety Health and Engineer Safety Laborer Total Labor Task Engineer Cost, $
Technician Cost, $
Cost, $
Cost, $
Cost,$
Planning and 1,737 3,684 4 224 2,125 11,770 Preparation Decontamination or Dismantling of 2,304 850 3,154 Radioactive Facility Components Restoration of Contaminated Areas on 1,275 1,275 Facility Grounds Final Radiation Survey 1,228 11,520 850 13,598 Table 21 Packaging, Shipping, and Disposal of Radioactive Wastes - Storage Areas (Excluding Labor Costs)
(a) Packing Material Costs Estimate of the types and volumes of waste expected to be generated, along with the number and types of containers required for packing the waste.
Number of Type of Unit Cost of Total Waste Type Volume (ft3)
Packaging Containers Container Container, $
Costs, $
Asphalt/Soil 40 93 ft3 box (b) Processing, Packing, Shipping, Disposal Cost Estimate of the volume of waste to be disposed and the packing, shipping, and disposal costs.
Waste Type Disposal Volume (ft3)
Unit Cost ($/ft3)
Total Disposal Costs, $
Asphalt/Soil 40
- No incremental costs for containers or disposal for this small waste volume. Can be accommodated in void spaces of equipment disposal boxes (see Table 9).
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 32 Table 22 Equipment/Supply Costs - Storage Areas (Excluding Containers)
Estimate of the quantity of equipment and supplies required for decommissioning.
Equipment/Supplies Total Equipment/Supply Cost, $
Radiation Screening Instruments 13,400 TOTAL 13,400 Table 23 Laboratory Costs - Storage Areas Estimate of costs for analyses to be performed by an independent third-party laboratory.
Activity Total Cost, $
Testing and analysis - 48 samples@ $120 ea.
5,760 TOTAL 5,760 Table 24 Miscellaneous Costs - Storage Areas Estimate of any other applicable costs.
Cost Item Total Cost, $
Certification Survey (ORISE) 20,800 TOTAL 20,800
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 25 Total Decommissioning Costs - Storage Areas Total of the reported costs in Tables 20, 21, 22, 23 and 24.
Task/Component Planning and Preparation (From Table 20)
Decontamination and/or Dismantling of Radioactive Facility Components (From Table 20)
Restoration of Contaminated Areas on Facility Grounds (From Table 20)
Final Radiation Survey (From Table 20)
Packing Material Costs (TOTAL from Table 21)
Processing, Packing, Shipping, Disposal Costs (TOTAL from Table 21)
Equipment/Supply Costs (TOTAL from Table 22)
Laboratory Costs (TOTAL from Table 23)
Miscellaneous Costs (TOTAL from Table 24)
TOTAL - Storage Areas E06-04-007 Version 7.0 Page 33 Cost, $
11,770 3,154 1,275 13,598 13,400 5,760 20,800 69,757
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 5.2.2 Containerized LLRW Inventory E06-04-007 Version 7.0 Page 34 The LLRW inventory consists of drummed or boxed waste materials that are radioactively contaminated but that do not designate as chemically dangerous per Ecology regulations. They are essentially all solid-phase materials; all of the relatively few drums containing liquids, e.g.,
radioactively contaminated oils, are stored on double containment pallets or in drums within drums. Treatment and/or disposal options are available for each of the major containerized LLRW categories; disposition pathways vary primarily based on combustible versus non-combustible classification of the waste. Primary disposition pathways include:
for combustible wastes, incineration in AREVA's SWUR facility, followed by uranium recovery processing of the resultant ash; and for non-combustible LLRW, disposal at the U.S. Ecology-operated Hanford LLRW disposal site.
Table 26 summarizes the volumes and associated disposition costs for the containerized LLRW inventory. As noted in the table, current inventories are now somewhat lower than reasonably assumed maximum inventories, due in large part to the site's ongoing efforts to minimize its backlog of stored wastes. The maximum expected volumes have been conservatively utilized to estimate disposal cost liabilities.
5.2.3 Containerized Mixed Waste Inventory The containerized mixed waste inventory consists of wastes that are both radioactively contaminated and chemically dangerous (per Ecology criteria). Like the LLRW inventory, they are essentially all solid-phase; the few remaining liquid-containing drums are stored on containment pallets. Treatment and/or disposal options are available and being utilized for all of the major currently generated containerized mixed waste categories. Viable options for the final disposition of a relatively small volume of legacy mixed wastes and very small volume of currently generated mixed wastes have not been identified but continue to be pursued in the commercial sector.
Disposition pathways for the containerized mixed wastes depend primarily on the specific acceptance criteria of the available commercial mixed waste disposal vendors. Primary disposition pathways, depending on the specific waste stream, include:
direct shipment to the contracted mixed waste disposal site for treatment and/or disposal with or without pre-compaction; and offsite treatment via a permitted commercial mixed waste treatment facility followed by disposal of the treated residues at the contracted mixed waste disposal facility.
Table 26 also summarizes the volumes and associated disposition costs for the containerized mixed waste inventory. As in the case of the non-mixed LLRW, the current inventory of containerized mixed wastes is smaller than currently assumed maximum inventories. As such, the maximum expected inventories have been utilized to estimate disposal cost liabilities.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 26 Containerized Waste Inventory Costs Disposal Rate Current 4
Max
$/ft3 Volume ft3 Expected Volume ft3 LLRW2 - Incinerate in
$268.53 4,479 10,890 SWUR LLRW - Direct disposal at 3,720 2,500 LLRW burial site LLRW - On hold for 3,928 5,000 further processing LLRW -Total 12,127 18,390 MW3 - Disposal at
$370.11 1,510 1,600 contracted mixed waste disposal site MW-Total 1,510 1,926 Logistics/Shipping Support Shipping Costs E06-04-007 Version 7.0 Page 35 Max Total Cost, $1
$2,924,292
$2,924,292
$592,176
$592,176 N/A**
N/A***
No incremental disposal costs above $12.460M already allocated to US Ecology (see Table 9 b.)
Logistics/shipping support included in Table 12.
- Disposal rates include shipping costs, as applicable.
1 Because this waste is already containerized, the cost of containers is not included.
2 Low-level radioactive waste 3 Mixed waste 4 As of October 1 51 2017
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 5.3 Environmental Remediation E06-04-007 Version 7.0 Page 36 Decommissioning financial liability can be associated with environmental contamination with licensed materials to the extent that the contamination requires remediation during decommissioning to meet the unrestricted use criteria of 10 CFR 20.1402. At the Richland facility the most significant area of known soil contamination was the area associated with the legacy surface impoundment system. This historically contaminated area and its residual decommissioning liability are discussed below in Section 5.3.1. Similar discussion relative to other historic site spills/releases of licensed materials to the environment is provided in Section 5.3.2. Lastly, Section 5.3.3 addresses potential investigation/remediation costs associated with two potential soil contamination areas, namely soil underlying certain areas of the U02 Building and soil potentially impacted by underground piping.
5.3.1 Legacy Surface lmpoundment System The Richland site maintained and operated a surface impoundment system over the time period of 1971-2004 for the management of the plant's radioactively-contaminated (low-level uranium) liquid effluents. Certain of those impoundments initially installed with single liner systems developed leaks, resulting in contamination of the underlying soil. The leaks also resulted in uranium contamination within the shallow confined groundwater aquifer underlying the site.
From 1983 until their last usage in 2004, all of the impoundments were operated with multi-linered containment systems with inter-liner leak detection/leachate collection; no additional leaks were documented over that period.
The surface impoundment system has been removed from service in accordance with a consent decree and formal closure plan under Washington State Department of Ecology (Ecology)
Dangerous Waste Regulations. The work involved processing of the stored waste inventory, removal/disposal of lagoon structural components, characterization of contamination levels in underlying soil, and remediation (removal and offsite disposal) of contaminated soil to meet Ecology cleanup levels for uranium and regulated non-radiological chemicals. Certification of completion of the work in accordance with the approved closure plan and associated soil cleanup levels was submitted to Ecology in September 2006; Ecology concurrence was received on November 14, 2006.
AREVA believes that the surface impoundment area now conservatively meets NRC requirements for unrestricted release and that no additional remediation will be required at the time of final plant decommissioning. The Ecology-imposed uranium cleanup level of 12.1 mg/kg translates to an activity level of 29 pCi/g for uranium at a U-235 enrichment of 3.5%. In reality the residual soil uranium concentrations present upon completion of the Ecology-mandated closure work were generally well below the 29 pCi/g limit in that cleanup to a very conservative fluoride soil cleanup limit typically drove soil removal/disposal to an extent well beyond that required to meet the uranium cleanup limit. AREVA has calculated Derived Concentration Guideline Levels (DCGLs) of 63 pCi/g for U-234 and 66 pCi/g for U-235, U-236, and U-238 based on RESRAD 6.3 and ICRP 30 (using more up-to-date ICRP models would yield even higher DCGLs). While realizing the final NRC release of the former surface impoundment area will be based on NRC-approved DCGLs and final status and confirmatory surveys, it is not anticipated that such DCGLs will necessitate cleanup beyond that already conducted.
In accordance with its NRC license (SNM-1227) and Ecology Groundwater Compliance Monitoring Plan, AREVA continues its semi-annual monitoring of downgradient wells for gross alpha and uranium. Groundwater levels of gross alpha and uranium have continued their decline over the last three years and are expected to continue to decline via natural attenuation
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 37 in that the Ecology uranium soil cleanup level was calculated to be protective of groundwater at the 30 ppb Ecology groundwater cleanup limit, which also corresponds to the current federal (EPA) drinking water limit for uranium. In the first-half 2017 groundwater sampling event, none of the site's six groundwater monitoring wells downgradient of the legacy surface impoundment area still exceeded 30 ppb uranium. The highest measurement during this most recent sampling event was 28.4 ppb uranium. It should be noted that there is no domestic or agricultural usage of groundwater on the AREVA site or on the hydrologically-downgradient US Department of Energy Hanford Site.
Residual decommissioning cost liabilities related to the legacy surface impoundment area are limited to the costs associated with the planning for, and the conduct of, a technically compliant final survey, including anticipated NRC regulatory oversight and the conduct of an NRG-required third party certification survey. These residual costs are addressed in Tables 27-30. The costs will be incurred at the time of final plant decommissioning in that the NRC has granted AREVA an alternate schedule for official decommissioning of the remediated surface impoundment area in accordance with 10 CFR 70.38(f) (November 15, 2006; TAC L31973).
5.3.2 Historic Spills and Releases (Documented)
As required by 10 CFR 70.25(g)(3), AREVA maintains records of information important to the decommissioning of the Richland site, which includes areas of known or suspect environmental contamination that will require additional characterization and, if needs be, remediation at the time of plant decommissioning. These potential environmental remediation areas are a subset of the areas listed per 10 CFR 70.25(g)(3)(ii), i.e., records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site. Information in this regard has been derived from two major sources, namely (1) a major site-wide remedial investigation/feasibility study (RI/FS) conducted in the early 1990s which included a formal hazardous substance source review (the RI/FS was in response to surface impoundment-related issues and included both radiological and non-radiological constituents), and (2) the site's ongoing hazardous spill/release reporting procedure and associated spill reports/log.
Records of these past spills/releases typically reveal residual contamination levels below 30 pCi/g uranium-based activity; furthermore most of the areas are highly localized and typically were remediated at the time of occurrence. Extensive environmental remediation efforts are not anticipated for these areas to meet decommissioning radiological release criteria. Costs will primarily be related to characterization (investigation, sampling, analysis) with the potential for limited soil removal costs. Any limited soil removal required will not result in incremental disposal costs in that the soil can be easily accommodated within the void spaces in the approximately 450 93 ft3 burial boxes that will be utilized to contain removed facility equipment (see Table 9). A review of site spill logs for 2012 through October 2017 indicated no additional radiological environmental releases requiring evaluation at time of decommissioning beyond those previously accounted for. Estimated decommissioning costs related to environmental remediation of documented historic spills/releases (unrelated to the surface impoundments) are provided in Tables 31 -34.
5.3.3 Potential Soil Contamination Areas Beyond the legacy surface impoundment area and the pertinent historic spill/release sites discussed in Sections 5.3.1 and 5.3.2, respectively, two other environmental areas of potential soil contamination will need to be accessed and evaluated at the time of plant decommissioning.
The first area is the soil underlying the historic and current wet chemical processing areas
[primarily ammonium diuranate (ADU) chemical conversion] within the Uranium Dioxide (U02)
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 38 Building. The long-term processing of uranium-bearing solutions in conjunction with concrete flooring challenged by the harsh chemical environment have created the possibility for the release of uranium to the soil column below those areas. Access to this soil for characterization and possible removal will necessitate concrete removal, soil characterization, soil excavation, and possible offsite soil disposal.
The second area of potential soil contamination is the soil underlying underground piping, historically or currently conveying uranium-bearing solutions. It is estimated that approximately 3,000 feet of trenching will be required to gain access for removal of the approximately 6,000 lineal feet of underground piping that has conveyed uranium-bearing solutions, past or present.
Estimated decommissioning costs for these two areas of potential soil contamination are provided in Tables 35-42. Conservatisms relative to the U02 wet chemical processing area estimate include removal of 1400 ft 2 of concrete to allow backhoe access versus an implicated floor area of 500 ft 2, and removal of all soil to a depth of ten feet over a total surface area of 1000 ft2 (twice the implicated floor area). Relative to the underground piping removal/
remediation, the estimate conservatively assumes soil removal/disposal to a depth of ten feet below ten percent of the 3000 feet of trenching.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 39 Table 27 Residual Labor Requirements for Final Release of Former Surface lmpoundment Area (Work Days)
Estimated number of work days by specific labor category that will be required to complete the planning and preparation for, and the conduct of, a final release survey for the former surface impoundment area.
Senior Engineer NRC Health and Activity Engineer Safety Work Days Work Days Work Days Technicians Planning and Preparation Preparation of Documentation 10 for Regulatory Agencies Submittal of Decommissioning Plan to 5
15 NRC when Required by 70.38(g)(1)
Development of Work Plans 5
Procurement of Special 4
Equipment Staff Training 4
2 Conduct of Survey Final Radiation Survey (gridding, sampling, sample 12 12 preparation)
TOTALS 15 25 15 14 Table 28 Total Labor Costs for Final Release of Former Surface lmpoundment Area Estimated work days for each specific labor category (from Table 27) multiplied by the total cost per work day for the correspondinq labor cateqor (from Table 7).
Senior Health and Task Engineer Engineer Safety NRC Total Labor Cost, $
Technician Cost, $
Cost, $
Cost, $
Cost, $
Planning and 12,285 7,982 768 33,480 54,515 Preparation Conduct of Final Radiation 7,368 4,608 11,976 Survey
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 40 Table 29 Laboratory and Miscellaneous Costs - Final Release of Former Surface lmpoundment Area Estimate of costs for analyses to be performed by an independent third-party laboratory as well as o th th. d rt rt t
er 1r pa :y suppo COSS.
Activity/Item Total Cost, $
Testing and analysis: 480 samples@ $120 57,600 ea.
40 sampling excavations (backhoe) 18,980 NRC Inspections 36,000 Certification Survey 86,814 TOTAL 199,394 Table 30 Total Decommissioning Costs - Final Release of Former Surface lmpoundment Area Total of the reported costs in Tables 28 and 29.
Task/Compo_nent Cost, $
Planning and Preparation 54,515 (From Table 28)
Conduct of Final Radiation Survey 11,976 (From Table 28)
Laboratory and Miscellaneous Costs 199,394 (TOTAL from Table 29)
TOTAL-Former Surface lmpoundment Area 265,885 Table 31 Labor Requirements - Historic Spills/Releases (Work Days)
Estimated number of work days by specific labor category that will be required to investigate, characterize and remediate pertinent environmental releases/spills recorded in accordance with 10 CFR 70.25(g)(3)
Activity Engineer Equipment Laborer Work days Operator Work Days Work Days Work plans/procedures 3
Pre-characterization dismantlement and/or 2
2 excavation Soil sample collection (characterization and 2
confirmation)
Soil removal/packaqinq (if required) 3 3
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 41 Table 32 Total Labor Costs for Historic Spills/Releases Estimated number of work days for each specific labor category (from Table 31) multiplied by the total cost per work day for the corresponding labor category (from Table 7)
Activity Pre-characterization dismantlement and/or excavation Soil sample collection characterization and confirmation Engineer Cost, $
1,842 1,228 Equipment Operator Cost,$
926 1,389 Laborer Cost, $
850 1,275 Total Labor Cost, $
1,842 1,776 1,228 2,664 Table 33 Laboratory and Miscellaneous Costs - Historic Spills/Releases Estimate of costs for analyses to be performed by an independent third-party laboratory.
Activity/Item*
Total Cost, $
Testing and analysis: 55 samples@ $120 ea.
6,600 NRC Inspections, certification survey Covered in Table 12 and 29 costs
- No incremental soil disposal costs. Anticipated soil volumes accommodated in void spaces of equipment disposal boxes (see discussion in Section 5.3.2).
Table 34 Total Costs - Environmental Remediation for Historic Spills/Releases Total of reported costs in Tables 32 and 33.
Task/Component Work plans/procedures (from Table 32)
Pre-characterization dismantlement and/or excavation from Table 32 Soil sample collection (from Table 32)
Soil removal/packaging (from Table 32)
Laboratory testing and analysis (from Table 33 TOTAL - Environmental Remediation Cost, $
1,842 1,776 1,228 2,664 6,600 14,110
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 42 Table 35 DimensionalNolume Assumptions for Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping a) Soil Below U02 Building Parameter Impacted Area, ft2 Area Removed, ft2 Disposal Vol., ft3 Concrete (floor) 500 1,400 700 Soil 1,000 10,000 b) Soil Below Underground Piping Parameter Length, ft.
Disposal Vol., ft3 Trenching 3,000 Piping 6,000 1,116 Soil 8,400
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 43 Table 36 Planning and Preparation - Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Estimate the number of work days, by specific labor category, that will be required to complete planning and preparation activities.
Activity Safety
- Engineer, Health and
- Laborer, Operator,
- Engineer, Work Safety Work Work Work Days Days Technician, Days Days Work Days Preparation and Submittal of Documentation for Regulatory Agencies Submittal of Decommissioning Plan to NRC Development of Work 10 10 Plans/Safety Plans Staff Training 4
2 4
2
- Included in labor costs for this activity in Table 3 for Production and Production Support Facilities.
EHS&L Document E06-04-007 Environmental Protection - Miscellaneous Reports Version 7.0 Decommissioning Funding Plan Page 44
-~-----------------------~-
Table 37 Environmental Investigation/Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Estimate the number of work days, by specific labor category, for environmental investigation/
remediation activities Location Below U02 Building Below Underground Piping
- Operator, Work Days 18 79 Laborer, Work Days 23 533 Health and Safety Technician, Work Days*
13 17
- Engineer, Work Days 2
2
- Health and Safety Technician labor includes radiation protection oversight of work plus collection of soil samples for pre-characterization and final confirmation.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 45 Table 38 Total Work Days by Labor Category - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Total work days estimated for each specific labor category from Tables 36 and 37.
Activity
- Engineer, Safety
- Operator, Laborer, Health and Work Days
- Engineer, Work Work Safety Work Days Days Technician, Days Work Days Development of Work 10 10 Plans/Safety Plans Staff Training 4
2 4
2 Environmental Investigation/
4 97 556 30 Remediation
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 46 Table 39 Total Labor Costs by Major Decommissioning Task - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Estimated work days for each specific labor category (from Table 38) multiplied by the total cost per work day for the corresponding labor category (from Table 7)
Activity
- Engineer, Safety
- Operator, Laborer, Health and Total Work
- Engineer, Work Work Safety Labor Days Work Days Days Technician, Cost, $
Days Work Days Development of Work 6,140 5,790 11,930 Plans/Safety Plans Staff Training 2,316 926 1,700 768 5,710 Environmental 2,456 44,911 236,300 11,520 295,187 Investigation/
Remediation
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 47 Table 40 Packaging, Shipping and Disposal of Radioactive Wastes - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping a) Packing Material Costs Waste Type Volume, ft3 Number of Type of Container Total Containers Container Unit Cost, $
Packaging Costs Soil/Concrete 19,100 Piping 1,000 Total 20,100 223 93 ft3 box 1,800 401,400 b) Shipping and Disposal Costs Waste Type Disposal Volume, ft3 Disposal Cost, $
Shipping Cost, $
Containerized Waste 20,100 262,700**
for Burial
- No incremental disposal costs above $11.485M already allocated to US Ecology (see Table 9b).
- Assumes 37 shipments at $7, 1 DO/shipment based on current TN rates.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 48 Table 41 Laboratory and Miscellaneous Costs - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Activity/Item*
Cost, $
Equipment (Backhoe) Charges 215,641 Materials 2,784 Analytical Uranium in soil (364@ $120 ea.)
43,680 Nitrate/fluoride in soil (57 @ $30 ea.)
1,710 TOTAL 263,815
- Does not include miscellaneous expenses that apply for the site-wide decommissioning effort, e.g., insurance, NRC inspections, logistics support, etc. (see Table 12).
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 7.0 Page 49 Table 42 Total Decommissioning Costs - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Total of reported costs in Tables 39, 40 and 41.
Task/Component Cost, $
Development of Work Plans/Safety Plans 11,920 (from Table 39)
Staff Training (from Table 39) 5,710 Environmental Investigation/Remediation 295,187 (from Table 39)
Packing Material Costs (TOTAL from Table 401,400 40a)
Shipping and Disposal Costs (from Table 262,700**
40b)
Laboratory and Miscellaneous Costs (TOTAL 263,815 from Table 41)
TOTAL - Potential Soil Contamination Areas 1,240,732
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 6.0 Adjustment of Cost Estimates and Funding Level E06-04-007 Version 7.0 Page 50 As required in 1 O CFR 70.25(e), AREVA will adjust these cost estimates at intervals not to exceed three years. Associated funding levels will be adjusted as needed. Consistent with guidance in NUREG-1757, the review will consider changes in costs of goods and services, including inflation; changes in facility conditions or operations; and changes in expected decommissioning procedures.
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 7.0 Certification of Financial Assurance Principal: AREVA Inc., 2101 Horn Rapids Road, Richland, WA 99354 NRC License Number SNM-1227 for AREVA Inc. (same address)
Issued to: U.S. Nuclear Regulatory Commission E06-04-007 Version 7.0 Page 51 I certify that AREVA Inc. is licensed to possess the following types of unsealed special nuclear material licensed under 10 CFR Part 70 in the following amounts:
Type of Material Amount of Material Uranium compounds in any chemical/physical 75,000 kg U-235 form enriched up to 5.00 wt. % U-235 (uranium compounds)
Uranium enriched in U-235 (any enrichment or 350 g U-235 chemical/physical form)
I also certify that financial assurance in the amount of
- ,ii;;-,.......
1?,.!:
~ "
\\
J
- 'z 1.;
r
~ f _
EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 8.0 Financial Assurance Instruments E06-04-007 Version 7.0 Page 52 This section provides copies of financial assurance instruments (Exhibits 1 and 2) to demonstrate financial assurance for all of the estimated decommissioning costs. The mechanism utilized by AREVA is the letter of credit/standby trust agreement provided for in 10 CFR 70.25 (f)(2).
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