ML19259B251
| ML19259B251 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 12/15/1978 |
| From: | Ballard R Battelle Memorial Institute, COLUMBUS LABORATORIES |
| To: | Kratzke R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7901180130 | |
| Download: ML19259B251 (6) | |
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Qp Mr. Robert Kratzke
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4 Fuel Reprocessing & Recycle Branch 9,
g Office of Nu, clear Material Safeguards and Security U.S. Nuclear Regulatory Commission Washington, D.C.
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Dear Mr. Kratzke:
This letter is in response to our recent telephone conversations and reiterates several of the points that have been made.
In addition, I will try to summarize where I think we are now.
BCL submitted to the Department of Energy (DOE), Chicago Operations Office, a financial plan to accumulate funds for the eventual decontami-nation of our nuclear facilities. The plan was developed to provide a long-range solution to a potential future problem.
In other words the plan is not intended to assure that funds are currently available to cover previously contaminated facilities but rather to recognize the need for an orderly mechanism to accumulate funds to cover the future cost of a liability created by current and future operations. The purpose of obtaining DOD approval is to get them (and other sponsors) to recognize the necessity of assessing current users for a cost that will actually be incurred in the future.
Since the Nuclear Regulatory Cocmission (SRC) has not adopted regulations nor promulgated guidelines in this area the plan is not necessarily expected to precisely parallel the eventual financial cocmitments associated with licensing conditions. However, since the plan makes good business sense and since it goes beyond currently promulgated regulations it is expected that it should satisfy most of any future requirements.
It should, however, be emphasized that we are addressing future contamination problems but, with time, the plan can also help solve current contamination problems.
DOE has tentatively approved the concept of creating a reserve to cover the eventual cost. They have, however, withheld final approval pending a review by NRC.
In this regard Harley Toy transmitted a copy of the plan to you on November 22, 1978. From DOE's point of view your review would presumably address the assumptions of the plan based on its intended purpose and determine the adequacy of the plan to meet the future obliga-tions of BCL and BCL's sponsors of research.
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Mr. Robert Kratzke 2
December 15, 1978 You indicated a desire to review the decontamination / decommissioning plan that was utilized to develop the required funds. As I indicated to you, an extensive, detailed plan was not developed, primarily because there is no intent to decommission or decontaminate our facilities at this time and changing regulations would in all probability make a detailed plan obsolete by the time it becomes necessary to decontaminat; decommi'ssion the om facilities. We did however develop a cursory plan which was used to determine the magnitude of the effort.
This was then compared to the efforts and costs associated with retirement of the Battelle Research Reactor and the Battelle Plutonium Laboratory. A copy of a memo dated 12-27-77 from R. W. Klingensmith to K. C. Brog which briefly describes the effort and cost is enclosed.
You also indicated concern regarding the possible necessity to decontaminate the facilities prior to the time that adequate funds are available from the plan.
As I pointed out, the plan is not intended to cover this type of contingency except to the extent assets are available in the fund. This is addressed in the plan, i.e., "[ establishment of this fund] does not reduce the total liability of any party except to the extent of the assets available in the fund".
I think this is fairly clear and would propose that no change in the language be made.
If any further commitments by Battelle are to become issues in the license renewal process, they should be addressed separately from the proposed financial plan.
The final issue which you raised pertains to the level of decontamination.
Again, I think this is outside the scope of the financial plan to accumulate reFerves.
The. level of decontamination can only be adequately addressed at the time a decontamination / decommissioning plan is developed.
The intent, however, is to have funds available to decontaminate to " releasable levels" but to my knowledge this has not been defined by NRC.
If the above adds anything in the way of clarification, it may be incorpor-ated into the plan document.
After you have had an opportunity to review the cursory decontamination /
decomr'.ssioning plan, if you have further questions, do not hesitate to contact me.
Since the implementation of the financial accumulation is very important to Battelle we will be happy to meet with you and/or others at NRC to clarify further points.
If necessary we can probably also arrange for a representative from DOE to be present.
As 1 envision it now, if the data provided is sufficient to justify NRC's recognition of the plan as a desirable concept (not necessarily a solution to all the anticipated licensing requirements), a l 'er from you to DOE would be in order. Any reservations you have regard ng the assumptions incorporated in the plan could be outlined if we are unable to work them out before hand.
Mt. Robert Kratzke 3
Decenber 15, 1978 I will call you in a few days to discuss any further input you need from us.
Sincerely, F
Roger K. Ballard Manager Research Finance RKB:dc Enclosure cc:
Mr. Ja=es Buchar Contracts Manage =ent Office U.S. Department of Energy Chicago Operations Office 9800 South Cass Avenue Argonne, Illinois 60439
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EUS Nh Project Numbe, 117-5861 (585)
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Columbus Laboratories J.B. Brown, Jr.'.
R.W. K1ingensmith December 27, 1977 Date To K.C. Brog R.W. Klingensmith' From Estimate of Effort Required to Totally Decontaminate subject The Battelle Hot Laboratory In response to the inquiry by NRC regarding costs and efforts involved to decontaminate the Battelle Hot Laboratory the following first-order analysis has been made.
To a large degree the cost and effort involved in decontaminating the Hot Laboratory are dependent upon the levels to.which the various components are to be decontaminated.
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On this basis, the analysis made assumes a decontamination level equivalent to permitting use of the Laboratory building for non-radiation oriented research purposes.
Facility Components On the basis of existing operational contamination levels the Hot Laboratory facility is licensed to permit three levels of area contamination; non-contaminated areas, suspect areas, and contaminated areas.
In non-contaminated areas there is no air-borne radioactive particulate, no smearable contamination on any surface and the radioactive background is less than 1.0 mr per hour.
Non-contaminated areas in the Laboratory include the operating areas of the cells, locker and restrooms, photographic darkroom, boiler room, machine shop, personnel monitoring stations, support laboratories, storeroom, offices and conference room areas.
Decontamination required in these areas will be minimal.
Suspect areas are defined as work areas in which the radiation levellmay usually be 1.0 to 2.0 nr per hour i.e., slightly above the normal background of the non-contaminated These areas include the high bay area which contains the truck bay, the storage areas.
pool and the associated transfer area, the high energy cell entry vestibule (cash washdown room), and the top of the high energy cell. The Laboratory back loading dock is also considered a suspect contaminated area.
Decontamination of suspect contaminated areas would require moderate effort.
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HDIORANDUM TO:
K.C. Brog FROM:
R.U. Klingensmith 2
Dececber 27, 1977 Contaminated areas are those areas in which radioactive or conta=inated materials are routinely handled directly. These areas include the interiors of the hot cells themselves, the control areas which provide personnel and equip =ent access to the cells, the contaminated equip ent storage area,.
the radioactive material dry storage tubes, and the liquid waste evaporator room.
Deconta=ination of contaminated areas and components would require a envieus effort.
Decontamination Operations By f ar, the greatest effort would be required in the decontamination of the high and low level cell interiors and the dry storage tubes. These facilities since the early 1950's have been directly exposed to air-borne radioactive particulate matter generated by the cutting and handling of exposed fuel fron high burnup fuel rods and other materials with high specific radioactivity content.
The high energy cell and the cechanical test cell similarly are exposed to highly contaminated and radioactive caterials but cutting and other destructive handling operations are not perfor=ed in these two cells. They are therefore more easily decontaminated then the high and low level cells. The sa=e is true for the access control areas.to the cells and the contacinated equip =ent storage roo=.
Nevertheless, a maxinus effort would be required to decontaminate these components.
The alpha-gn mn and netallographic cells are highly conta:inated due to the extensive a=ount of metallographic grinding and polishing which takes place.
Each of these cells is an individual stainless steel box which vould have to be-removed, decontaminated and disposed of.
Contaninated Ecuipment Within the Hot Cell Laboratory are nany pieces of specialized laboratory equipment.
Effective decontamination of such equipaent uould be virtually impossible due to individual complexity. This equipment includes approxinately 60 manipulators and core than 100 pieces of najor laboratory equip =ent.
Handling and preparation of this equipment for disposal vould require a major effort.
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J MEMORMIDUM TO:
K.C. Brog December 27, 1977 3
FROM:
R.U. Klingensmith Waste and Scrap Disposal It has been assumed that total decontamination of the facility would not Because of its include the disposal of fuel or other SNM caterials.
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accountability, this material would be disposed of under government or
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Exclusive of these materials, a total industrial project control.
decon'tamination of the Hot Laboratory would generate a vast amount of ilable '
waste and scrap materials which vould have to be disposed of by ava means.
In addition to generated vaste and scrap, the transfer and storage pool d
contains approximately 250,000 gallons of deionized but slightly contaminate Its disposal vill require a major ef fort..
water.
Effort and Costs Based upon experience at the Battelle Research Reactor, and estimates made for 'the Battelle Plutonium-Laboratory, it is. estimated that decontamination of the Battelle Hot Laboratory would require a two year time period and anT expenditure of $3.5 million.
million for non-fueled waste and scrap disposal and $0.5 million for the r disposal,of contaminated water.
If these funds are to be generated over the life of the facility, they should It night be necessary to place a portion be given consideration at this time.
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of project generated overhead funds into escrow or to place an addit o burden on all research projects.In order to remain competitive any added burde That is, non-contaminating projects e.g. mechanical costs.
lesser assessed equitably.
properties evaluation of reactor pressure vessel materials would carry a s
burden than highly' contaminating projects e.g. high burnup fuel rod destructiv examination.
These actions would effect sponsor costs and BCL's competitiva position -
thereby requiring careful planning.
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