ML19269B774

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Us Dept. of Commerce, National Institute of Standards and Technology - NIST Decommissioning Funding Plan, September 2019
ML19269B774
Person / Time
Site: 07000398
Issue date: 09/23/2019
From: Copan W
US Dept of Commerce, National Institute of Standards & Technology (NIST)
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML19269B774 (18)


Text

UNITED STATES DEPARTMENT OF COMMERCE National Institute of Standards and Technology Gaithersburg, Maryland 20888-STATEMENT OF INTENT U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 0FFICE OF THE DIRECTOR Director, Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001

Dear Sir,

As Director of the National Institute of Standards and Technology (NIST), I exercise authority and responsibility to request from the Congress of the United States of America, through the U.S. Department of Commerce and the Office of Management and Budget, funds for decommissioning activities in NIST facilities pursuant to a decision to discontinue operations authorized in those facilities by U.S. Nuclear Regulatory Commission Material License No.

SNM-362. Authority is established by 15 U.S.C § 272b, 31 U.S.C. §§ 1105 and 1108, Department of Commerce Administrative Order 203-1, and NIST Administrative Manual Subchapter 8.03.

I am advising pursuant to 10 CFR 30.35(e) and 10 CFR 70.25(e) ofmy intent within this authority to request that funds be made available when necessary in the amount of$9.03 Million for decommissioning NIST laboratories housing radioactive material and accelerator facilities with residual structural activation located on the NIST campus at 100 Bureau Drive, Gaithersburg, Maryland. This funding level is based on the revision to the NIST Decommissioning Funding Plan ( enclosed) which reflects the regulatory conditions, licensed activities, and economic conditions as of calendar year 2019. I intend to request and obtain these funds sufficiently in advance of decommissioning to prevent delay of required activities.

Appropriate escalations will be applied as necessary to accommodate future conditions when decommissioning is required.

The documents referenced in the first paragraph are enclosed as evidence that I am authorized to represent NIST in this transaction.

Sincerely, Walter G. Copan, P Under Secretar Commerce for Standards and Technology &

Director, National Institute of Standards and Technology Enclosure NIST Decommissioning Funding Plan, September 2019 cc:

T. Naquin, NMSS, NRC E. Mackey, OSHE M. Mejias, GRSD, OSHE A. Thompson, Chair, IRSC NlSI

Decommissioning Funding Plan September 2019 National Institute of Standards and Technology Gaithersburg, MD

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 2 of17 1.0 2.0 3.0 4.0 4.1 4.2 TABLE OF CONTENTS Acronym List....................... *................................................................................................. 3.

Executive Summary............................................................................................................. 4 Objectives................... :.............................................................."........................................... 6 Process.................................................................................................................................. 6 General Assumptions...........................,............................................................................... 7 Radioactive Waste Materials.. :.................................................................":....................... 8 Sealed Sources........ *......................................................................................................... 8 Unsealed Sources............................................................................................................. 9 Release Criteria............................................................................................................ :..... i 1 4.3 5.0 6.0 7.0

. Review of Previous Clearance Surveys.............................................................................. 12 7.1 7.2 7.3 7.4 7.5 7.6 7.7 7.8 7.9 7.10 7.11 7.12 7.13 8.0 Decommissioning Process and Cost Estimate Details....................................................... 13 Detailed Descriptions of Facilities and Equipment........................................................ 13 Planning and Preparation.................. :............................................................................ 14 Decontamination or Dismantling of Radioactive Facility Components*......................... 15 Restoration of Contaminated Areas............................................................................... 15 Final Radiation Survey.................."................................................................................. 16 Site Stabilization and Long-Term surveillance.......................... :................................... 16 Total Days by Labor Category....................................................................................... 16 Worker Unit Cost Schedule............................................................................................ 16 Total Lab.or Costs by Major Decommissioning Task..................................................... 16 Packaging, Shipping, and Disposal of Radioactive Wastes............................................ 16 Equipment Supply Costs (excluding containers)..,........................................................ 16 Laboratory Costs............................................................................................................ 16 Miscellaneous Costs....................................................................................................... 17 Periodic Updates to Decommissioning Cost Estimate....................................................... 17

License No. SNM-0362 September 2019 CFR DAW D&D DCB DCGL DFP DOE dpm DSV

Default Screening Value High-Efficiency Particulate Air Multi-Agency Radiation Survey and Site Investigation Manual Maryland National Institute of Standards and Technology Nuclear Materials Safety and Safeguards U.S. Nuclear Regulatory Commission Nuclear Regulatory Commission Guidance Document Occupational Employment Statisti~

Performance Assessment Branch RESidual RADioactive Radiation Safety Officer Special Nuclear Material

  • Statement of Intent

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 4 of17 1.0 Executive Summary In a letter dated September 29, 2016 (ML16279A280), U.S. Department of Commerce National Institute of Standards and ** Technology (NIST) submitted its triennial decommissioning funding plan (DFP) update for the statement of intent (SOI) regarding its Special Nuclear Material (SNM) licerise, SNM-362. On October 11, 2016, the Fuel Manufacturing Branch requested technical assistance with the DFP update from the Performance Assessment Branch (PAB). On November 21, 2016, PAB staff determined that NIST's DFP submittal was adequate to perform a technical review. On February 23, 2017, the PAB branch completed its technical review ofNIST's DFP submittal..

Pursuant to 10 CFR 30.35(e) and* 10 CFR 70.25(e), this report addresses the three year resubmission of the decommissioning funding plan, considering adjustments necessary to account for changes in cost and the extent of contamination..

As required by 10 CFR 30.35( e) (2) and 10 CFR 70.25( e) (2), this report specifically considers the effect of the following events on decommissioning costs:

i.

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

Minor spills occurring over th(! last three years have been cleaned/decontaminated to pre-spill conditions.

ii.

Waste inventory increasing above the amount previously estimated.

No significant changes in waste inventory since the last evaluation.

iii.

Waste disposal costs increasing above the amount previously estimated.

No significant changes in waste inventory since the last evaluation.

iv.

Facility modifications.

No significant changes to the type and number of facilities since the last evaluation.

  • v.

Changes in authorized possession limits.

The SNM-362 limits have not increased significantly since the license renewal.

vi.

Actual remediation costs that exceed the previous cost estimate.

No significant remediation costs changes identified.

vii.

Onsite disposal.

Non-applicable as NIST is not authorized to perform this activity.

viii.

Use of a settling pond.

Non-applicable as NIST is not authorized to perform this activity.

Laboratory facilities are expected to be completely decontaminated and remediated at the time

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 5 of17 termination of operation is expected. This work will consist of removing all radioactive material, decontamination of contaminated building surfaces, and remediation or removal of volumetrically-contaminated materials. Laboratory facilities will then be surveyed and released for unrestricted use in accordance with NUREG 1575, Multi-Agency Radiation Site Survey and Investigation Manual (MARSSIM),

Radioactive accelerator components, waste, and non-structural material will be removed and disposed of as radioactive waste. Accelerator facilities contain activated structural material that cannot be safely removed without demolishing the entire building, which in most cases consists of several stories. Such activities would be extremely costly and would subject personnel to unnecessary risks during the decommissioning process. Furthermore, the NIST property is U.S. Government owned and is expected to remain long after the facility is decommissioned.

For those reasons, a limited release followed*by long-term monitoring is the preferred avenue for estimation of decommissioning costs.

Cost estimates were developed using conservative "middle of the road" assumptions regarding likely extent and duration of remediation activities. Remediation was assumed to proceed to levels suitable for unrestricted release of the site. Cost estimates were prepared in accordance with and in the format ofNUREG 1757 "Consolidated NMSS Decommissioning Guidance" Volume 3. Per NUREG 1757, a contingency of 25% is required to be added* to decommissioning estimates to address unidentified and unanticipated conditions.

The revised estimate for the Gaithersburg facility is:

Table 1.1 - NIST Gaithersburg, MD Facilities D&D Cost Estimate 2019 Estimate

  • 25% Contingency Subtotal Laboratory Areas

$3,711,418

$927,855

$4,639,273 Accelerator Areas

$3,510,474

$877,618

$4,388,093 TOTAL

$7,221,892

$1,805,473

$9;027,366 Cost estimate details were provided previously as attached spreadsheets included as appendices in our September 2016 submission. These *spreadsheets have been updated to reflect current cost estimates. The changes reflected since the September 2016 submission are included in Appendix A. Additionally, the scoping survey of the accelerator spaces that was conducted in 2010 had also been included as an appendix previously. The scoping survey and our conclusions provided in our last submission have not changed.

Nothing in this document should be construed as binding at the time of final decommissioning.

The survey methods, release limits, radionuclides of concern, and facility configurations described are based on conditions observed during the site visit, historical documentation, sample analysis, and professional opinion as to the.process of the final decommissioning and survey.

License No. SNM-0362 September 2019 2.0 Objectives National Institutes of Standards and Technology Decommissioning Funding Plan Page 6 of17 The principal objectives of this analysis are to: 1) develop updated revised estimate of total

, facility decommissioning costs for NIST's Gaithersburg operations, 2) provide a documented inventory of facility features and charact.eristics, and, 3) describe the steps that will need to be taken to effect complete decommissioning of the site.

3.0 Process Estimating the amount of remediation that would be required and the amount of material that would be handled as radioactive waste was performed in a similar manner as would be used for estimating a decommissioning job. A schedule of equipment, features, and characteristics was originally developed to capture the size of each space and key features relevant to developing decommissioning cost estimates. Specifically, facility floor plans were reviewed, and the changes of principal features and equipment of each laboratory were inventoried ahd categorized from the last DFP submission. Any significant changes were incorporated into the estimate. The process, as described below, continues to be the paradigm used in formulating the DFP. For this estimate, the previous estimate submitted in 2016 was reviewed and updated as appropriate.

In 2010, Philotechnics was hired by the NIST to perform a comprehensive initial DFP assessment. Histo.rical records and databases were reviewed to assess the isotopes, activities, and source uses in each laboratory. Existing records of routine radiological monitoring were also used. Philotechnics personnel performed independent surveys and measurements in all laboratory spaces to verify that the conditions were as indicated in the established records. This information was then used to estimate the degree of remediation and the fraction of material

  • that would be generated as radioactive waste.

Following review of the records, facility drawings, physical and radiological data used to determine the amount of material that would potentially need disposal as radioactive waste, Philotechnics evaluated the potential alternatives of decontamination, re-monitoring, and free release instead ofradioactive waste disposal. The approach of decontaminating the area versus removing contaminated portions of the area for disposal as radioactive waste was evaluated from an economic perspective. This evaluation formed the final basis for determination of the labor and disposal costs for this decommissioning cost estimate.

As indicated previously, the NIST radioactive materials database was reviewed to determine the radionuclides of concern in each laboratory area. NIST Radiation Safety personnel routinely perform weekly contamination smear surveys, which are analyzed on a gas proportional counter or liquid scintillation, arid direct reading measurements for dose rate and/or count rate in the unsealed source use laboratories. NIST Radiation Safety personnel also perform quarterly surveys in the sealed source use and* storage areas. NIST management provided the existing routine *contamination survey data from November 2007, March 2008, and September 2008 to Philotechnics to use as guidance to determine the likely extent of contamination in laboratory areas. Contractor personnel performed subsequent confirmatory surveillance of all identified unsealed radioactive materials laboratories. In many laboratories, direct contamination measurements using count rate monitoring instruments were impossible due to the presence of radioactive materials. In these areas the results of the NIST routine

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 7 of17 contamination monitoring smear results were used.

Samples of structural materials and shielding were collected in spaces affected by accelerator operation to determine the radionuclides present and estimate the extent of activation.

Historical records were reviewed including the radioactive materials license, previous DCEs, and laboratory closure surveys. NIST management was consulted regarding past and present operations and their effect on future decommissioning.

The work scope and activity sequence to support license termination were developed. Cost estimates for projects were based on anticipated Time and Materials rates for goods, labor and services necessary to complete each project. It became clear that unrestricted release of accelerator facilities would be expensive and dangerous work, because many of those areas are activated throughout the volume of structural materials and possibly into the soil. Some of those areas are below the water table, rendering safe handling of radioactive material and control of the spread of radioactivity virtually impossible while those structures are being dismantled and removed. For those reasons, after consultation with NRC personnel, it was decided to pursue restricted release combined with long-term surveillance for those areas.

Labor estimates were derived from the work scope and a project plan outline. A project plan outline was developed for each facility detailing the sequence of tasks required to decommission the facility arid terminate its radioactive material license. An overall project schedule was estimated that considered work to be performed, material flow paths, optimal number of crews and crew size and constraints (i.e., bottlenecks) in the D&D process. Crew sizes and task durations were estimated based on the numbers and locations of tasks to be performed.

Marketplace rates were obtained for each element

  • of the project including project labor, materials, supplies, sampling and waste packaging, processing and disposal. NUREG 1757 requires the cost estimate to assume an independent contractor performs the work. Salaries for the appropriate labor categories were used based on 2016 2018 data from the U.S. Department of Labor, Bureau pf labor Statistics-the last year for which data is available. These salary values are updated annually and incorporated into the DCE. Where availabie, salaries local to

. the Washington-Gaithersburg area were*used. In cases where nb local data was provided, the data from the nearest high-priced geographical area was used. The unit rates were extended through the estimated quantities to determine total cost for each line item.

Radioactive waste estimates were based upon the volume of material in the laboratories, storage areas* and supporting systems. For D&D purposes, contaminated equipment was assumed to be disposed of as radioactive waste rather than being decontaminated and released.

This is due to the cost of labor required to decontaminate and survey equipment typically exceeding the cost of disposal. Material that is not likely to be contaminated above release limits is assumed to be surveyed for unconditional release in accordance with Regulatory Guide 1.86.. Activated shielding, structural material and equipment, and debris from remediation of contaminated surfaces will be handled and disposed of as radioactive waste.

4.0 General Assumptions Overall, "middle of the road" assumptions were made concerning the likely extent and duration

LicenseNo. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 8 of17 of necessary remedial activities. For laboratories, remediation to unre.stricted levels (i.e., the facility could be released for any future use without restrictions) was assumed, meaning there are no long-term* costs associated

  • with site surveillance and monitoring following decommissioning. Some accelerator facilities will require surveillance and monitoring after license termination as discussed later. It is assumed decommissioning activities will begin within a few months after accelerator operations cease such that short-lived activation products will have decayed to negligible levels.

4.1 Radioactive Waste Materials In developing estimates of volume of radioactive waste, overall outside dimensions were used for equipment, components and furnishings. These overall volumes were assumed to be size reduced somewhat on site, so they were multiplied by an average density of 15 lb/ft3 Dry Active Waste (DAW) and 20 lb/ft3 (metal) to determine the total mass of waste. For example, a standard office desk would be estimated as 5 ft. wide by 2.5 ft. deep and 2.5 ft. tall with an overall volume of3 l.25 ft3 and an estimated mass of 470 lbs. A waste fractioniwas then applied based on the anticipated percentage of equipment expected to be contaminated. Consumables used in the D&D process showed up in waste estimates under DAW.

The accelerators and directly affected equipment such as targets, beam dumps, and shielding are assumed to be radioactive and will be disposed as radioactive waste.

Ventilation system waste estimates were based on dimensions of components. Ventilation up to and including the HEPA filters is considered in this report.

Waste mass is multiplied by marketplace rates for waste processing and disposal. Packaging and transportation costs were estimated by volume and were added to the total waste disposal figure. Potential overestimates of component volumes as a result of using overall dimensions were offset by smaller pieces of equipment that were not individually estimated. Actual volume of waste expected to be removed from the site was considered in the cost estimate. No credit was given for reuse at other facilities or possible resale value. Waste processing activities were assumed to take place at a licensed facility in Tennessee, with a one-way travel distance of 525 miles.

4.2 Sealed Sources According to the Health Physics database, NIST possesses approximately 402 sealed sources (286 of which are greater than 1 uCi) that will need to be packaged and shipped for disposal or storage. This is a slight decrease from the previous DFP submitted in 2016.

Since the closure of Barnwell, no disposal option exists for many sources. NIST is critical to the success of a technological society and it is difficult to imagine a scenario whereby it is completely eliminated. Decommissioning of the Gaithersburg site would most likely be associated with construction of a new facility elsewhere and most sources would be moved and put into service in the new facility. Still, complete decommissioning and disposal of all sources remains a remote possibility and some cost should be attributed to it. Rather than

. itemize individual sources and weigh hypothetical transfer/disposal/storage options, we will assume for now that sealed sources will be transferred to the U.S. Department of Energy.

Discussions with DOE personnel indicated $500,000 may be reasonable. The sources will be shipped as a Type B shipment to Nevada, a distance of 2400 miles. Additional costs are

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 9 of17

$100,000 for a Type B package and shielding, $84,000 for transpoi:tation to Nevada, and

$60,000 for security and administration of Increased Controls at NIST during the decommissioning project.

Only sources belonging to NIST and having activity greater than 1 µCi are considered here.

Sources belonging to other licensees will be returned to them. Sources less than or equal to 1

µCi will be included with other waste and shipped to a waste processor for treatment and/or disposal.

4.3 Unsealed Sources The health physics database was used to estimate the amount of radioactive material in the form of unsealed sources on site. The total activity of those sources is approximately 11.2 Ci.

Some of this activity is contributed by nuclides of short half-life and therefore the total activity will be reduced accordingly. Unsealed material can be mixed with other low-level waste for disposal. Only sources belonging to NIST are included in this estimate; it is assumed all other sources will be returned to the customer. This is a slight decrease from the previous DFP submitted in 2016.

Labor Estimates: Labor cost estimate are based on the 2018 Bureau of Labor Statistics (BLS)

Occupational Employment and Wage Estimates data and are provided in Table 4. Where possible, the labor rates in the table reflect those applicable to the Occupational Groups in the Washington, DC metropolitan area. If the BLS data tables did not list the Washington, DC metropolitan area as a reference, NIST used the table indicating the "Top Five Salary States" and chose Maryland (if listed) or the state closest to Maryland. Contractor profits are included in the 75% overhead.

All labor estimates are expressed in workdays. Workdays are actual days on the job. Project schedules were based on 5-day workweeks excluding weekends, holidays, etc., consisting of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per day.

Labor estimates for Planning and Preparation include time for document preparation, decommissioning plan submittal to regulatory agencies, work plan development, equipment procurement, staff training and mobilization. Pre-planning labor estimates assume.

straightforward internal and external document, plan and procedure reviews and approvals.

The duration of field activities for decontaminating and dismantling the facilities were estimated based on the task sequence and project schedule.

Crew sizes and number of workers were limited to those that could be efficiently utilized in the field. The size of the work force size will vary. At its peak, it is assumed to consist of one Project Manager directing the activities of two crews. Each crew will consist of one Supervisor; two Health Physics Technicians; four Skilled Craftsmen, and four Unskilled Laborers.

Additionally, one shipper and one administrative assistant will report directly to the Project Manager.

The duration of activities for remediation of facilities and grounds was based on the expected level of remediation that would be required to return the facility to unrestricted release conditions. Similarly, estimates for the level of effort required for the final radiation survey were based on previous experience with facilities of comparable complexity.

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 10 of17 For non-accelerator facilities, the assumed endpoint is license tennination and unrestricted release of the facility. For accelerator facilities that are below grade, the assumed endpoint is restricted release with monitoring for a *period of time, followed by unrestricted release. This was previously described in our previous submission.

Annual labor rates were estimated for the project manager, a project supervisor, a health physicist, a shipper, health physics technicians, radiation workers and administrative support.

Labor rates included base salary and fringe benefits (e.g., vacation, health insurance, etc.). A rate of 75% was applied for overhead costs and contractor profit. The base annual labor rate plus the overhead expenses was divided by the number of workdays per year (taken as 260) to detennine a daily cost for each category of employee.

Labor categories used are:

Table 4.1 -Occupational lnfonnation and Labor Rates.*May 2018 Occupational Value Occupation Occupational Employment Statistic (OES)

Title

Code, Reference Location Project 11-9021,

$110,610 http://www.bis.gov/ oes/ current/ oes119021. htm Manager MD Supervisor 47-1011,

$77,100 http://www.bls.gov/oes/current/oes471011.htm MD Shipper 53-1048,

$62,890 http://www.bls.gov/oes/current/oes531048.htm MD HP Technician 19-4099,

$75,410 http://www.bls.gov/oes/current/oes194099.htm MD Skilled-47-4041,

$53,880 http://www.bls.gov/oes/current/oes474041.htm Laborer MD Unskilled 47-2061,

$36,110 http://www.bls.gov/oes/current/oes472061.htm Laborer MD Admin 43-6014,

$40,240 http://www.bls.gov/oes/current/oes436014.htm MD Living expenses were taken from allowable government per diem rates - $292 per day for Montgomery County, MD. Project management, supervision and technical staff are paid the daily living allowance since they are assumed to be from -outside the local area. Radiation workers (laborers) and administrative support staff were assumed to be local hires and are not paid a living allowance. The daily living expenses were multiplied by 7 days per week then divided by 5 workdays per week to correctly incorporate living expenses into the daily wage rate.

License No. SNM-0362 September 2019 5.0 Release Criteria National Institutes of Standards and Technology Decommissioning Funding Plan Page 11 of17 The ultimate release criteria are specified in 10 CFR 20.1402. Pathways applicable to such an occupant include external dose, inhalation, soil ingestion, and drinking water from radioactivity that migrates to ground water.

Tools, materials, and removable equipment will be surveyed for unconditional release as applicable using applicable regulatory for the radionuclides of concern.

Building surfaces and installed equipment will be surveyed using the guidance contained in NUREG 1575, Multi-Agency Radiological Site Survey and Investigation Manual (MARSSIM). Areas adjacent to one another having similar radiological characteristics will be grouped together as applicable into survey units. Contamination release limits will be derived from a number of sources. For planning purposes, the radionuclide known to be present or shown in the database as having been used that is associated with the lowest release limit will be used according to the following guidance:

0 Default screening values listed in NUREG 1757, Appendix B, are used where listed.

For radionuclides not listed in NUREG 1757, the release limit will be derived using the NRC D and D Ver. 2.1 software code default parameters.

At the time of actual decommissioning and License termination, future site usage may be more stringent; in that case the RESRAD family of codes may be used.

Actual radionuclides of concern and the relative abundance of each will be determined early in decommissioning, during the characterization phase; that process will yield accurate derived concentration*guideline limits (DCGLs). Therefore, the limits derived in support of this DCE are thought to be quite conservative.

  • In this DCE, the following values are limiting, assuming no more than ten percent of the total activity is removable:

Table 5.1 - Limiting Radionuclides Radionuclide(s)

Default Screening Value Basis (dpm/100 cm2)

Beta-gamma emitters 7,100 Co-60 except H-3 and C-14 Transuranics 23 Am-241 Uranium 88 U-238 H-3 1.2E+07 10% of screening value C-14 3.7E+06 Screening value For activated building components, the major dose pathway is external exposure from gamma emitting radionuclides. Default screening values for contaminated surface soil listed in NUREG 1757, Appendix B are used. They are:

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 12 of17 Table 5.2 - Surface Soils DSVs Radionuclide DSV pCi/g Co-60 3.8 Eu-152 8.7 6.0 Review of Previous Clearance Surveys No additional rooms have been cleared since the last reporting period.

As reported in 2016, surveys supporting prior clearance of several rooms from radiological controls were reviewed as shown below:

a e. -

rev1ous1y eare a ora ories or ooms T bl 61 P l Cl dL b t.

R Building Room(s) 218 C002 245 Cl 12; Cl 15; B030; C201; B009; B024; C334; BOl; C133; B133; C116 224 A114 222 A206; Al 10; Al 16; A122; A128; A132; A148; B125; B126 221 A41 In general, surveys appear to indicate no residual radioactive material is likely to be present; however, documentation lacks sufficient detail to make that determination with certainty. For instance:

Dose rate surveys indicate radiation dose rates are at or near ambient levels.

Results of direct measurements for total contamination are not routinely recorded.

Smears. are counted for gross alpha and beta; however, results are reported in units of net cpm. Instrument efficiency is not shown on the survey. Each page bears a statement in bold type that reads, "~20 dpm/100 cm2 Alpha and ~1000 dpm/100 cm2 Beta/Gamma removable unless noted."

Residual contamination levels in those labs may in fact be less than the DCGL that would be in effect today based on usage; however, in the event of license termination, some follow-up surveys would need to be performed.

Room 222/A122 contained natural and depleted uranium and thorium. The DCGL for depleted uranium is in the neighborhood. of 88 dpm/100 cm2 total contamination, assuming less than 10% is removable. It is not clear from reviewing the clearance s.urvey that the DCGL would be met.

Rooms 222/A132 and 245/C133 contained Pu-238. The DCGL for that radionuclide

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 13 of 17

. is approximately 24 dpm/100 cm2 total contamination, assuming less than 10% is removable. It is not clear from reviewing the clearance survey that the DCGL would be met.

Philotechnics believes laboratories previously released from radiological controls will require some type of follow-up survey, described in following sections. Many previously-used rooms have been completely gutted and remodeled; others are now offices; still others had adjoined other radiological laboratories and the wall separating them was removed. Rather than list every previously-used room individually; time and resources are allotted to performing follow-up surveys in all previously-used rooms as a group.

7.0 Decommissioning Process and Cost Estimate Details Since the last submission of the DFP in 2016, 27 rooms have been added to the total decommissioning footprint. This accounts for less than 1 % of the total area under consideration and had no significant impact on decommissioning costs. The work crew consists of:

Project Manager (1)

Project Supervisor (2)

Shipper (1)

Health Physics Technicians ( 4)

Skilled Laborers (2)

Unskilled Laborers (2)

Administrative Assistant (1)

The time required to complete the project is approximately 150 days on site: 90 days for the laboratories and 60 for the accelerators. This is less than the maximum limit of 180 days per calendar year to work under reciprocity with the U.S. NRC. Therefore, one reciprocity fee of

$1800 will cover both aspects of the work.

Following is a description of the assumptions made and data entered into individual worksheets to calculate the potential cost of decommissioning. Two sets of spreadsheets were developed for this cost estimate. One set of spreadsheets pertains to laboratory areas and the other to the accelerator areas.

7.1 Detailed Descriptions of Facilities and Equipment In addition to the accelerators, Building 245 also houses most of the active radiological laboratories.

Laboratories vary in size, configuration, materials, and equipment according to their function.

Each individual laboratory that was inventoried for this DCE. The inventory lists, as a minimum, room dimensions, amount of furnishings and equipment used and stored in the

  • room, the radionuclide(s) currently or previously used, and the expected MARSSIM class based on current use and survey data.

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 14 of17 Initial assignment ofMARSSIM class for final status surveys is as follows:

Table 7.1 - Previously Cleared Laboratories or Rooms CLASS 1

. Current use of unsealed material Some remediation may be expected

. Current or previous use of neutron

. Some radwaste may be expected -

sources fraction inversely proportional to

  • Areas adjacent to accelerators release limit.
  • Areas with uncertain history Accelerator facilities will have a lot ofradwaste Some rooms are not listed in the database as ever having radioactive materials - so if we don't know what was used, we assume the worst.

CLASS2

  • Accelerator support areas separated Verification that materials are not by shielding activated or contaminated

. Previous use ofunseale.d TRU, U, Removable contamination surveys Ra, or Th sources and clearance previously performed cannot detect surveys were done (many have been alpha emitters below DCGL gutted and remodeled).

. No remediation ~s.expected

. No radwaste (except sources) is expected.

CLASS3

  • Current use of sealed beta, gamma No history of leaking sources.

or alpha sources Removable contamination surveys

. Previous use of unsealed beta-previously performed should detect gamma sources but clearance most beta-gamma emitters.

surveys were done No remediation is expected

. Restrooms and hallways "upstream". No radwaste (except sources) is of personnel contamination expected monitors.

There are approximately 100 previously-used rooms not specifically listed in the inventory.

Average dimensions of20 feet by 25 feet with 15-foot ceilings. They are assumed to be 50%

CLASS 2 and 50% CLASS 3. Since the last submission of the DFP in 2016, no credit has been assessed for the clearance of rooms.

  • 7.2 Planning and Preparation Planning and preparation includes filing for reciprocity to conduct the decommissioning, preparatioi::i of work plans including the Decommissioning Plan, site-specific training for workers, and mobilization to the site. The Project Manager develops work plans and submits reciprocity applications. The laborers and administrative assistant are assumed to be local hires and no time is required for mobilization; the other workers need a full day to mobilize to the site. The Project Manager also must secure a contract for a crane and crew.

License No. SNM-0362 September 2019

  • National Institutes of Standards and Technology Decommissioning Funding Plan Page 15 of17 Characterization is performed to determine the radionuclides present in each area and the extent of contamination. Health physics technicians will enter each area where radioactive materials have been used, collect samples, scan surfaces, segregate potentially radioactive material from non-radioactive, and identify any mixed waste.

In most cases, the health physics database maintained by NIST identifies current and historical use of radionuclides in each room. The time estimated to characterize the room is based on that information. For instance: if a room contained transuranics, uranium, radium, beta-gamma emitters and 1-129, the room will be scanned three times. A beta-gamma probe (floor monitor for large floor areas and BP19 or equivalent for other surfaces will be used to measure contamination from most beta-gamma emitters. An alpha-sensitive probe will be used to measure contamination from alpha emitters. A very slow scan rate of only an inch or so per second is required. Finally, a probe sensitive to gamma and very low energy beta emitters (such as the GP-13 or equivalent) will be used to measure contamination from 1-129, Co-57, and similar difficult-to-detect radionuclides. Smears will be collected and counted for gross alpha and gross beta and analyzed on a liquid scintillation counter. Samples will be sent to an

  • independent laboratory for radionuclide identification.

7.3.. Decontamination or Dismantling of Radioactive Facility Components The removal and packaging of radioactive material such as contaminated equipment and preparation for transport to a licensed processor or disposal facility. Most material is neither contaminated nor activated and will be surveyed for unconditional release~ Labor hours are allotted for those unconditional release surveys as well as to move, remove, and break down equipment as necessary to facilitate release surveys or make areas accessible for MARSSIM surveys.

The order in which various buildings will be decommissioned is unknown; however, in Building 245, laboratory areas will be decontaminated and decommissioned before accelerator facilities for a number of reasons: accelerators contain short-lived byproduct material and delaying work allows for some decay; most accelerator spaces are below laboratory spaces and it makes sense to start at upper floors and work down; laboratories will be fully decontaminated and remediated while some accelerator spaces will be locked shut and subject to long-term surveillance.

7.4 Restoration of Contaminated Areas Based on existing survey data, surface scans performed during the site visit, and interviews with knowledgeable individuals, very few laboratory areas will require any remediation.

Accelerator facilities (described separately) will require extensive remediation of floor, walls, equipment, and structural materials. The Time ofFlight Facility is above grade and remediation efforts will result in partial demolition of the building. Other activated accelerator spaces are below grade. Many are below the water table, such that demolition of those structures would increase the likelihood ofreleasing radioactive materials to the environment. Many of the most highly activated areas are load-bearing or exterior walls. Complete remediation would therefore require complete demolition of all of Building 245 - a costly endeavor. For reasons

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 16 of17 of cost reduction, worker safety and protection of the environment, those areas will be remediated to the extent practicable and then re-evaluated.* Sub basements containing those accelerators will be secured, and long-term monitoring instituted, until activation products decay to levels acceptable for unconditional release.

7.5 Final Radiation Survey The final radiation survey is performed by health physics technicians, with guidance from the project manager and project supervisors and administrative support. In cases where no decontamination or remediation was required, the characterization survey may be used as the final status survey for a particular area.

7.6 Site Stabilization and Long-Term surveillance Because the goal is unconditional release of the laboratory facilities, there are no long-term surveillance requirements associ.ated with them.

7.7 Total Days by Labor Category This is the sum of person-days calculated.

7.8 Worker Unit Cost Schedule Worker mean nationwide salaries are taken from the Bureau of Labor Statistics and are adjusted to account for the cost of fringe benefits. A 75% multiplier is also added to account for profit to the contractor performing the decommissioning work. Workers who are not local hires are paid the government per diem rate of $292 daily for the Gaithersburg area.

7.9 Total Labor Costs by Major Decommissioning Task

  • The cost of each major task multiplied by the daily labor cost for each worker identified in Table 4.1 above.

I 7.10 Packaging, Shipping, and Disposal of Radioactive Wastes This reflects the costliest component of the facility decommissioning. It is assumed waste is shipped to a licensed waste processor in Oak Ridge, Tennessee, a distance of approximately 600 miles.

  • 1.ll Equipment Supply Costs (excluding containers)

The approximate costs of personnel protective clothing and respirators, rental of specialty equipment including health physics survey instruments, and consumables required to complete the decommissioning.

It is assumed a crane and crew will be needed for removal of accelerators and large equipment.

Other equipment includes health physics survey instrumentation, concrete cutters, jack hammers, containment structures, vacuum cleaners, negative ventilation systems, nibblers, and shears.

7.12 Laboratory Costs The total of all samples to be collected and sent out for analysis. It is assumed all samples will

License No. SNM-0362 September 2019 National Institutes of Standards and Technology Decommissioning Funding Plan Page 17 of 17 be analyzed for gamma emitters, Sr-90, H-3, C-14, and alpha emitters such as uranium, plutonium, and americium isotopes. Samples collected from accelerator facilities will be analyzed for gamma emitters.

7.13 Miscellaneous Costs Other costs not specifically captured elsewhere. It is assumed the decommissioning contractor will perform the work under reciprocity agreement with the U.S. NRC at a cost of $1800.

Liability insurance and state/local taxes are included at the rate of 6 percent and 10 percent, respectively, of the on-site labor costs. The cost of shielding materials needed for accelerator spaces is included here. These costs are based on an actual quote including shipping charges.

8.0 Periodic Updates to Decommissioning Cost *Estimate This cost estimate was prepared using the tables and instructions provided in NUREG 17 57.

Tables were converted to Excel spreadsheets and modified as necessary to enhance their applicability to the NIST site and to facilitate updating costs in the future. As areas are decommissioned from radiological use or new areas are added,. that information may be changed in the spreadsheet. Labor and per diem rates are likely to change in the future. That information may be updated in the spreadsheet to reflect future labor costs. Transportation costs including mileage, fuel surcharges, overweight/oversize charges; costs of shipping

  • containers; and disposal, site access and license costs may be updated by inserting applicable values into the spreadsheet.

For reference, the table below shows expected escalation of decommissioning costs over the next 11 years. The annual escalation rate was estimated as the average annual United States rate of inflation between 1946 (the first full year after World War II) and 2008 according to the U.S. Consumer Price Index. That rate is 4.1 percent.

Escalation Laboratory Accelerator 25%

Year Factor Areas Areas Contingency TOTAL 2019.

NA

$3,711,418

$3,510,474

$1,805,473

$9,027,365 2020 0.041

$3,863,586

$3,654,403

$1,879,497

$9,397,487 2021 0.041

$4,021,993

$3,804,234

$1,956,557

$9,782,784 2022 0.041

$4,186,895

$3,960,208

$2,036,776

$10,183,878 2023 0.041

$4,358,558

$4,122,576.

$2,120,283

$10,601,417 2024 0.041

$4,537,258

$4,291,602

$2,207,215

$11,036,075 2025 0.041

. $4,723,286

$4,467,557

$2,297,711

$11,488,554 2026 0.041

$4,916,941

$4,650,727

$2,391,917

$11,959,585 2027 0.041

$5;118,535

$4,841,407

$2,489,986

$12,449,928 2028 0.041

$5,328,395

$5,039,905

$2,592,075

$12,960,375 2029 0.041

$5,546,859

$5,246,541

$2,698,350

$13,491,750.

2030 0.041

$5,774,281

$5,461,649

$2,808,982

$14,044,912