ML19336A002
| ML19336A002 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 11/27/2019 |
| From: | Mejias M US Dept of Commerce, National Institute of Standards & Technology (NIST) |
| To: | Ty Naquin NRC/NMSS/DFM/FFLB |
| Naquin T | |
| References | |
| Download: ML19336A002 (3) | |
Text
- Adobe Acrobat page reference November 27, 2019 MEMORANDUM FOR:
Mr. Tyrone Naquin Project Manager (NRC/NMSS/DFM/FFLB)
FROM:
Mr. Manuel Mejias NIST Radiation Safety Officer (SNM-362 license)
SUBJECT:
Update to NISTs 2019 Decommissioning Funding Plan NIST submitted its triennial decommissioning funding plan (DFP) update for the statement of intent (SOI) regarding its Special Nuclear Material (SNM) license, SNM-362 on September 23, 2019 pursuant to 10 CFR 30.35(e) and 10 CFR 70.25(e). The 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. Thus, the 2019 submission is an update to the DFP sent September 29, 2016 (ML16279A280) for which NRC subsequently completed its technical review on February 23, 2017.
This is a supplement to the 2019 submittal (ML19269B774) based on the telephone conversation held on November 18, 2019. The methodology used to update the cost estimate for the SNM-362 license is based on the assessment prepared by Philotechnics for NIST in 2009. Recognizing the need for an external contractor to confirm the adequacy of adjustments to cost due to labor and waste, it is NISTs plan to contract for another external assessment in support of the next DFP submission due in 2022. This would seem prudent since it comes a year before the NISTs next materials license renewal application which is due in 2023.
Upon initial review of the 2019 DFP it was observed by you that the total cost was lower than the total cost submitted in 2016. My staff and I have evaluated both submittals and confirmed that the total cost for 2016 was in error as the recommended contingency value of 25% per NUREG 1757 was erroneously applied twice resulting in an overestimate of approximately two million dollars. The total cost declared in the 2019 submission is correct and is intended to supersede the previous amount stated in 2016 for which we now know was in error. The error can be clearly seen on the September 29, 2016 submittal.
Page* 322 shows the totals for the Laboratory decommissioning cost as $3,363,114 with a 25%
contingency of $840,779 (25%) for a total estimate of $4,203,893.
Page* 358 shows the totals for the Accelerator decommissioning cost as $3,218,000 with a 25%
contingency of $804,500 (25%) for a total estimate of $4,022,500.
Page* 48, Table 1-1 summarizes the D&D cost estimate (see below). Note that the Total estimates were inadvertently used in this table and the contingency was applied a second time leading to the 2M$
discrepancy.
UNITED STATES DEPARTMENT OF COMMERCE National Institute of Standards and Technology Gaithersburg, Maryland 20899-8392
November 27, 2019 Page 2 of 4 Table 1.1-NIST Gaithersburg, MD Facilities D&D Cost Estimate 2016 Estimate 25%
Contingency Subtotal Laboratory Areas
$4,203,893
$1,050,973
$5,254,866 Accelerator Areas
$4,022,500
$1,005,625
$5,028,124 TOTAL
$8,226,392
$2,056,598
$10,282,990 In summary, the increase in cost from 2016 to 2019 is roughly $801K driven primarily by inflation with some adjustments due to laboratory space and labor costs.
For comparison, the table below is the updated cost estimate for 2019.
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 estimates for the NIST 2019 DFP are based on the premise that certain sub grade portions associated with the former linear accelerator facility will be held for restricted use during a decay period of approximately 31 years from the time of characterization. Activated 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.
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
November 27, 2019 Page 3 of 4 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.
The NISTs response to NRC on August 31, 2009 (ML092810475) describes the thought process and methodologies used to estimate decommissioning costs. Cost estimate details are included in the attached spreadsheets included as appendices. Additionally, a scoping survey was conducted in the accelerator spaces; that response also included as Appendix A of that document.
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. As noted above the assumed endpoint is license termination and unrestricted release of the facility; consequently, long term stabilization and monitoring is not required and no costs are incurred for this element.
The proposed area for restricted release covers the A-wing subbasement rooms that previously had the high-power LINAC and associated magnet and target rooms in building 245 (rooms A0007, A0005, A0010, A0017, and A0018). The approximate lab/facilities area is 13,000 square feet of indoors rooms.
No activation is known for outside areas. As part of the preparation for renovations of building 245 soil samples were taken and none tested positive for contamination. This area would be maintained by NIST with appropriate signage and surveillance.
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, it is assumed for now that sealed sources will be transferred to the U.S. Department of Energy.
Discussions with DOE personnel were conducted in 2009 and reasonable cost estimates were determined and incorporated into D&D cost estimate prepared by Philotechnics in August 2009.
In 2015, the NIST awarded Ecology Services, Inc. (ESI) a contract for the removal, packaging, transport, and disposition/disposal of various sealed sources located at NISTs Gaithersburg, Maryland facility. The sources were a wide range of items with activities as small as a few picocuries to an irradiator with over 1,800 curies. Many preliminary activities were required before actual source removal could begin and included: obtaining permission from the Texas Low Level Radioactive Waste Compact to import out of compact waste into the Waste Control Specialists (WCS) disposal facility, obtaining permission to utilize lead shielding in WCS disposal containers, obtaining permission and required permits to ship radium waste to the US Ecology Richland, Washington disposal facility, obtaining custom built lead shielding for disposal packages, obtaining special form capsules from the Off Site Source Recovery Program (OSRP),
gaining approval from OSRP to transfer large Co-60 sources to Southwest Research Institute (SwRi),
arranging specialized Type-B shipping containers, and arranging licensed contractors to remove sources from large irradiators.
Thus, in an ever-changing environment, plans to send NIST owned material to an end destination would involve a variety of methodologies as described above. NIST is critical to the success of a technological society and it is difficult to imagine a scenario whereby it is completely eliminated.
November 27, 2019 Page 4 of 4 The role of the Standard Reference Material Program is to provide reference materials that are the definitive physical sources of measurement traceability in the United States. The Program promotes and supports the development and certification of NIST SRMs essential to industry, academia, and government in order to facilitate commerce and trade and to advance science and technology.
The NIST, by its very nature, possesses many radioactive sources that are on loan from various customers. Some of these sources remain at our Gaithersburg facility for days and some remain for years.
To this end, GRSD maintains a database that tracks all radioactive materials on site. The NIST has in place a loan program that provides details on the responsibilities of both parties. Only sources belonging to NIST are included in our D&D cost estimate; it is assumed all other sources will be returned to the customer. NIST maintains inter-agency agreements with the DOE for nuclear materials associated with calibration programs. It is understood that in the unlikely event of stopping all operations at NIST, the nuclear materials that are DOE-owned will be returned to the appropriate facilities. In addition to the DOE materials, NIST maintains several Cooperative Research and Development Agreements (CRADA) in support of calibration activities with various domestic and international entities. In those agreements it is clear that materials coming to NIST for calibration will be returned to the customer when the calibration services are completed or no longer available.
For the 2019 cost estimate, the total activity of unsealed sources was approximately 11.2 Ci. This would be an overestimate as a percentage of this total would be short-lived nuclides. The approach made in 2009 was to couple the disposal cost of unsealed materials into the total DAW (Dry Active Waste) cost estimate.
The NIST possesses 402 sealed sources of which 286 are less than 1 µCi. The approach made in 2009 was to assume that sealed sources will be transferred to the U.S. Department of Energy, rather than itemizing individual sources and weighing hypothetical transfer/disposal/storage options. Discussions with DOE personnel, at the time, indicated $500,000 may be reasonable. This value was then coupled into the total D&D cost estimate via our Packaging, Shipping, and Disposal of Radioactive Wastes component. The total cost in 2016 for unsealed (DAW) and sealed disposal is $44,451 and $900,000 respectively and sums to $944,451. This is 28.1% of the total Laboratory decommissioning cost
$3,363,114 (without contingency).
Therefore, a reasonable estimate for NIST controlled sources would be to take the percent cost determined in 2016 (28.1%) and apply it to the laboratory decommissioning cost for 2019 ($3,711,418).
This value is $1,042,264.
Should you have any questions regarding this memorandum or associated documents, please contact me or my staff, John Claassen at extension 5758.
Cc:
Elizabeth Mackey, Chief Safety Officer Alan Thompson, IRSC Chair