ML19350C333

Site Decommissioning Plan for Nuclear Fuel Div at AL Nuclear Fuel Fabrication Plant

ML19350C333
Person / Time
Site:	07002909
Issue date:	12/31/1980
From:	WESTERN NUCLEAR, INC., WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
Shared Package
ML19350C329	List: ML19350C328 ML19350C331 ML19350C333 ML19350C336 ML19350C339
References
18190, NUDOCS 8103310941
Download: ML19350C333 (42)

Text

{{#Wiki_filter:' i [ WESTINGHOUSE ELECTRIC CORPORATION j NUCLEAR ENERGY SYSTEMS l l lO I l SITE DECOMMISSIONING PLAN FOR THE NUCLEAR FUEL DIVISION l AT THE ALABAMA i NUCLEAR FUEL FABRICATION PLANT i i 4 { December 1980 E) 9 Lti230 L 810331094l

1 i i l 1 J l !O f f \\ REVISION RECORD ilO i i i Revision No. Date of Revision Pages Revised Reason for Revision l l\\O I J i. l' l I k i 6 r l I O i L { i O l Iii

_ _ _ _ _ _.. _ _ _ _ _. _ _ _. _ _ _. _ _. _ _ _ _ _ _ _..... _ _. _ _. ~ _ _ I j j 4 t I I h l i i 9 ll TABLE OF CONTENTS i r I@ ? l-Section Title Page j i t l INTRODUCTION xi L 1 STATEMENT OF PURPOSE 1-1 i i. 2

SUMMARY

2-1 l 3 SITE AND OPERATIONS DESCRIPTION 31 I I j-4 DISPOSAL AND RELEASE CRITERIA 4-1 I I 5 CONCEPTUAL DECOMMISSIONING PLAN 5-1 ) 51 Pla'nning and Preparation 5-1 5-2 Radiation and Radioactivity Control 52 j 5-3 Conceptual Implementation - 5-3 l 6 ' 6 ~ DECONTAMINATION METHODS i J i 7 EQUIPMENT VOLUME AND SURFACE DATA 7-1 j 8 , COST ESTIMATE 8-1 1: i P FINANCIAL SURETY 9-1 l l 1 4 i l ~! -l I f 4 ! k. .e a V-4 .,.c.-a,_.u..-..,__.__.,.u____.

, - -. ~ - - - - - _ - - -.. l 2 l I i I 1 r i l 1 1 I i l !O I i 1 l i LIST OF ILLUSTRATIONS l l l Figure Title Page ) 3-1 ANFFP Site Location 3-3 l 32 ANFFP Site Layout 34 l 5-1 Decommissioning Flow Plan 5-5 l 5 ( l I i i l O I i I l l O I O -{ vii i r w m-w - %ym y.. + m ww. = e-"**~'" + ' ' - - - - ~ ' " " " '

P l l r I l LIST OF TABLES l Table Title Page t i 61 Decontamination Aids 6-2 [ r l 62 Decontamination Methods 6-3 i ? l i l I i + l I I t [ i I l P l i i 9 ix i I

INTRODUCTION The Westinghouse Nuclear Fuel Division's Alabama Nuclear Fuel Fabrication Plant (ANFFP) is - designed to strictly control and prevent hazardous situations and actions under normal condi-f tions of operation, and to prevent conditions which could lead to accidents. Engineered safe-7V guards and administrative controls provide multiple barriers for maintaining releases of radiation, radioactivity, and hazardous materials at the insignificant levels discussed in the ANFFP En-vironmental Report. These multiple barriers also serve a useful ancillary purpose in that they 4 are. designed to' carefully confine radioactive materials within (or proximate to) process equip-I - ment and enclosures and to enhance facility maintenance and cleaning. Through this initial ~ attention to design detail, at the en'd of useful plant life the efforts and expense required to I return the site facilities to unr'estricted use are thus minimized. ANFFPLManagement's current interest in planning for ultimate' decommissioning is primarily directed toward~ design of the facility with future disposition in mind, operation of the facility so as to keep radioactive' materials carefully confined within their intended constraints, and as- - surance of financial arrangements for defraying all final disposal expenses. Before commencement of future decontamination of' facilities and grounds for the purpose of decommissioning, a Detailed Decommissioning Plan will be prepared and submitted to the U.S. l Nuclear Regulatory Commission staff for review'and approval. i e 1 xi 1 4 U* 6 u- ~ + m-e e- + --+*- ,w .w ,m v--- + - - -a' 4 r- -#e--- v - T-

[ t } l-1 l@ 1 SECTION 1 i j @- STATEMENT OF PURPOSE I q. j This evaluation was prepared by the Westinghouse Nuclear Fuel Division, for the purpose of f estimating future costs of decommissioning the proposed Alabama Nuclear Fuel Fabrication Plant (ANFFP). In addition to the estimate of cost, a discussion of decommissioning methods and a conceptual plan of decommissioning activities are included. This evaluation is not in-t 1-tended to be a detailed decommissioning plan, but rather a preliminary planning tool, i t i i The concepts, costs, and. regulatory requirements presented in this evaluation are based on con-i 1 ditions as they exist in December 1980. The contents and rationale represent a judgment and best estimate for the impact of a far future event and should be viewed accordingly. I ^ h r ~r i t i { Hr l~ 1. l -11 i s '.....m.....--.e.,-,

4, h C t s 3.- i .[d SECTION 2

SUMMARY

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I { The Nuclear Regulatory Commission's Division of Nuclear Materials Safety and Safeguards re-l f-quires that an application for a license be accompanied by a plan and cost estimate for de-q- commissioning and financial arrangements to assure adequate funds to cover the costs at the I ~ time of decommissioning. l Westinghouse has accumulated actual experience in this area, including the preparation and sub-i mittal of a decommissioning plan for the Columbia, South Carolina fuel fabrication plant and {~ implementation of (both) retsase for unrestricted use and decommissioning at the Cheswick, [ Pennsylvania fuel laboratories. The Alabama Nuclear Fuel Fabrication Plant (ANFFP) plan f makes maximum use of this experience in formulating a conceptual program in sufficient de-tail to indicate the scope of activities and estimate the costs involved. c - The ANFFP-Decommissioning Plani including resulting cost estimates, is prepared within the j 1. following guidelines: 1. ' Applicable experience obtained in planning the Columbia plant decommissioning and in-planning and carrying out the Cheswick Site fuel laboratory decontamination and ~ r decommissioning activities are utilized to the extent practicable in preparing the ' ANFFP plan and cost estimate. ~ V l, * # - 2. ! Costs are expressed in 1980 dollars. 3. Packaging, transportation; and disposal charges are calculated using information from l an ' existing low level waste disposal facilityf as the repository for regulated material l~ and equipment.' t' 4.- . Current radiolog; cal' limits and decontamination technology are utilized. ir

5. ' All process and ancillary equipment in controlled areas is to be cleaned to the extent 1_.

practicable and based on results of surveys and disposal requirements, is to be pack-l m e, - aged, transported to,' and dispositioned at a licensed disposal-facility'(or other li-

censed facility).'

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96. < All buildings are to be cleaned to levels established for unrestricted use.

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7. All process-related underground piping is to be removed and cleaned to the extent practicable and based on results of surveys and disposal requirements. is to be pack-aged, transported to, and dispositioned et a licensed disposal facility. The ground surrounding such piping is also to be surveyed and removed for disposal if it exceeds established limits. 8. During initial plant mnstruction activities, approximately 4 inches of top soil are to 3 be removed from thu 30 developed acres (16,133 yd ). This material is to be used in site grading (e.g., placed over existing undisturbed top soil). Final landscaping is to result in extensive grass-covered areas and new tree and shrub areas to stabilize the soil. Thus, the top soil will be available for redistribution following decommissioning. Within the above guidelines, Westinghouse has inventoried the equipment and material desig-nated for use in the proposed ANFFP and has estimated the portion likely to require addi-tional control after all practicable treatments have been applied. This portion would be pack-aged and transported for disposition at a licensed disposal facility. Similarly, the costs required for cleaning those portions of the facility requiring additional control (such as walls, floors, etc.) were estimated. The estimate provides an allowance for professional health physics staffing to perform a com-prehensive initial survey and then to prepare a specific overall plan for approval by the appro-priate licensing agency prior to the initiation of decommissioning activities, it also provides for the required health physics surveillance during the entire operation, including the final clearance surveys of the " clean" facility, and an acceptance inspection by the appropriate licensing agency as a condition of terminating the license. Based on the above guidelines, and the independent contractor's estimate for decommissioning the similar Columbia facility, the total task costs for the ANFFP facility are estimated to be approximately $5,000,000. Further, it is estimated that it will take approximately one to two years to complete the decommissioning task. O O O 2-2

V SECTION 3 fl SITE AND OPERATIONS DESCRIPTION v The Westinghouse Alabama Nuclear Fuel Fabrication Plant (ANFFP) will be located near the D] ( central part of Alabama in Autauga County. The site is approximately 12 miles northwest of Montgomery, on County Route 4, near Prattville, Alabama. Large population centers near the site include Prattville to the north and Montgomery to the southeast. Nearby towns, highways, the Alabama River, and transportation links (railroads and airports) are shown in figure 31. The site is bounded on the north by Autauga County Route 4, on the east by farmland and the Prattville sanitary land fill, on the west by Autauga Creek and the Union Camp paper manufacturing plant, and on the south by the Alabama River. The manufacturing plant facilities will be located approximately in the center of the plateau portion of the site which is presently being used for cotton farming and cattle grazing. The total site area is approximately 814 acres. The fuel fabrication facilitie.3, parking lot, and land-scaped gr6unds will occupy approximately 30 acres. Relative locations of the buildings on the site are shown in figure 3 2. 'The SNM Building is the principal manufacturing area where radioactive material chemical con-version, pellet preparation, fuel rod loading and storage, and final assembly operations are to be performed. This building is multistory, constructed with concrete outer walls and structural steel framework. All Special Nuclear Materials (SNM) authorized under the SNM license will be received, processed, and stored (with the exception of UF6 cylinder, storage) within this build-p ing. Preliminary liquid waste treatment, including waste treatment holdup tanks, will also be (j! located withir, the SNM Building. Treated liquid waste, after processing for removal of low enriched uranium and required chem-ical constituents,'will be dispatched to the Liquid Waste Treatment Area, where it will be ad-n justed to the proper pH by addition of sulfuric acid. ) All buildings and structures referenced will be contained within the SNM Building Plant Area, which is to be surrounded by a security fence (at a minimum distance of 150 feet from the nearest contained structures).- g ( ) v 3-1

The ANFFP will be primarily engaged in the manufacture of fuel assemblies for commercial nuclear reactors. The processing operations authorized under the SNM License will consist of receiving low enriched (less than or equal to 5.0 w/o U-235) uranium hexafluoride; processing the hexafluoride to produce uranium dioxide powder; and processing the uranium dioxide through pellet pressing and sintering, fuel rod loading and sealing, and fud assembly fabrication. These operations will be accompanied by appropriate controls to enhance radiological and in-dustrial safety, nuclear criticality safety, safeguards, and environmental protection. Certain scrap and waste materials generated on site are to be processed so as to permit them to be recycled back into production operations, or, to be more closely controlled before dis-card. Such processing operations include chemical dissolution and precipitation, wet mechanical separation, and dry thermal processes. In addition, combustible wastes are to be incinerated, on-or off-site, in equipment specially de-signed for this purpose. (This operation greatly reduces the volume of waste materials for dis-posal, and enhances accuracy of measurements made to determine the nature and quantity of SNM being discarded.) No liquid waste storage ponds or lagoons will be utilized at the Alabama Nuclear Fuel Fabrica-tion Plant. O O O O 3-2

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mU SECTION 4 (') DISPOSAL AND RELEASE CRITERIA V The cost estimates for transportation and disposal of low level radioactive waste materials

/~N presented in section 8 are based on 1980 dollars and current license conditions for an existing v)

\\ low-level waste disposal facility. Under existing license conditicns, radioactive waste materials received at the reference licensed disposal site must be carefully packaged in accordance with regulatory (DOT, NRC, State) requirements and facility management disposal criteria. The packaging costs listed in section 8 are based on Low Specific Activity (LSA) packaging requirements. This position is predicated upon the allowances o' 49 CFR 173.396(a), which states in part; The following materials are not classified as fissile radioactive materials, are exempted from this section, and must instead be packaged in accordance with other provisions of this subpart as appropriate: (5) A package containing less than 350 grams of fissile material, if there is not more than (p _) 5 grams of fissile material in any cubic foot within the package." Similarly, " Low Specific Activity" is defined in 49 CFR 173.389 which states in part: " Low . specific activity material means. (5) Objects of nonradioactive material externally contaminated with radioactive material, provided that the radioactive material is not readily dispersible and the surface con - tamination when averaged over an area of 1 square meter, does not exceed 0.0001 millicurie (220,000 disintegrations per minute) per square centimeter of Group i radionuclides or 0.001 millicurie (2,200,000 disintegrations per minute) per square p centimeter of other radionuclides." \\'"/ l. The packaging requirements for LSA are as provided in 49 CFR 173.392. In summary, the cost estimates presented in this plan are based on LSA packaging and trans- .portation requirements and on an existing low-level radioactive waste disposal facility's licensa (m) conditions. To enable these limits to be met it is essential that all material packaged for dis-posal be assayed for U 235 content, using an approved procedure, prior to release from the Alabama Nuclear Fuel Fabrication Plant (ANFFP) Controlled Area. n, 4-1 m

Release of equipment and packages from the ANFFP site area, or to uncontrolled areas on-site, must be in accordance with the following: e Hesidual contamination must be as low as reasonably achievable, not to exceed the following limits: Maximum Fixed Average Fixed Removable Nuclides Contamination Contamination Contamination 2 2 2 Uranium Alpha 15,000 dpm/100 cm 5,000 dpm/100 cm 200 dpm/100 cm 2 2 2 Beta Gamma 15,000 dpm/100 cm 5,000'dpm/100 cm 1,000 dpm/100 cm Erritters (1.0 mrad /hr at 1 cm) (0.2 mrad /hr at 1 cm) Radioactivity on surfaces must not be covered by paint, plating, or other coating e material unless levels, as determined by a documented survey, are below the residual limits (specified) prior to applying the covering. Radioactivity on interior surfaces must be determined by making appropriate meas-m urements at appropriate access points, provided that radioactivity at these locations is likely to be representative; otherwise, surfaces shall be presumed to have radio-activity in excess of the limits. O O O 4-2

O SECTION 5 CONCEPTUAL DECOMMISSIONING PLAN g U 5 1. PLANNING AND PREPARATION OQ Prior to the commencement of Alabama Nuclear Fuel Fabrication Plant (ANFFP) decommission-ing, an extensive study and evaluation program will be initiated. The following considerations will be included in the study: a. Compliance with regulations applicable at that time. b. Dose equivalent rates and radioactivity levels of components. c. Physical size and weights of various components. d. Excavation requirements. e. Equipment available to transport waste products. \\j f. Containers available in the industry approved for packaging of equipment, components, and other waste materials. g. Control guidance within which to function, such as: (1) What dose equivalent rates are acceptable? (2) What work is to be done in Controlled Areas? (3) What work can be done in Restricted Areas? p (4) What types of radiation and radioactivity control measures are to be used? i h. Assignment of a category to each item (or groups of items), which would involve placing items in categories for packaging, assay, and handling where consideration can be given to dose equivalent rate, volume, and weight. m , (J) i. Disposal of equipment, materials, and piece parts. l l j. Disposal of radioactive sources. l k. Disposal of earth with excessive levels of radioactivity. ("N, L S-1 L

I. Razing of structures and facilities (as required). m. Cleanup to meet limits for levels of radioactivity. n. Disposal of materials generated by decommissioning activity. o. The analysis of all materials disposed of during decommisAning for U 235 content. 5-2. RADIATION AND RAC!OACTIVITY CONTROL Control of radiation exposure and spread of radioactivity is of primary importance during the conduct of decommissioning activities Appropriate measures will be taken to minimize (or eliminate) radiation exposure to personnel and spread of radioactivity to the environment. Upon completion of each action phase (such as dismantling and decontamination of a portion of a process area), radiation and radioactivity surveys will be performed. Af ter the surveys are analyzed for a particular work area, the area will be released, or further decontaminated (es necessary), to achieve acceptable limits. During all dismantling operations, continuous air sam-pling will be conducted. Also, grab samples will be taken at the point of worker involvement. The control level on air samples will be 25% of the applicable M ximum Permissible Concen-tration (MPC) for the isotopes involved. The control area will encompass all process areas where radiation or radioactivity exists in amounts above the limits established for clean areas. Personnel entry to, and exit from, con-trol areas will be through designated access control points only. All equipment entry and exit from the process work areas will have a designated control point. (This will serve as a survey point for initist release and proper documentation for transport loading.) All transport vehicles arriving at the ANFFP facility will be cleared, logged in, and isst d passes. The vehicles will then be weighed and surveyed (if applicable), before moving to the designated loading area. To avoid overweight during loading, portable scales will be used to determine the individual axle weight of each truck and trailer. When the loading operation is completed, the truck will be moved to a designated area and surveyed for release. Soil and water samples will be collected and analyzed to confirm that the surrounding environ ment has not been affected. If any radioactivity levels in excess of allowable limits specified in applicable regulations are found, soil from the affected areas will be removed and transferred to a licensed disposal facility (or otherwise treated as necessary to bring it to an acceptable level). O 5-2

a 5 3. CONCEPTUAL IMPLEMENTATION When it eventually becomes necessary for Westinghouse to decommission the Alabama Nuclear Fuel Fabrication Plant, a contractor will be selected and all cognizant parties will be included in the decision making process to ensure an orderly progression of decommissioning activities. .p. Westinghouse personnel and the selected contractor will meet with the appropriate Nuclear Regulatory Commission staff to review criteria procedures and to identify the NRC representa-tives who will be authenticating the results of the final surv y. .p Required decommissioning support systems will be left in service until all other equipment has lh been removed, packaged, and possession is transferred to an authorized receiver. This will per-mit'Special Nuclear Material (SNM) processing and analysis throughout the entire effort, and . will provide a means of processing SNM waste removed during the decontamination process. All piping in process areas will be flushed thoroughly to ensure that internal radioactivity has been removed before any dismantling occurs. Utility service to the facility will be left intact; however, isolation and disconnection will be made before removal of the equipment in each service area. (A schedule of service disruption and disconnection will be developed during the initial survey period.) I .X The initial radiolcgical survey and cleansing tests will be comprehensive. After the results of these surveys and test

• have been analyzed and after a final decommissioning plan is developed and approved, decommissioning will begin (See figure 5-1 for conceptual implementation flow).

A radiological assessment of process structures and areas will be performed after all SNM and . process system equipment and hardware is removed. These structures will have to meet radio-activity control criteria for packaging; otherwise appropriate decontamination will have to be h- . performed prior to dismantling and packaging in accordance with established disposal criteria. Overhead piping and connecting piping will be removed and similarly processed. I -g Following removal.of all equipment from the process areas, reuse decisions concerning the ) buildings and grounds will be made. Affected areas and equipment located in any'open, uncovered areas will be addressed during f the final phase of decommissioning. (Equipment and small structures that are affected, however, lmight be included in shipments of m'aterial from the process area.) In areas where affected-s . underground piping is removed, the ground surrounding the' piping will be surveyed, and re-g ~' moved for burial if established radioactivity: limits are exceeded. The final survey' of the ANFFP_ buildings and site will begin only after the complete removal: j g i of all radioactive material from the site, and after the final survey and release of all heavy L(%/); - equipment,. vehicles, and support equipment.' l~ '5-3 ll

O O O O O O O DISPOSE OF PERFORM INITI AL NONRADIOACTIVE RADIOLOGICAL SURVE Y EQUIPMENT AND SUPPLIES U REMOVE NON PROCESS PERFORM WASTE AND REMOVE EXCESSIVE RE LATED MATE RI ALS, + RADIOLOGICAL + SEGREGATE ~* RADIOACTIVE MATERI AL SCRAP ASSAY EQUIPMENT AND HARDWARE EVALUATION (REMOVE SNM) n DISPOSE Of t ~* RADIOACTIVE SCRAP .m - a g 1r y REMOVE PROCESS DISMANTLE I WASTE AND PERFORM FINAL SYSTEM EQUIPMENT STRUCTURES SCR AP ASSAY RADIOLOGICAL SURVEY AND HARDWARE AND FACILITIES l n n PERFORM RADIOLOGICAL ASSESSMENT OF PROCESS PREPARE STRUCTURES AND ARE AS FIN AL REPORT CONDUCT CLEAN OUT i CAMPAIGN OBTAIN l FINt.L CLE ARANCE Y l m 8 l Figure 5-1 Decommisioning Conceptual implementation Flow n l = - - - -. r

1 4 O l SECTION 6

O DECONTAMINATION METHODS f

Table 61 lists decontamination aids and table 6-2 lists decontamination methods and the order in which testing might be done in accordance with expected conditions at the Alabama Nuclear Fuel Fabrication Plant (ANFFP). i l i i i e O l O O 4 O 61 -...-.~...... - -....-..

TABLE 6-1 DECONTAMINATION AIDS Method Surface Function O Vacuum Cleaning Dry or wet Rapid removal of loose dirt - (absolute filter at exhaust side) helps prevent airborne activity l i Steam Painted or metal; Steam strip of dirt and oil from I irregular (such as finished and hard to reach corners, etc.) surfaces. Detergents Nonporous Dissolves or loosens and entrains films. Complexing Agents: Oxalates Nonporous, nonrust Holds radioactivity in solution Carbonates or oxidized Citrates l Organic Solvents Nonporous Quick grease and oil dissolving l action, very little solution to I dispose of as waste. l Also used for paint removal. Inorganic Acids Metal Dissolution of metallic surfaces and radioactive salts and/or oxides. Caustics: Trisodium Painted (vertical) Quick reduction in radioactivity Phosphate by dissolution and complex formation. Abrasion Nonporous Reduce level as low as desired i by physical removal of con-taminated surface. O O 6-2 L

4 I l' f TABLE 6-2 DECONTAMINATION METHODS (Listed in Recommended Order of Trial) Materials Method of Decontamination Concrete 1. Vacuum [ 2. Detergent and water i

3. Wetting agent mixture i

4. Steam cleaner 5. 10% ammonia citrate solution 6. HCE solution (30-60%) 7. Chip away area i Steel 1. Vacuum 2. Detergent and water 3. Decon 4306 D(a) (if oxidized) 4. TiO2 paste (keep wet) 5. Remove section i Transite 1. Vacuum 2. Detergent and water

3. Wetting agent mixture (versene) 4.

Remove section 5. Abrasive powder (keep wet) - Aluminum 1. Vacuum 2. Detergent and water -

3. ' Wetting agent (a) (if oxidized)

'4. Decon 4306-D 5. TiO2 paste (keep wet) 6. Remove section Glass

1. Commercial window cleaner

2. Detergent or' Na3 PO4 solution

3. - 10% ammonia citrate solution O

Tile - 1. Vacuum 2. Detergent and water (wet vacuum) 3.- Trisodium phosphate (Na3 PO ) 4 i 4. 10% ammonia citrate solut on 5. Acetone (or other solvent) ~ 6. Remove section Linoleum - 1. Vacuum ~

2. ~ Detergent and water

. 3. Solvent - 4. Dilute HCR 5. Ammonia citrate solution 6. Remove section-4 6 _ . _ u.-.,.-._..... -. _

TABLE 6-2 (cont) DECONTAMINATION METHODS (Listed in Recommended Order of Trail) Materials Method of Decontamination lO Painted Surfaces 1. Vacuum 2. Detergent and water i 3. Wetting agents 4. Decon 345 or decon 4182 A 'I l 5. Steam Cleaner 6. Dilute HCC 7. Paint remover Wood 1. Vacuum 2. Remove section Soil 1. Process (for uranium recovery) 2. Disposal (at licensed facility) 1 a. or equivalent commercial decontamination agents O O l 9 O 6-4

~ l O SECTION 7 O EQUIPMENT VOLUME AND SURFACE DATA The following list shows equipment volumes and surface areas used in estimating the total vol-l ume of materials for disposal during decommissioning of the Alabama Nuclear Fuel Fabrica-tion Plant (ANFFP): 3 ITEM VOLUME (ft ) EQUIPMENT Conversion 50,000 Powder Processing 6,000 Pelleting 65,000 Rod Loading and Inspection 5,000 v Scrap Recovery 6,000 t Ef fluent and Waste Treatment 105,000 Ancillary Labs and Services 1,000 Subtotal: 238,000 i SURFACES (Assumes average 0.25 incl removed) Floor and Walkway Areas 3,540 O Wall Areas 1,550 Ceiling Areas 3,540 Subtotal: 8,630 3 Total (Rounded): 250,000 ft o 71

i I i l t i O i i SECTION 8 {Q COST ESTIMATE l l i The following list shows expense parameters used in estimating the cost of decommissioning { the Alabama Nuclear Fuel Fabrication Plant (ANFFP): i Parameter Cost ($) LABOR i i. Craft Personnel 1,400,000 Health Physics Personnel 600,000 Subtotal: 2,000,000 I TRANSPORTATION AND DISPOSAL l Equipment 100,000 Packaging (275 boxes @ $1500 ea.) 412,500 ) Transportation (200 loads @ $500 ea.) 100,000 3 . Disposal (@ $8 per ft ) 2,000,000 f Subtotal: 2,712,500 1 1 SURVEYS l Initial Site 45.000 Final Release 85,000 Subtotal: 130,000 i CONTINGENCY l 1 - 10 percent - 484,000 Total (Rounded): $5,000,000 ..O 8-1 i l

i 4 I r I v l' t i SECTION 9 [6 FINANCIAL SURETY i l The Decommissioning Plan for the Alabama Nuclear Fuel Fabrication Facility (ANFFP) includes consideration of financial arrangements for defraying the expenses at the time of implementa-tion. An April 25,1978 letter (Attachment 9.1) to the U.S. Nuclear Regulatory Commission, from J. J, Taylor (Vice President and General Manager, Westinghouse Water Reactor Divisions) addresses this subject. (Although the introduction to this letter discusses the specific Columbia, l' SC and Cheswick, PA licensed sites, the text of the letter applies its commitments to "... all of the sites for which Westingh'ouse holds a Part 70 license.".) l 1 i i !~ O O 9-1 . ; e,,. Y

_..1 Wastinghouse W31ter Reactor gy'scenru Electric Co parat, tan Om, sions r;:reuo rennsysania 1522a V j J rapar Y,ce Ptesidant a C-terall. tanager April 25,1978 WRD-890 O v U.S. Nuclear Regulatory Commission Office of Nuclear' Material Safety & Safeguards Division of Fuel Cycle and Material Safety. Washington, D. C. 20555 Attention: Mr. L. C. Rouse, Chief Tuel Processing and Fabrication Branch Gentlemen:

Subject:

Westinghouse-NRC 10Iaterial License Financial Decommissioning Plan Several discussions have been hel' recently between Westinghouse and the d p NRC concerning the NRC licensing requirements relating to decontamination d and decommissioning the Columbia, S.C., and Cheswick, Pa., licensed sites. These discussions include the following subjects: 1. Decontamination of sites so that they can be released for unrestricted use. '2. Decommissioning of nuclear facilities.' 3 Cost estimatcs of the above. (A) 'v 4. Financial arrangements for assuring the availability of adequate . funds over the cost of El and #2 above. T' Westinghouse will comply./ith the applicable laws'when decontamination (g _ and decommissioning are required. This letter discusses the financial arrangements of Westinghouse to cover these projected costs. The other ~ three subjects'above have bei2n or will be covered in separate presentations !O the NRC. -n 4 i \\"/ P00R ORlGlNAl. 16130

2 -- The priraary financial plan will be carried out as a normal accounting function required by Financial Accounting Standard #5, " Accounting for Contingencies" and also by other generally accepted accounting practices. This involves a periodic review of the costs of decontamination and/or decommissioning, and, at the same time, an estimate of the proceeds from disposition of the related ar-sets. If the estimated future costs exceed the estimated future proceeds, an accounting provision will be made for the difference. This reflects current Westinghouse practice. Westinghouse also proposes two' notification points to provide continuing assurance to t'he NRC of Westinghouse's ability to pay these costs when they occur. First, Westinghouse will notify the Commission if at any time its cash position is less than the estimated cost of decontaminating and decommissioning all of the sites for which Westinghouse ho!ds a Part 70 license. Secondly, Westin time its debt-equity ratiofl) ghouse will notify the Commission if at any _ ever exceeds 40%. This is the approximate level at which a comfortable borrowing level would no longer exist. ~ We feel that these combined actions provida a satisfactory program' to assure that adequate funds will be available when needed for decommissioning er decantaminating the Westinghouse licensed sites. Very truly yours, ^,{ - Ta y Vice President and ' General Manager ~ G Ir.terest bearing debt vs. Interest bearing debt plus equity. O}}