ML19351C745

Pennsylvania State Univ., Unified Decommissioning Funding Plan

ML19351C745
Person / Time
Site:	Pennsylvania State University
Issue date:	12/12/2019
From:	Erdman M, Guo Y, Shannon King Hershey Medical Center, Pennsylvania State Univ, Pennsylvania State Univ, University Park, PA
To:	Office of Nuclear Reactor Regulation
References
Download: ML19351C745 (30)

Text

l Unified Decommissioning Funding Plan For The Pennsylvania State University Radiation Facilities At University Park, Hershey Medical Center, And Related Campuses December 12, 2019 l

Prepared by:

Yuanqing Guo Radiation Safety Officer, University Park Steve King Radiation Safety Officer, Hershey Medical Center Mike Erdman Hershey Medical Center 12/1212019 Executive Summary Page 1 of6

Introduction and Executive Summary These decommissioning funding plans (DFPs) were prepared using NUREG-1757 Volume 3 Rev 1 (2012) as a guidance document. The section designations correspond to the numbering system used in Appendix A.3 of the NUREG.

The Pennsylvania State University comprises 23 major campuses spread across the state as shown in Figure 1 (note that the Penn College of Technology is not under Penn State's Environmental Health and Safety oversight and thus is not counted in the list of supported campuses shown on the map). However, the use of radioactive materials is currently limited to the following 4 locations by either a Pennsylvania Department of Environmental Protection (PA DEP) issued license or by a Nuclear Regulatory Commission (NRC) issued license:

1. University Park Campus (UP)-the main campus (PA and NRC licenses)

2. Penn State Breazeale Nuclear Reactor (PSBNR) at UP (NRC license)

3. Harrisburg Campus (UP PA license)

4. Penn State Hershey Medical Center (PSHMC) (PA license).

Of these four locations, only three regularly utilize radioactive material: University Park, the Hershey Medical Center, and the Breazeale reactor. The Harrisburg campus, while an authorized place of use under the UP PA state license, has only one laboratory that has utilized P-32 occasionally in 2018 and 2019 since last update of the DFPs in 2016.

There are five licenses that are held by Penn State University:

DFP License Number Issuing Agency Brief Description and Campus Location Appendix PA-0100 PADEP Broad scope byproduct materials, UP & others A PA-0127 PADEP Broad scope byproduct materials, PSHMC campus B PA-0127A PADEP Self-shielded irradiator license, PSHMC campus C SNM-95 NRC Special Nuclear Materials, UP campus D R-2 NRC Research and Test Reactor license, UP campus E Because of the disparate geographical and radioactive material usage differences between the licenses, each has been separated into a self-contained appendix to this document. The PA DEP will want to review Appendix A, B, and C. The NRC will want to review Appendix D and E.

The method for estimating decommissioning costs was changed in December 2012 when an update to 10 CPR 30.35.(e).(l).(i).(A) now requires costs estimates to be based on the cost of an independent contractor to perform all decommissioning activities. The cost estimates in this DFP reflect this change.

Records of information important to the decommissioning of Penn State's licenses are retained at the University Park Environmental Health and Safety offices and at the Health Physics offices at the Hershey Medical Center. Facility descriptions, including currently active buildings, numbers of active lab, and most used radioisotopes have been given in the Section A.3.4 Facility Description of each attachments.

12/1212019 Executive Summary Page 2 of6

Detailed room number and isotopes used in each room and dates are included in the building decommissioning reports that are submitted to Pa DEP or NRC for review. In addition, Historical Site Assessment resource lists have been given in Section A.3.6 Planning and Preparation of each attachment.

The decommis~ioning cost estimates for each license, individually and combined, are as follows:

Penn State University Unified Decommissionine Cost Estimate License Type DFP Appendix Estimated Cost($)

PA-0100 Broad Scope A $3,792,779 PA-0127 Broad Scope B $3,270,340 PA-0127A Irradiator C $540,316 SNM-95 Special Nuclear Materials D $286,710 R-2 Reactor E $21,480,473 Penn State University TOTAL $29,370,618 Basic Assumptions Common to All DFPs Several assumptions must be made to estimate the cost of decommissioning the facilities under each license. The assumptions common to all licenses are listed below while assumptions specific to a license are contained in that license 's appendix.

1. Compliance with 10 CFR 20.1402.

The operations plans and the cost estimates are based upon meeting the release limit of 10 CFR 12/12/2019 Executive Summary Page 3 of6

20.1402. This release limit requires that "residual radioactivity that is distinguishable from background radiation results in a total effective dose equivalent (TEDE) to an average member of the critical group that does not exceed 25 mrem per year."

2. One license is terminated at a time.

It is very unlikely that multiple, or all, licenses would be terminated at the same time. Because of shifts in the focus of research utilizing radioactive material over time, it is much more probable that only one license would be terminated at any one time. Normally Penn State staff would be available for decommissioning work in these instances; however, this DFP assumes an independent contractor will perform all work.

3. Decommissioning estimates are based on current inventory and use locations.

While each license may allow a larger selection of isotopes and activities than presently in use, this DFP is based on current inventories and use locations. As required by NRC regulations, the DFP will be updated every three years to reflect the future status of inventories and locations.

4. Penn State University will continue a "clean operations" policy.

In accordance with 10 CFR 20.1406(c), Penn State will continue its long-standing policy of maintaining use locations free of contamination. This means that whenever a room, area, or major piece of equipment becomes contaminated, it is cleaned or disposed of, as appropriate, soon after discovery. Penn State can support this assumption by review of many years of survey data that show our laboratories do not have significant contamination issues. This "clean operations" policy is al~o in effect at the Hershey Medical Center.

5. No remodeling costs are included.

Decommissioning costs do not include removal or disposal of non-radioactive structures or materials beyond that necessary to terminate the radioactive material license. Costs are not included for replacing hoods or bench-tops that were removed due to contamination. No follow-up costs for remodeling and renovation are included in these estimates.

6. No credit for salvage.

No credit is taken for salvage of equipment or materials that would likely be sold or transferred to another licensee, nor is credit taken for sale of non-radioactive use items.

7. No license amendments required.

No license amendments are expected for decommissioning. All activities are within the normal scope of tasks currently performed on a regular basis in accordance with established written procedures. If these tasks are performed by Penn State employees or by an outside group, the tasks are expected to be commensurate with normal activities.

8. Vendors will ship Type B materials.

Large activity sources that require Type B shipping containers will be shipped by outside vendors in accordance with the disposal methods currently used. No costs are included for Penn State to write and document a quality assurance plan. The outside vendor(s), specifically licensed to perform this work will perform the packaging and shipping of the material.

12/12/2019 Executive Summary Page 4 of6

9. Decommissioning of buildings. .

Buildings in which " ... no principal activities under the license have been conducted for a period of 24 months ... " are decommissioned in accordance with 10 CFR 30.36.(d).(3). Generally, it is infrequent that a building that had radioactive material labs is decommissioned because labs do not terminate their use often. When a building is decommissioned its hoods, ducts, and sinks are checked for contamination, all labels and tags are removed, and a report is filed confirming compliance with 10 CFR 20.1402. This building report relies heavily upon the agglomeration of individual room decommissioning reports and is available for inspection. Buildings and spaces previously released by the NRC and PA DEP are not included in these DFP estimates.

10. A licensed radioactive waste site is available.

This DFP must be based upon the assumption that the shipment of radioactive waste is possible.

Penn State currently has the ability to store waste for about six years prior to shipping, but decommissioning can only be accomplished if a low-level radioactive waste disposal facility is available.

11. The Department of Energy (DOE) will accept the return of their materials.

Certain sources and materials must-be returned to the DOE for disposal. If the DOE refuses to receive this material then long-term storage costs may be significant; these costs are not included in these DFP estimates.

Basic Assumptions Common to Only PA Broad Scope License DFPs Additional assumptions have been incorporated into the DFPs for Pennsylvania Department of Environmental Protection issued broad scope licenses.

1. Waste 'On-hand' equals one year's waste generation.

This DFP assumes that one year's worth of normal operations waste is already 'On-hand' and waiting disposal at the start of decommissioning. Added to this amount will be the decommissioning waste so that the total amount of radioactive waste will be slightly larger than just from decommissioning activities only.

2. A portion of prior licensee decommissioned use locations are included due to the potential need for additional verification surveys.

Related to assumption 3 above, laboratories and use locations which are no longer authorized for radioactive material work are surveyed and inspected by Radiation Safety staff. Location owners are required to have all radioactive material removed and to clean their facilities and equipment to background levels. Radiation Safety staff then perform a more detailed survey (compared to standard quarterly surveys) to verify the space is releasable. The space is then de-posted and allowed to be used as unrestricted space.

When an entire buildin'g no longer has any radioactive material users, it has been Penn State practice over the past several years to then invite the PA DEP to inspect and officially release the building. However, this current practice does not take into account buildings which are not currently being used where the PA DEP has not had the opportunity to perform independent 12/12/2019 Executive Summary Page 5 of6

analysis. Therefore, it is possible that a portion of the historical previously released spaces will need additional survey work to verify cleanliness. We assume that up to ~5% of licensee released laboratories that are not yet officially released by the PA DEP will require additional survey work. The cost for these additional surveys is included in both broad scope license DFPs.

Reasons for the Differences in Cost Estimates with this DFP The difference in cost estimates between this 2019 DFP and the 20163 DFP are due to these factors:

1. All costs have been updated to 2019 values.

2. For the Breazeale Reactor Facility, although the facility-specific DFP cost estimate, Appendix E, is in agreement with other reactors, the Georgia Institute of Technology decommissioning cost continues to be the worst case scenario and thus Penn State will continue to use that cost for this DFP.

(

12/12/2019 Executive Summary Page 6 of6

APPENDIX E - University Park R-2 NRC Reactor License Section A.3.4 Facility Description License Numbers and Types The Pennsylvania State University maintains license number R-2 issued by the Nuclear Regulatory Commission as a license for the Penn State Breazeale Nuclear Reactor (PSBNR) as a test and research reactor at the University_Park Campus.

Types and Quantities of Materials Authorized The following are the licensed materials and quantities permitted under R-2:

Table 1 - PSBNR R-2 License Details Line Isotope Form Allowed Quantity Item A

B C

D E

F G

Description of How Licensed Materials Are Used The Penn State Breazeale Nuclear Reactor (PSBNR) is a lMW water cooled natural convection reactor using TRIGA fuel that has been in operation since 1955. It is the center piece of the Radiation Science and Engineering Center (RSEC) and the Nuclear Engineering Department, and is used for teaching, research, and training in reactor physics, nuclear science and engineering. The reactor is also used as a test reactor for activities such as irradiation and neutron testing of components, archeological artifacts, and the production of isotopes for use at the University Park campus.

Routine surveys are performed by Radiation Protection staff weekly to assure that safe working conditions are maintained. Normal operating procedures require that radioisotope laboratories minimize contamination. Typically, surveys show no removable contamination above background (approximately

< 50 dpm/100cm 2) on surfaces and equipment using liquid scintillation counting (LSC) and Geiger meters. Penn State maintains a "no contamination" policy and any finding above background is promptly addressed and decontaminated.

• Because of this continuous characterization of the radiation environment, normal decommissioning typically requires only the removal of the fuel, core components, moderating and cooling water, the pool structure, miscellaneous activated support components, and radioactive waste consisting of paper, plastic, and glass lab ware followed by appropriate surveys of the facility and equipment.

12/12/2019 Appendix E Page 1 of24

All fuel is owned by the Department of Energy (DOE) and is assumed that the DOE will take back all fuel. All fuel disposal costs, other than shipping, are assumed to be covered by the DOE.

Description of Facilities Currently, the rooms covered by this decommissioning funding plan (DFP) are:

Table 2 - PSBR Bttildings and Rooms Number of Campus Building Use Rooms UP I UP I UP I UP I UP I UP I TOTAL Rooms I Within any given approved laboratory space, researchers are encouraged to limit work with radioactivity to as small an area as possible, i.e. one bench top. Individual instruments and equipment that are used to store or process radioactive samples are labeled with a Caution Radioactive Material label.

The decommissioning costs of this license are difficult to quantify therefore the costs from similar facilities will form the basis for estimating Penn State's future costs. Cost and labor estimates were obtained from the Georgia Institute of Technology for the decommissioning of their 5 MW reactor in 2001, from the University of Virginia for the decommissioning of their 2 MW reactor in 2002, the decommissioning plan estimates of the AFRRI TRIGA reactor found in AFRRI Report TR89-2 (similar to the Oregon State University TRIGA reactor), the Cornell University Ward Nuclear Center TRIGA reactor in 2006, and the MIT reactor decommissioning funding estimate contained in MIT letter dated October 1, 2014 to the Nuclear Regulatory Commission (NRC).

Radioactive Waste On-Hand Before Decommissioning All wastes with a half-life of less than or equal to 120 day half-life is held for decay for at least 10 half-lives, then surveyed and released as non-radioactive waste. Liquid wastes with half-lives greater than 120 days are disposed via sanitary sewer by Radiation Protection staff after ensuring the isotopes, 12/1W019 Appendix E Page 2 of24

solubility, concentration, and total activity are within all allowable release limit criteria. All other long lived wastes are shipped to an appropriate waste disposal facility.

Currently all radioactive waste generated by the PSBR facility during routine operations is processed by the Radiation Protection Office and comingled with waste from other laboratories in one waste handling facility. However, greater than 90% of the wastes 'On-hand' at any given time is generated as the result of Penn State's broad-scope licensed activities.

Since all other radioactive wastes generated during the project have been disposed of after the project was completed, instead of as 'On-hand' waste at the time of the decommissioning process.

For the purpose of this decommissioning funding plan (DFP) it is assumed that any PSBR facility waste that happens to be 'On-hand' at the time of the decommissioning process will be inconsequential to the final volume and cost of the waste that will be generated during decommissioning activities. Therefore, the amount of PSBR facility waste 'On-hand' at the time of decommissioning shall be considered to be zero. The information provided below is included only as a reference for the typical types, volumes, and cost of disposal experienced by the licensee over the past several years .

- . Tab)e*3-'- Waste Histw-y -

Number, typ*e Total Total Volume Year of Container Isotopes Activity Weight Cost (Unit Volume)

(Waste Type) (mCi)

H-3, C-14, U-5, Cardboard Nat, Fe-55, 78 ft 3 2014 Boxes Co-60, Zn- 19.4 mCi 629 lb $3,522 (15.6 ft:3/box)

(DAW) 65, Ca-45, Th-Nat H-3, C-14, 1, 55-gal Metal Co-57, Co-Drum 60, Fe-55, 0.95 mCi 7.35 ft3 130 lb $910 (Metals) Cs-137, Mn-54, U-Nat 1, 30-gal Fiber Drum Fe-55 0.005 mCi 4.1 ft3 /drum 49 lb $ 289 (LSC Vials) 1, 30-gal Plastic Drum Overpacked in 1, C-14, H-3, 55-gal Metal Co-60, Cs- 5.2 mCi 4.1 ft3 /drum 49 lb $7,937 Drum 137 (Mixed Liquid Waste) 2 5-gal Metal Eu-154, Cs- 0.02 mCi 0.67 ft3 304 lb $2,37lr 12112/2019 Appendix E Page 3 of24

Drum 137, Co-60, (Lead) Na-22, Cs-137, Co-60 U-Nat 26 Containers &

Contaminated 1605 lb $12,118 11 Bags Asbestos Ra-226, 3 LSC Standards 0.07 mCi (3 LSCs) (3 LSCs) $1,080 Cs-137 TOTAL $28,227 2015 None None None None None $0.00 2016 None None None None None $0.00 H-3, C-14, U- I nat, Fe-55, Ca-45, Co-13, Cardboard 60, Zn-65, 202.8 ft3 2017 Boxes Cs-137, Na- 37.5 mCi 1350 lb $9,534 (15.6 ft3/box)

(DAW) 22, Mn-54, Sb-124 Mn-54, Ba-133, Ni-63 Co-57, Co-1, 55-gal Metal _60, Cs-137, Drum Co-58, Mn- 2.2 mCi 7.35 ft3 268 lb $2,184 (Metals) 54, Zn-65, \

~

Fe-55, Ni-63 6, 30-gal 24.6 ft3 Fiber Drum Fe-55, Ca-45 1.2 mCi 354 lb I $3,540 (4.1 ft3/drum)

(LSC Vials) 1 LSC Standard Ba-133 0.02 mCi $950 1 ECD Source Ni-63 15.0 mCi $950 Total $17,158 H-3, C-14, U-Nat, Fe-55, 9, Cardboard Co-60, Eu- 140.4 ft3 2018 7.9 mCi 693 $5,094 Boxes (DAW) 151, Na-22, (15.6 ft3/box)

\__

Mn-56, Ca- '

45 5, 30-gal Fe-55, Ca-45, 20.5 ft3 Fiber Drum Na-22, Ra- 0.9 mCi 351 $3,580 (4.1 ft3 /drum)

(LSC Vials) - 226

$23,530 12/12/2019 Appendix E Page 4 of24

- ** -)

Total $32,204 H-3, C-14, U-nat, Fe-55, 4, Cardboard Na-22, Co- 62.4 ft3 2019 2.48 mCi 337 $2,477 Boxes (DAW) 60, Cs-137, (15.6 ft3/box)

Th-Nat, Ra-226 3, 30-gal Ra-226, Fe- 12.3 ft3 Fiber Drum 0.09 mCi 188 $1,931 55, Na-22 (4.1 ft3/drum)

(LSC Vials) 1 LSC Standard Ra-226 0.01 mCi $575 1 ECD Source Ni-63 15.0 mCi $575 2 Alnor Ra-226 0.014 mCi $2,900 Dewpointers 12, Cardboard 18.0ft3

• Boxes H-3 0.17 mCi 178 $4,948 (1.5 ft3/box)

(Biological)

TOTAL $13,406

• Dry Active Waste (DAW)

• • The waste of activated reactor components generated during the 2018 neutron beam port modification projects was disposed of right after the project is completed. Therefore, it would not be treated as waste 'on-hand" before the decommissioning process.

The cost per waste type is provided in Table 4.

Table 4- Waste Cost History Year Waste Type Cost per Cubic Foot Cost per Pound Waste Broker 2014 Dry Active Waste $45.15 $5.60 Ecology Services, Inc. Metals $123.81 $7.00 LSC Vials $70.49 $5.90 Mixed Liquid Waste $1,935.85 $161.98 Lead $3,538.80 $7.80 Contaminated Asbestos $7.54 LSC Standard $1080 / 3 LSCs $360 /LSC 2017 Dry Active Waste $47.00 $7.10 Ecology Services, Inc. Metals $297.14 $8.15 12/12/2019 Appendix E Page 5 of24

LSC Vials $143.90 $10.00 LSC Standard/ECD

$950 I each $950 I each Source 2018 Dry Active Waste $36.28 $7.35 Ecology Services, Inc. LSC Vials $175.00 $10.00 2019 Dry Active Waste $39.70 $7.35 Ecology Services, Inc. LSC Vials $157.00 $10.27 LSC Standard/ECD

$575 I each $575 I each Source Biolocical $274.88 $28.00 For easier analysis, the U!1,it costs table above has been rearranged as follows:

Table 5 - Cost per Cubic Foot LSC Mixed LSC Year DAW Metals Biological Lead Asbestos Vials Waste Standards 2014 $45.15 $123.81 $70.49 $1,935.85 $3,539 2017 $47.00 $297.14 $143.90 2018 $36.28 $175.00 2019 $39.70 $157.00 $274.88 Table 6 - Cost per Pound Year LSC Mixed LSC DAW Metals Biological Lead Asbestos Vials Waste Standards 2014 $5.60 $7.00 $5.90 $161.98 $7.80 $360/LSC 2017 $7.10 $8.15 $10.00 $950/each I 2018 $7.35 $10.00 2019 $7.35 $10.27 $28.00 $575/each Although the amount of PSBR facility waste 'On-hand' at the time of decommissioning shall be considered to be zero, for information purpose, the largest amount of all types of waste for the past three years will be assumed to be the waste 'on-hand' at the time of decommissioning. The cost for the disposal of the waste 'on-hand' is calculated in Table 7 below, which is included in the decommissioning funding plan for Penn State broad scope license. Therefore, the total cost in Table 7 is not included in the Table 25 - Total Decommissioning Costs.

The projected cost of disposal for waste 'On-hand' will be based on the market rates currently in effect as quoted by our LLRW disposal contractor, Ecology Services, Inc. (February 2019):

12/1212019 AppendixE Page 6 of24

Table 7 - Cost for Disposal of Waste On~Hand At Start of Decommissioning DAW Metals LSC Biological Poun(ls 1350 268 354 178 Cost per Pound* $7.35 $9.20 $10.27 $28 Total $9923 $2466 $3636 $4984 Grand Total $21,009

• Cost per Pound pricing provided by Ecology Services, Inc. (February 2019)

Volume of Contaminated Subsurface Materials The PSBR is a pool type reactor using 71,000 gal of ultra-pure water for neutron moderation and cooling. Throughout the operating history of the facility, pool water leaks have occurred to varying degrees and at varying times. Most recently, in early October of 2007 a pool water leak was detected with the release of an estimated 12,300 gal (based on integrating the reported variable leak rates contained in the NRC inspection report, accession number ML073480163, over the 43 days of the event). At the time of the incident and for 3 months following (into December 2007), well water was sampled at 5 locations near the PSBR facility. The data showed a maximum well water concentration of slightly less than 600 pCi/L with a 1000 pCi/L minimum detectable activity (MDA).

When decommissioning does occur, soil sampling will be performed to assess radiological condition under the facility. Because no significant levels of tritium were found in wells due to the last event, it is assumed that any radionuclides that may be present from pool leaks have remained under the facility. A worst scenario would be the removal of a volume of soil the size of the reactor bay to a depth of 5 feet.

Section A.3.5 Number and Dimensions of Facility Components Type of Space: Reactor, bay, rooms, and components.

Average Size: Not Applicable Level of Contamination: < 100 dpm/100 cm2 Table 8 - Reactor Components Component - Number of Components Dimensions of Component I

I I

I

• I I

I I

I I

I 12/12/2019 Appendix E Page 7 of24

I I -

I I

I I

I I

Bulk Equipment:

Waste Containers 3 1.5 x 1.5 x2.5 feet Hand Items (Misc tools, etc.) 100 Section A.3.6 Planning and Preparation (Work Days)

Current Conditions _

A third party contractor will be utilized for the decommissioning effort. It is assumed that normal operations continue up until the date the contractor comes on site. The contractor will need to first familiarize themselves with the facility and define the scope of work. . 1 The Radiation Protection Office (RPO) and/or PSBR maintain all records pertinent to the u.se of radioactive materials under the licenses. These include receipts, stock vial inventory, locations of use or storage, waste inventory, personnel, and sealed sources. The recor,ds are kept electronically in a database and updated as the record is generated (i.e. inventory is updated as stocks are received; lab survey data is updated soon after the survey is completed, etc.) Radiological surveys are performed on at least a weekly basis and paper records kept for at least three years; therefore, a review of these documents will demonstrate the recent levels of contamination which may be expected.

Historical Site Assessment The following records are available in the RPO and/or PSBR with regard to historical use of radioactive materials:

A) Paper survey reports of the facility where radioactive material has been used for the past three years.

Survey reports are not to scale, but represent the pertinent fixtures and equipment used for radioactive materials work. Surveys may extend to non-use areas and equipment that may be in a particular location. Survey reports typically record the radionuclides recently used and may not reflect all historical uses in a particular location; however, historical purchase records are available.

B) ,A listing of all locations by user, nuclides: building and room number where radioactive materials were ever authorized under state license.

)

C) A listing of locations where radioactive materials are currently authorized.

D) A database of all radioactive waste currently being held in storage, whether for decay-in-storage, or ship-out.

12/12/2019 Appendix E Page 8 of24

E) Scale _floor plans of buildings are maintained by Facilities Management but survey maps used by the RPO show major room components.

F) Annual summaries of discharges to the sanitary sewer system by the RPO are available.

Other Activities Based upon the current level of use, Penn State's "no contamination" policy, and a review of past surveys showing no contamination in the general facility, it can be concluded that radiological conditions are already within the release criteria for the bulk of the facility.

The contractor will prepare the actual decommissioning plan for regulatory review. This will define the scope of work, the radiological conditions of the site, and provide a plan for action. Upon approval by the regulator, a working plan will be developed to include a strategy for systematic decommissioning surveys along with manpower and equipment requirements.

I Some estimates are from decornµiissioning plans for Georgia Institute of Technology, University of Virginia, the AFRRl TRJGA (AFRRl Report TR89-2), the Cornell reactor facility, and MIT reactor's decommissioning estimate as these facilities are similar to the PSBR. Note that not all of these past facilities had data that is directly comparable to the detailed breakqowns suggested in NUREG-17 57; most offered only lump-sum cost data and these will be address ip. the last section of this DFP.

I The following table summarizes the work days associated with planning activities:

Ta_bfo 9 <l~I~gnine- alld Pr~p_aratfQn WorkPersQil-Dav~

Wiute

]Jeajth. ' -w* Clerii:al l,ahQrer Constnittioi;j

~t_

Civil/Mech/QA* . Project Activity Physicist Tech_riic~ !Mmin (3)

Supervisor Speciamt

• Engineer Manager (1) (2) (1) (1)

(1) .

(1) q).

Prepare documentation 60 20 30 0 0 60 30 30 for regulatory agencies Submittal of decommissioning 5 0 10 0 0 5 5 5

( plan

. Development of 90 20 120* 0 90 90 90 120 work plans Procurement of -

equipment and 10 0 5 0 15 10 10 10 supplies Staff training 5 10 0 15 5 5 5 5 Characterization of radiological 40 90 30 15 -o 40 0 45 conditions Other 5 10 5 15 5 5 5 5 12/12/2019 Appendix E Page 9 of24

(mobilization)

Total 215 150 200 45 115 215 145 220 Person-Days

• Assume 260 work days per year.

Section A.3.7 Decontamination or Dismantling of Components (Work Days)

Based upon the continuous survey and decontamination efforts conducted during the normal radiation safety surveillance program, there are few components which need to be addressed in this category.

Activated Items ,,.

Specific items to be considered exposed to neutron activation include materials composed of aluminum, steel, stainless steel, graphite, cadmium, lead, concrete, reactor core structure, suspension tower, miscellaneous metal items, beam tubes, D20 tank, and possibly others. As mentioned in the Radioactive Waste On-Hand Before Decommissioning section, during the 2018 reactor neutron beam port modification project, the reactor suspension tower and the D20 tank were replaced. The old suspension tower and the DiO tank are currently stored in the reactor pool for radioactive decay. Therefore, there would be two (2) suspension towers and two (2) D20 tanks for dismantling during the nuclear reactor decommissioning. All reactor confinement structure, equipment, and materials will be surveyed and designated as contaminated or uncontaminated. Uncontaminated equipment and materials will be released for unrestricted use or disposed as clean waste. Contaminated equipment will be decontaminated and handled as other uncontaminated material or removed and packaged for processing "

and direct disposal as radio~ctive waste.

Reactor Pool Structure After removal of the pool water and all items in the pool, the interior surfaces will be decontaminated by hydro-lazing the waterproof coating. Reactor components and activated pool hardware will be removed for disposal as low level radioactive waste. Piping embedded in the concrete pool walls and floors will be surveyed and decontaminated, as necessary, and left in place if clean. Surface and core samples of the pool concrete walls will be performed to determine the extent of the contaminated areas. Contaminated material will be removed and packaged. The structural integrity of the pool will be augmented as necessary if it is threatened because of removal of material.

Reactor Pool Water Pool water will be analyzed for contaminates other than tritium (knbwn to be present) and then disposed via sanitary sewer in a controlled method to remain within discharge limits.

D20 Water This water is known to contain tritium but is owned by the DOE. It will be drummed and then all D20 will be held for transfer back to the DOE.

Water Purification / Demineralizer The resin will be collected and disposed. The tank and related piping will be wiped down.

12/12/2019 Appendix E Page 10 of24

Hot Cells The two hot cells and manipulators are not in use, currently not contaminated, and do not hold unsealed materials; the cells are currently used to store sealed discrete sources. The cells are not included in this version of the DFP.

Type of Space: Reactor, bay, rooms, and components.

Average Size: Not Applicable Level of Contamination: < 100 dpm/100 cm2 r

' .. ~-.

_ . Coni_pon~Iit .

-i>~ofi M~thod _-

. *-HP (l) . _

ll:P Tech . Qe1cal . ~aborer (2)_ -Admln

. .(1)" . .

'(J)

C~~iliul;'tio~-

Supermor

-. (1) .

• =

Speciamt (1)

Civil/Mech/QA Engineer

- .(1) :*

F°rojctt Mllruigcr

' / {1).

Hydro-Reactor Pool .

laze, 30 120 40 360 120 120 120 120 Structure Disposal Reactor Core Disposal 40 180 80 120 40 240 30 Structure Reactor Suspension Tower Disposal 10 40 40 120 10 60 15 10

.(old)

Reactor Suspension Tower Disposal 10 40 40 120 10 60 15 10 (new)

Control Rods Disposal 10 20 10 10 10 120 15 10 Wipe Reactor Bridge 15 20 40 60 20 15 15 20 Down D20 Tank (old) Disposal 10 20 10 15' 10 120 15 10 Disposal 10 20 10 20 15 150 20 15 DiO Tanlc (new)

I Disposal 10 20 10 40 10 60 15 10 Support Neutron Beam Disposal 10 20 10 15 10 80 15 10 Tubes Drum, D20 Water hold for 5 15 10 15 5 15 5, 5-.

DOE Pool Water Disposal 10 15 40 15 10 120 5 10 Wipe Circulating Pumps 10 30 40 120 10 40 20 10 Down Wipe Water Purification 10 15 20 45 10 40 10 10 Down Wipe Heat Exchanger 10 15 20 30 10 20 10 10 Down Moderator/Coolant Wipe Pipinp; 20 20 20 90 20 20 10 20 Down 12/12/2019 Appendix E Page 11 of24

Evaporator Shed Disposal 10 20 5 30 10 15 5 10 Underground Disposal 10 30 5 60 10 20 10 10 Tanks/Piping Wipe Waste Containers 5 10 5 5 5 10 5 5 Down Hand Items (Misc Wipe 15 30 60 10 15 40 15 15 tools, etc.) Down Total 260 700 515 1300 360 1365 370 360 Person-Days Assume 260 work days per year.

Section A.3.8 Restoration of Contaminated Areas (Work Days)

Assuming the worst case that there are radionuclides in the soil under the pool structure and underground tanks that will require removal, an estimated soil volume of 4,200 ft3 (20 x 40 x 5 ft) under the reactor pool footprint and 600 ft3 (approx. four times the volume of 2 tanks) will be used for this DFP. It is also assumed that should soil removal be required, access to the soil will be from inside the pool by removal of the pool floor; no otb,er structural demolition is assumed.

Table 11 :_ -Restoration of Containinated N~ W:ork Person-Days HP Oerlcal/ Construction WuteMgmt Ctvil/Mcch/QA HP Laborer Project Manager Activity (1)

Tech Admin (3)

Supcrvhor Specialist Engineer (1)

(2) (1) (1) (1) - (1)

Removal of Pool 30 60 10, 120 30 30 20 30 Floor Soil Excavation 15 40 5 120 40 40 40 20 Backfill 5 5 5 90 30 5 30 20 Excavate Tanks 10 20 5 30 10 30 10 10 Soil Excavation 5 10 5 30 10 20 10 10 Backfill 5 10 5 30 5 5 10 10 Total 70 145 35 420 125 130 120 100 Person-Days Section A.3.9 Final Radiation Survey {Work Days)

Table 12 - Final Radiation Survey Work Person-Days HP Oerical / Construction Wa.'lteMgmt Civil/Mech/QA .

HP Laborer Project Manager Activity (1)

T~ch Admin (3)

Supervisor Spcciali.rt Engineer (1)

(2) (1) (1) (1) m Final Characterization 20 40 10 5 5 20 5 20 Survey Final Report 15 20 15 5 5 15 5 15 Total 35 60 25 10 10 35 10 35 Person-Days 12/12/2019 Appendix E Page 12 of24

Section A.3.10 Site Stabilization Long Term Surveillance {Work Days)

There are no known areas requiring stabilization or long term surveillance for this license.

Section A.3.11 Total Work Days By Labor Category Table 13 -Total Work Days By Labor Person-Days HP *aerkal/ *constrnctlon Wu-tcMgmt Civil/Mech/QA HP Laborer Project Manager Activity (1)

Tech Admin (3)

Snperviwr Specialist Engineer (1)

(2) (1) (1) (1) (1)

Planning and 215 150 200 45 115 215 145 220 Prep Decontamination 260 700 515 1300 360 1365 370 360 Restoration of 70 145 35 420 125 130 120 100 Contam Areas Final Rad 35 60 25 10 10 35 10 35 Survey Site Stabilization 0 0 0 0 0 0 0 0 Total 580 1055 775 1775 610 1745 645 715 Person-Days Section A.3.12 Worker Unit Cost Schedule Salary data for Certified Health Physicists was obtained from the article "The 2018 CHP Salary Survey

published in the Health Physics News; January 29, 2019. (Latest data accessed on October 22, 2019):

http://hps.org/documents/2018 chp salary survey.pdf o Median CHP salary for the Northeast= $133,750 Salary and labor rate data for Pennsylvania May 2018 (latest data accessed on October 22, 2019) was obtained from: https://www.bls.gov/oes/current/oes pa.htm o Life, Physical Social Science- nuclear technician (code 19-4051) = $93,380

• Office admin support - info and records clerk (code 43-4199) = $44,110

• Construction laborer (code 47-2061) = $41,260

• Management - construction manager (code 11-9021) = $106,270

. )

• Waste Management-Nuclear Engineers (code 17-2161) = $115,760

• Civil/Mechanical/Quality Assurance- Civil Engineer (code 17-2051) = $88,740

• Project Management - General and Operations Managers (code 11-1021) = $133,480 12/12/2019 Appendix E Page 13 of24

\._

..

• Table 14 ..:__Worker.Unit Cost'Schedule_ . -  ;

C11.n,,tnictioi:i Waste~t C):vWMccli/Q4 . frQJcct

• Labor Cost HP HPTcch

• CicifC!I ,Adntin' .

/. *

• Laborer Maruigcr SopcrviJo_r Spec~, E;nitio~r

_Compon~vt (1) (2), (1)

(3) (1) (1)

" -- " (1) " (1)

Salary ($/yr) $133,750 $93,380 $44,110, $41,260* $106,270 $115,760 $88,740 $133,480 r

Fringe 22% 22% 22% 22% 22% 22% 22% 22%

Benefits (%)

Overhead &

Profit Rate 30% 30% 30% 30% 30% 30% 30% 30%

(%)

~

Total cost

$203,300 $141,938 $67,047 $62,715 $161,530 $175,955 $134,885 $202,890 per Year($)

Travel and Per-Diem $252 $252 $252 $252 $252 $252 $252 $252 per Day Total Cost per Person- $1034 $798 $510 $493 $873 $929 $771' $1032 Day*

• Based on 260 work days per year Section A.3.13 Total Labor Costs by Major Decommissioning Task

". -** Tabie - 15 *_,_ -total. t.:abor Costs *.

Wit*.

Clerical/ Coµst Cl:v/1\lccl! Project HP HP Tech Laborer Mgipt /QA Acfu1ty (1) (2), Adm.in

'(J)

Sliper:v .

Specialist * .En&In.ecr Manager (1).

Total!!

(1) , (1) .. (1) - ,* . (ff - ' *'

Planning and Prep $222,310 $119,700 $102 000 $22,185 $100,395 $199,735 $111,795 $227,040 $1.105 160 Decontamination $268,840 $558,600 $262,650 $640,900 $314,280 $1,268,085 $285,270 $371,520 $3.970 145 Restoration of

$72,380 $115,710 $17,850 $207,060 $109,125 $120,770 $92,520. $103,200 $838,615 Contam Areas Final Rad Survey $36,190 $47,880 $12,750 $4,930 , $8,730 $32,515 $7,710 $36,120 $186 825 Site Stabiliz.ation $0 $0 $0 $0 $0 $0 $0 $0 $0 Total Cost $599,720 $841,890 $395,250 $875,075 $532,530 $1,621,105 $497,295 $737,880 $6100,745 Section A.3.14 Packing, Shipping, and Disposal of Wastes Note: Labor costs for waste processing is included in .this section and not in the above analysis.

Packaging Material Costs r Packing costs are based only on the items in Table 10 that are for disposal. The pool water is not included here because it may be disposed via the sanitary sewer and therefore only labor costs are shown for this item. To be conservative, soil disposal is included. The demineralizer uses ion exchange resin and is assumed to require disposal in five (5) 55-gallon drums.

12/12/2019 Appendix E Page 14 of24

Because of the "no contamination" policy, there would be a minimal amount of waste generated from decommissioning. There are no areas in which protective clothing, other than gloves, need to be worn.

Note that no labor costs are associated with packing materials needed .

Table 16 - Packing. Material CosJs -- --

Total Number of Type of - . Contain-er Waste Type Volume Packaging Containers Container Unit Cost

. Costs I

• • I I

I

1 I I

• • I

--* I I

l I I

I I

• Total $145,803 A. Based on the average price received from two vendor quotes for 90 cubic foot B-25 metal boxes; Quote 1 of $2050 per container from Metal Solutions Design & Fabrication, LLC; and Quote 2,

$1350 per container from Container Products Corporation.

B. https://www.uline.com/Product/Detail/S-10758/Drums/Steel-Drum-with-Lid-55-Gallon-Open-Top-Unlined Shipping Costs Once the facility has been decommissioned, there is labor cost associated with the collection of the waste containers, documenting the shipment, and packing the truck. These costs are addressed below. To 12/12/2019 Appendix E Page 15 of24

calculate the number of standard 40 foot semi-truck loads needed, the volume of a 40 foot trailer (http://www.yrc.com/shippers/sefui-trailer-dimensions.html) is 3083 :ft3. The total volume to be shipped is:

• Wast~Type

• Container Uni't * , :Nlfl)lber *~f Cqnta,ine~ . .* Total~Vofotge Volu;;n.~ ecomnt 4- 0.11-hand ft3'

• • I

• • I

\

• • I Total r

Therefo1re three (3) 40 foot trucks (two full and one partial) will be needed to ship all wastes. The labor

• costs for preparing, packing, handling containers, and packing the truck are:

l;'able,18 ;__ ShiPP.btl'.(La.bor Work :P~tSof!-))~vs - .. - --- - "

• .1 ' '

Wute Civ/Mech/

HP HP Tech Clerl.c11J / Laborer Const Mgmt QA

,Project Activity (1) ai Admin

. (3)

Snperv Speclallit Engfuur Miqia!Jer Totah

.. (1) (1) . (1)  ;

(1)' (1)

Pool Rubble 10 20 5 30 10 20 10 10 115 Core 15 30 10 45 15 30 10 10 165 Old Tower 5 10 5 15 5 10 5 10 65 New Tower 5 10 5 J5 5 10 5 10 6}

'../

Control Rods 10 20 5 15 10 15 5 5 85 OldlhOTank 5 10 5 15 5 10 5 5 60 NewlhO Tank 5 10 5 20 , 10 15 10 10 85 NewlhO Tank 5 10 5 ' 15 5 10 5 5 60 Support Neutron Beam 5 10 5 15 5 10 5 5 60 Tubes 12/12/2019 AppendixE Page 16 of24

Pool Soil 20 40 10 60 20 20 20 10 200 Evap Shed 10 10 5 30 10 10 10 10 95 Tanks 10 10 5 30 10 10 5 10 90 Tank Soil 10 20 5 30 10 10 5 10 100

,Total 115 210 75 335 120 180 100 110 1245 Person-Days Table 19 - Shippin Labor Cost Waste Civ/Mcch Oeritlll / Comt Project HP HP Tech Laborer Mgmt /QA Activity (1) (2)

Admln (3)

Snperv Specialist Engineer Manager Totals (1) (1) (1)

(1) (1)

Pool Rubble $10,340 $15,960 $2,550 $14,790 $8,730 $18,580 $7,710 $10,320 $88,980 Core $15,510 $23,940 $5,100 $22,185 $13,095 $27,870 $7,710 $10,320 $125,730 Old Tower $5,170 $7,980 $2,550 $7,395 $4,365 $9,290 $3,855 $10,320 $50,925 New Tower $5,170 $7,980 $2,550 $7,395 $4,365 $9,290 $3,855 $10,320 $50,925 ~

Control Rods $10,340 $15,960 $2,550 $7,395 $8,730 $13,935 $3,855 $5,160 $67,925 Old D20 Tank $5,170 $7,980 $2,550 $7,395 $4,365 $9,290 $3,855 $5,160 $45,765 NewD20 Tank $5,170 $7,980 $2,550 $9,860 $8,730 $13,935 $7,710 $10,320 $66,255 NewD20 Tank $5,170 $5,160 $45,765

$7,980 $2,550 $7,395 $4,365 $9,290 $3,855 Support Neutron Beam

$5,170 $7,980 $2,550 $7,395 $4,365 $9,290 $3,855 $5,160 $45,765 Tubes Pool Soil $20,680 $31,920 $5,100 $29,580 $17,460 $18,580 $15,420 $10,320 $149,060 Evap Shed $10,340 $7,980 $2,550 $14,790 $8,730 $9,290 $7,710 $10,320 $71,710 Tanks $10,340 $7,980 $2,550 $14,790 -" $8,730 $9,290 $3,855 $10,320 $67,855 Tank Soil $10,340 $15,960 $2,550 $14,790 $8,730 $9,290 $3,855 $10,320 $75,835 Total Cost $118,910 $167,580 $38,250 $165,155 $104,760 $167,220 $77,100 $113,520 $952,495 Shipping costs were provided by Ecology Services, Inc. Note that normal rad waste would ship to Energy Solutions in Oak Ridge, TN (705 miles) and to EnergySolutions in Utah (1800 miles) for a total of 2500 miles.

Table 20 - Total Shipping CostsA Overweight Distance Labor Total Waste Number of Unit Cost Surcharges Charges Shipped Cost Shipping Type Truckloads ($/mile/load) ($/mile)

($/mile) (miles) ($) Costs All 3 $4.20 $0.58 $0 2500 $35,850 Truck 3 $2,800 ' $8,400 Rental Labor $952,495B $952,495 Total $996,745 A. Shipping Costs pricing provided by Ecology Services, Inc. (November 2016)

B. Labor cost from table 19 12/12/2019 Appendix E Page 17 of24

Waste Disposal Costs All wastes are assumed to be low level radioactive waste and not require any special handling or disposal methods. Historically, the cost per pound is more consistent year to year so this DFP will estimate disposal cost by weight rather than volume. The following densities are assumed for each waste type: '

Concrete= 150 lb/ft' Soil = 100 lb/ft3 Ion exchange resin= 3000 lb Shed material- aluminum= 171 lb/ft' For the reactor core, tower, and D20 tank, these are not solid stainless steel items so the weight to be disposed has been adjusted for the air space.

Table 21- Waste Disposal CostsA Unit Cost Surcharges Total Disposal Waste Type Total Weight (lb)

($/lb) ($/lb) Cost 12/12/2019 Appendix E Page 18 of24

Total $5 965 670 A. Unit disposal costs based on quote received from Ecology Services, Inc. (February 2019)

Section A.3.15 Equipment and Supply Costs The only supplies anticipated will be gloves, smears, vials, scintillation fluid.

No other equipment costs are necessary as Penn State has a sufficient number of survey meters (GM, NaI, alpha, neutron, and liquid scintillation counting) to supply the decommissioning team.

ment and Su Costs Unit Cost Total

$7 000 1 $5,000 $5,000 4 weeks $3 000/week $12,000 Total $24 000 Section -A.3.16 Laboratory Costs Any analyses will be performed by an independent third party laboratory. Quotes for analysis were requested from two different radio-analytical laboratories: GEL Laboratories, LLC; and, TestAmerica Laboratories. For conservative price estimating, the highest cost from either vendor for each type of analysis is used to determine the Unit Cost for each type of sample.

Table 23 - Laboratory Costs Equip/ Supplies Quantity Unit Cost Total Sample Analysis - Soil: Gross Alpha & Beta 50 $75 $3,750 Sample Analysis - Soil: Gamma Scan 50 $120 $6,000 Sample Analysis - Water: Gross Alpha & Beta 20 $70 $1 400 Sample Analysis - Water: Gamma Scan 20 $110 $2,200 Sample Analysis - Water: Tritium 20 $80 $1,600 Total $14,950 12/12/2019 Appendix E Page 19 of24

' {

Section A.3.17 Miscellaneous Costs Present methods of waste disposal are through a waste broker and no special licenses or site permits are necessary. Contractors provide proof of insurance before being awarded contracts. The work associated with decommissioning is not taxable by Pennsylvania.

The Nuclear Regulatory Commission will bill for regulatory oversight efforts to include final status survey reports, e<;>nfirmatory survey efforts, department lab, or contractor fees and oversight of license termination activities. An estimate of these costs is included in the following table.

- -- -- ----- T~ble 24 - Mts~ll~ge_oll~ _CQ~ts - - -- -- -- - - --

Cost Item Total License fees, insurance, taxes, other $0 NRC oversimt $50,000 Total $50,000 12/12/2019 Appendix E Page 20 of24

Section A.3.18 Total Decommissioning Costs The total decommissioning costs are shown in Table 25. This estimate does not take credit for any salvage value that might be realized from the sale of potential assets.

• Table 25 - Total Decommissioning Costs ..

Task/Component Cost Percentage Planning and Preparation (Table 15) $1,105,160 8.3%

Decontamination/Dismantling (Table 15) $3,970,145 29.9%

Restoration (Table 15) $838,615 6.3%

Final Rad Survey (Table 15) $186,825 1.4%

Site Stabilization (Table 15) $0 0.0%

Packing Material Costs (Table 16) $145,803 1.1%

Shipping Costs (Labor and transport) (Table 20) $996,745 7.5%

Waste Disposal Costs (Table 21) $5,965,670 44.9%

Equipment Costs (Table 22) $24,000 0.2%

Laboratory Costs (Table 23) $14,950 0.1%

Miscellaneous Costs (Table 24) $50,000 0.4%

Subtotal $13,297,913 100.0%

25% Contingency $3,324,478 Total Decommissioning Cost Estimate $16,622,391 12/12/2019 Appendix E Page 21 of24*

Comparison to Other Reactor Facilities A comparison to other reactor facilities that have completed decommissioning activities is shown in Tables ~6 to 29. The MIT reactor facility prepared a decommissioning cost estimate in October 2014 and can be found in Table 30. Their estimate is based on costs from a study performed by Duke Engineering in 2001. '---

The costs for decommissioning of the Georgia Institute of Technology 5 MW reactor were provided by Bill Miller, Project Manager, in 2001.

Table 26 "' Georgia Institute of Technology 5 MW reactor Decon;imissi.onin~ Cos~

Basic Tasks Cost Consultant Support & Characterization $242,100 Decommissioning Contract $5,948,282 Executive Engineer $728,682 ALARA Allowance $39,171 Special Costs* $161,718 Resident Inspector $21,511 Total $7,141,464 Assumed Cost Increase pt:;r Year 5%

N = Elapsed Years from 2001 to Present 18 Adjusted Cost to Present Dollars= (2001 Est)*(l.05)N $17,184,378

, 25% Contingency $4,296,095 Present Day Total Cost $21,480,473

• Health Physicist Overtime, video record, relocate rad storage area.

Estimates for decommissioning of the University of Virginia research reactor were provided by Paul E.

Benneche in 2003.

Table 27 - University of Virginia Reactor Decommissioning Estimates (Included parts of other licenses)

Basic Tasks Cost Outside consultant site characterization and plan

$250,000 preparation.

External contract for decommissioning the facility (initial

$4,500,000

$3.5M, current estimate of $4.5M.)

• Internal costs (This includes about 10 - 15 person years for overseeing UV's program and complying with reactor license requirements.) $1,656,000 (Assuming $80,000

• 1.38 (for benefits)* 15 years= 1,656,000) 12/12/2019 Appendix E Page 22 of24

Total $6,406,000 Assumed Cost Increase per Year 5%

N = Elapsed Years from 2003 to Present 16 Adjusted Cost to Present Dollars= (2003 Est)*(l .05)N $13,983,495 25% Contingency $3,495,874 Present Day Total Cost $17,479,368

• As described in a personal communication from Paul Benneche, the internal costs to UV were not well documented. However he estimated 10 - 12 person-years for UV to oversee the decommissioning.

AFRRI Report TR89-2 was published in 1990 for the decommissioning cost estimates of a TRJGA reactor. Costs from Table 5, page 8 of the report in 1990 dollars.

Table 28 - AFRRI TRI GA Reactor Basic Tasks Cost Energy use $5,600 Labor costs (all) $1,929,300 Waste disposal costs $589,179 Contingency/other $631,000 Site demolition and restoration $376,800 Total $3,531,879 Assumed Cost Increase per Year 5%

N = Elapsed Years from 1990 to Present 29 Adjusted Cost to Present Dollars= (1990 Est)*(l.05)N $14,537,693 25% Contingency $3,634,423 Present Dav Total Cost $18,172,116 Cornell University decommissioned their reactor in 2006 using an outside contractor for the demolition work but performed the preparation and planning work internally and self-managed the project. The contractor performed demolition, waste disposal, and radiation safety functions for a lump-sum amount of $2,700,000. Cornell estimated that had the contractor performed all duties, the cost would have been double at $5,400,000. It should be noted that the reactor was shut down in 1996 and fuel was removed and shipped to DOE in early 2000. The reactor pool fully protruded into the high bay and was completely demolished. An additional approximately 2 feet of soil directly under the reactor was also removed. The project started in March 2006 and lasted for 8 months.

Table 29 - Cornell University Reactor Basic Tasks Cost Contractor lump-sum for all activities $5,400,000 12/12/2019 Appendix E Page 23 of24

Total $5,400,000 Assumed Cost Increase per Year 5%

N = Elapsed Years from 2006 to Present 13 Adjusted Cost to Present Dollars = (2006 Est)*(l .05)N $10,182,505 25% Contingency $2545,626 Present Day Total Cost $12,728,131 The MIT reactor facility prepared a decommissioning cost estimate in October 2014. Their estimate is based on costs from a study performed by Duke Engineering in 2001.

Table 30 - MIT Reactor Basic Tasks Cost Labor lump-sum for all activities - 2014 $29,900,000 Disposal lump-sum for all activities - 2014 $4,907,000 Total $34,807,000 Assumed Cost Increase per Year 5%

N = Elapsed Years from 2014 to Present 5 Adjusted Cost to Present Dollars= (2014 Est)*(l.05)N $44,423 532 25% Contini;1;ency $11,105,883 Present Day Total Cost $55,529,415,

SUMMARY

This decommissioning funding plan has an estimated total cost of $16,622,391, which is in good agreement with cost-adjusted estimates from other reactors. While the MIT estimate in Table 30 is significantly higher, that facility is not necessarily an ideal comparative model based on the type of reactor and higher associated costs related to salaries, per diem, and other related expenses based on its geographical location.

As Tables 26-29 represent actual decommissioning costs, they are a more reltable estimate of the costs to decommission the PSBR. The highest cost estimate, after adjusting for an annual 5% cost increase per year fro~ the time of the original data to today, is the Georgia Institute of Technology decommissioning estimate of $21,480,473. This value will continue to be used as the basis for the decommissioning funding plan cost estimate of the Penn State Breazeale Reactor facility.

12/12/2019 Appendix E Page 24 of24