ML20037D577

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GE Wilmington Mfg Dept,Wilmington,Nc Closure & Decommissioning Plan
ML20037D577
Person / Time
Site: 07001113
Issue date: 06/12/1981
From:
GENERAL ELECTRIC CO.
To:
Shared Package
ML20037D575 List:
References
19413, NUDOCS 8108270606
Download: ML20037D577 (70)
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Text

{{#Wiki_filter:-_ o.-- s i i GENERAL ELECTRIC COMP ANY WILMINGTON MANUFACTURING DEPARTMENT WILMINGTON, NORTH C AROLIN A j CLOSURE AND DECOMMISSIONING PLAN 4 12 JUNE 1981 i l l l l 13113 I 0108270606 810721 PDR ADOCK 07001113 C pyg

-c TABL Q CONTENTS

1.0 INTRODUCTION

2.0 FACILITY DESCRIPTION 2.1 The Site 2.2 Plant and Operations 2.3 Operational Features Relevant to Decommiscioning 3.0 GENERAL DECOMMISSIONING & CLOSURE GUIDELINES 4.0 PLANT-SPECIFIC DECOMMISSIONING AND CLOSURE ASSUMPTIONS 5.0 DECOMMISSIONING ORGANIZATIONAL STRUCTURE 6.0 DECONTAMINATION, DISMANTLEMENT AND CLEAN-UP METHODOLOGY 6.1 Wet Uranium Processing Areas 6.2 Dry Uranium Processing Area 6.3 Indoor Contained-Uranium Process / Storage Areas 6.4 Outdoor Contained-Uranium Storage Areas 6.5 Uranium Bearing Process / Storage Tanks 6.6 Uranium Bearing Lagoons 6.7 Hazardous Materials 7.0 RADIOLOGICAL AND INDUSTRIAL SAFETY 8.0 DECONTAMINATION & CLEANING 8.1 Activities 8.2 Equipment NRC LICENSE SNM-1097 DATE 6/12/81 PAGE 0 i DOCKET 470-1113 R EV I S I ON d

9.0 WASTE MANAGEMENT 10.0 FINAL RELEASE 11.0 SCHEDULE OF PROPOSED ACTIVITIES 12.0 COST ESTIMATES 13.0 FINANCIAL STATEMENT d i NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION O ii d

~...., LIST OF FIGURES Figure Title Page 2-1 Plant Site - State and County Locations 2-2 2-2 New Hanover County and Adjacent Counties 2-3 2-3 Plant Site (Heavy Outline) and Environs 2-4 2-4 Principal Buildings & Facilities - Developed 2-7 2-5 Plant Entrance 2-8 2-6 Process Flow 2-10 2-7 Process Liquid Waste Flow 2-12 3-1 Site Organization for Decommissioning and Closure 5-2 6-1 Decontamination and Removal Sequence for Wet 6-4 Process 6-2 Decontamination and Removal Sequence of Activities 6-6 for Dry Process Areas 6-3 Dry Uranium Processing Area Decontamination 6-9 Disposal Sequence 6-4 Disposal and Decontamination Sequence for Indoor-6-11 Contained Uranium Procesc/ Storage Areas 6-5 Disposal Sequence for Outdoor-Contained Uranium 6-14 Storage Area 6-6 Disposal Sequence for Process and Storage Tank 6-17 Module 6-7 Decontamination Disposal Sequence for the Uranium-6-20 Bearing Decontamination 11-1 Schedule for Decontamination Activities 11-4 13-1 Corporate Commitment Letter 13-2 6/12/81 NRC LICENSE SNM-1097 DATE PAGE DOCKET 470-l'.13 R EV I S ION

LIST OF TABLES Table Title Page 2.1 Uses of Developed Areas of the Plant Site 2-5 ~ 3.1 Acceptable Surface Contamination Levels 3-2 8.1 Typical Tools and Equipment for Dismantlement 8-3 12.1 Estimated Decommissioning and Closure Cost 12-3 NRC LICENSE SNM-1097 DATE 6/12/81 PAGE 0 iv DOCKET 4:0-1113 R EV I S ION

1

1.0 INTRODUCTION

This plan is prepared and submitted as evidence of the General Electric Company Wimington Manufacturing Department (.WMD) compliance wi':h Chapter 7 of Special Nuclear Material License No. SNM-1097. It is written in conformance to the Guidelines for Decontamination of Facilities and Equipment Prior to Release.for Unrestricted Use or termination of Licenses for By Product, Source, or Special Material (NUREG 0435; Rev. 1, 1976) for decommissioning nuclear facilities and to demonstrate financial capability to support closure activities. The plan also addresses site closure requirements as specified in the 1980 Resources Conservation and Recovery Act (RCRA) 40 CFR Part 265, Subpart G. Decommissioning and closure activities will result in the cleaning and removing radioactive and hazardous waste contaminatien which may be present on materials, equipment and structures. Cleaning will be followed by verification of effectiveness. The plan provides information concerning the plant, the types of items to be decontaminated, the disposition of facilities used for hazardous materials, the assumptions upon which the cost of decommissioning / closure is derived, and a schedule of time it will take for decommissioning and closing the facility. Financial considerations are also included. NRC LICENSE SNM-1097 DATy 6/12/81 PAGE DOCKET 470-1113 REVISION ~

It is the intent of WMD to decommission the facility so as to reduce the level of radioactivity remaining in the facility to residual levels acceptable for release of the facility for unrestricted useage and for NRC license termination. Facilities which have been used to generate, store, treat or dispose of hazardous waste materials will be placed in safe condition. It is important to recognize that WMD has been in operation since 1969. The Department has procedures, people, instrumentation and equipment to assure nuclear and industrial safety. The plant is experienced in techniques for decontaminating discrete items and areas, and in verifying the degree co which cleaning has been accomplished. The technology is available to decontaminate the facility; people know-how is present; management has developed safe practices through years of experience. WMD is capable and competent to decommission the plant in accordance with the plan. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 1-2

2.0 FACILITY DESCRIPTION 2.1 The Site 2.1.1 Location and Layout General Electric's plant at Wilmington, North Carolina, is situated on a 1664-acre site in New Hanover County, approximately 6 miles north of the city of Wilmington. (Refer to meps, Figures 2 -1 through 2-3. ) New Hanover l County la located in the southeastern corner of the I state, in the coastal plains region. The County is l btunded by the Atlantic Ocean and by Pender and Brunswick Counties. The region around the site is I sparsely settled and the land is characterized by heavily timbered tracts occasionally penetrated by short i roads. Farms, single-family dwellings, and light commercial activities are located chiefly along highways. l The major portion of the site is bordered on the east by U.S. i Highway 117 and on the west by the Northeast Cape Fear River. Fr;urteen acres lie to the east of U.S. 117 and are undeveloped except for water wells and an employee park. The I northern and southern boundaries, marked by fences, are surveyed lines through undeveloped forest'and marsh lands. Of the total 1664 acres, only 150 acres have been developed. The developed portion is used as shown in Table 2.1. i l t NRC LICENSE Sri-1097 DATE 6/12/81 PAGE DOCKET 470-1113 REVISION 0 2-1

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TABLE 2.1 USES OF D2VELOPED AREAS OF THE PLANT SITE DEVELOPED AREA Area Size (Acres) Manufacturing Buildings 16.9 other Buildings 7.8 Waste Treatment Facilities 26.3 Power Supply Line* 31.7 Paved Roadways, Outside Storage and Parking 30.7 Unpaved Roadways and Parking 12.5 Landscaped Areas 24.1

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2.2 Plant and Operations 2.2.1 External Appeara..ce Figure 2-4 is an aerial photograph showing principal buildings and facilities of the developed plant area. There are seven principal building structu,,res: the equipment building, the tube building, the fuel building, the waste treatment building, the maintenance building, the office building and 'he site warehouse. c During site development, particular attention was given to building orientation and arrangement and to landscaping. Large trees have been left standing and supplemented with more than 9000 new tree plantings, understructure plantings, and ground cover. Parking lots and roadways are designed to minimize adverse effects and to complement the aesthetic value of the area. Entrances to the plant have been cleared of foliage only as necessary to provide safe entrance to and from the highway (Figure 2-5); much of the natural and woods ground cover were retained, i .w. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 REVISION 0 2-6

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O 2.2.2 Plant Operation The fuel manufacturing process produces fuel for nuclear reactors. The process begins with the receipt of slightly enriched uranium up to 4 percent U-235 in the form of uranium hexafluoride (UF6), or not more than 6 percent U-235 in the form,of uranium dioxide (UO2) powd er. Conversion of UF6 to UO2 utilitizes the ammonium diuranate (ADU) process or a dry di" 70 conversion proceos. The UO2 is formed into es which are sincered, ground to si a and loaded into tubes. Loaded tubes are fitted with end cap closures, welded and assembled into bundles. The fuel fabrication process is outlined in the process flow sheet (Figure 2-6). 2.2.3 Non-Nuclear Operations In addition to the fuel manufacturing operations described above, other activities conducced by General Electric at the Wilmington site include the manuf acture of auxiliary equipment for nuclear reactors, the fabrication of Zirconium components for fuel assemblies and the machining of aircraft engine rotating parts. These activities are typical of conventional metalworking plants and are carried out in facilities physically separate from the fuel building. l NRC LICENSE SNM-1097 DATE 6/12/91 PAGE DOCKET 470-1113 R EV I S ION 0 2-9

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e 2.2.4 Effluent and Waste-Handling Systems 2.2.4.1 Storm Waters A surface drainage system controls storm water runoff. This storm system drains runoff from the site via a natural channel called Brickyard Creek, which empties into the Northeast Cape Fear River. Brickyard Creek lies entirely within the General Electric

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2.2.4.2 Sanitary Wastes Wastes originating in washrooms and sanitary facilities are routed to a sanitary waste treatment system. The treated effluent from the system is discharged into the Northeast Cape Fear River. In addition to the main sanitary treatment system, two small septic tank systeme handle sanitary wastes at facilities which are remote from the main buildings. 2.2.4.3 Process Liquids Process liquid wastes originiating from the site operations are collected and then either treated in the waste treatment systems prior to release so that the resultant combined discharge to the river meets government regulatory requirements or sent to a licensed disposal site. See Figure 2-7. The laste collection systems are designed to collect chemically compatible wastes for the subsequent treatment processes and to prevent entry of incompatible wastes into these systems.

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NRC L[ CENSE SNM-1097 DATE 6/12/81 PAGE DOCKET +70-1113 R EV I S ION 0 2-11

NEHSO3 OR SO2 PLATING Ca(OH)2 f WASTE t i EQUIPMENT BUILDING ir J DRUM i SPENT NITRIC Ca(OH)2 h SPENT ~ ETCH TUBE BUILDING SETTLING BASIN i / % Ca(OH)2 \\ /\\ / NITRATE NITRATE LAGOONS WASTE g i FUEL BUILDING REWORK : FLUORIDE Ca(OH)2 WASTE O o o da w ~ ~ \\r r /\\ / z I GOONS j REWORK : c a c' g p \\ / \\ j AERATION LAGOONS RAD WASTE $U N \\ /\\ / CHEMICAL LAGOONS d f" OAM di: ' CREEK i FIGURE 2-7 PROCESS LIQUID W ASTE TREATMENT NRC L; CENSE Sbi-1097 DATE 6/12/81 pAgg DOCKET 470-1113 P.EV I S ION O _2-12 C

3 2.2.5 Solid Waste Waste materials include packaging, worn out shop clothing, tools, scrap material, and used equipment. Waste material is collected (and stored pending disposal) in two primary classifications based on whether it is uranium contaminated and whether it is combustible. Contaminated noncombustible wastes (includes filters from the air cleaning system, pumps, motors, valves, segments of process piping, various filter and centrifuge sludges, and the like) are either reprocessed chemically or collected in boxes for ultimate burial at a low level radiological waste disposal facility. Contaminated combustibl e l'. ems such as paper, cloth, and plastic are reduced to ash in a specially designed incinerator. 'the incinerator offgas is treated by water acrubbing and filtration. The ash is sampled and analyzed for uranium and either reprocessed or buried 1 in a low level radiological waste disposal facility. Noncontaminated waste materials that are not hazardous are hauled by a local waste disposal contractor to an approved landfill. Noncontaminated waste materials that are hazardous (RCRA) are disposed of by burying in a landfill permitted for handling these wastes. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 4/0-1113 R EV IS ION 0 2-13

2.3 OPERATIONAL FEATURES RELEVANT TO DECOMMISSIONING 2.3.1 Procedures Inasmuch as the Wilmington Manufacturing Department has produced nuclear fuel since its startup in 1969, it his established effective operational controls for safety in normal and abnormal situations, many of which are typical of decommissioning activities. Controlled document systems are in place to integrate operational organizations with those resconsible for nuclear safety and radiation protection. Department and Sectien-level ~ rocedures, and Operating Instructions constitute a communicacion hierarchy which assures that management directives are communicated to individuals at all levels. Procedures provide for personnel, environmental, and nuclear material monitoring for routine and nonroutine operations. In addition, numerous major facility modifications which have occurred since plant startup have resulted in the establishment of procedures and controls for proper conduct of contractor personnel in nuclear environments. Abnormal operations, not covered by routine procedures, require Radiation Work Permits which specify the se,foty requirements for the specific unique work to be done. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE 0 2-14 DOCKET 470-1113 R EV TS ION

2.3.2 Organization I i Nuclear safety responsibilities are assigned to an organization whose charter includes the engineering and evaluation of criticality and radiological controls for all aspects of the Wilmington Manufacturing Department i business. Ongoing radiation protection activities are carried out by an organization, independent.of production, which continuously monitors and reports radiological conditions for all operations in the l facility. A traffic / transportation organization routinely arranges for the safe transportation of fissionable material to customers and disposai sites. Each of the above functions has established operating routines to govern the conduct of work at the plant site l to assure safe and compliant operations in routine and nonroutine situations. l l l l 2.3.3 Equipment In-house air campling systems and criticality / radiation alarm systems are available to provide information i concerning airborne uranium concentration and radiation levels. These systems provide data for radiation exposure evaluations of personnel working inside t radiation control areas and continuously monitor the site for criticality. l The Fuel Manufacturing building air filtration system which consists of HEPA filters and scrubbers has provided a high degree of environmental safety and control during plant operations. Stack sampling systems l provide continuous assurance that no contamination above regulatory limits is released to the environment. l These will be maintained oprational during decommissioning. .J NRC LICENSE SNM-1097 DATE 6/12/81 PAGE 0 DOCKET #70 4113 R EV I S ION 2-15 l

The laundry will be maintained to provide cleaning facilities for protective clothing and respirators used during decommissioning activities. Equipment in the laundry also provide the capability for checking leaks in the respirator filters and face masks. Equipment in the Radiation Protection Laboratory, currently used to measure and evaluate radiological samples, will be available during decommissioning. The WMD fire protection system will be available throughout the decontamination operations. This consists of fire alarm boxes, sprinkler systems, hoses, extinguishers, and a water supply provided through the site water tower or an emergency fire water pond. Fire protection equipment such as self-contained breathing apparatus (SCBA) equipment, rain gear, pumps, and hoses will be maintained and available. Additionally, fire response capability by outside agencies is available if needed. The in-plant communication systems consisting of public address, telephone, and radio will be maintained during decommissioning. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE 0 DOCKET 470-1113 R EV I S ION 2-16 E

3.0 GENERAL DECOMMISSIONING & CLOSURE GUIDELINES Table 3.1 specifies the design basis surface contamination levels which will be used as stand- 's in the decontamination and survey of surfaces or premises and equipment prior to disposal or release for unrestricted use. General guidelines for'the decommissioning effort will be: 3.1 A reasonable effort will be made to eliminate residual contamination. l 3.2 Radioactivity on equipment or surfaces shall not be l covered by paint, plating, or other covering material unless contamination levels are below the limits specified in Table 3.1 prior to applying the covering. 3.3 The radioactivity on the interior surfaces of pipes, drain lines, and ductwork shall be determined by making measurements at all traps, and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the interior of the pipes, drain lines, or luctwork. I Surfaces of premises, equipment, or scrap which are likely to be cot.taminated but are of such size, construction, or location as to make the surface inaccessible for purposes of measurement shall be presumed to be contaminated in excess of the limits. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 3-1

a l TABLE 3.1 ACCEIPTABLE SURFACE CONTAMINATION LEVELS b b NUCLIDEa AVERAGE c MAXIMUMbd REMOVABLE e 2 2 2 15,000 dpm a/100 cm 1,000 dpm a/100 cm U-nat, U 235, U-238, and 5,000 'pm al100 cm associated decay products 2 2 20 dpm/100 cm Transuranics Ra-226. Ra 228, 100 dpm/100 cm2 300 dpm/100 cm Th 230,Th 228, Pa 231 Ac 227,1125,1129 2 2 200 dpm/100 cm Th-nat, Th-232, St 90, 1000 dpm/100 cm2 3000 dpm/100 cm Ra 223 Ra 224, U 232, I126,1131,1133 2 2 1000 dpm M/100 cm 2 15,000 dpm M/100 cm Beta-gamma emitters (auclides 5000 dpm sky /100 cm with decay modes oth sr than alpha etnisson or spontane ous fission) except St-90 and others noted above, sWhere surface contammation by both alphar and beta-gammaremitting nuclides exista, the limits established for alpha-and betaWting nuclides should apply independently. bas vand in this table, dpm (diantegrations per minute) means the rate of emisson by radioactrve matenal as (.etermined by correcting the counts per minute observed by an appropnate detector for background, efHeien:y, and geometric factors associated with the astrumentatiott CMeasurements of average contammant should not be averaged ont more than I square meter. For objects of less surface area, the average should be dettved for each such object. 2 4The maximum contamination levet applies to an area of not more than 100 cm, 2 'The amount of removable radioactree material per 100 cm of surface area should be ceternuned by wiping that area with dry filter or soft absorbent paper, applytag moderate pressure, and assenang the amount of radioscove matenal on the 31pe with at appropnate mstrument of taown etnciracy. Mien remevable coctanunation on objects of leu marface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped. Ref: NUREG-0436 Rev. 1 - Attachment A " Guidelines for Decontamination of F M ilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byprcduct, Source, or Special Nuclear Material" NRC LICENSE SNM-1097 DATE PAGE. l DOCKET #70-1113 R EV I S ION 0 3-2

3.4 Special requests may be made to the NRC to authorize the release of premises, equipment, or scrap having surfaces contaminated with materials in excess of the limits specified. This may include, but may not be limited to, special circumstances such as razing of buildings, or transfering of premises or equipment to another organization continuing work with radioactive materials. 3.5 Radiation exposure limits shall be consistent with allowable limits specified in 10CFR20, " Standards for Protection Against Radiation". 3.6 Shipments of radioactive materials associated with decommissioning shall conform with the requirements of 49CFR170-199, Hazardous Materials Regulations. 3.7 Prior to release for unrestricted use, a comprehensive radiation survey will establish that contamination is within the limits specified in Table 3.1. A copy of the survey report shall be filed with the Division of Fuel Cycle and Material Safety, NRC, Washington, D.C.

20555, and the Director of the Regional Office of the Office of Inspection and Enforcement, NRC, having jurisdiction.

3.8 The site will be closed in a manner that minimizes need for further maintenance and controls to the extent necessary to protect human health and the environment. 3.9 Independent reviews of the premises will be made to verify that all hazardous waste and contamination have been removed and that the premises meet regulatory release limits. .c NRC LICENSE c'4M-10 3 7 DATE 6/12/81 PAGE DOCKET #70-1113 REVISION 0 3-3

4.0 PLANT-SPECIFIC DECOMMISSIONING AND CLOSURE ASSUMPTIONS Currently underway at GE WMD are several projects which will have a substantial impact on the total effort required for decommissioning the facility. Among these is the incinerator project scheduled for completion in late 1981. The decontamination facility and the wasta l uranium recovery operation planned for, operation in 1985 will significantly decrease the amount of material required for burial at decommissioning. The availability of these fr.cilities and other assumptions which bear on the decommissioning plan are as follows: 4.1 Plant will have had normal operations in the interim prior to decommissioning 1.e., no unplanned events have I occurred to perturbate the condition of the facility at the time of decommissioning. ,4. 2 All in-process uranium will have been removed from the site prior to tha initiation of decommissioning activities. 4.3 By the time decommissioning of the plant will take place, the NRC will have established by regulation de winimis levels of special nuclear material (low-enriched uranium, specifically) authorized for transfer to recipients not specifically licensed by the Commission. 4.4 An off-site Eacility will be available to accept uranium l during decommissioning. l l 4.5 Off-site low level radioactive waste burial faciliti0s l will be available. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET #70-1113 REVISION 0 4-1 I

4.6 Decommissioning activities will be performed by l personnel familiar with plant operations and radiation protection procedures. 4.7 Safety control practices in place for plant operations will be utilized for decommissioning activicies. 4.8 Non-contaminated equipment and facilities will be disposed of by standard corporate practices prior to initiation of decommissioning. 4.9 Dismantling will be programmed and time phased so as to maintain incineration, decontamination and uranium recovery capabilities for as long as possible. 4.10 All hazardous waste will be removed to eliminate the need for long term monitoring. 4.11 Decommissioning and closure activities will result in NRC and EPA approval to use the site for non-nuclear purposes. NRC LICENSE SNM-1091 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 4-2

5.0 DECOMMISSIONING ORGANIZATIONAL STRUCTURE Although the current plant personnel will perform the decommissioning task the organization structure during decommissioning will differ from the current production-oriented structure. The work will be accomplished under a Project Manager who will have at his disposal key experienced professional engineering support in safety related areas, safeguards, shipping, environmental protection, security, planning and operations. An organizational structure identifying the functions planned for decommisaloning is provided in Figure 5-1. Several important functions will be available throughout the decommissioning operations. These are described below. 5.1 Nuclear Safety Engineering, whose function it will be to oversee the criticality safety of the uranium removal l process and activities where uranium will be collected, stored or recovered. 1 i 5.2 Radiological Safety Engineering, whose responsibility it will be to oversee exposure control and radiological safety parameters for the work being performed. A wholebody counting facility and operator will provide internal monitoc.;g capabilities for total dose assessment. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S I ON 0 5-1

i e 1 0 l l I SITE PROJECT MAFAGER l SECRETARY l I i 1 i 8 l ACCOUNTING NUCLEAR EtNIRON- ^ ^ P L ST P SCR SPECIALIST .gliGMEE{g y TNrrn i INDUSTRIAL RADIATICN SAFETY PROTECTION l ENGINEER l l I MAIN 11 NANCE PLANNING & CRAFTS CONTRACTCRS ENGINEER SUPERVISOR F' i l I U ldMANT14-1DECCN-MATERIAL FINAL MENT TAMINATION HANDLING CLEANING & OPERATIONP ACTIVITIES PACKAGING SURVEY CFEW l I ( SITE ORGANIZATION FOR DECOMMISSIONING AND CLOSURE FIGURE 5-1 l l l t l l l l l l 6/12/81 NRC LICENSE SNM-1097 DATE PAGE 0 5-2 DOCKET 470-1113 R EV IS I ON

5.3 Radiation Protection will have tne responsibility for performing working-area meauuremer.ts to assure the radiation safety of employees by determining the cleanliness (lack of radioactive contamination) of materials, by conducting contamination measurements of shipments, and by nuclear release of materials to sell or use elsewhere. 5.4 Environmental Engineering will be responsible for evaluating sample analyses to assure the protection of the health and safety of the public. It will assure that samples are taken, analyzed and nondestructive measurements made as required to verify that release criteria limits have been met for hazardous and other non-radioactive materials. 5.5 Industrial Safety Engineering will be respcnsible for I overseeing the industrial safety of operations which include equipment usage and operations, air quality, protectiva equipment, and for cooruinating efforts of l outside support agencies (fire, police, hospital) in the event of an emergency. 5.6 The Operations Supervisor will be responsible for all operational activities which involve contactors, maintenance and craft employees. He will report directly to the Pro 4ect Manager and will be responsible for assuring that decommissioning is carried out as planned. NRC LICENSE SNM-1097 DATE 6/l:/81 PAGE DOCKET 470-1113 R EV I S ION 0 5-3

l 5.7 A Shipping Specialist will schedule trucks, coordinate loading, provide documentation, and arrange for shipments of materials to the various sites and burial facilities. 5.8 Finance Operations will handle time cards, purchases, contracts, and the overall financial status of the operation. 5.9 A minimal security force will need to pruvide security to l equipment and to control access to the site while decommissioning is underway. 5.10 The Project Manager will have overall responsibility for all facets of the operation. He will be responsibla to see that the various facets of decomtamination, material handling, dismantlement, shipping, final clean-up are done orderly, safely, and completely. 5.11 A Nuclear Materials Management Clerk wili. be responsible for bookkeeping activities for any uranium inventory generated during decommissioning activities. I l l l NRC LICENSE SNM-1097 DATE 6/12/81 PAGE oc:KET 470-1113 R EV I S I ON 0 5-4 j

6.0 DECONTAMINATION, DISMANTLEMENT AND CLEAN-UP METHODOLOGY 6.1 Wet Uranium Process Area There are a number of areas where uranium has been processed in liquid solutions such as the ADU conversion process (from UF6 vaporization through hydrolysis, centrifuging and calcination), the uranium purification system, (a nitric acid disolution process), the rad waste system, the centrifuge room at the waste treatment facility, the decon facility, the waste uranium recovery system, uranium liquid transfer systems, sludge recovery systems, and the incinerator building. Elements of the wet uranium processing areas will include but may not be limited to the following types of equipment, materials and items: containments & hoods process equipment curbing pipes drains pumps filters resins floor grating scrubber systems hores sludges pipes tanks All items such as carts, work tableu, buckets not needed for the decontaiaination process will be removed and placed in containers for burial or transferred to the decon room for decontamination. The sequence is shown in Figure 6-1. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 PEVISION 0 6-1

O A The plan for decontamination of the wet uranium processing area will be to first remove equipment. Particular attention will be given to process lines where material could be held up. Recovered material will be processed in the waste management syt tem until dismantlement of that system is required. All curbing will be kept intact until the potential for spillage is remcved. Spillage will be controlled by quickly drying spills so as to prevent spreading of contamination. Then work will progress from areas with the greatest potential for contamination to areas with the least potential for contamination. Piping will then be removed and, based upon the economics of decontamination versus burial, will either be shipped to the decon room for uranium recovery or placed in containers for burial. Tanks, columns, resin containers containing uranium will be cleaned inside to the extent possible so as to recover material, reduce the volume of uranium, and to prepare the item for disposal. In some cases it will be necessary to reduce the volume of containers by sectioning them with torches, Attention will be paid to potential. airborne; evacuation with portable trunks, bic/ars, and respiratory equipment will be used as appropriate. Equipment such as the centrifuges, dump stations, containments will be dismantled, transferred to the decon room for cleaning where, after treatment, a determination will be made whether to fully decontaminate it for reuse or to bury it. = NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 6-2 I

conveyors, cable racks, elevators, and other like materials will be dismantled, decontaminated as appropriate, and either prepared for burial or cleaned sufficiently to meet release limits. After stripping the inside of tne area, work will commence on building utilities and shell. Overhead piping, conduit, lights, etc. will be decontaminated or removed. Ventilation ductwork will be removed when appropriate, maintaining negative pressure until decontamination efforts in the area are complete. The ceilings, walls, and floor will be washed, chipped, scrapped and/or removed until acceptable release limits are achieved. I l ~_ NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-111-R EV I S I ON O 6-3

WORK TABLES, CONSOLES, FURNITURE ir PROCESS LINES h TANKS, EQUIPMENT a PUMPS CURBING o CONVEYORS a CABLE CARRIERS o FILTERS / VENTILATION /DUCTWORK g CEILING RAFTERS a WALLS FLOOt<b, DRAINS DECONTAMINATION AND REMOVAL SEQUENCE FOR WET PROCESS AREAS FIGURE 6-1 NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 REVISION 0 6-4

l 6.2 DRY URANIUM PROCESSING AREAS These are the areas where powder is blended, pressed, ground, and/or loaded into open-ended fuel rods. Also scrap is collected and processed into forms suitable for direct recycle or fed to the recovery process. Elements of dry uranium processing areas will include, but not be limited to, the following types of equipment, materials and items: Blenders Grinders Can Storage Loading Stations Carts Pellet Presses Containments Pellet Storage Conveyors Process Equipment Desk / Work Tables Storage Cabinets Dump Stations Tile Floor False Ceilings Ventilation Ductwork i Filters Welders Furnaces Work Tables l l [ The plan for decontamination of the dry uranium process areas is to work to remove and decontaminate the most l l contaminated items first, working from the most to least l contamination, maintaining all safety related items such as ventilation, air monitoring, radiation monitoring until the last phase of decontamination. The sequence is shown in Figure 6-2. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 RIVISION 0 6-5

BOATS, CANS v DESK, FILES, WORK TABLES h PROCESS EQUIPMENT h CONTAINMENTS v STORAGE CABINETS v CONVEYORS CEILING / RAFTERS Iy FILTERS /VEMTILATION DUCTWORK v WALLS v FLOORS /SCMPS DECONTAMINATION AND REMOVAL SEQUENCE OF ACTIVITIES FOR DRY PROCESS AREAS I FIGURE 6-2 NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 6-6

(. External surfaces of all process equipment will be cleaned by processes such as vacuuming, wiping, and/or washing to remove gross removable external contamination. Equipment destined to be shipped to other NRC licensees will be decontaminated to acceptable shipping levels, packaged, and shipped to the customer. Large equipment to be scrapped will be dismantled and/or sectioned to facilitate decontamination or burial. Whenever practical, material will be taken to the decontamination facility where attempts will be made to complete the decontamination. Surveys will be performed by the radiation protection group to verify the effectiveness of the decontamination efforts. When it is determined that items cannot be decontaminated because of circumstances such as porosity, complexity, or inability to measure the residual contamination levels, they will be packaged, placed in containers, and sent for burial. Items successfully decontaminated will be available for uncontrolled disposal. Gross contamination will be removed from such items as containment holds, cabinets, work tables, desks, files, conveyors, boots, cans, and the like. Then these items will be evaluated as to the cost relationship of burial or further processing aimed at uncentrolled release. In all cases, where 100% verification that items are clean cannot be achieved, such items will be treated as contaminated and handled accordingly. See Figure 6-3 for deconti 71 nation and disposal sequence. 1 6/12/81 PAGE NRC LICENSE SNM-1097 DATE 0 DOCKET 470-1113 R EV I S ION 6-7

All ceiling structures (e.g. beams, support members, conduit, light fixtures, and sprinkler lines) will be systematically evaluated for contamination. Gross contamination will be removed and extensive decontamination efforts will be performed to remove traces of contami'.ation. It is anticipated that extensive surveys will be required to evaluate the effectiveness of decontamination activities. Materials or structures found that cannot be cleaned to acceptable release limits will be removed and buried as contaminated. All tile and the residue glue will be removed for burial. Decontamination efforts on concrete floors will be directed towards anchor holes, crevices and cracks in the floor and towards hot spots. As necessary to achieve acceptable release limits concrete flooring will be removed. Walls will be cleaned and/or removed as necessary to achieve acceptable release limits. W-NRC LICENSE SNM-10 97 DATE 6/12/81 PAGE DOCKET #70-1113 R EV I S ION O 6-8 i

i EQUIPMENT PERTORM GROSS EXTERNAL DECONTAMINATIO'l YES PACKAGE FOR SOID7 SURVEY ACCEPTABL SHIPMENT NO DISMANTLE Cb NO PACKAGE FOR ~- SHIP M Abh,pP BURIAL BURIAL SITE A YES DECONTAMINATE l SURVEY FOR RELEASE NO NOT CAPABLE CLEAN 7 07.DEING DE-CONNED YES DI"2 POSE DRY URANIUM PROCESSING AREA DECCNTAMINATION DISPOSAL SEQUENCE FIGURE 6-3 NRC L ICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 6-9

~ 6.3 INDOOR CONTAINED-URANIUM PROCESS / STORAGE AREAS There are areas inside the buildings where radioactive material is stored and/or handled in sealed containers. Typically these areas are bundle assembly, bundle packing, site shipping andsite receiving. In the bundle area fuel rods and fuel bundle aesemblies are processed or stored prior to shipment. In the powder packing area, sealed cans of powder are stored awaiting shipment. Shipping and receiving areas include inspection, loading, and unloading facilities. The integrity of the fuel product handled in these areas is such that the probability of contamination is negligible and not expected. None of these areas are generally contaminated as proven by routine survey programs which monitor for contamination on containers, vehicles, and work areas. Elements of an indoor contained-uranium process storage area may include the following equipment, materials and items: Barrels Outar Containers Fixtures and Tools Overhead Cranes Fork Lifts Pallets Inner Containers Process Equipment Insulating Material Scales Lift Straps Locking Rings The areas will have beer. cleared of packed powder, fuel rods, bundles, and other radioactive materials prior to the beginning of decommiasioning activities. Radiation and ccntamination surveys will be made to verify the absen e of contamination or that it is below release limits. See Figure 6-4 for disposal and decontamination sequence. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S I ON 0 6-10

REMOVE ALL CONTAINERS \\/ SURVEY FOR RELSASE V ^ CLEAN DECONTAMINATE BURIAL ' BURIAL SITE YES h/ RELEASE DISPOSAL AND DECONTAMINATION SEOUENCE FOR INDOOR CONTAINED URANIUM PROCESS / STORAGE AREAS FIGURE 6-4 M NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET #70-1113 R EV I S ION O 6-11

i 6.4 OUTDOOR CONTAINED-URANIUM STORAGE AREAS There are areas outside the buildings where containers with uranium are stored. Normally these areas consist of asphalt or marl pads containing (1) boxes of material to be sont to burial sites, being held for incineration, or being stored for later use, (2) 55 gallon drums of uranyl nitrate solution (UNH), waste, oil, etc., awaiting disposal, (3) shipping containers of fuel and powder, (4) 5-gallon cans of scrap powder, and (5) UF6 cylinders. Elements of an outdoor contained-uranium area may include, but may not be limited to, the following types of equipment, materials and items: 5-gallon containers Marl surface 55-gallon containers Metal Shipping Containers BU type drums Sea Vans chocks Tie Downs Cylinders Wooden Pallets Hard Surface (Asphalt) Wooden Shipping Containers All containers of material stored on outdoor pads are designed to prevent or minimize the potential for leakage. Liquids are stored in lined cans or in lined metal BU containers, UF6 is stored in shipping cylinders; dry contaminated materials are stored in plastic bags within wooden or metal containers. The pad areas are routinely surveyed to monitor for contamination and, if contamination is found it is immediately cleaned up. Protective clothing is not worn when moving materials on the pads. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S I ON 0 6-12

The areas will be cleared cf all containers as indicated in Figure 6-5. Surveys will be performed with j instrumentation capable of detecting surface contamination above release limits. In addition, core samples will be taken at intervals across the pads and around its edge into the soil to monitor for any contamination. Prior tr: elease of the pads, all contamination will be recovered, reduced to releasable levels or recovered and shipped to burial. i l NRC LICENSE SNM-1097 DATE _ 6/12/81 PAGE DOCKET 470-1113 R EV IS I Oy 0 6-13

REMOVE ALL r CONTAINERS V SURVEY FOR RELEASE SHIP TO ^ DECONTAMINATE BURIAL BURIAL SITE YES 1 \\/ RELEASE I DISPOSAL SEQUENCE FCR OUT!;OOR-CONTAINED URANIUM STOPAGE AREA FIGURE 6-5 ~ ..m NRC LICEtlSA SNM-1097 DATE 6/12/81 F'AG E 00CKET #70-1113 R EV I S ION O 6-14 .e -m w w p, ,y e

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6.5 URANIUM-BEARING PROCESS / STORAGE TANK APEAS These areas contain large storage tanks and are located near the manufacturing building and at the waste treatment facility. In these areas uranium-bearing liquid material is treated, stored or processed. Elements of a uranium-bearing process / storage tank area may include the following equipment, materials or items: Curbing Sumps Dry Wells Steel Storage tanks (up to 100,000 gal) Manholes Tanks Piping Valves Pumps Normally the tanks are filled with liquids containing small concentrations of uranium. These tanks will have been emptied prior to the start of decommissioning activities. When work begins on these tanks the inspretion ports will be opened and an evaluation will be made whether the tanks can be decontaminated or whether dismantlement is necessary. The clean-up sequence will be from the process tanks to the pumps and piping and wil?. end with the tanks at the waste treatment facility. This will preserve the capability to treat cleaning solutions used in decommissioning. See Figure 6-6 for disposal sequence. I

w. -

i4RC L IC E.':SE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 6-15 k

E. If possible deccatamination efforts will permit the tanks to be kept intact. Sensitive radiation instruments will be used and swipe surveys will be made to assess the effectiveness of decontamination efforts, to provide information to estimate the relative value of continued decontamination efforts or to establish that the tanks can be released. It is probable that piping will be sectioned, cleaned and then packaged for burial. Cutting, cleaning, packaging will be performed under the surveillance of a radiation protection team to provide continued evaluation to assure the radiological safety of the workers, to prevent any spread of contamination, to evaluate the effectiveness of the cleaning operations, and ultimately to release the area. 1 i i NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET #70-1113 REVISION 0 6-16 ..r. ,+y -~

o F b INSPECTION \\/ O NO CUT UP OR PACKAGE FOR SHIP TO s x N TAMINATEf TAKE OUT e BURIAL e BURIAL SITE xES \\/ PROCEED TO CLEAN \\/ SURVEx FOR COhTAMINATION 4 \\ NO CLEAN YES d \\/ RELEASE DISPOSAL SEQUENCES FOR ~" ~ PROCESS AND STORAGE TANK MOCULE FIGURE 6-6 1 NRC L ICENSE SNM-10 37 DATE 6/12/81 PAGE DOCKET #70-1113 REVISION 0 6-17 e-

6.6 URANIUM-BEARING LAGOON AREAS There are lagoons on the plant site which contained uranium-bearing liquids and sludges. The liquids j generally have very low concentrations level vranium contamination, having been treated in the waste treatment facility prior to release to the lagoons. Elements of a uranium-bearing lagoon area may include the following equipment, materials, and items: Asphalt liners Buried Pipes Fencing / covers Floats Liners Pumps, Valves and Controls Safety Lines Safety Rings Uranium Bearing Sludge and Liquid The pipelines, pumps, etc. associated with the lagoons will be thoroughly flushed chemically and rinsed with water. The entire system will be blown out.

Pipes, pumps, and valves will be disposed of where contamination cannot be accomplished and or the item verified to be " clean".

Other items such as the safety lines, floats, rings, fence covers, etc. wil] be appropriately disposed of after removal. l l l 6/12/P' NRC LICENSE SNM-1097 DATE PAGE DOCKET 470-1113 R EV I S ION 0 6-18 l

l The lagoons will be emptied.and flushed with cleaning fluids. After additien of cleaning liquids to the lagoons have been terminated, the liquids will be allowed to evaporate. The cleaning sludge remaining in the lagoons will be stripped, stored for onsite uranium recovery and/or neutralized and shipped to burial. The Hypalon liners will be cleaned with high pressure water, detergent and rinses. Sections that cannot be decontaminted to release levels will be removed and prepared for burial. Soil under the lagoons will be tested for uranium contamination and removed for burial if necessary. Soil may be brought in to backfill the excavations, or contoured, and the areas released for unrestricted use. Lagoons involving radioactive materials or hazardous waste will be treated in like manner, i See Figure 6-7 for decontamination sequence of uranium-bearing lagoons and equipment. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DO C KE'. 470-1113 R EV I S ION 0 t 6-19

.~ Clean Pipes, Tanks, Etc. N No Clean Yes Drain Lagoon %/ Evaporate Liquids v Scoop Out Sludge Y** Clean Release Either No or Cut Prepare Ship to s m out for burial Burial Site Clean Yes Backfill witn Clean Soil DECONTAMINATI?M DISPOSAL SEQUENCE FCR THE URANIUM-BEARING LAGOONS AND EQUIPMENT FIGURE 6-7 6/12/81 N.7C LICEf!SE SNM-1097 DATE PAGE 0 6-20 DOCKET 470-1113 R EV I S ' ON

6.7 HAZARDOUS WASTE MATERIAL AREAS Hazardous waste materials, aus defined by RCRA are liquids, solids or sludges which pose a potential threat to the public-health and safe.ty if released in an ) uncontrolled manner. Undesirable characteristics of hazardous waste are: corrosiveness, pH, toxicity, ignitability, and reactivity. The WMD RCRA program has identified hazardous waste areas and has established control procedures to monitor on-going storage treatment and shipment activities. Elements of a hazardous waste material area include the following equipment, materials and items: Storage Tanks Portable Transfer Tankers Pumps, Valves, Controls Small Storage Drums or Reservoirs at Generation Point i ~ Process Area Where Chemicals Are Used Protective Wet Gear Fencing Isolation Fiberglass Covers Prior to the decision to close and decontaminate the WMD site, all hazardous wastes will be shipped offsite for disposal. Storage tanks will be cleaned or dismantled for shipment to a burial site. All equipment at generation stations will be cleaned up and released for uncontrolled uses. NRC 1.ICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET #70-1113 REVISION 0 6-21

7.0 RADIOLOGICAL AND INDUSTRIAL SAFETY During decontamination and closure activities, employee exposures and potential release pathways will be very closely monitored. There will be no relaxation of criticality safety, radiological safety or environmental safety programs. All safety and regulatory requirements involving safety will be closely adhered to. The criticality monitoring system which provides live time monitoring wherever bulk quantities of uranium is handled or stored on the plant site will be operationally maintained to assure that the system will provide an alarm in the unlikely event a criticality occurs. The system currently provides remote readout capability at the Emergency Control Center which will remain active as long as the monitoring system is needed. An interim emergency response plan will be prepared prior to the start of decommissioning. A live time air sampling system is used to monitor airborne uraniun concentrations in the fuels manufacturing controlled areas. This system will be modified as appropriate and used to monitor all activities including the abnormal activities where the potential for high airborne levels will increase. Removal of this system will be delayed until only the shell of the building remains and the potential for airborne uranium approaches zero. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION O 7-1

Another safety system which will be essential during decontamination is the fire alarm system with fire alarm boxes strategically placed throughout the site. Once triggered, the system sends out a coded alarm which identifies the area of the fire. Activities during decommissioning such as cutting, dismantling and nonroutine trash accumulation will make this safety system essential. Necessary environmental monitoring programs established during the operations of the plant will continue during the decontamination / closure activities to assure that contaminants are being contained. Samples currently are taken at the stack release points, from soil around the site, at the dam or discharge point, and from wells around the site. These samples will be analyzed for specific contaminants. A history of data has been generated to provide a reference point for the evaluation of the effectiveness of the environmental monitoring program during decommissioning. Radiation exposure to employees will be monitored through existing programs, such as dosimeter baCging, air sampling of airborne contamination, and wholebody counting. This rapresents no change in current practices which meet the regulatory requirements specified in 10 CPR 20, Radiation Protection. All personnel and equipment will be monitored with instrumentation capable of detecting the presence of radioactive contamination. l NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 7-2 1

Employees trained in Radiation Protection practices and contamination control techniques will perform decontamination activities. Protective clothing utilized in the facility will be available in sufficient quantities to allow for personnel contamination control. Various types of respirators will be available to provide the degree of protection necessary for the decontamination job being performed ranging from half mask respirators to fresh air suits. For jobs requiring dismantlement of heavily contaminated items, isolation tents with portable blowers and absolute filters will be utilized. This tenting technique will also be available for decontamination activities where significant dusting potential exists. mo-6/12/81 NRC LICENSE SNM-1097 DATE PAGE 0 7-3 DOCKET #70-1113 R EV I S ION

8.0 GENERAL DECONTAMINATION AND CLEANING METHODS Removal of radioactive material from contaminated surfaces will be accomplished in three ways: (1) by physical cleaning of the surface, (2) by using of chemicals to dissolve surface films containing radioactive materials or (3) by removing the surface of the structure itself. Physical cleaning methods include sweeping and vacuuming, handwiping, sandblasting, and washing with various cleansing agents. Chemical decontamination uses acid basic or chelating solutions to dissolve residual contamination from surfaces; this technique is usually applied to wet processing systems, such as pumps, piping, storage tanks, etc. If physical cleaning and chemical decontamination techniques do not reduce contamination levels on equipment and/or building surfaces to acceptable radioactivity release levels, it will be necessary to use more extensive methods such as sandblasting or scarfing that physically removes surface layers or to remove the item for burial. Removal of contamination from sealed pourous surfaces such as painted walls and floors, asphalt, tank exteriors, etc. can be accomplished using a variety of techniques. For loose contamination, vacuuming or simple sweeping compounds are often effective. For more difficult contaminations, various cleansing compounds combined with handwiping, handscrubbing, and/or power scrubbing techniques are available. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 170-1113 R EV I S I ON 0 8-1

Freon, acetone, alcohol and other solvents are effective degreasing agents that can be used in removing contamination films from surfaces. Organic solvents have an advantage of not being corrosive to equipment and electrical connections. Variable pressure, high or low-velocity liquid jets can be effective for some types of contamination work. The device can be operated by one man, at pressures up to 300 atm (4400 psig), using a hand-held jet lance. For those contaminants for which the liquid jet is effective, the jet is a very rapid decontamination method. Table 8.1 lists typical tools and equipment used for dismantlement. Some typical chemical solutions which might be used for chemical decontamination of the plant are a solution of 0.025 - 0.1 AlNO3 (which can be used to remove uranium deposits), a solution of 20% HNO3 - 6% AlF3 to remove sludge deposits, a solution of 10 HNO3 - 0.1 wt % CaF to remove uranium contamination from stainless steel), and a tri-sodium phosphate solution for general cleaning. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET #70-1113 R EV I S ION 0 8-2

TYPICAL TOOLS & EQUIPMENT FOR DISMANTLEMENT Tools Oxyacetylene Torch Guillotine Pipe Saw Tube Cutter Ratcheting Pipe Cutter Reciprocating Saw Nibbler Assorted tools such as impact wrenches, bolt cutters, etc. High-velocity Liquid Jet Low-velocity Liquid J6t Hydraulic Concrete Surface Spalling Device Concrete DrilJs Electric / Pneumatic Hammers Portable A Frames Portable Wash Tanks Portable Greenhouse Erection Kit Portable Spray Cleaning Booth Portable Power Brushes Portable Abrasive Blasting Unit TABLE 8.1 . ~, _ NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET #70-1113 R EV I S ION 0 3-3

v. Chemical solutions selected will be compatible with the available waste treatment processes and with materials used in the system. Concrete surfaces in the plant which are contaminatud to a depth of a few centimeters and that cannot be cleaned to an acceptable release level by surface wiping or washing techniques will be physically removed and packaged for disposal. Several criteria must be considered in selecting a concrete removal method. The method should facilitate control of airborne contamination and minimize the potential for personnel exposure to radioactivity. The size and weight of removed materials will be controlled to facilitate packaging and shipping for disposal. s . ~ - NRC LICENSE SNM-1097 DATE 6/12/81 PAGE 0 8-4 DOCKET #70-1113 R EV I S ION

9.0 WASTE MANAGEMENT Large quantities of contaminated material will have to be removed during the decommissioning or closure of the plant. If these materials cannot be treated or decontaminated to releasable levels, they will be properly packaged and shipped to an authorized disposal site. Contaminated waste materials that will"be generated during decommissioning or closure include: Contaminated process equipment, tanks, and hoods Contaminated piping, ducts, and fixtured lie?A and roughing filters Concrete rubble Contaminated lagoon liners Contaminated soil Misc. non-combustible materials (pumps, motors, etc.) All shipmente of radioactive material will be made in compliance with federal, state, and local regulations. Federal transportation regulations of DOT and NRC establish container requirements, dose rate limits and handling procedures to ensure the safety of the public and transportation workers during shipment of radioactive materials. Current federal regulations applicable to the transport of radioactive materials are: " Total 49 Code of Federal Regulations Part A70-179 (40 CFR 170-179) - Department of Transportation reguations governing the transport of hazardous materials. 10 CFR 71 - NRC regulations governing the packaging and sh'pment of radioactive materials NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCK 2T 470-1113 R EV I S ION 0 9_1 d

j r In addition, for highway transport, state agencies regulate vehicle sizes and weights and, in some cases, transportation routes and times of travel. All hazardous waste will be packaged in safe contait ers commensurate to the hazard involved to meet regulatory packaging, shipping, and burial requirements. Materials that cannot be given uncontrolled releise will be shipped to sites authorized to handle and bury the specific material. Hazardous waste liquids will be sent to companies authorized by license to receive, treat, and dispose of them. Materials handling will be done according to procedures for transfer, storage, preparation and shipping. NRC LICENSE SNM-1097 DATE 6/12/81 PA"E DOCKET #70-1113 REVISION 0 9-2 i

10.0 FINAL RELEASE j As areas / buildings are being decontaminated, contamination surveys will be made to determine the degree to which decontamination is being achieved. Upon completion of all decommissioning activities, a detailed health and safety analysis will be performed. This survey will determine the level of residual material. It is intended to demonstrate that there is no risk to j the health and safety of the public, that limits are within those specified by regulatory agencies, and that the premises can be released to use by any industry. A detailed survey report will be prepared which identifies the premises, shows that sufficient efforts have been mad to eliminate residual contamination, describes the scope of the survey, and reports the findings of the survey in specified units. A copy of this survey will be submitted to the NRC and the State of North Carolina for review, i The NRC will be invited to the' site to confirm the survey results in anticipation of their final release to uncontrolled occupancy. When decommissioning or closure of the facility is completed (i.e., removal of hazardous waste and sludge, equipment cleaned or removed, and storage areas or tanks free from any hazardous waste contaminants) WMD will submit to the RCRA Regional Administrator certification by the Ptsject Manager and an independent registered professional engineer that the facility has been closed in accordance with the specifications of she appproved closure plan. _~ NRC LICENSE SNM-1097 DAT; 6/12/81 PAG E DUCKET #70-1113 REVISION 0 10-1 3 u

O 11.0 DECONTAMINATION SCHEDULE Figure 11-1 shows the relative sequence and schedule for i decontamination activities. i Upon completion of final process cleanout and removal of the uranium inventory, the decon activities will commence. These activities are briefly ou~tlined below: 1. The areas close to the shipping docks (the powder storace warehouse and UF6 cylinder storage areas) will be cleared first to provide staging areas for the storage, packaging, and shipment of decontaminated equipment and materials from the plant. 2. Plant areas ;111 then be decontaminated, generally in the order of decreasing amount of contamination, i.e. from the most contaminated to the least contaminated. 3. The outdoor lagoon areas system will be dismantled and decontaminated upon completion of liquid processing. 4. The hot maintenance, rad-waste, incinerator facility, and the ventillation filter rooms will be decontaminated near the end of the campaign so they can support the decommissioning operations. 5. The laundry room and change rooms will be thi final areas to be decontaminated. = = - -. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE 0 11-1 DOCKET 470-1113 R EV I S IO;1

6. The hazardous waste areas will be cleaned concurrent with decontamination activities. Cleaning will progress from the equipment manufacturing building, to the fuels component operations, to fuels areas and then to outside areas 7. The final activity will be to conduct a thorough radiation survey of all areas in and around the plant. i NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV IS ION 0 11-3

O 1 DECONTAMINATION SCHEDUi.E WET URANIUM PROCESSING DRY URANIUM PROCESSING AREAS URANIUM DEARING PROCESS / STORAGE TANKS INDOOR CONTAINED-URAN!UM STORAGE AREAS OUTDOOR CONTAINED-URAN!UM STORAGE AREAS HAZARDOUS MATERIALS RNAL CLEANING / SURVEY OF BUILDINGS RNAL SITE SURVEY AND CLEANUP INSPEC1.ON AND RELEASE i 0 5 10 15 20 25 30 35 40 45 50 55 UME. WEEKS FIGURE 11-1 SCHEOULE FOR DECONTAMINATION ACTIVITIES ~ 5%'M 4 NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 REVISION O 11-4

O 12.0 DECOMMISSIONING COST 12.1 The estimated cost for decommissioning the Wilmington nuclear facility and closing the Wilmington manufacturing site is 12.3 million dollars. See Table 12.1 for cost breakdown. This estimate includes the cost of special-purpose equipment, materials, labor, site support services, waste packaging, transportation, burial, and other miscellaneous owner expenses. The cost estimates assume an efficient decommissioning activity but a 25% contingency is added to allow for unforseen problems which might arise during decommissioning. It is important to note that the cost estimate is based on the assumptions stated in Section 4 of this Plan. The costs were developed using estimates provided by responsible and Knowledgeable personnel in the various functions. 12.2 Burial cost estimates are based upon the current cost for burial; i.e., S8.50 per cu ft plus $1.00 per cu ft escrow perpetuity account charge (Chem Nuclear Corporation). It is most likely that this cost area will escalate at a higher rate than other factors because of continuing national problems with low level waste disposal. 12.3 Transportation costs assume burial at Beatty, Nevada, a site selected to provide some conservatism and flexibility since the quantity for burial is large and burial sites have been limiting the quantity allowed for burial. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 R EV I S ION 0 12-1 L

e 12.4 The cost for a license to decommission the site is estimated to be $100,000 based upon the current routines established by the NRC. 12.5 Nuclear liability insurance for a facility being decommissioned has not been determined. An allowance of $250,000 is included for the annual insurance premium ~ for both nuclear and conventional insurance. 12.6 RCR.T regulations specify that an outside consultant who is a registered engineer must perform an independent survey to determine that cle.nup activities have been performed per procedure, that measurements ara regrasentative of the actual situation, and that the total site is free of hazardous raaterials. A written report must then be submitted to the state certifying the plant is " clean." It is estimated that this fee will be $20,000. NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET #70-1113 R EV I S ION 0 12-2

r TABLE 12.1 ESTIMATED DECOMMISSIONING AND CLOSURE COSTS $000(1981) Decontamination and Dismantlement ~ Materials and Contract Labor $1500 GE Labor 2400 Project Salaried Personnel 1100 Burial 1700 Transportation 200 Site Services: Telephone 300 Utilities 1900 Taxes 200 Insurance 250 Consultant Inspection 40 Licensing / Inspection NRC 100 Planning / Preparation Costs 50 Subtotal $9840 25% Contingency $2460 $12,300 i NRC LICENSE :NM 1997 DATE 6/12/81 oAGE DOCKET #70-1113 R EV I S ION 0 12-3

l 1 4 13.0 FINANCIAL STATEMENT The decommissioning and closure cost far the Wilmington manufacturing plant including the full fabrication facility

1. estimated to be 12.3 million dollars.

This cost is considered to be small compared to the total assets of the General Electric Company. Therefore, there appears to be no credible likelihood that General Electric would be unable to meet the financial commitment generally associated with closing and decommissioning activities as outlined and estimated above. Figure 13-1 documents the Corporate commitment to provide them rehources to decommission the plant when and if necessary. mm. _ NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET 470-1113 REVISION 0 13-1 i

c. ~ G EN ER ALh ELECTRIC oc~cm etccme co**~v HEchiVED BY. .,. co........ s.se JOS E.CAUFO..sh Sta d S e .OT pe. SE Af 080 A.L. KAFLA.1 ..........~. May 14, 1979 i l Mr. W. T. Crow Fuel Processing & Fabrication Branch i Division of Fuel Cycle & Material Safety ) Office of Nuclear Material Safety & Safeguards i U. S. Nuclear Regulatory Comission 1 Washington, D. C. 20555 i

Reference:

NRC License SNM-1097, Docket #70-1113 )

Dear Mr. Crow:

1 i This letter is to infonn you that General Electric Company will-have available, at the time of decommissioning, i the resources deemed aecessary to satisfy its obligation to i decommission its nuclear fuel mar.ufacturing plant in Wilmington, I North Carolina. Sincerely, ' g' f / 4 W 4 R. H. Beaton i i i i FIGURE 13-1 CORPORATE COMMITMENT LETTER e,-- NRC LICENSE SNM-1097 DATE 6/12/81 PAGE DOCKET #70-1113 R EV I S ION O 11-20.3, - - -U}}

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