ML20057C006
| ML20057C006 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 09/21/1993 |
| From: | Leroy P LOUISIANA ENERGY SERVICES |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9309240276 | |
| Download: ML20057C006 (21) | |
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LOUISANA re,,0,m. s,a m.
EgERGY cv "* "c 8 o"*4
- September 21,1993 Mr. John W. N. Hickey, Chief Enrichment Branch Division of Fuel Cycle Safety and Safeguards, NMSS U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Docket No.: 70-3070 Louisiana Energy Services Claiborne Enrichment Center Additional Information i
File: 6046-00-2001.01
Dear Mr. Hickey:
Provided in Attachment A is the additionalinformation requested by your letter to LES dated September 15,1993 related to the cost estimate for decommissioning funding, hydrogen fluoride (HF) monitoring, and the design of the Product Sa_mpling Autoclave.
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Also enclosed is a report on decommissioning activities at Urenco's Almelo facility in the i
Netherlands which formed the basis for the responses to questions regarding j
decommissioning (letter from F.A. Stockschlader to Dr. P.C. Upson dated June 3,1993).
Please call me at (704) 382-2834 if there are any questions concerning this.
Sincerely, Peter G. lxRoy Licensing Manager PGIJN100.993 Enclosures s
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PDR ADOCK 07003070 C
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4 September 21,1993 Mr. John W. N. Hickey, Chief Page 2 i
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(w/ one copy of enclosures)
Mr. Morton B. Margulies, Esq., Chairman l
Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Diane Curran, Esquire j
Harmc.n, Curran, Gallagher, & Spielberg 2001 S Street, NW, Suite 430 Washington, DC 20009-1125 Mr. R. Wascom Office of Air Quality and Radiation Protection Louisiana Department of Environmental Quality PO Box 82135 Baton Rouge, Louisiana 70884-2135 Ms. Nathalie Walker Sierra Club Legal Defen,e Fund 400 Magazine Street Suite 401 New Orleans, LA 70130 i
Attachment A Additional Information Requested by NRC Staff A
Product Samnling Autoclave Tilting Device The NRC staff has reviewed the sampling autoclave seismic analysis submitted by letter dated July 21,1993. Our present understanding of the design (with clevis mounted hydraulic cylinders) is that the analysis assumes that the combination of scissors and hydraulic mechanisms would not transmit transverse seismic forces while maintaining full support of the required load in the vertical direction. The design and analysis as presented do not support this assumption that the scissors / hydraulic cylinder will not be subject to transverse loads. Additional clarification of design details (e.g., specification of ball joint ends on hydraulic cylinders) or of indeterminant analysis of the design is required.
Besponse:
The following paragraph is being added to the design specification for the Product Sampling Autoclave. A copy of the revised design specification will be submitted to the NRC as soon as it is approved.
"The features required to tilt the Product Liquid Sampling (specifically the pivot shaft attached to the autoclave shell and the correspondence hearings attached to the floor pads) shall be designed and installed such that the autoclave assembly moves smoothly in a vertical plane. Deviation from the true vertical plane due to shaft / bearing tolerances and the maximum horizontal (worst case) forces from a seismic event shall be such that no bending loads are applied to the hydraulic cylinders employed to tilt the autoclave assembly to the 30* inclined position. Specifically, a spherical bushing located at the rod end of each hydraulic cylinder of the tilting mechanism shall have a range of motion suflicient to prevent bending loads from being applied to the hydraulic cylinder rod end."
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Attachment A Additional Information Requested by NRC Staff Alpha Monitors Alpha monitors, calibrated to respond within short time periods, serve the function of protecting workers against hazard due to potential release of uranium and hydrofluoric acid.
The present NRC staff understanding of the CEC design is that continuous alpha-in-air monitors will be present in the UF6 Handling Areas and the Blending Area of the Separations Building. The monitors would be calibrated to alarm if equivalent HF levels reach 3 ppm.
Provide additional description and clarification on the placement and operation of these monitors. Provide an estimate of the response time to alarm at the specified contaminant concentration level. Provide description of operator and equipment response (e.g., ventilation system function) to an alarm signal.
Response
Continuously operating alpha-in-air monitors will be located in the UF, handling areas and blending areas as specified by the IIcalth Physics (IIP) Manager. These will be calibrated and set such that activation of their alarms correlates with 3 ppm (~2.4 mg/m') or less IIF concentration. 3 ppm (-2.4 mg/m') IIF is approximately half the American Industrial Ilygiene Association (AIIIA) Emergency Response Planning Guideline Level 1 (ERPG-1) which is 4.1 mg/m'. An ERPG-1 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing other than mild, transient adverse health effects or without perceiving a clearly defined objectionable odor. Alarm signals will be provided locally and to the Central Control Room; response time for alarm activation will be within 5 minutes. Procedures shall specify that the ventilation systems for the affected areas be shut down immediately should die alarms be activated. As an alternative to using alpha.in air monitors for both alpha and IIF monitoring, IIF monitors may be provided. The IIF monitors would have the same alarm setpoint (3 ppm FIF) and alarm both locally and in the Central Control Room.
Attachment A Additional Information Requested by NRC Staff i
G Eacility Decommissioning Cost Estimates 1.
Include in the decommissioning funding plan, at the time of decommissioning, the j
costs of:
(a) characterizing the CEC facility and site; (b) NRC staff review of the proposed methodology to be used to characterize the facility and site and the characterization data obtained; (c) generating a detailed decommissioning plan; (d) NRC staff review and approval of the decommissioning plan; and (c) NRC's confirmatory survey of the facility and site following the final radiation survey.
Besnonse:
)
Based upon your request for additional information the cost estimate for decommissioning the CEC has been reviewed and compared with the most recent data j
from decommissioning activities at Urenco's Almelo facility in the Netherlands. The following adjustments have been made:
(a)
Based upon Urenco's on-going experience in the decommissioning of gaseous centrifuge enrichment facilities, the cost of characterizing the CEC facility and site is estimated to be $0.1 million ($1993).
(b)
Based upon the costs incurred to date to review the LES license application, the cost of NRC stati review of the facility characterization is estimated to br $0.05 million ($1993).
(c)
Based upon LE3' experience in developing and submitting NRC required information, the ci,s of generating a detailed decommissioning plan is estimated to be $0.1 million ($1993).
(d)
Based upon the costs incurred to date to review the LES license application, the cost of NRC stali review and approval of the facility decommissioning plan is estimated to be $0.05 million ($1993).
(e)
Based upon the costs incurred to date to review the LES license application, the cost of the NRC's confirmatory survey of the facility and site following the final radiation survey is $0.5 million ($1993).
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Attachment A Additional Information Requested by NRC Staff (f)
Based upon the costs incurred in the decommissioning of the two pilot plants at Almelo, the cost estimate for building the CEC decommissioning decontamination facility, performing system cleaning, dismantling "luipment and systems, and performing decontamination has been revised from $28.4 million to $23.1 million. This is based primarily upon scaling the costs associated with decommissioning at the Almelo facility based upon the number of centrifuges decommissioned at the Almelo facility (i.e.,
approximately 14,500), and the number of centrifuges that will have to be decommissioned at the CEC. This is because the number of centrifuges also determines the amount of support systems, piping and equipment.
Therefore the amount of decommissioning to be performed is directly and primarily attributable to the number of centrifuges to be decommissioned.
The cost for decommissioning Almelo's 14,500 centrifuges (=12,400 centrifuges from pilot plants and 2,100 from other plants) was approximately $7.4 million. This cost includes the capital cost of
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equipment, and labor and management cost. This translates to approximately $20.5 million to decommission the approximately 40,000 CEC centrifuges. Escalating this cost to $1996 at 4% per year results in an estimate of $23.1 million.
Safety Analysis Report (SAR) Table 11.8-2 has been revisal to include the revised cost estimates, as well as the revised schedule noted in the response to question C.2 below, and is enclosed. A revision to the SAR, Environmental Report, and License Application will be made in.the near future to reflect the revised cost estimate.
2.
Modify the 5-year estimate to decommission the facility by accounting for the anticipated time requirements for the five activities mentioned in Comment #L i
Response
One year has been added to the overall estimakd duration for decommissioning as follows:
I (a) two months have been allowed to characterize the facility and site, (b) four months have been allowd for NRC review of the characterization, (c) generating a detailed decommissioning plan is estimated to take approximately six months. However, this activity and NRC facility / site characterization approval may be performed in parallel. Therefore, two months have been added to the overall schedule.
(d) four months have been allowed for NRC review and approval of the decommissioning plan.
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.i Attachinent A AdditionalInformation Requested by NRC Staff P
(e) three months have been allowed for the NRC's confirmatory survey. No change to the overall schedule has been made since a year was originally i
estimated to complete the final radiation survey. It is estimated that both the final radiation survey and NRC confirmation survey can be performed l
within one year.
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The estimated overall schedule for decommissioning is shown in Figure 1 " Estimated Decommissioning Schedule."
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3.
Describe the decommissioning activities conducted at the two European pilot plants located at Almelo and Capenhurst. Identify differences between these activities and those anticipated at the CEC.
j Resnonse:
A description for decontaminating the centrifuges is provided below. It should be noted that both pilot plants are located at Urenco's Almelo facility in the Netherlands. The flow scheme is shown in Figure 2 " Flow Diagram Centrifuge Decontamination." Piping and other equipment (e.g., desublimers) are decontaminated in a similar fashion. The centrifuges are disconnected from the system process piping and moved to the 4
decontamination facility. On a dismantling table, the bottom bearings are removed and
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drained in a special oil drain. The centrifuges are turned or rotated from the vertical to j
the horizontal position. The centrifuges are transported to a glovebox for removal of the rotor and gas system parts aller the top flange has been sawn off.
The centrifuge recipient is sawn into pieces approximately three feet long and the rotor parts are separated and collected. The gas system is cut into small pieces by grinding.
The top bearings are removed.
All parts are then cleaned in ultra sonic baths with 10% citric acid, arranged according
- to type and rinsed with fresh water. After drying, parts are separakd by alpha / beta monitoring as to which are clean and those that remain contaminated. Still contaminated parts are treated by wetblasting using glass pearls and rinsed again and re-monitored. Clean parts are collected according to different materials such as aluminum and stainless steel parts (e.g., bottom bearings, bolts). For de-classification, parts are shredded or pressed to render them unrecognizable.
The decontamination processes at the CEC will be very similar.
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i Attachment A Additional Information Requested by NRC Staff 4.
Provide a breakdown of the costs incurred in decommissioning the two pilot plants.
Response
The breakdown of the costs incurred in decommissioning at the two pilot plants is as follows:
- Investment in decontamination facilities.................. $ 1.83 million e Labor and operating (including supervision nnd admin)......
4.66 million
- Depreciation 0.95 million Total..............................................
$ 7.44 million 5.
Provide the sizes of the two pilot plants relative to the CEC, their periods of i
operation, and the dates of their commencement and completion of decommissioning activities.
Response
Sii.e of Plant Operation l'erim!
Decommissioning Dates Pilot Plant 1. SPI
= 8,0(H) centrifuges 1972 1981 1982-1991 Pilot Plant 2. SP2 Unit 1
= 1,500 centrifuges 1973 1976 1982-present Unit 2
= 2,900 centrifuges out Started 1974 1982-present i
of 3,500 centrifuges with a lifetime of 8 to 16 years have been decommissioned j
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Attachment A Additional Information Requested by NRC Staff 6.
Provide the contamination levels encountered at the two pilot plants before and after decontamination activities. Explain the differences between these levels and those expected at the CEC.
i Resnonse:
The centrifuges decommissioned contained approximately 10 grams uramum contamination prior to decontamination. This is expected to be the level of contamination found in the CEC centrifuges. After decontamination and smelting, the levels of contamination were approximately 1-2 ppm uranium. No significant contamination is expected outside process equipment, since any contamination outside process equipment (e.g., walls or iloors) would be promptly decontaminated as part of normal operations and CEC ALARA policy.
7.
Provide the dose impacts.both internal and external, to the workers engaged in decontamination activitics at the two pilot plants. Explain the differences between these dose impacts and those expected at the CEC.
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Response
No internal radiation doses have been received because the decontamination of centrifuges has been performed in glove boxes. In the eight years of pilot plant decommissioning work performed between 1984 and 1991, the maximum dose to a worker was 0.5 millisievert (50 millirems) in a year. The average dose to a worker was 0.2 millislevert (20 millirems) per year.
8.
Describe the procedures anticipated to be used at the CEC to remove uranium deposits (UO F ) from equipment and piping before and after dismantling activities.
22 Describe the treatments that are anticipated to be used to immobilize intractabic residues.
Response
See response to question C.3. Based upon more recent decontamination experience, no intractable residues are encountered.
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l Attachment A Additional Information Requested by NRC Staff 9.
State whether I 20,000 and I 50,000 are annual salaries of operators and
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supervisors, respectively, or whether they include other costs such as overhead, employee benefits, etc.
Resnonse:
See response to question C.4. The cost of operators, supervision, overhead, and employee benefits has been included.
10.
Account for contingencies in the cost estimates.
t
Response
A contingency of $3.5 million has been applied to decommissioning activities. Reference enclosed revised SAR Table 11.8 2. This estimate is based on the fact that LES will be updating the decommissioning cost estimate at least once every five 3 ears. Therefore, a larger contingency is not warranted.
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Attachment A Additional Information Requested by NRC Staff TABLE 11.8-2 Estimated Decommissioning and Tails Disposition Costs & Duration Cost ($ MM, Time Activity 1996 $s)
(Yrs)
Characterize CEC facility / site
$ 0.11.
0.17 NRC Staff review of facility / site 0.05 0.33 characterization Develop and submit to NRC detailed 0.11 0.50 (c) decommissioning plan NRC Staff review and approval of 0.05 0.33 decommissioning plan Decontamination Facility Installation, i
System Cleaning, Dismantling, 23.10 4.00 Decontamination Decontamination /Decommissioningof Decontamination Facility 1.90 (a)
Sale / Salvage 0.00 (a)
Radioactive Waste Disposal 1.40 (a)
Hazardous / Mixed Waste Disposal 0.10 (a)
Tails Disposition (b) 485.3 (a)
LES Final Radiation Survey and NRC Confirmatory Survey 1.50 1
Contingency 3.50 N/A TOTALS
$ 517.12 6
For related information, reference also the decommissioning funding plan contained in the CEC License Application.
(a) To be performed along with dismantling and decontamination.
(b) Tails disposal costs are estimated to be $16.175 million per year of tails production.
1 (c) Four months overlaps with NRC review of characterization.
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Figure 1 Estimated Decommissioning Schedule 0 (years) 1 2
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5 6
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a) Characteri:efacility and site - 2 months.
b) NRC staff review offacility and site characterization - 4 rnonths.
c) Generate detailed decommhsioning plan - 6 months.
d) NRC staff review and approval of the decommissioning plan - 4 months.
e) install decontamination facility - 9 months.
f) Sprem cleaning - 3 months.
g) Dhmantlement, decontamination, waste disposal - 3 years.
h) Final radiation sumy and NRC confirmatory surny - 1 year.
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Dr. P.C. Upson
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la Oxford Road C3.06.1993
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Decomissioning (dismantling, decentaminatien) i The attached : sport su::rarises our :teanwhile :r. ore than 10 years of I
i experience in the above fields.
Annex 2 shows, that the de:r.inant activities were related to the I
dis =antling an'd decontanination o: the SP1 and the first stage (GD of the SP2.
The for er Dutch pilot plant SP1 is new used as a r.orn.a1 storehouse.
In the t onner G;-hall of SP2 the disuntling and decanta.ina ion ic:ilities are ncv acecm edated.
Yours sincerely, i
l F.A. Stockschl.Ider 1
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b DECOMMISSIONING 1.
DU IN!T10t.
Decommissicning is understood to bs tre resoval, dissantling and i
decontamination of centrifuges and systens which are contaminated n'ith uraniun.
2.
DECONTAMINATION CF CENTRIFUGES AND PLANT SYSTEMS Altnoegn the first decontamination esperience dates frca 1975, the first workshop was established in the separaticn plant SP1 in 1982.
i The first smelt of decontaminated alumirium was exactly 10_ years ago, I
en 30th March 1963.
i since then abcut 13.000 decommissioned centrifuges and about 1500 Centrifuges which had failed or been removed for investigaticn have been cecentaminated and sent for scrap. 586 tonnes of aluminium from these centrifuges and from piping have been melted and sold.
The present centrifuge decentaminatica processing differs only in details from that at the beginning.
The certrifuge cecontamination has meanwhile been reictatec to a modern, new accomodation in $P2. Scree Equip lr,ent, like the grinding equipmer.t and the dismantling box was modified as well as the whole exhaast system. The shredder for maragSg steel was set up in this workshcp.
Alumirium is the mest important ccmponent of the processed raterial.
After decontamination and alpha / beta monitoring this is transportec' to an exterr,a1 smelter, smelted and sold. The maxinum allowable urania content ir. the horrogenized material.which is offered for sale is 5 mg per kg 11cminium.
Normally the uranium values are between 1 and 2 mg per kg aluminium.
Ccnventional dispesal of the slag (as enemical waste) is possible when the uranium centert is <150 mg per kg alaminium.
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Analyses of the rnaterial are carriec cut by ECN (Energie Centrum Necerland) at Petten.
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METH005 USED FOR DECONTAMINATION 3.1 Descrietiec On a dismantling taDie bottom tearings are removed and drained in a special oil drain. The centrifuges are turned or rotated from the vertical to the horizontal position. The centrifuges are transprried to a glovebox for removal of the rotor parts and gassystem after tne top flange has been jawn of f.
The recipient is sawn inte pieces of about I metre and the rotor crash parts are separated and collected.
The gassystem is cut into small pieces by grinding. The top bearings are renoved.
All parts go on to a cleaning in ultra sonic baths with 10% citric acid, arranged accorcing to type and rinsed with fresh water. After drying parts which are still contaninated and parts which are clean are selectec by alpna/ beta monitoring.
i Still contaminated parts are treated by wetblasting using glass pearls and rinsec again before re-menitoring.
Clean parts are collected separately accordir.g to different naterials such as caraging steel, aluminium and (mostly) stainless parts like bottom bearings, bolts etc.
Aluminium parts are collected in a trar.5 pert container together with the ecmplete electric drives for transport to the smelter.
The caraging steel parts are shrecced in small pieces to declassify i
them.
Bearings are made oil free and pressed, also for :lassification reasons.
3.2 riewschera (see annex ])
u 3.3 Other materials Most of the other raterials from' :entrifuge based enrichment plants consist of aluminium-and stainless steel piping. After reducing their length the decontamination is similar to the centrifuges.
Desublimers are treated in a cifferent way. Before dismantling they are washed in situ. After dismantling the sta1nless steel parts are treated in the same way as cther (centrifuge) parts, but ccpper and morel parts are cleaned in a bath containing 5% nitric acid.
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4 COST BA515 The provision for decontariinetton bears only those costs which are directly connected with the above menticned activities. (See annex 2.)
The department nas also dismantled other non-contaminated systems, sometimes with the help of other departments. The associated costs are boekee against the operatirg results for that year. These booked costs amount so far to f 550.000 for SP1 and f 75.000 for SP2.
Deconissioning work 1-occasianally carried out for UCN-AS. These costs are assumed to be e qual tc the income frem the sale of the aluminium scrap arising.
5.
PERSONNEL COSTS In 1983 the group had two employees and five agency personnel. In 1986 the agency personnel were taken ento the payroll. From 1987 to 1990 the departeent enployed six people, thereafter three. Part of the cost of a group leader is tooked agnir.st decomissioning. This group leader is supervised by the head of the department f:r analyses, chemistry and decontamination.
Up to 1989 about 7500 manneurs per year were spent directly on decommissioning. After that the activity reducec, to aboat 2000 direct
- tours in 1992.
S lh00VE FROM ALUMINIUM AND MARAGING STEEL 7te cet inceme from aluminium anc maraging steel is taken inte account in builcing uo the reserves. Up to 1992 f 1.825.033 was booked to the reserves from the sa'e of 586 tons of aluminium. No satisfactory method cf decontaminatice of maraging steel has so f ar been found and the raterial remains in store. It is expected that the disposal of this material will result in a net cost.
The incone from the sale of other. material (e.g. CDpper) benefits the operating results of that year.
7.
INVESTMENT Details of the investnents are shown in annex 3. The installation of the decommissioning f acilities in the SP1 cost f 557.000. In 1989 the removal of the equipment to the SP2 its installation and the installation cf additional equipment cost f I J76.000. The total investment in equipment up to J932 has been f 1.256.000.
B.
CONCLUSION The cecomeissioning of the SP1 was ;oncluced in 1991. Ey then all contaminated systems had teen removed and decontaminated and the associated parts cf the tutiding had also teen decontaminated. The accaredation is available for use without restriction.
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Annex 2 SUMMAltY OF ACTUAL. COSTS AND PROCEEDS FOR I)ECOMMISSIONING 1982-1992 7
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1 1983 1904 1985 1986 1987 1986 1989 1990 1991 1992 IDTAL :
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u investment 697 153 70 54 0
14 104 1.334 203 7
43 3.289 g
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Cost:
15 UO8V-cotts 152 825 695 662 655 656 426 604 802 354 6.831 Hanageme'it Admin. Staf f 108 133 121 93 148 143 84 104 130 53 1.123 Hanagewnt fee 51 52 51 37 50 40 26 44 47 23 421 Deprer. l a t ion il 99 116 126 97 120 176
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208 281 274 1.700 11 1.010 1.126 1.199 889 1,173 1.015 728j 960 1.260 704 i
10.075 l
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Nett proceeds alurainiums 297 536 410 82 129 267 53 25 19 1.826 "n
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'es Balance
!! j 713 590 781 007 1.044 748 675 935 1.241 704 8.249 Release of provision:
SFl il 395 142 693 G27 BR) 531 675 935 1.241 G.131
$P2 309 397 72 100 163 704 1.825 SP3 9
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206 248 SP4/3 23 11 II 45 11 7l3 :
590 781 807 1.044 748 675 935 1.241 704 8.249 7,
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Annex 3 I
i DEC0hBDSSIONING INVESTMENT AND INSTALLATIONS (f'000) lig Descrietion Machines etc. - Installation M 3
1982 SP1 installatico 411 Brush rinsing machine 57 Rinse bath 32 Vet blaster 18 Dismantling bcx 50 Cyclone installation 45 RF-detector 20 Band saw 3B Pipe cutter 12 Monitors a
286 411 697 1953 SP1 installation 146 Lathe etc.
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146 153 1984 Vitrasonic bath 70 70 I
19E5 Uhrasonic cleaner 3
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Crease evaporating dath 24 i
Epic. cutting machine 29 Extraction hooc' for saw
- J 64 64 1987 Tipping centainer 3
Radiation r.easuring head 3
Sealer, timer & printer j
14 14 j
TOTAL SP1 installat3 --
557 i
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M Qg, tert ot ien linchines et. Installation Total 1988 Shredding equipment 593 112 704 1989 SP2 installation Trailor 3.272 8
Storage tanks Instruttentation 12 Compressor B
14 Adaptation disuntling box lQ
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62 1.272 1.334 199')
SP2 insta11atten Lathe 93' Fork lift tru:x 24 Sawingbox 55
.31 110 93 203 1991 Cleaning basket Shear 6
1 7
7 1992 HFC-monitor Crane 25 1B 43 43 TOTA:.
SP2 installation TOTAL j s76 1.256 2.033 3.289
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