ML20134E667

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Forwards Licensee Contract Task Sheet for Review
ML20134E667
Person / Time
Issue date: 09/19/1996
From: Madera J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Decicco J, Serig D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20134B601 List:
References
FOIA-96-444 NUDOCS 9702060403
Download: ML20134E667 (29)
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Text

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t From:

John R. Madera d l

To:

JXDl. DIS TDeCICCO, Nmis O S e re. v,j o m s.s Date:

9/19/96 8:37am i

Subject:

ams task list - cleaned up -Forwarded i

i For arded mail received from: MFW1 w

Dennis and Joe. here is the AMS/ Chem Nuclear _ Contract Task Sheet for your review.

Please have our attorney involved with the financial assurance issues

( l believe it was Steve Lewis) look at this to see if he sees any major l

problems.

Thanks JRM Files:

m0:AMSTASKS.WP5 1

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( Y> 0 0 f nr14h y\\o f e TASK LIST I

h0 WP-SUB:0NTRA: TOR agrees to perform the following services subject to the ass umptions and spec'fications provided herein and in the Agreement:

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Tast 1 prxecure Development ana Permitting for 5ealed Sources 7,

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.s Ultr( t'.,1 Task Description SUSCONTRACTOR shall provide sufficient consultation se rvices prior to source shipping to ensure on -site activities are efficien 1 and effective.

In adcition. SUBCONTRACTOR shall prepare all shipping p apers and permit forms pursuant to 10 CFR 61 and 71 and all other applica ble federal. state and disposal site regulations-Assunctions Qg The SUBCONTRACTOR shall utilize this opportunity to identify means for

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,pr/ rnnimizing the number of shipments to the disposal site from AMS reduci

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g the total disposal volume, and refining the initial Cost est, mates bg p W ro on in Exhibit 2 fcr Tasks 2 end 3 4

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  • Cs 0 g _\\.ob [f.c( [ - sealet sources to Oe snippea are tnose descr1Dec in Tasks 2 anc 3 c

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lat:r an: e.:enses a'e inclu ed i-

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'rel ;r: : e :.,' e s eCulp"Ent 390 Casks proviced Dy SUB:CNTRA ~:;

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ra' CD" 'y witr at:l' cable regulatory agency -approved Ouality Assura c;e ;r:gr3 5 11cenge3 3r; perm 315 AW Re!;;'~ ;' ' ';les

,.O 7 ;eNice trcG & ra"e and tele; hone number of one (1) indiv1Cual responsiol e Is :-)\\ e\\ ULo%aQ 'tes

)( 0:anat,en of serv,ce&; neteeen suB:0MRACTOR and A}11 s paa g<m, {.,~[

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TOR to develop s'te -speci c procedu es r

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  • sereces Detaeen SUB:0NTRACTOR anc AMS.

PrDw :e at legit 72 re rs n;11ce as to wnen a site visit is desired

Orc, e ar'Iten irites:ticns to AM5 in regard to tre means by nhlcn EE.,r:es and snipoing c35(s should be prepared and stage::
",'
e a variar:e write -Up (Change order) fCr the suo:0ntract between SLS:WR:IOR and AM5 in:1uding a f1 ped price Cost 1or performing Tasks 2 3n: J Ore;are al applicat'ons. permits (including notifications fcr route -c etr:1'ed sn'p ents ; an; otner dcCumentatlor. rerjulred fcr ship ent Cf

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the sealed sources.

Provide written instructions to AMS on the methodology for submission /

execution of applications permits and other documents that are the responsibility of the generator.

As necessary. participate in communications between AM$ and the USNRC in regard to licensing issues.

Period of Performance:

This task shall be completed within 30 days after execution of the Agreement.

l Task 2: Receipt. Packaging. Transport and Disposal of "Unpackaged" Seal ed Sources Task Descriptio -

ONTRACTOR Shall receive, package, transport and di spose of c'

approximately

?.0 urles of sealed sources of 60Co Assumptions:

The unpackaged sealed sources of 60Co shall consist of the following:

(1) 100 sources currently located in the Source Garden with a total vol u e of approximately 9703 cm3 anc a curie content of 21989 as of June la 1996 (2) Seven (7) sources currently located in the Hot Cell or Source Garde n witn a totai volume of approximately 679 cm3 and a curie content of 3562 as cf June 14. 1996 (3) Eight (8) sources currently located in source excnange heads or shi pring containers with a total volume of approximately 776 cm3 and a cun e content of 5604 as of June 14. 1996 Tne sources snall De located at 1020 London Road. Cleveland. Ohio.

44110.

Ine disposal site shall be the Barnwell Low -Level Radioactive Waste t'anage~ent Facility (South Carolina).

Tre sources shall be packaged in a shielded transfer container that is sultaDie for this purpose prior to loading in a shipping task in prepara tion fcr stabilization by cement solidification.

Following the appropriate cure of the solidification matrix. cask clos a e procedures will proceed in preparation for shipment to the disposal r

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, De transferred to the disposal site [/n a single shipment Sou ces sna,il i

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All labor and expenses including state / local taxes, are included.

All personnel. equipment and casks provided by SUBCONTRACTOR shall com ply with applicable regulatory agency -approved Quality Assurance Programs, licenses and permits.

_AMS Resonnsibilitles:

Provide the name and telephone number of one (1) individual responsibl e for coordination of services between SUBCONTRACTOR and AMS.

Inventory and load sealed sources into the shielded transfer enntainar _

Provide physical characteristics, radiological composition, representa l

t1ve exposure rate and contamination levels or other information as deeme d necessary by AMS and SUBCONTRACTOR to satisfactorily specify and j

perfor m services.

Transfer the loaded container to a pre determined staging area within j

the London Road facility.

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Provice work space for packaging and shipment certification service. s trage of SM; ping containers, loading / unloading of shipping containers.

acr"stratne work area. and personnel hygiene area.

Operate ecsting in-house material handling equipment for the lo301ng of packaged material into/on the shipping containers / equipment and. as ne cessary. to support the packaging and shipment certification service.

Provide radiation protection services and health physics coverage.

Provide up to two (2) AMS employees to render assistance. as needed f cr tnis task.

Provide Otner radiation protection equipment (e g.

protective clothin 9 survey instruments, portaDie shielding, etc. ) as may be available at t ne Loncon Road facility or as specified by SUBCONTRACTOR in advance of on-site WCrk, i

SUBCONTRACTOR Respons10111tles:

Provide the name and telephone number of one (1) individual responsibl e for coordination of services between SUBCONTRACTOR and AMS.

Prcvide a schedule for all activities.

Provide a listing of specialty equipment and services that AMS must suppi y in advance of on -site work.

Provide _ in advance of on -site work, a coprof_ written pIOcedures and I

work instructions for AMS approval and for AMS use in preparing a

l Radiat1 on Work Permit, i

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Provide project management for on -site work Provide the required shielded liner, shipping container, packaging mat j

erials. shipping documents, labels, placards and materials / components / pro cedures in accordance with SUBCONTRACT 0R's Quality Assurance Program for packaging and transport of the sealed i

sources.

Provide exclusive-use transportation of the packaged sources to the di sposal site.

l iransfer the shipment from the AMS facility to the transport vehicle.

Ensure compliance with all USNRC. DOT. South Carolina and Ohio laws an d regulations for loading, shipment and disposal of the materials address j

ed in this task.

Ensure Barnwell acceptance of the shipment based upon the AMS descript 1on of its physical and radiological characteristics.

Prov1:e a receipt of disposal within one week of acceptance of the sou rces at ine disposal site Perecd of Per'ormance:

Th's tasi 55al' oe co ;'etea cimr 60 cavs after ws author,zation to p.rEefd is given.

Task 3: Receipt Packaging. Transport and Disposal of GE -500 and " Blue" Cask Task Description. SUSCNTRACTOR shall receive. package. transport and d1s pose of approd mately 19.400 curies of sealed sources and bulk canisters of 60Co_

i Assumpticn; The seaiec sca ces and bulk tanisters of 60Co shall consist of the fol r

lowing:

(1) 2S sources currently located in the GE -500 Cask with a total volume of approximately 2717 cm3 and a curie content of 10.080 as of June 14 1996 (2) 18 sources currently located in the " Blue Cask" with a total volume of approximately 1.747 cm3 and a curie content of 9.306 as of June 14 1996 I

The sources snail be located at 1020 London Road. Cleveland. Onio.

44110

l The disposal site shall be the Barnwell Low -Level Radioactive Waste l

Management Facility (South Carolina).

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&c 5 {e' N bThe GE-500 will be inspected. ver1 fled shippabl1 sourced to a transpo~

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rt trailer and transported to the disposal site for direct disposal.

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The " Blue Cask" will be shipped in a CS -B-120 "B" Cask.

kC The CNS-8-120 "B" Cask will be preshored, to the greatest extent possi i

g69hf ble. to accommodate the " Blue Cask" for transport.

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The " Blue Cask" will be loaded into the prepared shoring inside the sh 1pping cask sourced to a transport tra11er. and transported to the cispo sal site for direct disposal.

The GE-500 and the " Blue Cask" shall be transferred to the disposal 51 te in a single shipment.

l All labor and expenses. including state / local ta>es, are included All personnel. egalpment anc casks provided by SUBCONTRACTOR shall co"'

sly r.ith applicacle regulatory agency -approved Quality Assurance

grams. itenses ano permits Av5 Retp r m 1 1t'es-

? cvice tre name anc telepnone number of one (1) individual responsibi e f:r to:r:' ration of se v ces between SUBCONTRACTOR and AMS Irventory seale s %rces.

Using in-nouse rancling equipment. assist in loading " Blue Cask" into cresn re: CNS 120 "B" Cask Fr vice crysical craracteristics. radiological composition, representa 1,se e4pos/e rate anc contaunation levels or other information deemec n ecessary by Av5 anc SUBCONTRACT 0P to satisfactorily specify anc perform 5 ervices Transfer the casis to a cre -cetermined staging area within the Loncon Rcac fac1'ity rr:y ce c rk space for packaging and shipment certification service. s torage of shipping containers. loading / unloading of shipping containers.

acnm strative work area. and personnel hygiene area.

Operate existing in -house material handling equipment for the loading

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(age: material into/on the shipping containers / equipment and, as ne cessary. to support the packaging and shipment certification service I

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Provide radiation protection services and health physics coverage.

Provide up to two (2) AMS employees to render assistance. as needed, f or this task.

Provice other radiation protection equipment (e.g., protective clothin

g. survey instruments, portable shielding, etc.) as may De available at t he London Road facility or as ipecified by SUBCONTRACTOR in advance of on-s1*o work.

SUBCONTRACTOR Respons1bilities:

Pro ~ vide the name and telephone number of one (1) individual responsibl e for coordination of services between SUBCONTRACTOR and AMS.

Provide a schedule for all activities.

Provide a listing of specialty equipment and services that AMS must suppl y in advance of on -site work.

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._ Provide

,n advance of on -Oto erk a copy of written _ procedures and _

work instfuctions for A1 approval and for AMS use in preparina a

-(ajl_all_.p,n g,,Permj t, _,,

Obtain all necessary variances for shipment of either cask.

Procce croiect mana:;ement for en -site work.

Frcoce the presnored CNS -B-120 "B" cask. packaging materials shippin g documents. labels. placards and materials / components / procedures in accordance witn SUBCONTRACTOR's Quality Assurance Program for packaging j

end t ransport of the sealed sources.

Provide exclusive-use transportation of the packaged sources to the di sposal site.

Trans<er tne shipment from the AMS facility to the transport vehicle.

Ensure compliance with all USNRC. DOT. South Carolina and Ohio laws an d regulations for loaa1ng. shipment and disposal of the materials address ed in this tast.

Ensure Barnnell acceptance of the shipment based upon the AMS descript 1on of its pnysical and radiological characteristics.

Provice a receipt of disposal within one week of acceptance of the sou rces at the alsposal site Fer1oc cf Performance-This tast shall be completed _within 60 days after AMS authorization to pr oceed is l

l given.

Task 4-Procedure Development. Permitting and Packaging / Shorting /Bandin g of l

Task

Description:

SUBCONTRACTOR snall provide sufficient consultation se rvices prior to shipping to ensure on -site activltles are efficient and e ffective. In addition. SUBCONTRACTOR shall prepare all shipping papers a nd permit forms pursuant to 10 CFR 61 and all other applicable federal. S tate and disposal site regulations.

l Assumptions:

The waste to be shipped shall be as described in Tasks 5 through 10.

f The SUBCONTRACTOR shall utilize this opportunity to identify means of minimizing the number of shipments to the disposal site from AMS.

minimizing the total disposal volume (e.g., compaction, supercompaction.

l inciner ation) and refining the initial cost estimates shown in Exhibit 2 for Tasks 5 througn 10.

The waste to be shipped is the material described in Tasks 5 tnrough 10 All later and expenses. incluaing state / local taxes.-are included.

M' personnel, procedures. equipment and casks provided by SUBCONTRACTOR snSil comply with applicable regulatory agency -approved Quality Assura 1

nce Programs. licenses and permits.

AMS Pespons1D11111es:

Provide the name and telephone number of one (1) individual responsibi e fo' coordination of services between SUBCONTRACTOR and AMS.

Previde access to all locations within the London Road facility as may be necessary for the SUBCONTRACTOR to develop site -specific procedures.

SUSCONTRACTOR Respensibilities:

Provide tne name and telephone number of one (1) individual responsibl e for coordination of services between SUBCONTRACTOR and AMS.

Provice at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> notice as to when a site visit is desired.

l Provide written instructions to AMS in regard to the means by which ea ch form of waste should be prepared and staged.

Provide a variance write -up (change order) for the subcontract between SUBCONTRACTOR and AMS. including a fixed price cost for performing Tasks j

5 inrough 10 I

As necessary, participate in communications between AMS and the USNRC l

d in regard to licensing issues.

Prepare all applications. permits and other documentation required for shipment of the waste.

Provide written instructions to AMS on the methodology for submission /

execution of applications. permits and other documents that are the respo nsibility of the generator.

Period of Performance:

This task shall be completed within 30 days after AMS authorization to pr oceed 15 given.

f), -f t se Dry -

x kv,a 5 4e Task 5.

Receipt Packaging. Transport and Disposal of AW in Shielded D rums ]

Task Description. SUBCONTRACTOR shall receive. package transport and di spose of 18 shielded druTs (55-gallon) of dry solid waste containing 60Co Assumptions:

A tctal of 18 drums shall be staged for tnis task M e weign* of eacn Cru is at least 1.000 pounds.

'Pe Crums srall be located at 1020 London Road, Cleveland. Ohio. 44110

~~e c;ntact esposure rate on the drums may exceed 1.000 mR per hour. w itn certain Crums e.xnibiting contact exposure rates in excess of 50 R pe roar at isolate: locations.

Tre Cisposal site sr.all be the Barnwell Low -Level Radioactive Waste Ma regement Fa:'lity (Souin Carolina)

Tre ::ru cl' De,rspe:ted. over -cacked as necessarv sourcea to a ir ant:ce! ve icle anc transported to tre disposal site for direct cispose Tre c %ms shall De transferred to the disposal site in a single ship"e ni alcr; natn the items listed in Task 6 through 10.

Al' laDor and experises. incluaing state / local taxes. are included All personnel, eaulpment and casks provided by SUBCONTRACTOR shall com ply Ctn applicable regulatory agency -approved Quality Assurance Frograms. licenses and permits Av5 Respcr,s'011111es.

Frcvide tre na~ie and telephone number cf one (1) individual res;cnsit' e

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for coordination of services between SUBCONTRACTOR and AMS.

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Provide physical characteristics. radiological composition. representa tive exposure rate and contamination levels or other information as

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deeme d necessary by AMS and SUBCONTRACTOR to satisfactorily specify and perfor m services.

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Transfer the drums to a pre -determined staging area within the London Road facility.

Provide work space for packaging and shipment certification service. s torage of shipping containers loading / unloading of shipping containers.

I administrat1ve work area, and personnel hygiene area.

l Operate existing in-house material handling equipment for the loading of drums into/on the shipping containers / equipment and, as necessary, to support the packaging and shipment certification service.

Provice radiation protection services and health physics coverage.

Frcme up to two (2) AMS employees to render assistance as needec. f or inis tast.

Provide otrer radiation protection equipment (e.g., protective Cloth 1r

g. s n ey instruments, portable shielding. etc.) as may be available at t re Len':on Road f acility or as specified by SUBCONTRACTOR in advance of on-site wert.

t SUECONTRI-CTCR Respons1Silities -

Prov1Ce the name and telepnone number of one (1) individual responsibl e for coordinatior, cf services between SUBCONTRACTOR and AMS, Provice a scnedf e for all activities.

Proc ce a list'n; of specialty equipment and services that AMS must sci y w advar.ce of on -site work.

Preside. in a vance of on. site work. a copy of written procedures and m:d instructiers for AMS approval and for AMS use in preparing a Rarsta on Work Fermit.

Provice project management for on -site work.

Provide an overpack (as necessary)._ packaging materials, shipping docu ments. labels, placards ano materials / components / procedures in i

accordance with SUBCONTRACT 0R's Quality Assurance Program for packaging I

anc transport Of the drums.

Provide transportation of the drums to the disposal site.

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4 Transfer the shipment from the AMS facility to the transport vehicle.

Ensure compliance with all USNRC. DOT. South Carolina and Ohio laws an d regulations for loading shipment and disposal of the materials address i

ed in this task.

Ensure Barnwell acceptance of the shipment based upon the AMS descript 1on of its physical and radiological characteristics.

Provide a receipt of disposal within one week of acceptance of the was te at the disposal site Period of Performance:

This tasi shall be completed within 60 days after AMS authorization _to pr oceed is given.

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Task 6 Re:elpt. Packaging. Transport and Disposal of Drummed DAW g

Tast Cescr,;ticn SUBCONTRACTOR shall receive. package. transport and di spose of d re h 113 cu:c: feet of dry solid naste containing 60Co. packaged in 55 -gallon drums b e W e ?

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t oJ W[l b(,J Ass n i e s:

l A total c' 15 crums shall be staged for this task.

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Tre drums snall be located at 1020 London Road. Cleveland. Onio. 44110 Pr clJ M"{

A Tre :cntact esp;sure rate on the crums does not exceed 1.000 mR per no Q,

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'ne Olsposal site shall De the Barnwell Low -Level Radioactive Waste Pab '

nagelent F8:111ty (South Carolina)

're Cru S will be inspectec. Sourced to a transport vehicle and trans 0:'ted ID tre con i 'dation facility. compacted (5 -to-1). and packaged

': r direct cispcsal Tne aaste is assuTed to result in "not greater than Class A waste" foi losing co pacticn

're dr n snall be transferred to the disposal site in a single shio e along with the 1 tens listed in Task 5 and 7 through 10 j

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All laDc' and ( penses. including state / local taxes, are included All personrei equipment and casks provided by SUBCONTRACTOR shall cor ply *1t' aDclicable regulatory agency -approved Quality Assurance Progra s. licenses and permits.

AMS Respons1b111tles:

f Provide the name and telephone number of one (1) individual responsibl e l

for coorcination of services between SUBCONTRACTOR and MS, i

l Provide physical characteristics. radiological composit.on. representa l

tive exposure rate and contamination levels or other 1r. formation as deeme d necessary by AMS and SUBCONTRACTOR to satisfactorily specify and i

perfor m services.

Transfer the drums to a pre -determined staging area within the London I

l Road facility.

Provide work space for packaging and shipment certification service. s torage of shipping containers, loading / unloading of shipping containers.

i administrative work area, and personnel hygiene area.

i Operate existing in-house material handling equipment for the loading of drums and, as necessary. to support the shipment certification l

service l

Provide rad'ation protection services and health phys 1Cs coverage.

Provide up to two (2) AMS employees to render assistance, as needed, f or this task

rovice o;ner rad'ation protection e0uipment (e.g.

protective clothin

g. Su vey instruments. portable Shielding, etc.) as may be available at r

l l-ne London Road facility or as specified by SUBCONTRACTOR in advance of co-s,te work.

SUBCONTFKTOR Respons1oll1tles -

Provice the name and telephone number of one (1) individual responsibi e for coorcination of services between SUBCONTRACTOR and AMS.

Frovice a scnecule for all activities.

4 Provice a listing of specialty equipment and services that AMS must SLpol y in advance of on -site work, rrovide. in advance of on -Site work, a copy of written procedures and work instru:tions for AMS approval and for AMS use in preparing a RSClati on Work Fermit, l

Provide project management for on -site work Provide an overpack (as necessary), packaging materials. shipping docu merts. labels. placards and materials / components / procedures in

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accercance with SUBCONTRACTOR's Quality Assurance Program for packaging 1

and transport of the drums l

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Provide transportation of the drums to the disposal site.

Transfer the shipment from the AMS facility to the transport vehicle.

Ensure compliance with all USNRC. 00T. South Carolina and Ohio laws an d regulations for loading, shipment and disposal of the materials address ed in this task.

1 Ensure Barnwell acceptance of the shipment based upon the AMS descript lon of its physical and radiological characteristics.

Compact the contents of the drums by a factor of at least f1ve (5) for disposal.

l Provide a receipt of disposal w1 thin one week of acceptance of the was j

te at the disposal site l

Period of Performance:

This task shall be completed within 60 days after AMS authorization to pr oceed is given Task 7 Receipt. Packaging. Transport and Disposal of lon Excnange Resin s/ Charcoal Mecla Task Descriptico SUBCONTRACTOR shall receive, package. transport and di spose of 450 cubic feet Of lon exchange resan containing 60Co. packaged 1 n 55 -gallon drums.

Assumotlor.s :

A total of 60 drums shall be staged for this task.

1 The :: rums shall be located at 1020 Lon00n Road. Cleveland. Ohio. 44110 l

l The 11oJ1C content of each drum is less than 0.5% by volume. each drum is at least 85% full. anc each drum 1s acceotable for transpor_t in actor dance witn applicable regulations-The contact exposure rate on the drums does not exceed 1.000 mR per ho ur Ihe disposal site shall be the Barnwell Low -Level Radioactive Waste Management Facility (South Carolina).

The drums will be inspected, sourced to a transport vehicle and transp orted to the disposal site for direct disposal The crums shall be transferred to the disposal site in a single shipme nt along with the items listed in Task 5. 6 and 8 through 10.

I

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All labor and expenses. including state / local taxes. are included.

i All personnel, equipment and casks provided by SUBCONTRACTOR shall com ply with applicable regulatory agency -approved Quality Assurance l

Programs.. licenses and permits.

AMS Respons1bilities:

j Provide the name and telephone number of one (1) individual responsibl e i

for coordination of services between SUBCONTRACTOR and AMS.

Provide physical characteristics. radiological composition. representa tive exposure rate and contaminat1on levels or other information as deeme d necessary by AMS and SUBCONTRACTOR to satisfactorily specify and perfor m services.

De-water and transfer the drums to a pre -determined staging area withi n the London Road facility.

Provide work space for packaging and shipment certification service. s torage of snipping containers. loading / unload 1ng of shipping containers.

acm nistrative work area. and personnel hygiene area.

Operate er sting in -nouse material nandling eoulpment for the loaalco C+ d'ums ar0. as necessary. to support the shipment certification serv'ce Provice radiation protection services and health physics coverage.

I Prov1Ce up to two (2) AMS employees to render assistance, as needed. f Or tris tasi-Or r e c F er radiation protect,on equipment (e 9 protective clctnin j

g _ survey instreents portable shielding. etc ) as may De available at

  • re Mac:a R:a: facility or as specified by SUBCONTRACT 0L in cavance of i

cc-r te nork SUBCONTRACTOR Responsib111tles.

Fravide tre na're and telephone number of one (1) individual responsibl e for coordination of services between SUBCONTRACTOR and AMS.

Provice a schedule for all activities.

I Procce a listing of specialty equipment and services that AMS must suppl y in aLance of on -site work.

Frtvide. in aCvance of on -site work. a copy of written Drocedures and work instructions for AMS approval and for AMS use in preparing a

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Radiati on Work Permit.

Provide project management for on -site work.

P_rovide nad acino materials (as necessaryl. shipping, documents labels, placards and materials / components /procedares in accordance with SUBCONTRACT 0R's Quality Assurance Program for packaging and transport of the dru ms.

Provide transportation of the drums to the disposal site.

Transfer the shipment from the AMS facility to the transport vehicle.

Ensure compliance with all USNRC. 00T. South Carolina and Ohio laws an d i

regulations for loading, shipment and disposal of the materials address ed in this task.

Ensure Barnwell acceptance of the shipment based upon the AMS descript ion of its physical and radiological characteristics.

Provide a receipt of disposal within one week of acceptance of the was te at the disposal site Pem oc cf Performance This task shall be conoleted within 60 days after AMS authorization to pr oceed is g,,,. g,,

Task B-Rece'pt. Packaging. Transport and Disposal of HEPA Filters Tast Description. SUBCONTRACTOR shall receive. package, transport and di spose of 30 ME?A fi ters contamnated alth 60Co.

l unpackage:

Assunt'tes:

A total of 30 HEPA filters (lft x 2 ft x 2 ft) shall be staged for thi s 135k The filters shall be located at 1020 London Road. Cleveland. Ohio.

44110 The contact exposure rate on the filters may be in excess of three (3) R per hour The disposal site shall be the Barnwell Low -Level Radioactive Waste Ma nagement Facility (South Carolina).

The filters sill be inspected. overpacked. Sourced to a transport veh 1cle. transported to the consolidation facility compacted (2 1). and packaged for direct disposal.

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The waste is assumed to result in "not greater than Class A waste" fol lowing compaction.

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The filters shall be transferred to the disposal site in a single ship ment along with the items listed in Task 5 through 7, 9 and 10.

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l All labor and expenses. including state / local taxes are included.

All personnel. equipmert and casks provided by SUBCONTRACTOR shall com ply with applicable regulatory agency -approved Quality Assurance Programs, licenses and permits.

AMS Responsibilities:

Provide the name and telephone number of one (1) individual responsibi e for coordination of services between SUBCONTRACTOR and AMS.

1 Provide physical characteristics.. radiological composition. representa tive exposure rate and contamination levels or other information as i

l ceeme d necessary by AMS and SUBCONTRACTOR to satisfactorily specify and perfor a services.

Transfer the filters to a pre -determined staging area within the Londo n

oa fa
111ty.

Novide work space for packaging and shipment certification service. s tcrage of shipping containers. loading / unloading of shipping containers.

aamin'strative work area, and perscnnel hygiene area.

Operate existing in -house material handling equipment for the loacing of filters and. as necessary. to support the shipment certification servi ce.

Provide rac13tlon protection services and health physics coverage.

l Prov'de up to two (2) AMS employees to render assistance. as needed, f or inis task.

Provide otner radiation protection equipment (e g.

protective clothin

g. survey instruments. portable shielding. etc.) as may be available at t ne London Road facility or as specified by SUBCONTRACTOR in advance of cn site work SUBCONTRACTOR Responsibilities:

Prevloe the name and telephone number of one (1) individual responsibl e for coord1r.ation of services between SUBCONTRACTOR and AMS.

Provide a schedule for all activities.

Provide a listing of specialty equipment and services that AMS must

suppl y in advance of on -site work.

Provide. in advance of on -site work. a copy of written procedures and j

work instructions for AMS approval and for AMS use in preparing a Radiati on Work Permit.

Provide project management for on -site work.

Provide an nvornark narkagina materials _ shipping documents, labels, placards and materials / components / procedures in accordance with SUBCONTRACT 0R's Quality Assurance Program for packaging and transport of the filte rs.

Provide transportation of the filters to the disposal site.

Transfer the shipment from the AMS facility to the transport vehicle.

Ensu e compliance with all USNRC. DOT. South Carolina and Ohio laws an d r

regulations for loading, shipment and disposal of the materials address ec in this task.

Ersu e Barrnell acceptance of the shipment based uocn the AMS descript r

1;r ;' its phys 1 Cal and radiolog1 Cal Char 30terist1Cs.

Co pact the f41:ers by a factor of at least two (2) for disposal.

Prcvice a rece'p of disposal within one week of acceptance of the was te at the cisposal site l

Perloa of Pertermance-Tr15 tasi snail De co pletea 3:tnan 60 days _after AMS authorization to pr oceed is given Task 9. ;e: east Packaging. Transport and Disposal of Bo.xed DAW Tast Descr1;t':.

5;ECCNTRACTOR snail receive. package. transport and di spose of 1.150 cubic 'eet cf dry solid (caper) waste containing 60Co pa ckaged in 10 B -25 boxes and three (3) B -12 boxes Assump:1cns-A tctal of 13 Doxes shall be staged for this task.

Tne boxes shall De located at 1020 London Road, Cleveland. Ohio. 44110 j

The contact exposure rate on the boxes doe; not exceed 1.000 mR per ho ur The d'stosal site snall be the Barnwell Low -Level Radioactive Waste M3 nage",ect Facility (South Carolina)

[

The boxes will be inspected. sourced to a transport vehicle. transpor ted to the consolidation facility, compacted (5 -to-1). and packaged for d 1 rect disposal.

l The waste 15 a"W + ^ molt in "nnt oreator than class A waste" foi

_ lowing compaction.

The boxes shall be transferred to the disposal site in a single shipme l

nt along with the items listed in Task 5 through 8. and 10.

All labor and expenses, including state / local taxes are included.

l All personnel. equipment and casks provided by SUBCONTRACTOR shall com l

ply with applicable regulatory agency -approved Quality Assurance Programs. licenses and permits.

AMS Respons'b'11tles Provide tne name and telephone number of one (1) individual responsibl e for coordination of services between SUBCONTRACTOR and AMS.

Drovide pnysical characteristics. radiological composition. representa tive exDosure rate and contamination levels or other information as deeme d necessary by AMS and SUBCONTRACTOR to satisfactorily specify anc perfor m services.

Trars#er the bores tc a pre -determined staging area within the London Road fac1'1ty Provide work space for packaging and shipment certification service. S torage of snipping containers. loading / unloading of shipping containers, administrative work area, and personnel hygiene area.

CDerate ensting in -nouse material handling eculpment for the loading of boxes and. as recessary. to support the shipment certification se v ce Proc ce radiation protection services and health physics coverage.

i Pavloe up to two (2) AMS employees to render assistance. as needed. f or tnis task.

i Provice ether radiation protection equipment (e.g., protective clothin

9. Survey instruments, portable shielding, etc.) as may be aval'able at t he London Road facility or as specified by SUBCONTRACTOR in advance of on-site work SUB;0NTRA; TOR Respons1 bill:1es i

Pron de tne name ano telephone number of one (1) individual responsiol e i

I for coordination of services between SUBCONTRACTOR and AMS.

Provide a schedule for all activities.

l l

Provide a sting of specialty equipment and services that AMS must I

suppl y in advance of on -site work.

Provide in advance of on -site work. a copy of written procedures and work instructions for AMS approval and for AMS use in preparing a Radiati on Work Fermit.

Provide prcject management for on -site work.

j i

i Provide packacina materials (as necessarv) shipping documents. label

s. placards and materials / components / procedures in accordance with SUBCONTRACTOR's Quality Assurance Program for packaging and transport of the bo xes.

j Provide transportation of the boxes to the disposal site.

Transfer tne shipment from the AMS facility to the transport vehicle.

Ensure compliance with all USNRC. DOT. South Carolina and Onlo laws an d regulations for loading, shipment and disposal of the materials aadress ed in this task Ens ze Barnaell acceptance of the shipment based upon the AMS descript 1or of its pnysical anc radiological character,stics.

Compact tne contents of the boxes by a factor of at least five (5) for disp 0 sal Provide a receipt of disposal within one week of acceptance of the was te at tre ciscosal site Perloc of Performar.ce:

)

This task shall be completed witnan 60 days after AMS authorization to pr oceed is given i

Task 10- Receipt. Packaging. Transport and Disposal of Water Treatment Vessels Task Description SUB:0NTRACTOR shall receive. package. transport and di spose of two nater treatment vesseltnat are internally -contaminated uit h 60Co.

Assumptions-A tctal of two (2) vessels shall be packaged and staged for this task.

The vessels are constructed of stainless steel with nominal cyllnGrica 1

dimensions of two (2) feet by four (4) feet (e g.

a volume of approxim ately 18 ft3 per vessel).

Tne vessels shall be locatec at 1020 London Road. Cleveland. Onio.

44110.

The contact exposure rate on the vessels is less than 40 mR per hour The disposal site shall be the Barnwell Low -Level Radioactive Waste Management Facility (South Carolina)

Tne packaged vessels will be inspected, sourced to a transport vehic le. and transported for disposal.

Q M

W The waste is assumed to result in "not greater t% Class A waste" fol ye elggl p bs lowing compaction.

s ot C

The vessels shall be transferred to the disposal site in a single ship mert along with the items listed in Task 5 through 9.

YsJ' pV bb t,1 la0;" and expenses including state / local taxes. are included.

A oersoncel. e:ulpnent and casks provided by SUBCONTRACTOR shall co-c' 6'th a;;licatie regu atory agency -approved Quality Assurance l

'ogra-licenses and permits AV3 Res; 7
0: 1*'es Crow'de !"e cd 9 an: tele;none nu*cer of one (1) ind1V10Jal respons10l e c: "d'. ration C serv 1Ces betweer. SUBCONTRACTOR and AMS.
  • ':(1Ce physical chara;terist1Cs. ra01olog1 Cal composition, representa I ve eC:sure rate and contamination levels or other inforTation as
ee e 0 recessary by AMS and SL3 CONTRACTOR to satisfactcelly specify ar:

ce<f:e secoces

s':*er tre,e::- s *: a ;ce -ceterm'ned staging area wit-in the Lon :

r

at '3
-1 ty
rosice nori space for packaging anc shipTent certification service s torage o' srapping contairers. loading / unloading of snipping contairers.

a: ori trat,se work area. and personrel hygiene area Operate e>1 sting in -house material handling equipment for the loading of vessels anc. as necessary. to support the shipment certification serv' ce Irov1Ce r30'at' n prctection serv 1:es at: health pnys,c coverage.

C': 1ce Z * : ta: (2) AY3 e Oloyees to rer;er assistar e, 35 reeted

or this task.

Provide other radiation protection equipment (e.g.

protective clothin

g. survey instruments, portable shielding, etc.) as may be.available at t he London Road facility or as specified by SUBCONTRACTOR in advance of on-site work.

SUBCONTRACTOR Respons1bilities:

Provide the name and telephone number of one (1) individual respons1bl e for coordination of services between SUBCONTRACTOR and AMd.

(

i Provide a schedule for all activities, l

. Provide a listing of specialty equipment and services that AMS must suppl y in advance of on -site work.

)

Provice. In advance of on -site work, a copy of written procedures anc work instructions for AMS approval and for AMS use in preparing a Radiat1 on Work Permit.

Prcvide project management for on -site work.

frovide packaging materials._-shipping documents. labels, placards and materials components / procedures in accordance with SUSCONTRACTOR's 0;ah t y Assurance Program for packaging and transport of the vessels.

Drovide transportation of the vessels to the disposal site.

Transfer the shipment from the AMS facility to the transport vehicle.

Ensure comollance witn all USNRC 00T. South Carolina and Ohio lan's an o regulations for loading. shipment and disposal of the materials address j

eC in this task j

i Ersure Barnnell acceptance of the shipment based upon the AMS descript ic" of its D$sical and radiolog1 Cal characterist1C5.

Co oact the vessels by a factor of at least two (2) for disposal.

Provice a receipt of disposal within one week of acceptance of the was te at tne dispDsal site Period of Performance:

This task snail be completed with,n 60 days after AMS authorization to pr oceed 15 given.

s racru. m 1

Date:

10/15/96 AMS' " Strategic Plan for the London Road Facility" (" Plan")

As part of license compliance efforts, AMS is faced with numerous tasks ranging from very involved (license renewal application, underground drainage remediation, etc.),

i i

to routine surveys and reports. Due to limited personnel assets and financial resources, the tasks are prioritized and scheduled ac,cordingly to effect the maximum cost / benefits in a timely and efficient manner. This Plan is AMS' outline to accomplish this, and updates have been submitted quarterly.

The following Plans and revisions have been issued:

i Initial Plan October 11,1995 Revision 1 January 15,1996 i

Revision 2 April 11,1996 Revision 3 July 10,1996 i

The Plan divides the actions into high, intermediate, lower priority and on-going actions. (High priority has action planned in the next 12 months; intermediate priority j

has 1 - 3 years planning; low priority has 3 - 5 years planning) The following information is the update as of the lasted revision listed above:

Hiah Priority Actions Complete the Remediation Report This action included remediating the large amounts of water that infiltrated into the basement of the facility when the lateral was plugged by NEORSD, remova the CO-60 from that water, remediate the foundation drains, isolate the manhole and lateral, and remediate the NEORSD interceptor.

The Co-60 has been removed from the water from the basement, which is being stored in four 25,000 gallon bladders; the 100,000 gallons has about 40 microcuries (calculated), which gives around 100 picocuries per liter, less than the EPA drinking water standard for Co-60. Disposition of this water has not been determined.

i in the remediation of the foundation drains, which were replaced, there was contaminated soil that was isolated, piled in an lined wooden structure that still needs final disposition, but is part of the surveillance plan. The surveillance plan for residual activity outside the AMS building around the abandon foundation drains and lateral connector has been deferred, as per license amendment 43.

The disposition of the water in the WHUT room is still undetermined. AMS is investigating a stabilizing material called STERGO, which is a cross-linked polymer that absorbs and retains large amounts of water. AMS IS WAITING FOR NRC TO t

J

7__ _ _

i*

i J

i RESPOND TO TASK 3 OF THEIR " BUILDING RECOVERY PROJECT", A l

PROPOSAL TO STABILIZE THE RADIOLOGICAL CONDITION IN THE BASEMENT AND WHUT ROOM TO REDUCE IMPACT OF WATER INCURSION.

4 l

..., for reasons that are beyond AMS' control, remediation of the London Road Interceptor may be delayed significantly."

i License Renewal Application i

)

Initial renewal application in early 1995 was determined to be cumbersome and j

unmanageable; a significantly revised application was submitted on 10/30/95.

j After a deficiency letter was sent by NRC on 12/5/95, AMS responded with copies of l

requested procedures on 1/3/96,2/13/96, and 3/8/96. AMG HAS RECEIVED NO ADDITIONAL RESPONSE FROM THE NRC RE THESE UPDATES.

t

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Emergency Plan i

initial EP was submitted with renewal application. Because of extensive problems, a revised EP was resubmitted on 8/22/95, consistent with Reg Guide 3.67. NRC sent comments on 2/28/96; AMS response were forwarded 3/22/96, along with comments i

4 to first responders. On 3/12/96, AMS received a report on the structural integrity inspection; responses to items pertinent to the EP was submitted to NRC on 6/7/96.

Latest comments from Rlll to AMS dated 6/16/96; latest response from AMS dated 8/14/96. Possibility of revisiting the EP post disposal of bulk and sealed Co-60 l

(about 45,000 curies) i i

Decommissioning Funding Plan Initial DFP submitted with the renewal. Initial cost estimates were low for decontamination. AMS then submitted a Conceptual Decommissioning Funding Plan that was based on SAFSTOR. In January 8,1996, NRC accepts a decommissioning l

financial assurance based on January 1995 cost estimates. In June,1996, AMS submits a " Building Recovery Project, that proposes a large reduction in inventory, and a reduction in the letter of credit to do this inventory lowering. This credit 4

reduction is submitted as an amendment and approved by the NRC in license j-amendment 44.

l Train First Responders in Emergency Plan Provisions l

Within 60 days of the approval of the emergency plan.

j Stage emergency Exercise in Emergency Plan Provisions i

j Within 60 days of after training of the first responders.

)

l Intermediate Priority Actions Recover Hot Cell Capabilities Cross contamination was a concern because of the levels of contamination in the hot cell. After an evaluation, improved lighting and a source transfer mechanism was all that was needed to make the cell operational by the end of 1995.

Retum NPI Sources in July 1996, there were 34 sealed sources (? activity) at AMS that belonged to NPl.

As sources are bought from NPI to delivery to an AMS client, AMS sends a shipping container to NPI, now with a source in it for retum to NPl. NPI will allow only one source per shipment.

Identify a Market for Remaining Sources and Bulk Material Originally attempting to sell or give source to any market that AMS could find. This has been abandoned, and AMS is disposing of the bulk and sealed sources at Barnwell via Chem-Nuclear as broker; a contract is in place, and AMS is awaiting the approval of the safety procedures. This is part of the Building Recovery Project, is begin addressed now, and should be under the high priority.

Lower Priority Action Removal of Plug in the Hot Cell About 4,000 curies of sealed Co-60 are located in a storage well in the hot cell, but the hot cell plug is vuck, precluding a physical inventory. A contract for removal of the plug has been let(?). Once decision (?) made and permits approved, the project will begin.

Decontamination of Hot Cell AMS plans to decontaminate the Hot Cell to levels necessary to support planned future operations.

Complete / Confirm the Physical Inventory and Transfer / Ship Remaining Sources To be done after plug is removed from well. Intends to ask for an amendment to condition 14.c., requesting an exemption from physical inventory until after plug removed. (at the moment, they are in violation of their license condition)

Disposition of Solid Waste at the Facility About 3,000 cubic feet (400 fifty-five gallon drums) exist and stored at AMS. Looking

at disposal at same time as the bulk and sealed Co-60. AMS waiting for NRC procedure approval and is attempting negotiations with different brokers for disposal.

This is addressed in the Building Recovery Project, being addressed now, and should be under high priority.

4 Disposition of Treated Water in Collapsible Storage Tank i

Water from the basement flood was treated using sub-micron filtration and reverse 4

osmosis to reduce cobalt-60 to below drinking water levels; presently 100,000 gallons of treated water are being stored in storage tanks. AMS has EPA approval to evaporate, but that has become too expensive for 100,000 gallons. Not a radiological hazard; they are pursuing other options for disposal.

On-Goina Actions Audit / Assessment of Radiation Protection Program AMS intends to perform a series of audits of its radiation protection program to d

compare it with the standards that are out there. There is a litany of topics to be considered listed in the Plan. "Immediately after renewal..., the Radiation Safety Committee will set the audit schedule."

Upgrade of Standard Operating Procedures Nineteen Radiation Safety Procedures (RSP) are listed in the document, to be implemented upon license approval.

4 Housekeeping improvements includes waste consolidation, equipment decontamination, and facility surveys.

Expanded information in the Building Recovery Project.

Community Relations Purpose is to acquaint various officials and members of the print and broadcast media to what AMS does.

Reconnection of Sewer System to London Road interceptor AMS is not connected to a sanitary sewer system. There is no sanitary discharge from the facility, but groundwater accumulates in the manhole and is pumped to tanks, analyzed before discharge to the environment (the water flows across a parking lot, to a storm sewer catch basin). AMS is attempting to characterize, and to remediate the interceptor line, eventually to connect back to the sewer system.

AMS has also requested authorization to discharge from manhole directly to catch

l s

if i

I basin, and not collect and analyze, because the collec+ed water has all proven to be

~

free of insoluble Co-60 in the past. AMS will still need the court to rescind their order not to discharge directly.

i 1

I l

l l

a rv ki Date:

10/16/96 Subj: Building Recover Project Task 1, Disposal of Sealed and Bulk Co-60 at Commercial Low-Level Waste Burial l

Site. Task describes the proposal to contract a broker to dispose of the 44,000 curies at Barnwell. The major impact of this proposal effects the i

Letter of Credit of the Decommissioning Financial Assurance for the DfP. AMS wishes to use some of the money tied up in the Letter of Credit to dispose of the Co-60, and this would need NRC approval.

NRC has approved this money adjustment in Amendment 44. The safety procedures have been approved and RIII is about to give the go ahead for Chem-Nuclear to proceed with the disposal shipment.

Task 2, Disposal of the Dry Solid Waste Stored at the Facility.

This task is in conjunction with Task 1, with the same monetary provision. At present, AMS is still trying to negotiate with another waste broker besides Chem-Nuclear to procure a best price for the disposal. There is about 3,000 cubic feet of dry solid waste to be disposed (400 fifty-five gallon drums).

Task 3, Radiological Stabilization of the Basement.

The task is the l

decontamination of the basement area for unrestricted release of the basement, outside of the Waste Hold Up Tank (WHUT) room, and the j

stabilization of the radioactive material in the WHUT room, to ensure that liquids do not enter or exit the room for the duration of the safe storage period.

It is recommended that this task be pursued (decontamination of basement and stabilizing material in WHUT room); however, the evaluation of i

the feasibility of decontaminating and decommissioning the WHUT room should be made by AMS.

i Task 4,. Hydrological Stabilization of the Basement.

This task addresses the issue of water collecting in the underground drains and flowing to the new t

i manhole _which is presently isolated from the area sewer system. AMS presently collects this water in hold-up tanks, analyses the water for cobalt-60, then discharges it to a catch basin if the analysis shows no cobalt-60 content.

1 There is presently a separate request from AMS, dated June 25, 1996, requesting authorization to discharge directly from the manhole to the catch basin with no hold-up for analysis, and sampling the water once a week from the manhole instead, to verify that the water from the underground drain is not contaminated from the soil surrounding the underground drain. This issue is being addressed in a separate TAR, expected to be completed by early September.

. Task 5, Modifying Conceptual Decommissioning Plan and Decommissioning Funding Plan.

This task discusses the resubmittal of the Conceptual Decommissioning Plan and a subsequent Decommissioning Funding Plan in light of the decrease in inventory and the unrestricted release of parts of the London Road facility.

Pursuant to the completion of disposal of the 40,000 curies or so of bulk and sealed cobalt-60 sources, $nd of the low-level waste generated from decontamination of the facility, the estimates of cost for decommissioning of the facility should be readdressed. However, in all the correspondence to i

date, AMS has emphasized and requested approval for SAFSTOR methodology for l

J its cost estimates; all correspondence from Headquarters addressing this issue bave indicated why SAFSTOR would not be an option, and that the Generic

3 s

Environmental Impact Statement (GEIS), NUREG-0586, intends SAFSTOR to be an allowed use of a safe storage for a few days to a few months for material licensees. This continues to be our position.

In addition, in a letter from Kevin Null to David Cesar dated August 5,1996, condition number 24 was added to AMS' license to require that AMS submit to NRC for review a revised i;

Conceptual Decommissioning Plan (CDP) and cost estimate not later than August 1

30, 1996, and, assuming NRC approval of the CDP, a revised Decommissioning Funding Plan that will contain a description of a new decommissioning 4

financial instrument not later than September 15, 1996. NRC will review this new plan upon its arrival.

Task 6, Free Release Remainder of Building.

This task discusses the characterization and remediation of the London Road facility, similar to Task 3 but referring to decommissioning the areas outside of the basement.

After decontamination, surveys pursuant to NUREG-5849, " Manual for Conducting Radiological Surveys in Support of License Termination," will be performed by AMS, submitted to the NRC, with a request for confirmatory surveys for all but the WHUT room, Hot Cell, and the ventilation room.

This task is approved.

Task 7, Request Ex aption from Physical Inventory.

This task discusses AMS intention to request an exemption from the inventory license condition and discusses the reasons for this request.

Because the plug to the storage well has become lodged, physical inventory of the sources in the well is not possible. A license condition (14.c.) requires that an inventory be performed by June 1, 1993, and every 60 months thereafter. At present, the licensee is in violation of that condition, as noted in a letter to AMS dated August 13, 1993, although attempts have been made to remove the plug.

Review and determination by the NRC will be made with the information that is provided when the exemption request is submitted.

In the meantime, the determination of what should be in the well should be established from past inventories.

There is a large variation in the quantity of material that AMS has estimated to be present in the well, depending on which piece of correspondence is read (June 10, 1996 BRP letter indicates approximately 3000 curies of cobalt-60, while July 10, 1996, Revision 3 of Strategic Plan estimates 4000 cut.es of cobal t-60).

Task 8, Request Exemption from Emergency Plan Requirements. This task discusses the requirement for an Emergency Plan in accordance with 10 CFR 30.32 in light of the large possession limit authorized in the license. After completion of Tasks 1 and 2 of the BRP, license quantity limit requirements should be significantly reduced, from maximum amounts of 150,000 curies of solid metal and 135,000 curies of sealed cobalt-60 in AMS' present license, to a maximum of 10,000 curies, including the cobalt-60 in the plug well. AMS also indicates that the cobalt-60 will be sealed, non-dispersible material.

After disposition of all disposable material, AMS should first submit an amendment to modify the possession limit on the license (see task 10), and, after receiving a lower possession limit, submit either an Emergency Plan in accordance with 10 CFR 31.32, using Regulatory Guide 3.67, " Standard Format and Content for Emergency Plans of Fuel Cycle and Material Facilities," and NUREG-ll40, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," as guidance, or, in accordance with Title 10 CFR 30.32(i)(1), an evaluation that indicates that a dose of I rem effective dose equivalent or 5 rem to thyroid could not be delivered to a member offsite (which AMS indicates it could show).

i a

o Task 9, Request Extension of Safe Storage Pericd for WHUT Room. This task describes the desire of the licensee to continue the WHUT room in a storage capacity based on personnel exposure and waste volume considerations.

Revisiting the WHUT room evaluation of whether to continue existing storage of the room, or decontaminate, should be performed at least as often as a license renewal, taking into consideration As Low As Reasonably Achievable analyses.

AMS should be reminded that the longer the storage of the WHUT room, the longer its remediation will need to be considered in the estimation of decommissioning costs, and the higher the cost of the decommissioning funding i

instrument, coupled with the rising cost of waste disposal and inflation.

Consideration of continued storage will be based on the information provided in AMS' request for storage extension.

Task 10, Request Reduction'in License Limit.

This task will request a reduction in the licensed maximum possession limit of radioactive material.

3 As indicated in the Task 8 discussion, this should be accomplished by AMS as soon as possible after Tasks I and 2 are completed.

The decommissioning funding plan is based on the quantity of material the licensee is authorized to possess, and therefore, the funding plan complexity and liability coverage might be reduced by a reduction of the possession limit. Although the

" quantity" criteria for having to consider an emergency plan is still exceeded, the development and analysis of the plan, and the demonstration of the potential of exposing an offsite individual to less than I rem effective dose equivalent would be easier to complete.

Task 11, Submit Long-Range Strategic Plan.

This task discusses AMS' on-going plan to issue subsequent revisions to its Strategic Plan. AMS submitted its latest revision dated July 10, 1996.

AMS should continue to submit the plan since it provides information on progress made by AMS to resolve identified issues.

Task 12, Perform Routine Operations and Meet Regulatory Comitments. This task discusses AMS' intention to track outstanding regulatory and compliance issues along with th. above 11 tasks. Although this task does not generate a deliverable item except the task list of the BRP, the NRC can review this present list in the future to monitor progress of activities at AMS.

BRP, SUM.JED

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