ML20149G745
| ML20149G745 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/1994 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Axelson W, Hehl C, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20147H302 | List: |
| References | |
| FOIA-96-444 NUDOCS 9411040086 | |
| Download: ML20149G745 (7) | |
Text
,
p+* *%g lh )" . j I UNITED STATES NUCLEAR REGULATORY COMMISSION o, WASHINGTON. O.C< 20555 4 001
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\ / October 19, 1994 MEMORANDUM TO:
Those p tached list FROM: J. Paperiello, Director fDivision of Industrial and
/ Medical Nuclear Safety, NMSS SU8 JECT: POLICY AND GUIDANCE DIRECTIVE 94-05; UPDATED GUIDANCE ON DECAY-IN-STORAGE This directive provides guidance for granting authorizations for disposal by decay-in-storage. It is the current policy, and supplants guidance from previous technical assistance requests (TARS) and the Draft Policy and Guidance Directive issued April 3, 1992. In light of multiple TARS received i j
in the past two years reaarding decay-in-storage (DIS) that do not meet the l criteria of 10 CF' 35.92, it has become obvious that there is c nead for a set of generic critt.ria for review of these requests. As discussed in John Glenn's memorandum dated August 15, 1994, the Division of Waste Management (DWM) is currently conducting a generic assessment to determine the survey and I activity criteria necessary to dispose of radioactive material by DIS pursuant to 10 CFR 20.2001(a)(2). The DWM generic assessment is expected to be completed in February 1995. Until this assessment is complete, the regions may routinely grant new or renewal requests for DIS authorizations which meet the requirements of 10 CFR 35.92 (a)(1), (a)(2), (a)(3), (a)(4), & (b).
However, DWM previously concluded that materials with half-lives of 120 days 4 are appropriate for DIS after a minimum of 10 half-lives, if appropriate (
surveys are conducted to establish that residual activity is indistinguishable from background. Authorizations for DIS may be granted by the regions (as stated above) for isotopes with a half-life of less than or equal to 120 days without NMSS review pending completion of the assessment. No action is j requirG en previously granted DIS with different criteria unless a renewal !
request has been submitted by the licensee for review.
For a licensee whose request for DIS with alternative criteria to those listed in 135.92 is included with a request for other licensing actions, the region should inform the licensee that they may request the region to address i separately the DIS portion of the licensing request upon completion of the generic assessment. If the appropriate fee was submitted with the initial request, no additional fee will be required to complete the review of the DIS portion of the request. It. accordance with current procedures, Glenda Jack an in the Office of the Controller, License Fees and Debt Collection Branch, should be included in the concurrence chain for all letters providing fee information.
Individual TARS may be submitted pursuar,t 10 CFR 20.2002 for review by DWM, but completion of this review may te delayed until the generic issues are resolved.
Attachment 2 f
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LICENSING TRACKING SYSTEM DATE: 950926 [$)
PAGE: I e LTS WORh5HEET LOCFE' NO : 0:016055 LICENSE ta 34-190S9-01 STATUS: 2 "A: C0taTROL: 2735C7 'E;E: kT : ATE 5 'E eATE 7504E3 950727 ACTION TYPE: 4 /
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iN ~ C:EE : 19039 LICENSE REGION: 3 123UE DATE: ?50203 LE alNAL DATE: 7 91 1 :. .; EAFIRATION DATE: 19941231 NaME ADVANCE 0 MEDICAL SiSTEMS DECOM FIN ASSUR REOD: Y SUBM: Y DEPT / BUREAU: ______,__________,_________________ CONT PLAN RE00: Y APPRV: Y BUILDil10 :
STREET : 1020 LONDON ROAD b
CITY : CLEVELAND STATE: CH ZIP: 44110 CONTACT PERSON: SHERRY STEIN. REGULATORY AFF.0 PHONE: 216/466-4671
?RIMARY PGM CODE : 03211 SECONDARY PGM CODES: 03620 03520 INSFECTION REGION: 3 PRIORITY CODE: 1 INSPECTION CATECORY: B RADIATION SAFETY OFFICER: ROBERT MESCHTER STATES WHERE USE IS AUTHORIIED: 3 0 - ALL LISTED STATES 1 - SAME AS STATE IN ADDRESS 2 - ALL STATES 3 - f40N-AGPEEMENT STATES AUTHDEIZED STATES: _____________________________ (USE ONLY IF ABOVE IS ZERO)
REPORTING IDENTIFICATION SYMECL XWK APPROVAL FOR: REDISTRIEUTION: Y STORAGE ONLY: N TEMPORARY JOE SITES: N INCINERATION: N EURIAL: N EXEMPTIONS: (1) .___________________ .21.___________________
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[ UNITED STATES /
E NUCLEAR REGULATORY COMMISSION
%, / WASHINGTON, D.C. 20555-0001
.....f June 28, 1995 MEMORANDUM T0: Kevin Null Materials Licensing Section Division of Radiation Safety and Safeguards, Region III l FROM: Louis M. Bykoski v N'
Materials Decomissioning Section
, Low-Level Waste and Decomissioning Projects Branch Division of Waste Management, NMSS
SUBJECT:
REVIEW OF ADVANCED MEDICAL SYSTEMS, INC., COST ESTIMATE 1 RESPONSE NRC LICENSE N0. 34-19089-01 We have reviewed the Advanced Medical Systems, Inc., May 30, 1995, response to NRC's coments on the decommissioning cost estimate for the London Road site. We have provided our coments in the Attachment.
Attachment:
As stated ,,
m .
Contact:
Larry Pittiglio, NMSS/DWM C g 415-6707 Louis M. Bykoski, NHSS/DWM h\
415-6754 3 UO
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86s-vA RECEIVED 3/
JtR 0 1995 Ig REGION III
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SUBJECT:
REVIEW 0F ADVANCED MEDICAL SYSTEMS, INC., MAY 30, 1995, RESPONSE T0 i NRC'S COMMENTS ON DECOMMISSIONING COST ESTIMATE FOR THE LONDON ROAD SITE IN CLEVELAND, OHIO, (NRC LICENSE NO. 34-19089-01) i J I have completed my review of the Advanced Medical Systems, Inc. (AMS) May 30, i 1995, response.to the NRC's. comments (March 30, 1995,) on the decommissioning
'. cost estimate for the London Road' site and again concluded that the' estimated cost of $1,795,612 does not realistical_1y reflect the cost to decommission the i' facility. The basic reasons for my concerns about the cost estimate were the
- ones; identified in my ' initial review and in the NRC Request for Additional
- Information of March 30, 1995, to AMS. My initial concerns were
- 1) the cost i estimate is based the on the_ assumption that the soil under the building is i uncontaminated; and 2) the disposal cost was based on a cost of $181 per cubic foot. AMS' response (May 30,1995,).did not adequately respond to our initial
! concerns. In . addition, because Region - III is familiar with the site, we
- recommend that Region III needs to evaluate whether AMS __has_.. adequately
- characterJzed the site to support their position regarding soil contaminations and extent of contamination at the site. Finally, AMS' assumptions that the j .
) cobalt source will be shipped to "other" sites, and decommissioning will not take 4
\ place until the cobalt has decayed to a manageable level are unsupported.
l 3
AMS decommissioning cost is based on a disposal cost of $181 per cubic. I l recommends using a more realistic cost of approximately $300 per cubic foot (based on July 1, 1995, reopening at Barnwell) base charge plus surcharges i associated with curie content, weight, cask,. etc. This will result ina j significant increase in decommissioning cost.
i As previously discussed, recent water problems at the site has resulted in three i additional problems that may significantly impact the cost of decommissioning the l London Road site. The two problems are: 1) the concrete slab may have to be removed from the Hot Cell as a result of the water causing additional contamination of the concrete; and 2) the contaminated water may have caused i extensive soil contamination. Based on past experience, the impact of having to
- . remove and dispose of the contaminated concrete, and to remove and dispose of significant quantities of contaminated soil, the cost estimate for the AMS,
- London Road site, may be several times greater than the initial estimate.
! While AMS' response of May 30,.-1995, stated that no structural ' damage was i observed, and that recent core borings indicated no "significant" outside
- contamination exists, AMS has not performed an adequate site characterization to L support their conclusions. In addition, AMS' statement regarding "significant" l, outside contamination is a clear indicator that outside contamination exists.
- With regards to AMS' assumption that the soil under the Waste Hold-up Tank Room is not contaminated, the three core samples taken under the slab may not be
! sufficient characterization to support this assumption. Based on the current
! conditions at the AMS, London Road site, the estimated cost of $1,795,612 may be j off by several times the actual cost to decommission the site. As we discussei
. above, significant changes in the quantities will have a significant impact on j the total decommissioning cost.
' Attachment i
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2 In order to have a reasonable level of confidence in the cost estimate, we recommend that NRC require MS revise the cost estimate to reflect the recent cost for disposal at Barnwell, provide sufficient funds to address the uncertainties in their assumptions, or have Region III (because Region III is familiar with the MS' site) review the adequacy of the three existing cores and the condition of the building to determine if more characterization is required to assess the extent of the concrete and soil contamination identified above.
If Region III determines that MS needs to perform an additional detailed 1 characterization, we recommend that MS be required to implement a rigorous !
schedule for characterizing the site, and that the site characterization plan be reviewed by NRC to assure that the characterization addressed all outstanding issues.
Please contact Larry Pittiglio, if you need additional help.
l l
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_ _ _ _ _ _ _ _ . _ . ~ . _ _ _ _
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AUS 171995 i
i i
Advanced Medical Systems
- ATTN:' David Cesar Treasurer 121 North Eagle Street
- . Geneva, OH '44041 l
Dear Mr. Cesar:
4
.We have completed our review of your May 30, 1995 response to our March 30, 1995 deficiency letter regarding your cost estinate to decommission the London i
" Road facility. We still feel that your cost estimate of $1,795,612 does not realistically reflect the cost that will be required to decommission the facility. You have not demonstrated that the soil under the building is free j of contamination, and your proposed disposal cost of $181 -per cubic foot appears to be an under estimate based on the recent opening of Barnwell in 4
? .
t As previously discussed in our March 30, 1995 letter, recent water problems -
at the site has resulted in two additional problems that may significantly impact the cost of decommissioning the London Road site. The two problems j are: (1) the concrete slab may have to be removed from the WHUT room as a result of the water causing additional contamination of the concrete; i' and (2) the contaminated water may have caused extensive soil contamination -
under the basement slab. The impact of having to remove and dispose of.the contaminated concrete, and to remove and dispose of significant. quantities of j
contaminated soil may be several times greater than the initial estimate,
, Furthermore, the flooding problems in the basement occurred after SEG's site j characterization and cost estimate report of January 1995.- Therefors,.we !
believe that the three core samples through the basement floor prior to the
- flood may not possibly be representative of current soil conditions.under the
- . basement slab and WHUT room.
i
- In your response to our question concerning the possibility of structural *
! damage to the building due to recent water problems at the facility, you stated in ites (3) on page 2 of your letter that no structural damage was
- i. observed, and that recent core borings "outside" the facility indicated no i
' "significant" outside contamination exists. AMS has not performed an adequate '
site characterization to support these conclusions. In addition, your F statement regarding "significant" outside contamination is a clear indicator j; that "outside" contamination, in fact, does exist. !
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4 Advanced Medical Systems i Your decommissic..ing cost is also based on a disposal cost of $181 per cubic foot. A more realistic cost of approximately $300 per cubic foot (based on July 1,1995, reopening at Barnwell) base charge plus surcharges associated with curie content, weight, cask, etc., would be appropriate. .This will result in a significant increase in decommissioning cost. Please adjust your cost estimate, accordingly.
Due to the recent flooding problems and the contamination that was discovered under the isotope shop slab airlock and in the under drain system, please submit a revised characterization of the facility that includes a scientific assessment of the radiological conditions of the soil under the basement slab and WHUT room. We would expect that a re-characterization of the site and incorporation of current disposal cost at Barnwell into your decommission financial plan will dramatically increase your cost estimate to decommission the facility.
Given these recent events / discoveries at the 1020 London Road site, we feel that the January 1995 cost estimate and site characterization are no longer valid. Enclosed is a copy of the Draft Branch Technical Position on Site Characterization for Decommissioning that you should use to re-characterize the facility. -
We will continue our review of your application upon receipt of this information. Please reply in duplicate, within 30 days, and refer to Control Number 98507.
If you have any questions, please feel free to contact me at (708) 829-9834.
Sincerely, Original Signed By John R. Madera, Chief ._
Nuclear Materials Licensing Section License No.: 34-19089-01 Docket No.: 030-16055
Enclosure:
Draft Branch Technical Position On Site Characterization for Decommissioning DOCUMENT NAME: M:\03016055.DF5 To ,essive e copy of ilds desismaat issfasets in the bec "C" = Copy without endosures T = Copy with enclosures T = No copy 0FFICE DRSS/RIII l S. DRSS/RIII W DRSS/RIII l C. DRSS/RH4 l C. ,
1 NAME KGNULL: jaw )( A/. .CLPITT0GLIO C' MWEBER W JRMAQBUQ b DATE 08///,/95 8' P 08////95 (9)jp8/lb/95 08//(/95) 0FFIC)AL RECORD COPY
L Advanced MedicalSystems,Inc.
1020 London Rd.
Cleveland, Ohio 44110 216-692-3270 September 1,1995 Mr. John R. Madera, Chief Nuclear Materials Licensing Section II. S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Re: Decommissioning Funding Plan for Advanced Medical Systems. Inc. (License No. 34-19089-01, Control Number 98507s
Dear Mr. Madera:
Advanced Medical Systems, Inc. (AMS)is in receipt of your August 17,1995 lener wherein you indicated that i the January 1995 decommissioning cost estimate and site characterization for the 1.ondon Road facility are no !
longer valid. In response to that letter, and as follow-up to a discussion between representatives of AMS, Mr.
Mich-- 'eber, Ms. Cynthia Pederson and Dr. Donald Coo: on August 29.1995, AMS intends to prepare a k onceptual Jecommissioning Plan for the facility ,
)
i This plan will contain the decommissioning objective and its basis, a oescription of the items to be decommissioned. the proposed decommissioning methodology. an ALARA analysis to support the proposed methodology, a cost estimate (1995 costs) for implementing the tehodole.cy, and a review schedule for ensurmg the Plan's continued applicability for the duration of License No. 54 19059-01. The Plan will be submitted to the USNRC by October 23,1995, and will reference Contro! Number 98507. Once approved, the plan will be funded by the cotponition and reviewed for continued applicability at the agreed-upon schedule. l I
1000 have any questions or ifI can provide you with additional information. please call me at (216) 692-3270, Sh.ces cly , ,, -
WW Robert Meschter, R.S.O.
cc: D. Cesar D. A, Miller, Esq. - Stavole & Miller C. D. Berger. C.H.P. - IEM
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1 March 30,1995
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Advanced Medical Systems
[ (&0 ATTN: David.Cesar.
Treasurer 121 North Eagle Street Geneva,'OH -44041
Dear Mr. Cesar:
Y~f0Y 0/
We have completed our review ~of your cost estimate for decommissioning the London Road site and are concerned that your estimate of 1,795,612 dollars
.may not reflect the actual cost to decommission 'the facility. Overall, our concerns can be summarized as follows: ~(1)'the cost estimate is based on the-assumption that.the soil under the building is not contaminated, (2) the cost for-disposal of solid radioactive waste is based on a cost of $181 per cubic foot, '(3) the decommissioning plan does not anticipate demolition of the 1 building, and.(4) the decommissioning plan contemplated that the W.H.U.T. Room will not require remote decontamination techniques.
Based on recent wat'er problems at the facility, three additional issues may significantly impact the cost of. decommissioning the London Road site. The three issues are: (1).the water may have structurally damaged some parts of i the building which would need to be. considered in the decommissioning plan,-
(2) the basement floor slab including the W.H.U.T Room floor, may have to be removed due to further intrusion of contamination into the concrete, and (3) ;
the contaminated water may have migrated causing soil contamination. Based on i past experience, the impact of having to remove and dispose of contaminated concrete and soil. may cause the cost estimate for the London Road site to be
. greater than the-initial estimate. ,
^
Section 4.1 of your submittal entitled " Cost' Modifying Factors", states that the cost of radwaste processing, shipping, and disposal account for about ,
l
- ' 20 percent of the- total decommissioning cost. This is based on a disposal cost.of $181 per cubic foot. . Based on current data ~from other regional i compacts, a more realistic disposal cost would be 5400 to $450 per cubic- i foot, resulting in an increase of 20 to 25 percent over your current estimate. !
Due to the fact that the Midwest Compact disposal site has not been selected i
in Ohio, the $400 to $450 cost range per cubic foot may be a reasonable j estimate. '
In order for the NRC to have a reasonable level of confidence in your cost
- estimate, please submit a detailed structural evaluation of the existing building, and perform a more detailed characterization of the extent of any concrete and soil contamination.. Also, include in your estimate any special ,
remote decontamination techniques that.will be utilized to clean the W.H.U.T. '
room. Finally, please re-evaluate your' estimate for the cost of disposal of radioactive waste.
O'& ffSf
1
. . j Advanced Medical Systems i Please submit your response within 30 days of the date of this letter. If you have ar:y questions or require clarification on any of the information stated above, please do not hesitate to contact Kevin Null of my staff at (708) 829-9854.
Sincerely, 1
Original Signed By John A. Grobe Nuclear Materials Inspection Section 2 ,
i License No.: 34-19089-01 Docket No.: 030-16055 i
DOCUMENT NAME: M:\03016055.oth
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/ Advanced Medical Systems,Inc.
1020 London Rd.
Cleveland, Ohio 44110 216-692-3270 o j) tOD3 October 20,1995 Mr. James Caldwell Nuclear Materials inspection, Section 2 United States Nuclear Regulatory Commission 801 Warrenville Rd.
Lisle,IL 60523-4351 1 Re: Conceptual Decommissioning Plan - USNRC License No. 34-19089-01
Dear Mr. Caldwell:
1 As committed to in the " Strategic Plan for the London Road Facility", which was i forwarded to you on October 16,1995, and pursuant to my September 1,1995 letter to i
Mr. John Madera, enclosed is the " Conceptual Decommissioning Plan for the London Road Facility". Tliis plan contains the decommissioning objective and its basis, a description of the items to be decommissioned, a description of the proposed decommissioning methodology, an ALARA analysis to support the proposed methodology, a cost estimate (1995 costs) for implementing the methodology, and a review schedule for ensuring the Plan's continued applicability for the duration of License No. 34-19089-01.
This plan is being submitted under Control Num r 9850 nce approved, the plan will I be funded by the corporation to the level shown the m. In the meantime,if you have any questions or ifI can provide you with additional information, please call me at (216) 692-3270.
I a Robert Meschter, R.S.O.
cc: D. Cesar D.A. Miller, Esq. - Stavloe & Miller C.D. Berger, C.H.P. - IEM
)p RECEIVED m
DCT 2 31995
/
Oi. REGION IH '
4 I
! CONCEPTUAL DECOMMISSIONING i PLAN FOR THE LONDON ROAD FACIOTY l
1
- Submitted to:
l l Advanced Medical Systems, Inc.
l 1020 London Road i
Cleveland, Ohio 44110
, (216) 692-3270 i
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- by:
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Integrated Environmental Management, Inc. ;
l 1680 East Gude Drive, Suite 305 j Rockville, Maryland 20850 l
1 (301) 762-0502 j Report No. 94009/G-3114 i
- October 20,1995 l
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& < s ni..at , yve bf.i CONCEPTUAL DECOMMISSIONING PLAN FOR THE LONDON ROAD FACILITY i
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ADVANCED MEDICAL SYSTEMS INC. !
" Conceptual Decornmissioning Plan for the london Road Facility" l October 20.1995 i Revision 0. Page i
- l TABLE OF CONTENTS '
1 INTRODUCTION ..........................................'....1 Backg rou nd . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Purpose / Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
)
i ITEMS TO BE DECOMMISSIONED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 !
Ho t Cell . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Isotope Shop . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Sou rce Ga rden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Decontamination Room . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... 4 High Ixvel Waste Storage Room . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Clean Equipment Room . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 HEPA Equipment Room . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Back Basement ............................................5 WH UT R oom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Front Basement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Miscellaneous Restricted Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Miscellaneous Unrestricted Areas ................................7 Areas Outside of the Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Depleted Uranium Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 DECOMMISSIONING OBJECTIVE . . . . . . . . . . . . . .................... 10 CONCEI"I'UAL DECOMMISSIONING PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Decommissioning Alternatives .................................12 Short-term Risks ..........................................14 Long-Term Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Waste Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Decommissioning Cost Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Cost / Benefit Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Description of the Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Duration of Safe Storage Period ................................19 Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Final Release Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 REVIEW SC HEDULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 TAB L ES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 TABLE 1 - RADIOACTIVE MATERIALS INVENTORY . . . . . . . . . . . . . . . 23 TABLE 2 - AREAS TO BE DECOMMISSIONED . . . . . . . . . . . . . . . . . . . . 24 TABLE 3 - MANPOWER AND COST ESTIMATES . . . . . . . . . . . . . . . . . . 25
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ADVANCED MEDICAL SYSTEMS. INC.
" Conceptual Decommissioning Plan for the tendon Road Facility" October 20.1995 Revision 0. Page ii TABLE 4 - COLLECTIVE DOSE ESTIMATE FOR DECON AND SAFSTOR . 27 TABLE 5 - COST-BENEFIT ANALYSIS . . . . . . . . . . . ......... . . . 29 I
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l j ADVANCED MEDICAL SYSTEMS. INC.
- Conceptual Decommissioning Plan for the London Road Facitay" October 20.1995 Revision 0. Page 1 l
l
{, INTRODUCTION E
a ' Background . ~
. Advanced Medical Systems, Inc. (AMS) manufactured and fabricated sealed sources of"Co for i -.
teletherapy and radiography machines at its facility at 1020 London Road, Cleveland, Ohio.
l l .
Under the provisions of U. S. Nuclear Regulatory Commission (USNRC) license No. 34-19089-
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01, AMS currently possesses 60,974 curies of"Co, and 2,200 kilograms of depleted uranium 1
'(nickel plated) for use as shielding material. The types and quantities of all licensed materials in
[ . the AMS inventory are shown in Table 1. y
- y. 3 7
' e Purpose / Scope u Recently, AMS submitted an application t f
license No. 34-19089-01. As part of the j u. renewalpqcess, and pursuant to 10 C 40.36,. decommissioning funding plan is required.
- .u , This reppoYsupplements the renewal application, describes the AMS plan to decommission
- u the London Road facility 'after licensed activities are termmated. The extent of - the j u l' decommissioning efforts' described herein are intended to ensure that short- and long-term j u radiation exposures to workers and members of the general population after license termination -
- a are as low as reasonably achievable, and that the volume of radioactive waste to be disposed of
- n is minimi=t. Included in this report is a description of the decommissioning objective for the
! u AMS facility, the conceptual plan for decommissioning the site, an ALARA analysis to r a demonstrate that the preferred decomrcissioning methodology is consistent with the requirements i . so of 10 CFR 20.1101, and (conservative estimate of theDfor achieving the decommissioning
{ n
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objective. The decommissioning funding plan for AMS, submi
, m
. r separate cover)s based l
- upon the findings of th.is report.
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ADVANCED MEDICAL SYSTEMS. INC,
- Conceptual Decommissiomng Plan for the London Road Facility"
- October 20.1995
- Revision 0, Page 2 i.
, ITEMS TO BE DECOMMISSIONED The AMS operation, which occupies approximately 25% of an 80,000 square foot warehouse and a manufacturing building at the landon Road address, is contained on three floors. The main floor ,
. includes an office area, the Isotope Shop area, a hot cell, a source storage area and irradiation e facility, a' shielded work room, and miscellaneous unoccupied areas. The second floor contains
-e additional unoccupied office space, a mechanical equipment room, and the ventilation system equipment room. The basement contains a waste storage areas, additional unoccupied space, and
- a liquid waste holdup tank room (WHUT Room). The majority of the 6.3-acre property is '
._ covered _with asphalt or concrete.
so - The AMS facility was built specifically for the manufacture and distribution of sealed sources.
-- n Licensed radioactive materials are located in specific areas within the AMS building. The -
in following is a description of the various areas of the building, along with conservative estimates is of the quantity of radioactive material that exists in each area as of the date of this report. This is information is also summarized in Table 2.
,e Hot Cell
... The Hot Cell was designed and equipped to encapsulate sources of radioactive material used for o medical therapy and industrial radiography. The cell is six (6) feet square and has 5.5-foot thick is concrete walls and a four-foot thick floor and ceiling. There is a stainless steel floor pan in the o cell, and 0.25-inch thick by 11 foot tall steel wall plates. The cell has a six foot wide,42-ton a hinged door at the rear. There is a 60-inch thick viewing window at the cell front.
4 si Remote handlirg is accomplished with a pair of manipulators and a two-ton overhead crane.
- Every item of equipment in the cell and every item in the cell structure is removable. The
-n location of the Hot Cell on the first floor of the AMS building.
-m i u The Hot Cell is a " Restricted Area". It currently contains approximatel 4,000 curies ofb a less thark(1) curie of residual suride contamTniiBon use of the structural tiltegri[of a the bot cell, this radioactivity is not readily dispersible in the event of a fire, flood or building n damage.' The average ambient exposure rates within the cell are wroximately 12 R per hour, a with rates up to 200 R per hour on contact with certain surfaces.
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Denega, J. W., Neff & Associates, letter to D. A. Miller, Stavole & Miller regarding " Structural Analysis of !
WHUT Room and Hot Cell", July 25,1995. I w - -. . . - , - - . - --
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ADVANCED MEDICAL SYSTEMS. INC.
- Conceptual Decommissioning Plan for the London Road Facility" October 20.1995 Revision 0. Page 3 4
, Isotope Shop l 2 The Isotope Shop is located on the first floor next to the Hot Cell. This area has a concrete floor, a ceiling, and interior walls. The exterior walls are of painted brick. Cobalt-60 sources are 4 4 transported around this area in shielded containers.2 The Isotope Shop also contains a table-e mounted hood, a table, a sink, an old trash compactor, and three-ton overhead hoist with trolley, l e and a Tow Motor.3 Within the Isotope Shop is the Source Garden. I i !
7 The Isotope Shop is a " Restricted Area". However, viith the exception' of the Source Garden, it l do4e not contain a significant inventory oflicensed material. The radiation exposure rates in this l 2
area currently average between five (5) and 10 mR per hour, with a maximum of 80 mR per hour I io on the outside of the Decontamination Room doors.
ii The cgntamination levels in the Isotope Shop currently average about 50,000 disintegrations per 2
is minute'(dpm) per 100 cm . If it is conservatively assumed that the flat surfaces in the Isotope n Shop are uniformly contaminated at this level, and that the area consists of 85 af,'tli~ere is a%
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C of 1.91x104 curies of residual contamination currently in this Tream n Source Garden a The Source Garden is located in the southwest corner of the building within the Isotope Shop area.
n This storage location houses 54 vertical tubes in a six-foot square well that extends from the first a floor to the basement. An Ieshaped shield around the well at the basement level is provided by a two sand-filled compartments which are accessible through manholes in the first floor. The high-no density concrete walls containing the sand shield are two-feet thick.
4 si The 54 storage tubes in the Source Garden are arranged in a nine-by-seven rectangular array.
n The nine center spaces of the array are open and fitted with an irradiation plug which n accommodates objects up to 8.5 inches square by 12 inches high. The source tubes terminate in n a metal container through which cooling air is drawn from the room to the high-efficiency
. n particulate air- (HEPA-) filtered exhaust system.
u .The Source Garden is in a "Restric ea". Ithently contains approximately 30,000 curies'>
n of "Co in a non-dispersible (sealed form. Exposure rates over the Source Garden are a approximately 200 mR per hour.
1 2
One such container is the " transfer monster", which is used to move sources in and out of the Hot Cell.
5 The Tow Motor is an electric fork lift.
i ADVANCED MEDICAL SYSTEMS. INC. I
" Conceptual Deconunissioning Plan for the London Road Facility" j october 20,1995 '
Revision 0, Page 4 i The contamination levels in the Source Garden currently average about 50,000 disintegrations per
, minute (dpm) per 100 cm2 . If t is conservatively assumed that the flat surfaces in the Source Garden are uniformly contaminated at this level, and that the area consists of 38 m2 , there is a o
Q1 of 8.54x10-5 curies of residual contamination currently in this areaj - .
s Decontamination Room
. The Decontamination Room is located behind the Hot Cell and at the side of the Isotope Shop.
7 This area has a concrete floor and walls. The room provides space enough for opening the Hot
.. Cell door into the ventilation controlled space of the Decontamination Room.
. The room is equipped with water outlets and a floor drain which was used during previous
- e. ~ decontamination operations. This drain has since been sealed. In this area is a vault that contains u ancillary Hot Cell items and lead blankets, along with beam shields made of lead.
u The Decontammation Room is a " Restricted Area" that contains approximatho (2) mi 3 ,
~~
u of aitivity7The t average ambient exposure rates are approximately 80 to 100 mR per hour.
)
u The contamination levels in this 12 ft. by 12 ft. room are approximately 3,000,000 dpm per 100 a cm2 . If it is conservatively assumed that the flat surfaces in the Decontamination Room are 2
a uniformly contaminated at this level, and that the area consists of 18 m ,(@re is a tom ,
n (2.43x10-2 curies of residual contamination currently in this arel.;
n High Level Waste Storage Room -
W}?
w The High Level Waste Storage Room is located next the Hot on the first floor. This room ao has a concrete floor, walls and ceiling. There drums oQred here, along with spent n HEPA filters. The area in the front of the shield Watt positioned in the room serves as storage, n The Hi 12 vel Waste Storage Room is a " Restricted Area" that contains approximatelh a f getivityJIt currently has average ambient exposure rates of about 300 to 400 mR per hour.
u Contamination levels are insignificant (e.g., below the site release criteria).
n Clean Equipment Room a The Clean Equipment Room is located on the second floor. This room has a concrete floor, walls n and ceiling. It contains all of the facility service equipment with the exception of the HEPA a ventilation equipment.
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ADVANCED MEDICAL SYSTEMS, INC.
- Conceptual Deconumssioning Plan for the london Road Facility" October 20.1999 Revision 0. Pagc 5 i
The Clean Equipment Room is a " Restricted Area", however(it does not contain any dispers'ible ,
a hivity') It currently has average ambient exposure rates of less than one (1) mR per hour, with 3 a maximum, exposure rate of 30 mR per hour on the wall that adjoins the HEPA Equipment c Room. Chtamination levels are insigrifEiiitt. , .
s HEPA Equipment Room j e The HEPA Equipment Room is located on the second floor of the facility. This room has a 7 concrete floor, walls and ceiling. It contains the facility HEPA ventilation equipment. There is
= one large HEPA exhaust blower that holds four two-foot by two-foot HEPA filters in a housing.
. This system services all of the isotope areas except the Hot Cell. There is also a small HEPA io exhaust blower with only one HEPA filter in its housing. This system services the Hot Cell.
u The HEPA Equipment Room is a " Restricted Area"ctha ently contains approximatelhoD3 in du~ ries of activDIt has average ambient exposure rates of about 80 mR per hour, widi~a~
u maximum of 2,000 mR per hour on the exhaust duct from the Hot Cell.
2 io Contammation levels in the area average 11,000 dpm per 100 cm . Ifit is conservatively assumed a that the flat surfaces in the HEPA Equipment Rmm areunifogmnenminated at this level, and a that the area consists of 20 m2 a total of 9.91x16 curies of residual contaminaD,
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n (66~rrently in this area. ,
] - - -
W u Back Basement h ' )vh' '
u The Back Base is located in the basement. This room has a concrete floor and walls. There no is (drum yg one wall, with temporary shielding erected between the storage area n and the mam part f the room. There are approximately 500 high-density concrete blocks in the room that are posi loned to provide shielding from the WHUT Room, 22 p y?
n The Back Basemerkt is a " Restricted Area 6t contains approximately 15 Ci of activiDIt a currently has ave h nbient exposure rates of about 10 mR per hour, with a maximum of 50 a mR per hour. rumjs ted behind the storage shield have contact exposure rates that range a from 100 to 1,000 R per hour.
2 n Contamination levels in this area average 10,000 dpm per 100 cm . If it is conservatively a
assumed that the flat surfaces in the Back Basement are uniformjy-contaminated-at this leye 2
as that the area consists of 82 m (there is a total of 3.69x16 citries of residual contaminatiop so (c6rrently in tiils'atra%
s
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ADVANCED MEDICAL SYSTEMS. INC.
"Concepmal Decommissioning Plan for the london Road Facility
- October 20.1995 Revision O. Page 6
, WHUT Room l
3 The Waste Hold-Up Tank (WHUT) Room is located in the basement directly under the Hot Cell.
3 This room has a concrete floor, walls and ceiling. The room walls are three feet thick to provide o shielding from the room's contents. .
l I . The room contains a 100-gallon and a 500-gallon tank for liquid wastes. When the room was still e
in use, wastes were " held up" in the tanks until sampling / analysis confirmed that they could be I 1 discharged to the sewer system. However, in 1989 AMS ceased discharging liquid radioactive i
. waste to the sewer system. Shortly thereafter, the WHUT Room was sealed.
l
.- The WHUT Room is a " Restricted Area (that contains approximately 53 curies of actiDty,>The w exposure rates in the room currently range from 50 to 240 R per hour. l n Front Basement n The Front Basement is located on the east side of the basement next to the WHUT Room. It a consists of three rooms: the passageway between the front and back basement, the Chart Room, u- and the Blue Tank Room. The rooms have concrete floors, ceiling, and exterior walls. The !
a interior walls are wood-framed with painted drywall surfaces. There are 45 high<iensity concrete
~
w blocks in the Blue Tank Room that are positioned to provide additional shielding from the WHUT I
- n. room.
u The Front Basement is a " Restricted Area", however it does not contain significant residual u activity. It currently L average ambient exposure rates of about one (1) mR per hour, with a ao maximum exposure rate of 20 mR per hour in the Blue Tank Room.
at 2 Contamination levels average about 1,250 dpm per 100 cm . If it is conservatively assumed that u the flat surfaces in the Front Basement are uniformly contaminated at this level, and that the area u of 63 m2 there is a total of 3.55x104 curies of residual contamination currently in thTi 20 area. f n MisceWaneous Restncted Areas a There are a number of miscellaneous areas within the AMS facility. These include the air lock, n the Isotope Shop warehouse, portions of a caged storage area, and office areas on the second i a floor. These areas have been designated as " Restricted Areas". The average ambient exposure a rates in these areas currently rauge from " background" to one (1) mR per hour (isotope so warehouse and caged storage area).
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ADVANCED MEDICAL SYSTEMS. INC.
" Conceptual Decommissioning Plan for the London Road Facility
- October 20.1995 Revision 0. Page 7 l
3
- Average contamination levels range from zero to 5,000 dpm per 100 cm 2in the contaminated side )
- of the air lock. Ifit is conservatively assumed that the flat surfaces in the miscellaneous restricted areas are uniformly. contaminated _atJhisjevel, and that the_ area consists of 1,184 m2, there is a :
- o [ total of 2.67x104 curies of residual contamination currently in -
l l w .- <
I a Miscellaneous Unrestricted Areas i i
There are a number of other miscellaneous areas within the AMS facility that are not restricted l 7L for purposes of radiological control. These are a former chemistry laboratory, the Hot Cell l .
control office, the first floor office areas, portions of a caged storage area, and the counting room. I L. The exposure rates and contamination levels in these areas are not distinguishable from to background.
in Areas Outside of the Building is AMS and its predecessor disposed of"Co into the sanitary sewer system under the provisions of is Title 10, Code of Federal Regulations, Part 20.303. All discharges were accounted for and below sa permissible limits, is As part of a 1989 decommissioning effort, the lateral connection from the AMS facility to the i.
sewer system interceptor owned by the Northeast Ohio Regional Sewer District (NEORSD) was n partially decontaminated and covered with a layer of concrete in order to stabilize residual i.
materials. In May of 1989, AMS ceased generating any liquid radioactive waste, and discontinued is the disposal of licensed material into the sanitary sewerage system. !
i no Between Au' gust 17 and October 14, 1994, the USNRC performed a special inspection of the si London Road interceptor and the lateral connection from the AMS building to the interceptor.d n During this inspection, samples of sewer debris, water effluent, and a series of wipes were n collected and analyzed. The findings of the inspection were that residual radioactive materials in u excess of the criteria contained in USNRC Regulatory Guide 1.86, " Guidelines for n Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination a of Licenses for Byproduct, Source, or Special Nuclear Material" were present in the interceptor I n in the immediate vicinity (outfall) of the AMS lateral connection.5 However, there was no i
( * 'The connection is comprised of a sewer line, a manhole, and a lateral.
s Removable activity in excess of 1,000 dpm per 100 cnf was found on the sewer interceptor brick directly below the AMS lateral. Other lamman (e.g., the iron ladder below the lateral, the outer surfaces of the lateral, and at the 2:00 position of the lateral approximately one foot into the lateral from the interceptor) demonstrated measurable ;
activity, but at levels well below the release criterion.
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ADVANCED MEDICAL SYSTEMS, INC.
"Conceatual Decommissioning Plan for the lendon Road Facihty" October 20.1995 Revision 0, Page 8 i evidence of removable *Co activity above the release criteria in the outlet from the AMS
- processing drain, the sewer walls, or inside the lateral itself.'
s Later in 1994, NEORSD intentionally isolated AMS from the sewage treatment system. This a action rendered the facility storm- and ground-water drainage system non-functional, increased s the hydrostatic pressure on the foundation structure, and caused groundwater to leak into the e basement of the AMS facility. AMS instituted remedial actions for " isolation and remediation of 7 the radioactively contaminated manhole and sewer line exiting the facility to the London Road
. Interceptor", and recovery of the facility drainage system.
During the remedial activities, it was discovered that the foundation drainage system (e.g., drain io tile and gravel layer) was contaminated with "Co. Removable activity as high as 100,000 2
is dpm/100 cm was noted in the drain tile during excavation and investigation efforts. However, is { the2 hale layer upon which the building is built and which forms the base of the footer drains, did is ) not contain detectable _*Co. In fact, no "Co was identified other than between the drain tile and
- i. the shale. This finding confirms that contaminant migration did not occur.
f: k .. , & y ej
- L , v g, Q2 pm (y ...f J. ,(;w,& s.] b(sj is The footer drains along the east (front) and south sides of the building were replaced and the area is back-filled with clean gravel and soil. However, the footer drains in the vicinity of the Source o Garden could not be replaced because of the presence of high ambient gamma exposure rates in se the work area.7 Also, prior to abandoning the lateral connection that runs from the west side of is the AMS facility to the London Road interceptor, the four-inch discharge line from the AMS o building, the AMS manhole and the 15-inch lateral connection were filled with grout. In advance si of this action, the ambient exposure rates within the lateral were measured and found to be n approximately one (1) milliR per hour. The exposure rate in the manhole prior to grouting ranged n from 0.2 to 0.5 milliR per hour, with a maximum measured exposure rate of four (4) milliR per u hour at the base. The contamination status of the lateral was determined using dry disk smears n and a pancake GM detector. The results from this effort were negative for removable activity.
' A site characterization study performed by ORISE in 1989 confirms the lack of significant residual activity in the AMS system. During this study, ambient gamma exposure rates in excess of background were not identified in the vicinity of the lateral. Furthermore, soil samples collected in this area were negative for the presence of
- Co.
' A concrete wall constructed between the abandoned drains and the new foundaion drains, and the presence of an impermeable liner on the ground surface above the dramage systems serve to fully isolate the residual contamination in the abandoned drains from the new drainage system.
. . . _ . . _ __ . ~ . . .- ~. _ . .- . . . . _ . _-. ._ _. _ - . _ . . ._._. m__ .
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ADVANCED MEDICAL SYSTEMS. INC.
! " Conceptual Decommissioning Plan for the I.endon Road Facility" j Oc ober 20.1995 Revision 0, Page 9
) i If it is assumed thad0 linear feet of foundation drains remain outside the Source Garden
] : this length.is utliformly_ contaminated to levels of 100,000 dpm per 100 cm2, approximately
- a [8,76x10d curies remain i 4
.w . - _ . . . _
f -
i- o- If it is also assumed that the contamination inside the abandoned lateral and the manhole is evenly 4
j e distributed, the Microshield code can be used to generate " dose rate-to-activity" conversion factors.: Applying these factor to the measured exposure rate of one (1) millirem per hnnr in the 1
lateral and 0.5 milliR per hour in the manhole, translates into ap la 92x104 ,
]
. h02x104 curies, respectively, of residual radioactivity at this locations. ,
- e ' Depleted Uranium inventory 1
io AMS currently possesses approximately 2200 kilograms of depleted uranium for use'as shielding is materials and in the form of parts for teletherapy machines. The form of this material is stable u and easily sold / transferred to other licensees. Therefore, this material is not addressed further
{ n in this report.
1, i
i J
f i
i-1 I
e d
d i
1 8 Grove Engineering, Inc. Microshield 4.10, dated October,1993.
' As of the date of this report, AMS is in the process of determining whether residual radioactive materials are present beneath the basement slab of the London Road building. When there is evidence to support the presence of I sub-basement activity, this report will be modified accordingly.
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- l. ADVANCED MEDICAL SYSTEMS, INC.
.' ' Conceptual Decommissioning Plan for the London Road Facihty"
- october 20,1995 Revision 0, Page 10 i
c , DECOMMISSIONING OBJECTIVE ,
i i
i 2 A critical step in the decommissioning process is determining the objective of the action. The fa j .
objective typically refers to the maximum acceptable dose limit that will be incurred by members of the general public after all action is complete and the USNRC license is terminated.
i j i There are a number of dose limits promulgated by standards groups and regulatory agencies that l .
are considered to present negligible risk, any one of which would constitute an acceptable j v objective for decommissioning of the London Road facility. The following are a few examples:
9 i .
The National Council on Radiation Protection and Measurements recommends a j . dose limit of 100 millirem per year from manmade sources for individual members
- io of the public.20 - This limit is based on scientific recommendations developed i u through an impartial consensus process.
a u .
The USNRC, in a 1991 Final Rule, adopted the recommendations of the NCRP as u its basic dose limit applicable to any licensed facility."
i u '. The U. S. Environunental Protection Agency (USEPA) imposes a limit of 25 I
a millirem per year to any member of the public from nuclear fuel cycle facilities. 2 I: a .
In 1994, the USNRC issued proposed radiological criteria for decommissioning."
! u- The goal of these criteria, which are based upon a dose objective of 15 millirem j u per year, is to ensure that residual radioactivity from decommissioned sites is !
}.u " indistinguishable from background".
no .
In 1990, the USNRC issued a Policy Statement which established the framework
! si within which the USNRC would make licensing decisions to exempt some or all i
i
[ '
- National Council on Radiation Protection and Measurements, " Ionizing Radiation Exposure of the Population of the United States", NCRP Report No. 93, September,1987.
[ " Title 10, Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation", January 1,1994.
] " Title 40, Code of Federal Regulations, Part 190, " Environmental Radiation Protection Standards for Nuclear Power j Operations",1991. ;
i " Title 10, Code of Federal Regia'i=. Part 20, Proposed Rule, " Radiological Criteria for Decommissionmg", FR 4
59, No.161,43220 August 22,1994, i
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.._,--, ~ . - _ - - -- - ~ > - - - ~
ADVANCED MEDICAL SYSTEMS INC.
' Conceptual Decommissioning Plan for the lendon Road Facility" october 20,1995 Revision 0, Page 11 i
regulatory controls over certain practices involving radioactive materials. This -
2 Statement set a "below regulatory concern" dose criterion of 10 millirem per year, a
which was based upon what the USNRC considered to be an acceptable o hypothetical lifetime risk of cancer of 3.5 x 10d per rem ofionizing radiation dose. ,
s ' However, this policy statement was subsequently withdrawn. j 1
e' .* In addition to meeting the proposed decommissioning' dose objective of 15 1
millirem, the USNRC's proposed decommissioning rule would also require the licensee to demonstrate that the dose from residual radioactivity at the e decommissioned facility is ALARA." However, to minimize the burden of
-a documentation and analysis, the proposed rule would allow the licensee to comply si with the ALARA requirement by showing that the TEDE to the average member u of the population does not exceed three (3) millirem per year.
u For this assessment, a dose objective of three millirem is deemed applicable and is used as the a u basis for the following calculations. The reasons for selecting this objective are threefold: It is u- . the lowest of the values listed above and demonstrates a desire to implement conservative a radiological protection practices; it provides a regulatory basis for development of release criteria-
.n and the intent is consistent with federal requirements that licensed radioactive materials be handled l u and released in a manner that ensures that exposures are as low as is reasonably achievable I a (ALARA) taking into account economic and societal factors.
I
" U. S. Nuclear Regulatory Commission, "Below Regulatory Concern Policy Statement",55 FR 27522 (haly 3, 1990).
' " Title 10, Code of Federal Regulations, Pan 20, Proposed Rule, " Radiological Criteria for Decommissioning", FR 59, No.161, 43220, August 22,1994.
'Ihe definnaan of ALARA is taken from Title 10, Code of Federal Regulations, Part 20, " Standards for Protection
' Against Radiation".
ADVANCED MEDICAL SYSTEMS. INC.
" Conceptual Decomnnssiorung Plan for the Imion Road Facihty" October 20.1995 Revision 0, Page 12 CONCEPTUAL DECOMMISSIONING PLAN l
2 Decommissioning Altematives ~
s Once a USNRC-licensed facility rezches the end of its useful operating life, it will be i o decommissioned. This typically means that the facility will be safely removed from service, and i
all radioactive materials in excess oflevels which would permit unrestricted use of the facility will (
. be disposed of. However, the USNRC has determmed that several decommissioning alternatives 7 will potentially satisfy this These ii're "No Action", DECON, SAFSTOR and ENTOMB." The following are brief descriptions of each of these alternatives:
l No Action - This implies that AMS would simply abandon or leave the facility io after ceasing operations.
n .
DECON - This option is to remove all radioactive materials such that residual u levels permit the property to be released for unrestricted use. DECON will lead a to termination of the facility license and facility re-use shortly after cessation of u facility operations. Since DECON is generally completed within a few months or a years following facility shutdown, personnel radiation exposures are generally a higher than for options that spread the decommissioning work over longer time u periods to take advantage of radioactive decay. Similarly, larger commitments of a money and waste disposal site space are also required for DECON.
a -
SAFSTOR - This alternative places and maintains the facility in a condition that 2o ensures the risk to members of the general public is acceptable, that the facility can n be safely maintained in a shutdown condition to allow for radioactive decay, and u that it can be subsequently decontaminated and released for unrestricted use n (deferred decontamination). SAFSTOR consists of a short period of preparation so for safe storage, a variable safe storage period of continuing care consisting of a security, surveillance, and maintenance, and a short period of deferted a decontamination. l n a ENTOMB - This alternative requires the encasement of the facility in concrete to a protect the public from radiation exposure _until its radioactivity has decayed to a levels permitting unrestricted use of the facility.
" Terms and definitions taken from NUREG-0568 (U. S. Nuclear Regulatory Commission, Office of Standards Development, " Draft Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities", NUREG-0568, January,1981).
ADVANCED MEDICAL SYSTEMS. INC.
"Concepual Deconunissioning Plan for the lendon Road Facility" october 20,1995 1 Revision O. Page 13
$ The "no action" alternative is clearly gamacceptable to both AMS, regulatory agencies, and a state / local officials. Given the short half-life of the radioactivity at AMS, ENTOMB is also not f
a considered to be a viable alternativ or-th(AMS facility. Therefore, at AMS, only DECON and c SAFSTOR are considered to be potentially applicable decommissioning alternatives. .
ar~ p
~
l mf s DECO is the more traditional approach to facility decommissioning. Its primary advantages are e it is relatively uncomplicated, eliminates the need for continued monitoring, and releases the 1 facility for other uses within a relatively short time frame.8' Activities under this option would
. include removal of contaminated equipment (hot cell contents, ventilation systems, packaged
. materials, sources), and decontamination of remaining room surfaces to eliminate residual io radioactive materials above the release criteria, and performa a final release survey, n However, DECON would require a large initial commitmen f moneyj m_aximize personnel is radiation exposures, and result in a higher disposal volume as would be required for in SAFSTOR. Table 3 shows the manpower estimate for the DECON alternative.
IN I
in c
%dt & c t /UM 14 ut -b E-)
so SAFSTOR atisfies the requirements for protection of the public while minimizing initial is wmununents of time, labor, money, occupational radiation exposure, and waste disposal.
is Modifications to the facility would be limited to those which ensure the security of the building n against intruders, and ensure containment of tha licensed inventory. As a result of radioactive is - decay of this material, reductions in personnel exposure and simplifications in th exity of s s u operations can be achieved by deferring major decontamination efforts f 50 years. < Also, j zo because much of the residual radioactivity present in the facility will have deca ackground I n- levels after the storage period, the volume of material that must be packaged for disposal, if any, ;
n will be significantly reduced.
n The primary disadvantage of SAFSTOR is that personnel familiar with the facility at the time of a deferred decontamination may not be available. Consequently, more time for training and n orientation would be needed if the procedures for final license tennination are extensive. Other a disadvantages might include the fact that the site could be tied up in a non-useful purpose for an si extended period, regulatory uncertainties in the future, possible interferences by state or local a agencies, and the continuing need for maintenance, security and surveillance. Table 3 shows the a manpower estimate for the SAFSTOR alternative.
Other advantages of DECON include the availability of a work force highly knowledgeable about the facility, and elimination of the need for long-term security, maintenance and surveillance.
g_m- _ _ . _ _ . _ . - ~ _.._.m._. . _ _ _ . _ _ . _ _ _ . _ _ . _ _ . - - m. ._ . . _ .- . _ _ . _ _ __
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{ 'Concepmal Decommissioning Plan for the london Road Facility" october 20.1995
- Revision 0, Page 14 l'
j ,
. Short-term Risks j Both DECON and SAFSTOR were evaluated with respect to their potential for increasing health f and safety risks for members of the general public and workers involved in implementing the alternative. For this assessment, it was assumed that the general public will be protected from a exposures by administrative and procedural controls. Therefore, the shon-term impacts on this e population group are considered to tie negligible. It was also assumed that workers will follow 7 ALARA procedures and all OSHA regulations, and that internal exposures will be prevented.
For the DECON option, the goal will be to maintain radiation exposures to decommissioning workers to below regulatory limits. At AMS, the critical exposure time will be during source io packaging and shipment, the removal / dismantling of the hoods, ventilation system, hot cell, n ' source garden, and high-level waste disposition. For the work durations and exposure rates
$3 shown in Table 4, the total worker dose for the DECON alternative is estimated to be 1037 n person-rem.
3 io_ For the SAFSTOR option, only minimal personnel exposures are anticipated as the facility is i u placed into a safe storage mode. Assuming that these activities are on-going for the person-days a shown in Table 4, the total worker dose from external radiation is estimated to be 0.4 person-rem. i n Long-Term Risks a The primary long-term risk incurred by humans after decommissioning is complete is exposure a to the radioactive materials at the location of final deposition. For the DECON option, the long-a term risks to members of the general public will be negligible. Also, for the "Co that is '
a maintained inside of the building under SAFSTOR, the long-term risks to members of the general n public will also be negligible. A previous assessment of the impact of the residual radioactivity ;
n' that exists in the abandoned lateral and footer drains on members of the general public confirmed so this conclusion. ' Therefore, the relative long-term risks of DECON and SAFSTOR are a equivalent, and will result in individual doses of members of the general population that are well-a below the decommissioning objective, n Waste Disposal a Both of the decommissioning options engil disposal of radioactive materials at an off-site disposal .l n location. For DECON, a total of 3,600 cubic feet and 70 curies will be disposed of as radioactive
" Integrated Environmental Management, Inc., "AL. ARA Analysis for Remediation of the AMS Lateral Connection to the Sewer System', Report No. 94009/G-115, January 10, 1995.
ADVANCED MEDICAL SYsTDas, INC.
'Concepmal Decommissioning Plan for the London Road Facility
- October 20.1995 Revision 0, Page 15 r
i waste. For SAFSTOR, a total of 100 cubic feet a .0.22 cup will be disposed of as radioactive 2 waste. -
a Decommissioning Cost Estimates -
4 The following assumptions were used for developing-the decommissioning cost estimates for the l e
DECON and SAFSTOR_ options as shown in Tabije 3:
_m
. . The'1MS5uilding will not be uring the deconunissioning (i.e., the 7 building stmeture will remam tact). I hM. b pThere is no evidence that the soil oderneath the building is contaminated. Any hs residual radioactivity that maydin this a_rea is clearly not mobile and will so
) kpeg .
.y P remain in place until eventual 4emolition ofAMecause the soil activity j n j will have decayed to negligible leve o removal action is required.
e s s ~ w '$
n .z. y. The inventory of Co-60 sources and depleted uraniumlit' the facility will be shipped ngiP off site to another licensee.
io A W: tMTrditJ U t!rv
- ' To ensure pricing consistency, all radioactive materials sent for disposal will be l
i is 9 assumed to disposed of at the radioactive burial facility located in Barnyw_e_lLSouth
~~
w Carolina, and asbestos waste will be disposed 'of at the facility in Clive, Utah.
n
- The final release surveys will be performed pursuant to the guidance contained in w NUREG/CR-5849,' " Manual for Conducting Radiological Surveys in Support of a License Termination", USNRC Division of Regulatory Applications, Washington no D.C.,1990.
ai . The following unit costs were assumed: I;x:al technician labor at $30/ hour; loc.al n supervisory labor and licensing / regulatory support at a mean rate of at $60 per n hour; B-25 box cost at $500 per box; personnel protective equipment at $20 per a day per person; waste transport at $2.75 per mile; radioactive waste disposal costs a at $340 per cubic foot; and asbestos waste disposal costs at $150 per cubic foot.
- a For the SAFSTOR option, it is assumed that the WHUT Room, the HEPA equipment room, and n the hot cell will be placed in a safe storage condition for 50 years to allow decay of the radioactive a materials present in those rooms. It is also assumed that radioactive waste materials will be stored n on site for the entire 50 year SAFSTOR period, and that four hours per week (labor) are required so for facility maintenance / surveillance during this period. It is also assumed that additional security si systems and facility alarms will be installed to detect intmsion into the facility, water leakage, the u presence of smoke / fire, and other incursions. Finally, since the lateral connection to the sewer,
ADVANCED MEDICAL SYSTEMS INC.
" Conceptual Decommissiorung Plan for the lendon Road Facility" octo'xr 20,1995 Revision 0, Page 16 i
old manhole, and abandoned drain tile are adequately isolated, it is assumed they will remain in a place until the end of the 50 year SAFSTOR period.
3 For the DECON option;'it is assumed that all radioactive wastes generated during the 4 decommissioning and all the waste in the inventory, excluding WHUT Room materials and the s sealed source (willbnt for dihsDIt is also assumed that 3,000 cubic feet of the 9,000
. cubic feet of soil generated during the sewer remediation project is contaminated such that off-site ;
7 disposal is required. All contammated areas of the facility are assumed to be decommissioned in
. the DECON option.
l l
. Table 3 ws the decommissioning cost estimates for DECON and SAFSTOR. These are based
~
a on a variety of cost-estimating data, includin[ curves, generic unit costs, vendor information, u conventional cost estimating guicus, and prior similar estimates as modified by site-specific n information. Both capital and operation and maintenance (O&M) costs were considered, where l o appropriate, along with O&M costs that may continue beyond implementation of the l u decommissioning action. Present-worth analysis was used.20Alsing the above assumptions, and e
a uming a 25% contingency, the estimates are $3,304,474 and $912,860, respectively.
(~
u Cost / Benefit Analysis hues yF 9T)(L u According to the International Commission on Radiological Protection (ICRP), most decisions u about human activities are based on an implicit form of balancing the costs and benefits leading a to the conclusion that the conduct of a chosen practice is " worthwhile".2 Thus the ICRP - as well no as the USNRC - recommends that:
n .
No practice shall be adopted unless its introduction produces a positive net benefit; 22 .
All exposures to ionizing radiation shall be kept as low as reasonably achievable, n economic and societal factors being taken into account; arc.i 34 .
The dose equivalent to individuals shall not exceed applicable regulatory dose a limits.
'" Since AMS will set aside cash to fund decommissioning in an interest-bearing account, the effects of inflation on the present-day costs are negated.
2 International Commission on Radiological Protection, ICRP Publication 55, ' Optimization and Decision-Making in Radiological Protection", Pergamon Press,1989.
4 l
ADVANCED MEDICAL SYSTEMS. INC. I
' Conceptual Deconunissioning Plan for the IAndon Road Facihty" I October 20.1995 Revision 0. Page 17 i
With respect to radiological impacts only, a simple cost-benefit analysis can be performed by a evaluating the following: I X + as = Minimum 4
where X = the cost of achieving the decommissioning objective, S = the collective dose ,
s associated with the decommissioning activities, and a = a constant expressing the cost assigned I to the unit collective dose.22 Table 5, which is a summary of the cost-benefit analysis for the two 1- decommissioning options, clearly demonstrates that the SAFSTOR option provides the' greatest -!
. benefit at the lowest cost when radiological impacts are considered. !
e Description of the Methodology i n- When ready to decommission, the residual radioactivity of interest at AMS will consist primarily ;
o of residual materials generated as a result of source manufacturing, sealed sources, and bulk "Co.
-n In its current state, the hazards to the general population from this licensable inventory-are i u negligible. Furthermore, the short half-life of the materials demands consideration for delayed a
-f decommissioning in order to take advantage of radioactive decay.
l a Consistent with the ALARA concept, SAFSTOR presents the lowest overall radiological risk, a results in the smallest volume of solid waste to be disposed of, and ensures that radiation i n exposures will be maintained as low as reasonably achievable with economic benefits taken into i
u account. Therefo A5STOR1sTpreferred decommissioning metbhor the AMS
~
facility.
a 4 g g g j( 4 -[t.;. [A l pr N % ~A. l no - There are several subcategories of SAFSTOR. These are custodial SAFSTOR,23 passive '
ai SAFSTOR,24 and hardened SAFSTOR.25 The following are brief descriptions of each: !
Custodial SAFSTOR - requires a minimum cleanup and decontamination effort u initially, followed by a period of continuing care with the active protection systems as kept in service throughout the storage period. Full-time onsite surveillance by ;
22 A value of $1,000 per person-rem for a from Title 10, Code of Federal Regulations, Part 50, Appendix I, Section l
II.D is assumed to be valid for this assessment.
28 Nama-lawe taken from Schneider, K. J. And C. E. Jenkins, Technninov. Safety and Costs of Decommiuinnine n Reference Nuclear Fuel Reorocessine Plant. NUREG-0278. October,1977.
2' Nomenclature taken from U. S. Nuclear Regulatory Commission, Regulatory Guide 1.86, " Termination of Operating l icenses for Nuclear Reactors", June,1974.
25 Nomenclature taken from Manion, W. J. And T. S. LaGuardia, "An Engineering Evaluation of Nuclear Power '
Reactor Decommissioning Alternatives", AIF/NESP4)09, Atomic Industrial Forum, November,1976.
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' Conceptual Decommissioning Plan for the London Road Facihty" October 20.1995 j, Revision O. Page 18 i
operating' and security forces is required to carry out radiation monitoring, to
} a maintain the equipment, and to prevent accidental or deliberate intrusion into the facility and the subsequent exposure to radiation or the dispersal of radioactivity.
4 beyond the confines of the facility.
j
- Passive SAFSTOR - requires a more comprehensive cleanup and decontamination l effort initially, sufficient to permit deactivation of the active protective (ventilation) i -
systems during the safe storage period. All stmetures are secured and electronic c . surveillance is provided to detect accidental or deliberate intmsion. Periodic j
m monitoring and maintenance of the integrity of the stmeture is 'also required.
) io a Hardened SAFSTOR (temporary entombment) - requires comprehensive cleanup j si .
and decontamination, and the construction of barriers around areas containing
[
u significant quantities of radioactivity. These barriers should be of sufficient u strength to make accidental intrusion impossible and deliberate intmsion extremely i
so . difficult. Surveillance requirements are limited to detection of attack upon the
.u barriers, maintenance of the integrity of the stmetures, and infrequent monitoring.
a All three categories of safe storage require some positive ac, .a at the conclusion of the period n of continuing care to release the property for unrestricted u;e and termmate the license for a radioactive materials. Depending on the amount of residual radioactivity, these actions may range
- 'u- from completion of the final termination survey only, to dismantlement and removal of residual
! so radioactive materials prior to the termination survey. Maintenance of the facility's structures and I ^
i an ongoing program of environmental surveillance are also necessary for all categories of '
j 23 . SAFSTOR.
L Custodial SAFSTOR was deemed to be inappropriate for the AMS facility because of the need for j u ventilation systems and other support systems to remain operational to support AMS source j u exchange operations. Hardened SAFSTOR was deleted as an alternative because the existing
{m AMS physical layout and security stmeture is sufficient to preclude intmsion into the facility.
' b.
- The methodology of passive SAFSTOR is deemed appropriate because AMS intends to maintain '
a qualified staff on site to handle teletherapy source exchanges. This will require some of the n systems at AMS to remain operational, such as the ventilation system, fire, security, and alarm
[= _ system, and other equipment, to allow for source exchanges to take place. The on-site staff will 1 si conduct radiation monitoring, maintain equipment, prevent intmsion into the facility and deter 1
{ :. release of materials from the facility.
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ADVANCED MEDICAL SYSTEMS. INC.
"Concegwual Decommissionirg Plan for the London Road Facihty*
October 20.1995 Revision O. Page 19 Duration of Safe Storage Period -
The duration of the storage and surveillance period under SAFSTOR can vary from a few years 2
s to approximately 100 years,pepending on the type of facility. For the Iindonlo~a' d facility, a o
safe storage period of 50 years is deemed appropria3t . This period is based on consideration of a such factors as desirability of terminating the license, radiation dose reductions, and cost. It is e
also consistent with the USEPA policy on institutional control reliance for radioactivity
] 7 containment. Since the value of the property is small, even if released for unrestricted use, there j .
is little incentive to decontaminate the facility earlier than would otherwise be dictated by the e decay of radioactivity within the facility.26
,o Procedures ii The AMS facility will be placed in a passive SAFSTOR mode by taking the following actions:
u .
With the exception of the WHUT Room, the basement of the AMS facility will o have a gross decontamination performed.27 This will require the removal and 30 containerization of all unusable contaminated materials and equipment, removal of u the removable surface contamination on floors and walls by strip coating or a wiping, and performance of a contamination survey for the decontaminated areas.
17 Ele basement Will remain a restricted area.
n .
First floor areas (isotope shop, isotope shop warehouse, airlock, decontamination a room) will undergo a gross decontamination. This will tequire the removal and no containerization of all contaminated materials and equipment, removal of si removable surface contamination from wall and floor surfaces, and the n performance of a contamination survey of the decontaminated areas. These areas as will remain restricted areas.
30 .
ContaminatM HEPA filters will be removed, containerized, and replaced with new a filters. A gross decontamination will be performed in the HEPA equipment room
- 2. with strip coat or by wiping and the room will be surveyed upon completion. The u HEPA equipment room will remain a restricted area.
n .
The WHUT Room will be completely isolated from the basement by scaling all u openings with concrete patch. No entry will be made into the WHUT Room during so preparations for SAFSTOR.
U. S. Nuclear Regulatory Commission, " Draft Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities", NUREG-0586, January,1981.
2' The USNRC recommends, in NUREG-0586, that gross decontamination be performed prior to placing a facility into a safe-storage mode. While these actions may result in personnel exposure in the short-term, they will reduce or eliminate the potential for future exposures and/or spread of contamination to other areas.
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1 ADVANCED MEDICAL SYSTEMS, INC.
4
- Conceptual Decommissioning Plan for the London Road Facility
- October 20,1995
, Revision 0, Page 20 4
. i Prior to sealing rooms in the basement, alarming level devices will be installed to
- . indicate water incursion.
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The Hot Cell will be surveyed for contamination and radiation levels, sehled shut,
?- 4_ and placed out of service. The manipulators will be rendered inoperable and i
e placed out of service as well.- All water and electric utilities to the Hot Cell will
-. be removed from service.2 1
- 1 All waste materials will be containerized and stored either in the high level waste j .-
storage room or in other areas for lower activity materials, as appropriate. ;
L ?
1 e- FinalRelease Survey , 7 f'1 W a.
se - A final release survey will be performed upon completion of the safety storage period and prior j.n to any area restoration. In general, the survey methodology will be designed in accordance with i u the recommendations of NUREG/CR-5849.2' The objective of the survey will be to demonstrate 4
u that the radiological conditions at the AMS site meet the decommissioning objective, that surface ,
l 30 radioactivity in the building is less than the site-specific release criteria, and that radiation doses n- to members of the general population will not exceed 15 millirem per year. These conditions will l w be demonstrated at the 95 % confidence level. The survey data will also be used to calculate the n total inventory of residual radioactivity at the London Road facility. '
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'the only lighting for inspection of the area will be through the Hot Cell window.
1
" Berger, J. D., " Manual for Conducting Radiological Surveys in Support of License Termination", Draft Report for Comment, NUREG/CR-5849, ORAU-92/C57,1992.
- 1. i.
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j ADVANCED MEDICAL SYSTEMS, INC.
' Conceptual Decommissioning Plan for the London Road Facility".
October 20,1995 Revision 0. Page 21_
-REVIEW SCHEDULE This conceptual deconunissioning plan will be reviewed at least annually by the AMS Radiation a
' Safety Officer (RSO) to determine if it requires revision due to any changes in the status of the o AMS facility. This review will also include a review of the Deconunissioning Funding Plan if changes have taken place that might impact the cost estimates presented herein. This plan may be reviewed more frequently if significant events take place, such as a reduction in the inventory .
1
- of sources at the facility, decontamination of an area specifically addressed in this plan, or an a-incident involving the spread of contamination to previously uncontaminated areas of the facility e occurs.
io Should events at the AMS facility warrant a revision to this plan or the Decommissioning Funding vi Plan, the RSO will present the proposed changes to the Radiation Safety Committee for their sa : review and approval. Revised plans will be submitted to the USNRC shortly thereafter.
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ADVANCED MEDICAL SYSTEMS, INC.
" Conceptual Decommissioning Plan for the London Road Facility" October 20,1995 Revision 0, Page 22 .
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I TABLES b
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ADVANCED MEDICAL SYSTEMS. INC.
" Conceptual Decommissioning Plan for the lendon Road Facility-October 20,1995 Revision O. Page 23 '
i TABLE 1 - RADIOACTIVE MATERIALS INVENTORY r Item Form Material Description Estimated Activity (Cl)
Licensed Solid Bulk "Co Metal 11747 4 Material s Licensed Solid Scaled "Co Sources 49133 e Material 7 Licensed Solid Depleted Uranium Inventory 2175.52 kg e Material e Packaged waste Solid "Co-contammated materials contained in high- 29 level waste storage, boxes in the Isotope Shop and drums in the basement of the facility.
to Packaged waste Solid "Co in solid waste generated during the water 0.4 treatment project.
n Unpackaged Solid / sludge "Co- contaminated materials contained in WHUT 53 u waste Room
- Surface Solid Estimate of uncharacterized surface "Co activity <11 u contamination in the restricted areas of the facility is TOTALS (excluding uranium) 61033 4 4)'N h3l5i&'i; dig.Q t a A a.f; 4.siMN 3, 1
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ADVANCED MEDICAL SYSTEMS. INC.
" Conceptual Decommissioning Plan for the London Road Facility" October 20.1995 Revision 0. Page 24 I
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TABLE 2 - AREAS TO BE DECOMMISSIONED 3 l
- _ ]
/ _.._ w.
Area -
Current Activity (C[ Projected (50 years) Activity (Cl) i # Assuming No Removal Action Soiids'or Sosrces Other Residual Solids or Sources Other Residual Activity Activity Hot Cell 4000.00 1.00e +00 5.80 1.45e-03 o Isotope Shop 0.00 1.91e-04 0.00 2.77e-07 j s Isotope Shop 22648.00 0.00e+00 32.84 0.00e +00 e Warehouse 7 Source Garden 34232.00 8.54e-05 49.64 1.24c-07 e Decontamination 2.00 2.43e-03 0.00 3.52e-06 e Room to High level Waste 15.00 0.00e+00 0.02 0.00e +00 is Storage Room is Clean Equipment 0.00 0.00e +00 0.00 0.00e+00 is Room so HEPA Equipment 2.00 9.91e-06 0.00 1.44e-08 is Room is Back Basement 15.00 3.69e-05 0.02 5.35e-08 tr WHUT Room 0.00 5.30c +01 0.00 7.69e-02 is Front Basement 0.00 3.55e-06 0.00 5.15e-09 is Miscellaneous 0.00 2.67e-04 0.00 3.87e-07 no Restricted Areas si' Miscellaneous 0.00 0.00e +00 0.00 0.00e +00 24 Unrestricted Areas -
3 Areas Out:ide 0.00 1.97e-03 0.00 2.86e-06 no Building gy as Totals l [ 60914.k (5.40e+01 ) 88.33 7.83e-02
&s Excludes depleted uranium inventory.
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l ADVANCED MEDICAL SYSTEMS, INC.
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' Conceptual Decommissioning Plan for the taxion Road Facility" !
October 20,1995 i
' Revision 0, Page 25 '
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TABLE 3 - MANPOWER AND COST ESTIMATES -
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i Action Person-days Labor Costs ($) Other Costs Total Cost ($)
Required ($)
DECON Option l
l 4 Hot Cell 180 43200 54600 97800 1
., s Isotope Shop and 160 38400 34600 73000 a Source Garden 7 Decontamination Room 90 21600 17300 38900 a Clean Equipment Room 5 1200 5000 6200
- e HEPA Equipment 90 21600 19800 41400 I
- so Room ti Basement 360 86400 65200 l 151600 in WHUT Room 180 43200 114600 157800 j ' is Excavate _Outside Areas 60 14400 56300 70700 to All Other Areas 200 48000 24000 72000 i
1 is Ship Sources Offsite 60 14400 30000 44400 is Building Release 180 43200 11000 54200 it ' Survey l is Outdoor Release Survey (o 14400 7000 21400 i
. is Plannmg, Training, 400 160000 2000 162000 no Mobilization as Supervision 400 192000 4000 196000
- Waste Disposal 10000 1446179 1456179 23 . Subtotal 752000 1891579 2643579
- 24 25% Contingency 660895 as , Total ,/T3N74 '
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ADVANCED MEDICAL SYSTEMS, INC.
" Conceptual Decommissioning Plan for the London Road Facility" October 20,1995 Revision 0, Page 26 i
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i TABLE 3 - CONTINUED '
5* Action Person-days Labor Costs ($) Other Costs ($) Total Cost ($)
Required
! SAFSTOR Option 4 Hot Cell 5 1200 1000 2200 s WlIUT Room 60 14400 8000 22400 e HEPA Equipment 35 8400 4000 12400 Room 4 s Gross Decon. Of S- 57600 5000 62600 4 e other areas io Decon. Surveys - 40 9600 2000 11600 si On-going building (50 yr) 312000 50000 362000
, in maintenance and
! is surveys
. so Decontamination at 70 16800 25000 41800 3
is end of SAFSTOR ie Outdoor Release 180 43200 11000 54200 is Survey
- is Building Release 60 14400 7000 21400 is - Survey no . Waste Disposal 5 2000 38544 40544 i si Planning, trammg, 150 60000 1000 61000 22 mobilize as Supervision 75 36000 2000 38000 se Subtotal 575600 154544 730144 as 25% Contingency 182536
\
- 2e Total [ 912680 )
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ADVANCED MEDICAL SYSTEMS, INC.
" Conceptual Decommissioning Plan for the tondon Road Faci:ity" J* October 20,1995 ,
Revision 0, Page 27 !
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TABLE 4 - COLLECTIVE DOSE ESTIMATE FOR DECON AND SAFSTOR I
- Action Person-days Average Exposure Rate Collective Dose (person-Required (decay-corrected where rem) necessary) per Task (mR/hr)
L DECON Option 4 Hot Cell 180 12000 8642' s Isotope Shop and Source 160 10 12.8 e Garden Decontamination Room 90 100 72 J
e Clean Equipment Room 5 1 0.04 s HEPA Equipment Room 90 80 57.6 to Basement 360 10 28.8
- is WHUT Room 180 145000 0 s2 is Excavate Outside Areas 60 0 0 in All Other Areas 200 0 0 i4 Ship Sources Offsite 60 1 0.48 is Building Release Surveys 180 0 0 is Outdoor Release Surveys 60 0 0 i Planning, Training, 400 0 0 se Mobilization is Supervision 500 0 0 no Waste Disposal 30 5 1.2 1 2$ Total 1036.92 l 2'
Assumes that five (5) percent of the person-days required to perform the work required in DECON are spent in the hot cell.
22
'Ihere will be no entries into the WHUT Room during DECON.
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l ADVANCED MEDICAL SYSTEMS. INC. I
" Conceptual Deconunissioning Plan for the London Road Facility" October 20.1995 Revision O. Page 28 i
i TABLE 4 - CONTINUED '
i Actioit Person < lays Required Average Exposure Collective Dese Rate (decay-corrected . (person-rem) l where necessary) per Task (mR/hr)
- SAFSTOR Option i 1
4- Hot Cell 5 17.4 0.0348 22 i
s WHUT Room 60 0.5 0.012
- s HEPA Equipment Room 35 0.1 0.028 7 Gross Decon. Of other 240 0.1 0.192 e areas i e Decon. Surveys 40 1.4c-3 0.000448 u On-going building 2000 1.4e-3 0.0224 u maintenance and surveys m
sa Decontamination at end 70 0.1 0.056 is of SAFSTOR is Final Release Survey 240 0 0 is Waste Disposal 5 0.01 0.0004 is Planmng, training, 150 0 0 it mobilize is Supervision 75 0 0 is Total 0.35 nau -
- 22. Assumes that five (5) percent of the person-days required to perform the work required in SAFSTOR are spent in the bot cell.
" Assumes that five (5) percent of the person-days required to perform the work required in SAFSTOR are spent in the WHUT Room.
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4 ADVANCED MEDICAL SYSTEMS, INC.
" Conceptual Decommissioning Plan for the lendon Road Facility" October 20,1995
. Revision 0. Page 29 j-i 1
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i TABLE 5 - COST-BENEFIT ANALYSIS B
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- a. Option X S a ' Solution j ($)
s (Person-Rem) ($ per Person-Rem) ($)
j s DECON 3304474 1036.92 $1,000 4341394 i'
4 SAFSTOR 912680 0.35 $1,000 913030 1
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l t This report was prepared under the direction of j
Advanced Medical Systems,Inc. '
a by !
4 R. Alan Duff, R.R.P.T.
s integrated Environmental u- :;. -_..t,Inc.
e 9040 Executive Park Drive, Suite 205 7-KnoxvF.e. Tennessee 37923 i
e (615)531 9140
{
- s. and :
a Carol D. Berger, C.H.P.
ii Ictgrated Environmental":- ;_ :t, Inc.
3: 1680 East Gude Drive, Suite 305 is Rockvise, Maryland 20850 is (301)762 4502
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, HRC.iMNS, DIVISION TEL:301-504-5369 Nov 16'95 9:00 No.001 P.02
.
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! f.- g UNITED STATES I f S NUCLEAR REGULATORY COMMISSION 3
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wasnmcTon, o.c. =c.somi j % ,,, ,, 8 Noventer 3,1995 1
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i MEMORANDUM T0: George Pangburn, Acting Chief Operations Branch i Division of Industrial and Medical -
4 Nuclear Safety, NHSS .
4 l 3 FROM: Michael F. Weber, Chief N' 1 Low-Level Waste and Decomissioning j Projects Branch I i Division of Waste Management, NHSS i ,
}
SUBJECT:
REVIEW OF ADVANCED MEDICAL SYSTEMS CONCEPTUAL l
- DEC0lWISSIONING PLAN i
i
! In responsa to your request, we reviewed the Advanced Medical Systests Conceptual Decomissioning Plan, dated Octnhar 20, 1995. Wa arm attaching our :
i I I comments.
b l l License No. 034-19089-01 l Docket No. 030-16055 t
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Attachment:
As stated ,,p . . qp. .
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, CONTACT: T.C. Johnson, HMS$ - .
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415-7299 1
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NRC, IMtG DIVISIDtf T EL :301 -504-5369 Nov 16'95 9:01 No.001 3.03 f . ., .
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Coasnents on AMS Conceptual Decomissionino Plan i
! 1. Items to be Decossnissioned. op. 2-9 i
j We assume that the project manager agrees with the scope of the proposed decoassissioning and that the sources of contamination are reasonably
/
represented in the report.
- 2. Decommissionino Cost Estimates. 2nd Para.. o. 15 i ,
j AMS-1 posing to base its decossaissioning financial assurance amount on a
! F roach using a 50 year storage period.
e erat s for the 1988 decommissioning rulemaki In the_statament of
-(53'FR 24018p "the i
intent of the rule is to provide the necessary guidelin _ttregaWI to use of decessissioning alternatives in a manner which protects the public health t and safety." In the 1988 rulemaking, provisions for deferring dismantlement are licable only to power reactors where up to a 60 year period is i speci cally allowed.
i Deferred decommissionina rar mt Hals licensees and i
non-power reactorsCis not specifica1TyaallosiP ause the supporting ~
analyses in the %neric Ehvironmental Impac C temenf on Decommissioning Nuclear _Fac]Diles"_(GEIS1,_NilAEF0586, showed that there would be no
! significant advantages to delWin~gdec6iunissioning. for these types of i
licensees. Factors %t need-to-be considered ~lii~iddressing decommissioning
{ alt 4Wiatives include the following:
i a. Occupational eiiposures
- b. Costs ,
! y c. Waste disposal I i
- d. Financial viability of licensee
- e. Financial assurance provisions l In allowing up to a 60 year period for decommissioning power reactors, there i is about an 80 percent saving in occupational exposures for the deferred j option. The overall costs between DECON and SAFSTOR are about the same. For 3
a 50 year SAFSTOR period the waste volumes are 90 percent less than with ,
DECON. For a utility, utilities are considered to be r*= tally strong financial corporations due to the monopolistic system they operate in.
i Because the costs of DECON and SAFSTOR are similar, decommissioning financial !
l assurance is provided at levels that could fund decommissioning even if a j utility is unable to do so anytime during the SAFSTOR period.
l-d U The SEls indicates that there y be h.for materials licensees where deferred decommissioning may med Trotective of public health and i safety. In Chapter 14 of the GEIS, it is stated that deferred dismantlement I
could be a preferred option for source manufacturers which use short-lived i j nuclides that decay within a few weeks or months. However, longer SAFSTOR l 2
periods are not discossed as being suitable. This is especially the case of !
j ANS, where there the viability of the corporation is tentative due to its substantive decommissioning obligations and the speculative nature of its i limited business prospects for marketing teletherapy sources in the third 3 world. By provf(ing decommissioning financial assurance at a level that
,' Attachment i
' si. 2nna gi v i n un ' etc.evi-w n e,ov Nov 16'95 9:02 No.001 ?.04 l a
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would not allow the complete remediation of the facility at any time during the SAFSTOR period, the public taxpayer could be forced to accept a decomissioning funding.
obligation that substantially exceeds the proposed level of
- 3. Decommission 1na Cost Estimates. 2nd Para.._o.15 j o'
- x
- V;ko AMS estimates that the SAFSTOR period maintenance and surve
/ - ), k"% would be 4 staff-hours per week. !
'3 Based on the contamination levels in the l building, the groundwater seepage into the basement, restrictions on fy !
- j. f Jf Qp releasing water to the sewerage systes, and possible structural damage to the buildin , this estimate appears to be very low. These low maintenance and t, ;-
S' survall ance costs substantially affect the long-ters decommissioning costs.
y
,g 4. Decommissionino Cost Estimates. 2nd Para.. on.15-16 AMS is assuming that the lateral connection to the sewer system will remain inplace during the SAFSTOR period. What is the rationale for this't There appears to be no cost beneficial reasen to delay the remediation of this contamination.
- 5. Duration of Safe Storace Period. c.19 The report states that the safe storage period is consistent with U.S. EPA policy. What policy is this? Note that our policy, embodied in the 1988 regulations, is that there is no significant benefit for delaying decommissioning at materials licensee facilities.
- 6. Tahle 3 Will a more detailed decomissioning cost estimate be submitted? This table is a summary of cost calculations, but does not provide sufficient detail for us to verify the ecst estimates. We will review the detailed cost estimate when it is submitted.
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O v-l MAR 2 01996
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David Cesar, Vice President s
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Advanced Medical Systems, Inc. A t ' , m. s@M4 %. 4 121 North Eagle Street # -
Geneva, Ohio 44041 A ,
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Dear Mr. Cesar:
We have reviewed your letter dated October 20, 1995 with its accompanying
" Conceptual Decommissioning Plan" (Plan). The letter and Plan were submitted in response to our August 17, 1995, deficiency letter.
The purpose of this letter is to summarize our review of your response. We will address: (1) the requirement for decommissioning financial assurance, (2) our August 17 letter and your response, and (3) the AMS Plan - SAFSTOR vs. DECON.
As you are aware, decommissioning financial assurance for the possession of byproduct material is required pursuant to 10 CFR Part 30, Section 35. This regulation requires certain licensees to submit a decommissioning funding plan (DFP), which includes a cost estimate and a financial assurance instrument, to cover the costs of future decommissioning in the event that decommissioning is reauired at the present time. In other words, the cost estimate and financial assurance instrument must cover the decommissioning costs if decommissioning began today, as opposed to a projected decommissioning date in the future. The amount of financial assurance required is based upon the quantity of material authorized on a license.
Our August 17 letter primarily discussed two issues which pertain to the cost estimate AMS submitted in support of decommissioning financial assurance. To summarize, the issues are: (1) NRC's request that AMS revise its facility characterization to include an assessment of the radiological conditions of the soil under the basement and WHUT room floors, and (2) incorporation of the current disposal costs at Barnwell into AMS' DFP. In your October 20 letter, you did not address issue (1). As stated in our letter, we are not confident that the three core samples taken through the basement slab prior to the flood are representative of the current radiological conditions of the soil under the basement and WHUT room floors. The presence of radioactivity under the floor would presumably increase the quantity of licensed material and therefore, increase the cost estimate for decommissioning financial assurance.
Enclosed is a copy of our August 17 letter. Please submit an evaluation of the radiological conditions of the soil under the basement and WHUT room floors, or justify why the three core samples should be considered representative of the current radiological conditions.
19 pmv 4
i i D. Cesar :
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Contained within your Plan is a description of two methods for decommissioning the AMS facility - SAFSTOR and DECON, and the associated costs required for
- each method (910,000 dollars for the SAFSTOR option, and approximately i
3.3 million dollars for the DECON option). After comparing and contrasting these two options, AMS proposes to establish approximately 910;000 dollars financial assurance based on a SAFSTOR approach using a 50 year storage
- period. The deferment of decommissioning through implementation of SAFSTOR is
- only applicable to power reactors. The Statement of Considerations for the a
1988 decommissioning rulemaking (53 FR 24018) states, "The intent of the rule is to provide the necessary guidelines with regard to use of decommissioning i alternatives in .a manner which protects the public health and safety." In the j 1988 rulemaking, provisions for deferring dismantlement are applicable only to power reactors where up to a 60 year period is specifically allowed. Deferred j decommissioning for materials licensees and non-power reactors is not
- specifically allowed.
i i
The supporting analyses in the " Generic Environmental Impact Statement on
' Decommissioning Nuclear Facilities" (GEIS), NUREG-0586, indicates that there may be cases for materials licensees where deferred decommissioning may be the i- most protective of public health _and safety. In Chapter 14 of the GEIS, it is stated that deferred dismantlement could be a preferred option for source 4
manufacturers which use short-lived nuclides that decay within a few weeks or months. However, longer SAFSTOR periods are not discussed as being suitable.
In comparison to the utilities, the financial stability of many materials i licensees is uncertain. Therefore, by providing decommissioning financial l assurance below a level that would fund complete remediation of the facility at any time during the SAFSTOR period, the public taxpayer would be forced to accept a decommissioning obligation that substantially exceeds the proposed level of funding.
As presented in your plan, SAFSTOR is equivalent to decay-in-storage. Current l NRC policy limits authorization for decay-in-storage to radionuclides with half-lives no greater than 120 days. NRC considers storage of radioactive waste with half-lives greater than 120 days as extended interim storage.
Extended interim storage requires specific authorization. Furthermore, NRC
] policy states that extended interim . storage of low level waste should not be a
.' substitute for disposal to a licensed waste facility if access is available.
i Therefore, unless a materials licensee does not have access to a disposal
- facility, all radioactive waste with half-lives exceeding 120 days should be
' shipped off-site. As stated in our October 31, 1995, letter regarding your application for renewal, we feel strongly that AMS should take the opportunity
- to ship its radioactive waste to Barnwell.
i Table 3 to your Conceptual Decommissioning Plan entitled " Manpower and Cost
- Estimates" lacks the specificity the NRC needs to verify your cost estimate.
, A cost estimating table that organizes and provides an acceptable format to I
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, i D. Cesar <
the NRC for determining decommissioning cost components and activities is illustrated in Appendix F to Regulatory Guide 3.66 (enclosed). It provides an extensive checklist of decommissioning activities that must be included in a decommissioning cost estimate. Resubmit your cost estimating table using the format provided in Appendix F.
We will continue our review of your application upon receipt of the j information requested in this letter. Please reply in duplicate, within 30 days, and refer to Control Number 98507.
If'you have any questions or require clarification on any of the information stated above, you may contact us at (708) 8?9-9887.
i I Sincerely, i
i 1
Original Signed By '
John R. Madera, Chief i
Nuclear Materials Licensing Branch j License No. 34-19089-01 i Docket No. 030-16055 )
Enclosures:
As stated 4
I i
i DOCUMENT NAME: M:\03016055.DE6 Ta semelve a sepy of tNo aloeumont.insecate in the box: "C" = Copy without attachment / enclosure
- E* = Copy with attachment / enclosure 'N' = No copy 0FFICE DNMS/RIII c. D,NMS/RlII& y NMSS (_ DNMS/RIJK lt l NAME KGNull:brt R d 1 1IIFWebbr(pm por FCombs 4 A ggv't, JRMade M m DATE 03/ ([ /96 \ 03/ /6 796 03/ /96 +#f" 03/ If (f)6 OFFICIAL RECORD COPY { UO S ($
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d!L Advanced MedicalSystems,Inc. 1020 l_ondon Rd.
Cleveland, Ohio 44110 l - 216-692-3270 g ..< . ,
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- b. i ls . /1 A April 12,1996 ?
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! Mr. John R. Madera, Chief #
[
j Nuclear Materials Licensing Section U. S. Nuclear Regulatory Commission
['J,' j .] [ 'j '.gi
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- 801 Warrenville Road i Lisle, Illinois 60532-4351
- Re
- Conceptual Decomminioning Plan for Advanced Medical Systems Inc. (License j No. 34-19089-01, Control No. 98507 i
]-
Dear Mr. Madera:
1 Advanced Medical Systems, Inc. (AMS) is in receipt of your March 20,1996 letter to David l Cesar wherein comments on our Conceptual Decommissioning Plan were provided. Enclosed are j our responses to your comments, along with a description of our proposed follow-up actions.
i j Once you have approved these comments, the Plan will be funded by the corporation and reviewed for continued applicability at the agreed-upon schedule. In the meantime, if you have any
{ questions or if I can provide you with additional information, please call me at (216) 692-3270.
l Sincerely, Robert Meschter, R. S. O.
cc: D. Cesar D. A. Miller, Esq. - Stavole & Miller C. D. Berger, C.H.P. - IEM -
RECEIVED APR 171996 REGION III
) AFR 171996 3 ,-
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RESPONSE TO USNRC COMMENTS ON THE AMS CONCEPTUAL DECOMMISSIONING PLAN Agency Comment: The cost estimate and financial assurance instrument must cover the decommissioning costs if decommissioning began today, as opposed to a projected decommissioning date in the future.
AMS Response: The Conceptual Decommissioning Plan forwarded to you on October 3,1995 was based upon the SAFSTOR decommissioning methodology. The intent of the Conceptual Decommissioning Plan, in concert with the decommissioning funding requirement of 10 CFR 40.36, is that the USNRC would implement a similar decommissioning methodology should it be forced to draw on the financial assurance. included in the cost estimate (Table 3) is $362,000 dollars dedicated to weekly facility surveillance and maintenance for the duration of the safe storage period. The eventual goal of SAFSTOR is release of the site for unrestricted use.
i Therefore, the cost of on-going surveillance / maintenance, eventual decontamination and waste '
disposal is included in the cost estimate shown in Table 3 of the conceptual Decommissioning Plan. l Because these funds are already dedicated, there would be no additional financial burden to the I taxpayers of the state in the unlikely event of an AMS default during the term ofits license.
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Action Taken: No additional action required.
Agency Comment: The amount of financial assurance required should be based upon the quantity of I material authorized on a license.
AMS Response: Concur. However, on November 9,1995, AMS submitted a revised license renewal application wherein a materials limit for"Co of 93,110 Ci was requested! To date, the USNRC has taken no action on this application. The current license limit is 300,000 Ci, but it has been at least three (3) years since AMS has had in excess of 100,000 Ci of material in site.
Therefore, it is inappropriate to require AMS D provide financial assurance for an inventory that is significantly above the likely inventory at any point in time simply because action has not yet been taken on AMS's application to modify the limit.
Action Taken: No additional action required. However, timely USNRC action on our November 9,1995 renewal application would be greatly appreciated.
Agency Comment: Please submit an evaluation of the radiological conditions of the's6il under the basement and WHUT room floors or justify why the three core samples should be considered representative of the current radiological condition.
AMS Response: AMS maintains that the soils upon which the IAndon Road building was constructed have the same radiological character now as they did before the 1995 flood. The following are our reasons for this position:
' The requested limit was set to accommodate possession and sale of scaled sources as well as t12 radioactivity that exists in solid waste and residual radioactivity on buikling surfaces.
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.- i (1) Throughout the period of time that the basement of the London Road flooded due to the NEORSD's intentional blocking of all discharge paths, AMS maintained a minimal pressure differential between the inside and outside water levels in order to minimize uplift on the floor slab and eliminate the possibility of "back tiow" of contaminated water to areas outside of the building.
AMS's pumping efforts clearly provided the necessary level of pressure control, in fact, USNRC Inspection Report No. 030-16055/95006(DNMS) stated that, with the exception of one location on the second floor of the building, "the reinforced concrete core structure of the 1958 building that forms the hot cell, the WHUT room, the original radiography room, the source garden and the front and back basements was found to be in good condition". Furthermore, the inspector found "no additional signs of distress" on the basement slab, and concluded that "there was no observable significant impact on the structural integrity of the 1958 building as a result of the basement flooding event". Therefore, the structural evidence suppons our that the radiological conditions of the soil under the basement and the WHUT room have not changed since the three core samples were taken in 1994 (e.g., before the flooding).
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(2) During the 1995 sewer remediation project, AMS determined that the shale layer upon wluch the building is built and which formed the base of the existing footer drains, did not contain detectable radioactivity, in fact, no detectable activity was identified during the remediation other than that in the existing drain tile and fill material upon which they rested. Therefore, the radiological evidence from the remediation project supports our that the radiological conditions of the soil under the basement and the WHUT room are equivalent to the pre-flood conditicns.
(3) Between the 1995 completion date of the sewer remediation project and the date of this letter, over 80,000 gallons of water have been pumped from the foundation drainage system, confirmed j to be " clean" through laboratory analyses, and discharged' This indicates that no mobile j contamination is under the basement or in the new drainage system.
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i (4) Included herein as Attachment 1 is a Registered Hydrogeologist's report wherein he concludes I that the new foundation drain is hydraulically connected to the soils under the basement floor, and that it is unlikely that contamination migrated from the basement to these soils.
In summary, the findings of the USNRC Inspection Report, the fact that the water being pumped I from the foundation drains is radiologically benign, and the hydraulic connection between the soils under the building and the foundation d.ain all serve to support our position that the soils were not
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contaminated from the basement flood. Until the basement has been fully decontaminated, attempts to breach the integrity of the floor for the sole purpose of securing additional confirmation runs the risk of injectmg contamination into the sub-basement environment where none currently appears to exist.
Action Taken: Page 8, line 14 of the Conceptual Decommissioning Plan will be modified to mad: l
". . . did not occur. However, if information is obtained at some time in the future to invalidate this assumpdon (e.g., if contamination is detected in the remediated foundation drainage system),
Cobak40 was idenhfied in one 3,000-gallon batch (e.g., hold-up tank No. 880), as I reported in my letter of Febmary 26,1996 to Cyndua Pederson. USNRC Region III. However, the source of this material was the tank itself, whid was used as a pmcess tank dunng the water treatment project. The residual cobak40 that was in the tank when the fanndahan drain water was transferred to it was later removed by filtraten 2
this Plan will be revised to include the cost of addressing the additional contamination during
' decommissioning."
Agency Comment: The deferment of decommissioning through implementation of SAFSTOR is only applicable to power reactors. The GEIS (NUREG4586) indicates that deferred dismantlement could be a preferred option only for radionuclides that decay within a few weeks or months. By providing decommissioning financial assurance below a level that would fund complete remediation of the facility at any time during the SAFSTOR period, the public taxpayer would be forced to accept a daommissioning obligation that substantially exceeds the proposed level of funding.
AMS Response: AMS takes exception to this comment for the following reasons:
, (1) ne GEIS shows that SAFSTOR is an acceptable decommissioning alternative for "shon lived radionuclides" at power reactors as well as for materials licensees (see page 0-4, section 0.2.4 and page 14-9, section 14.3.2.2).' Furthermore, on page G-S of the GEIS, the definition of short-lived radionuclides is given as "those radioactive isotopes with half-lives less than about 10 years".
Since the "Co at AMS, a materials licensee, has a radiological half life of approximately five (5) years, the GEIS is supportive of decommissioning by the methodology of SAFSTOR for materials licensees.
(2) De GEIS does state that use of a " safe storage period of a few davn to a few montha may allow the radioactivity to decay to low enough levels that no further decontamination required" (see page 14-9, section 14.3.2.2) for a reference sealed source and radiochemical manufacturer. But the GEIS also states that while generic criteria were used for development of the report, "each facility can present problems that are unique to its decommissioning" (see page 14-4, section 14.2). The reference facility used to derive the findings for sealed source production was. a generic manufacturer of sealed sources that carried "out their operations in small batches in glove boxes, hoods or remote operation cells, and contamination outside these structures is linuted almost entirely to the ventilation ducts and filters" (see pages 14-4 and 14-5, section 14.2). The !
radiological conditions at AMS are distinctly different since there is extensive area contamination, significant solid waste recovered from remediation of the old sewer system, and there is a facility l that was closed to all access under the authorization of the USNRC (e.g., the WHUT Room).
Herefore, strict application of the GEIS' recommendations for the reference sealed source manufacturer to all sealed source manufacturers is inappropriate. .
(3) In evaluating decommissioning alternatives, there are considerations that go beyond immediate license termination and release of the site for unrestricted use. Both DECON and SAFSTOR will result in unrestricted release of the site. However, the GEIS clearly states that the overwhelming advantage of SAFSTOR at a facility like AMS is the reduction in occupational exposure and the quantities of radioactive waste from radioactive decay, he ALARA analysis shown on page 16 of the Conceptual Decommissioning Plan further demonstrates this advantages.
8 U. S. Nuclear Regulatory Commission, " Draft Generic Environmental Impact Statement on D+== sioning of Nuclear Facilities", NUREG-0586, January,1981.
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-(4) The mission of the USNRC is to ensure adequate protection of the public health and safety, the common defense and security, and the environment from the use of nuclear materials in the 1 United States. The USNRC and its licensees share a common responsibility to protect the public !
health and safety. Once a facility like AMS has reached the end of its useful life, there is no l question that it must be decommissioned.110 wever, decommissioning means that the facility must I be placed in a condition such that there is no unreasonable risk to public health and safety. It ;
would be contrary to the mission of the USNRC to categorically reject the SAFSTOR option as '
a decommissioning alternative for AMS. Furthermore, since the eventual goal of SAFSTOR is release of the site for unrestricted use, and'since the cost of on-going surveillance maintenance, l as.well as eventual decontamination and waste disposal is included in the cost estimate for the Conceptual Decommissioning Plan, there would be no additional financial burden to the taxpayers i of the state.
(5) The USNRC, in its October 20,1988 letter to Dr. Seymour S. Stein (AMS), concurred with AMS's February 8,1988 and July 6,1988 request to delay decontamination of the WHUT Room
~ until personnel exposure rates are reduced significantly. -(In the July 6th letter, AMS stated that:
"To move this material from its present safe concealment through the general public environment merely to deposit it at another safe concealment presents unreasonable and nrue y man-rem exposure and risk to the public health and safety at an unjustifiable exposure".) Since the l
- Conceptual Decommissioning Plan that is the subject of this letter was developed with similar 3
concerns in mind, AMS respectfully requests that the USNRC reconsider"its' current position on SAFSTOR in light of its previous position that " isolation can be carried out safely with some benefit in the reduction in occupational exposure and waste requiring disposal" (see page 1 of the October 20,1988 letter from A. Bert Davis to Dr. Stein).
Action Taken: None required.'
l Agency Comment: Table 3 to your Conceptual Decommissioning Plan entitled " Manpower and Cost l Estimates" lacks the specificity the NRC needs to verify'your cost estimate. Resubmit your cost esumating table using the format provided [ citation given].
AMS Response: Concur.
Action Taken: Included herein as Attachment 2 is additional cost information for, th_e SAFSTOR option. 'Ihis information is presented in the same format as Appendix F of USNRC Regulatory Guide 3.66, " Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40,70 and 72" (June,1990).
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ATTACHMENT 1 5
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p i Environnwatal
!~ Sahitiana, Inc.
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i April 11,1996 1
Ms. Carol D. 8erger Integrated Environmental Management, Inc. _
i 1680 East Guide Drive Suite 305 j RockviRe, Maryland 20850
DearCarol:
l 1 have reviewed the letter dated March 20, 1994 from the U. S. Nuclear Regulatory Commission (NRC) to your customer, AMS, regardng the Conceptual Decommissioning i Plan of the AMS Facluty. It is my opinion that, based upon the effect of the hydraulic j gradent in the vicinity of the basement when the basement contained water, the addllonal ssi(I-g of sons below the basement and the WHW room floors should not
! , be required. Ac.c.vid,s to the evidence, it is unikely that contamination migrated from
- the buBding to these soils, and, therefore, condtions in the solis would not have j changed due to the flooding of the basement referenced in the NRC's letter.
Following is a brief recap of the evidence and the historical events:
- 1. Prior to the flooding, three core samples were obtained from native sous under the basement in the vicinity of the WHW room. Contamination was not discovered in any of the samples:
- 2. Based upon a suspected discharge of radioactive contamination, the outfaN of the -
AMS Buldng basement drainage system was plugged by the local sewer authority.
As a result, ground water that normaNy was carried off site by the drainage system d began to accumulate and enter the basement; J
[ 3. Prior to the removal of the water from the basement, monitoring records show the
- ' water elevation in the drainage system to be higher than the water level in the basement. Additionoty, during the removal of water from the basement, the surface elevation of the basement water was intentionaNy neintained below the
, waterelevationin the drain system:
( 4. Since the flooding, the basement drainage system was closed in place and has l been replaced with a new subourface perimeter. drain system; and,
! 5. The new drain system is utitzed to remove ground water from the sous around the basement by pumping colected water into aboveground storage. Conts.h-tiwi i has not been dscovered in the removed water, and the water has been dscharged to the loca: sewer. Since the initiation of the pumping, the basement
, has been dy. -
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- Corporate Ofiloe 134 Holiday Court, Suite 306.. Annapolis, MD 21401
- Telephase
- (410) 841-5552. Fax: (410) 266-5588 i
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~ - - ... - - . ~ _ _ - , _, , __ ,
. QualityEnytronmentalSolutions hworporated i Carol D. Berger April 11,1996 4
Page 2 j My cort:lusion that soil conditions did not change during the period when the basement was flooded is based upon the following:
- 1. The original drainage system created a local sink, collecting ground water from the basement vicinity and maintaining the ground water level below the basement floor. The woier level observed in the drain is representative of conditions in the surrounding solls. In addition to intercepting ground water flowing toward the basement, the new drainage system is also hydraulically connected to the soils surrounding the basement floor:
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- 2. The differential water levels between the drainoce system and the basement during the period in which the basement contained water indicate o positive hydraulic gradient from the surrounding soils toward the basement. Water would not leak out of the basement under these conditiors and, i
i 3. If water was lealdng from the basement, contamination could be expected to show up in the water that is couected by the new drain system. Therefore, the lock of contamination in the removed water also indicates that the ground-water flow was 4 toward the basement during its flooded period.
I Thank you for the opportunity to be of service on this project. Please call me at 410-2 841-5552 if you have any questions recording this letter. 4 elV, i
a Donald E. P.G.
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! Registered H ogeologist !
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l ATTACHMENT 2 i
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Cost Estimating Table - SAFSTOR Alternative ';
(USNRC Regulatory Guide 3.66, Appendix F)
Table 1 l
4 Finaming and Fnparation 1
- Task Werk Days Total Cast Superviser Fenmaan HP Cledcal Total ($) .
Preparation of Documentation for Regulatory 4 4 2 0.5 10.5 4560 Agem:ies
. Submiual of Decommissionirig Plan to NRC 10 10 10 1 31 14560 whco repired by 10 CFR 30.36 Development of work plans 10 10 - 10 1 31 14560 Procunement of Spedal epipment 2 2 0 0.5 '4.5 1680 Staff training i 1 1 . 0.5 3.5 1620 Charactenzatson of radaologsal condition of the 20 20 5 2 47 19520 facility (includmg soil and tailings analysis or smundwater aanlysis,if appreshie)
Other 0 0 0 0 0 0 Tota: - 47 47- 28 5.5 l 127.5" ' 56400 7
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Table 2 4
2 Position Unit Cast for Workers Worker Com/ year ($)
Basic Salades ($/yr) Overhead Rate (%)
Supervisor 60000 100
- 2. 120000 Foreman 40000 100 80000 Cransman 30000 100 60000 4
3 Tectuacian 30000 100 60000 t Henkh Physicist 80000 100 , 160000 Laborer 30000 100 60000
, Clerical 20000 100 40000 i
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D~ame-=riam and/or di====entar of Rahaartive Fadlity ceanponents I
- No. Dimensions No. M*
Glove Boxes O n/a Amount of Floor -
200 m' l
Space 3 Fume Hood 0 n/a Ventilation -
50 m ductwork I
Hot Cells - 1 27 m' Amount of Wall -- 3100 m' i space 1
l Lab Bendus O n/a Other - -
1' Sink and Drain 2 25 m - -
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Table 3 1
Work Days Total 4 Task Cost Super Forem Techal HP CraAs Labor Total ($)
visor an dans men er
- Decon/ dismantle major componeris and/or 10 10 20 2 0 57
' 15 17680 processing storage tanks (llot cell SAPSTOR and decon after SAPSTOR)
Decon/dismantic laboratories, fbme Ixxxis, glove - - - - - - -
boxes, benches, etc.
Deam/dismantic waste areas (radwaste area, scrap 3 12 15 3 0 15 48 14400 recovery, other) WIIUT room Decon/ dismantle servia facilities (maitsenance 14 55 65 8 22 65 229 65920 shop, decontamination areas, vertilation systems, other) includes HEPA system and misc. Areas Decon/ dismantle waste treatment facilities and - - - - - - - -
storage areas on site (including exhume and package contaminated soil and tailings, if any)
Monitor for compliance, reclean sad monitor, if 2 8 10 2 0 10 32 9600 necessary Other (e g., contractor fees) 80 0 0 0 0 0 80 38400 Table 4 s
Equipseent/ supply Quantity Cust Personnel protective equipmert 1 kg 18000 Miu. Decon supplies I km 20000 Security system upgrade SAFSTDR les 2000 Office supplies, misc. other I lot 2000 Survey equipmera 1 tot 4000 Dean equipment rental 4 me. 20000 Misc. items for 50 yr. SAPS 1DR 1 lot 50000 Total 116000 9
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Table 5 Waste type Volume W) No. Of containers Type of Container Unit Cost of Cost of Contuer Container ;
LLW 2.83 i B-25 500 500 Asbestos 0.59 4 Drum 35 140 i Total 3.42 5 - --
640 1
$ Table 6 Distance shipped 2525 (miles)
Unit Cost for shipment 2.65 ($/ mile / truckload) l Additional Charges - Overweigls 0 ($/ mile) ,
1 Additional Charges - Surcharge 0 (1/ mile) i Waste Type No. Of shipments Unit Cost for Distance Shipped Surcharge ($) Transportation shipping ($) (miles) Cost ($)
LLW ! 2.654 700 0 1855 Asbestos 1 2.65 1825 0 4836 Total 6691 i
l Table 7 Burial Charges 340 ($/Rh Surcharges - Per corsainer 0($)
Surcharges - Disposal 0 ($/R$
Waste Type Burial Voimme (h') Unit Cast of BurW Surcharge ($) Burial Cost ($)
($/h')
Class A - LLW 100 340 0 34000 Asbestos 21 150 0 3150 Total 37150 10
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- Resterados of f'a=s==iaM Areas se Factity Grenad 2
Task Wod Days -
! Total Cost ($)
1 Sr ervisor
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Fenmaan HP Cledcal Total i _
? Backfdl and 0 0 0 0 0 0
- 1. remare em i
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4 l M -l j Funal Ranados Survey i
Task Wod Days
- Total Cost ($)
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- Supe, visor Fonsman fiF Cledcal Total .
c Onuloor release 36 40 20 1 87 43040
! survey Building release 12 15 6 0.5 33.5 144a0 1 survey Total 48 55 26- 1.5 130.5 57520 Tahle 10 ;
1 Site h airasia=, Laag-Tenn Survemance Of api ;
Tat Wed Days Total Cast ($)
- - . __; Fenunam HP Clarkel Total Oo-going 125 600 62.5 125 912.5 312000 buikkas
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Advanced Medical Systems i )
ATTN: David Cesar '
Treasurer 121 North Eagle Street-Geneva, OH -44041
Dear Mr. Cesar:
We have completed our review of your May 30, 1995 response to our March 30, 1995 deficiency letter regarding your cost estimate to decommission the London Road facility. We still feel that your cost estimate of $1,795,612 does not realistically reflect the cost that will be required to decommission the facility. You have not demonstrated that~the soil under the building is free of contamination, and your proposed disposal cost.of $181 per cubic foot appears to be-an under estimate based on the recent opening of Barnwell in South Carolina.
As previously discus' sed in our March 30, 1995 letter, recent water problems l at the site has resulted in two additional problems that may significantly impact the cost of decommissioning the London Road site. The two problems are: (1) the concrete slab may have to be removed from the WHUT room as a result of the water causing additional contamination of the concrete; ,
and_(2) the contaminated water may have caused extensive soil contamination j under the basement slab. The impact of having to remove and dispose of the j contaminated concrete, and to remove and dispose of significant quantities of i contaminated soil may be severa times greater than the initial estimate. '
Furthermore, the flooding problems in the basement occurred after 5T site characterization and cost estimate report of January 1995. Therefore, we believe that the three core samples through the basement floor prior to the flood may not possibly be representative of current soil conditions. under the basement slab and WHUT room. . i In your response to our question con:erning the possibility of structural l damage to.the building due to recent water problems at the facility, you 1 stated in item (3) on page 2 of your letter that no structural damage was
-observed, and that recent core borings "outside" the facility indicated no "significant" outside contamination exists. AMS has not performed an adequate ;
site characterization to support these conclusions. In addition, your statement regarding "significant" outside contamination is a clear indicator that "outside" contamination, in fact, does exist. ,
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o Advanced Medical Systems i i
l Your foot. decommissioning cost is also based on a disposal cost of $181 per cubic l A more realistic cost of approximately $300 per cubic foot i l
July 1,1995, reopening at Barnwell) base charge plus surcharges as(based sociatedon with curie content, weight, cask, etc., would be appropriate. This will result in a significant increase in decomissioning cost. PIE n e_ adjust your cost
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estimate, accordingly. ^ l Due to the recent flooding problems and the contamination that was discovered i
- under the isotope shop slab airlock and in the under drain system, please submit a revised characterization of the facility that includes a scientific 1 assessment and WHUT room.
of the radtologtcal conditions of the soil under the basement slab We would expect that a re-characterization of the site and incorporation of current disposal cost at Barnwell into your decomission financial ple dll dramatically increase your cost estimate to decomission he facility.
Given these recent events / discoveries at the 1020 London Road site, we feel that the January 1995 cost estimate and site characterization are no longer valid. Enclosed is a copy of the Draft Branch Technical Position on Site
' the Characterization facility. for Decomissioning that you should use to re-characterize We will continue our review of your application upon receipt of this information. Please reply in duplicate, within 30 days, and refer to Control !
Number 98507.
If you have any questions, please feel free to contact me at (708) 829-9834.
Sincerely, Original Signed By John R. Madera, Chief -
Nuclear Materials Licensing Section License No.: 34-19089-01' Docket No.: 030-16055
Enclosure:
Draft Branch Technical Position On Site Characterization for Decomissioning DOCUMENT NAME: M:\03016055.DFS Ta suostee o espy el ene desamment, ludisees in the bec *** = Copy without onciosures "E" = Copy with era +5es "It" = No copy 0FFICE DRSS/RIII l4 DRSS/RIII KM DRSS/RIII l C.
NAME KGNULL: jaw f( A/, _CLPIT10GLIO v . DRSS/ AIM l C . I MWEBER -1wh~ JRMAfeivib DATE 08//A/95 l' F 08////95 (915#8/16/95 08/ft/95)
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0FFICIAL RECORD COPY 1
CONVERSATION RECORD l TIME l DATE ;
(time) 3/15/96 1 -,.
O visti O CONFERENCE X TELEPHONE X INCOMING O OUTGOING NAME OF PERSON (S) CONTACTED OR IN CONTACT ORGANIZATION (OFFICE, DEPT.ETC.) TELEPHONE NO.
Jon Decicco, NMSS-
.;.sa ci AMS Conceptual Decommissioning Plan deficiency letter i i
l e- 1 l Jos called Mike Weber and told him that NMSS, through Vred Combs, concurs I cn the Region's proposed deficiency letter addressing AMS' Conceptual i D1 commissioning Plan.
1 Tha letter will be mailed out 3/18/96. '
i AcTTantrtentu i As noted above. ]
N ocum niius coNvensatioN oAi hy,uxthg sisuaT i Ksvin NulA 3[//[t14, l l hattat AcinaN TAKEN MM<dat 4/u i
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SIGNATURE TITLE DATE 1
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j l David Cesar, Vice President -
l l Advanced Medical Systems, Inc. '
i 121 North Eagle Street Geneva, Ohio 44041 ,
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Dear.Mr. Cesar:
? We have reviewed your letter dated October 20, 1995 with its accompanying
- " Conceptual Decomissioning Plan" (Plan). The letter and Plan were submitted i.
in response to our August 17, 1995, deficiency letter. y
! 1 The purpose;of this letter is to sumarize our review of your response. We
- -will address
- (1) the requirement for decomissioning financial assurance, 1 (2) our August 17. letter and your response, and (3) the AMS Plan - SAFSTOR i vs. DECON.
l: As you are aware, decommissioning financial assurance for the possession of
, byproduct material is required-pursuant to 10 CFR Part 30, Section 35. This regulation requires certain licensees to submit a decommissioning funding plan 1
- (DFP), which includes a cost estimate and a financial assurance instrument,-to !
cover.the costs'of future decommissioning in the event that decommissionino is reauired at the oresent time. In other words, the cost estimate and ?
financial assurance. instrument must cover the decomissioning costs if decomissioning began today, as opposed to a projected decomissioning date in l
the future. 'The amount of financial assurance required is based upon the quantity of material authorized on a license.
Our August 17' letter primarily discussed two issues.which pertain to the cost estimate AMS submitted in- support of decomissioning financial -assurance. To summarize, the issues are: (1) NRC's request that AMS revise its faci-lity characterization to include an assessment of the radiological conditions of l the soil under the basement and WHUT room floors, and (2) incorporation of the current disposal costs at Barnwell into AMS' DFP. In your October 20 letter, you did not address issue (1). As stated in our letter, we are not confident that the three core samples taken through the basement slab Drior to the flood are representative of the current radiological conditions of the soil under the basement and WHUT room floors. The presence of radioactivity under the floor would presumably increase the quantity of licensed material'and therefore, increase the cost estimate for decommissioning financial assurance. j Enclosed is a copy of our August 17 letter. Please submit an evaluation of the radiological conditions of the soil under the basement and WHUT room floors, or justify why the three core samples should be considered representative of the current radiological conditions.
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D. Cesar Contained within your Plan is a description of two methods for decommissioning the AMS facility - SAFSTOR and DECON, and the associated costs required for each method (910,000 dollars for the SAFSTOR option, and approximately 3.3 million dollart for the DECON option). After comparing and.. contrasting these two options, AMS proposes to establish approximately 910,000 dollars financial assurance based on a SAFSTOR approach using a 50 year storage i period. The deferment of decommissioning through implementation of SAFSTOR is i only applicable to power reacters. The Statement of Considerations for the j 1988 decommissioning rulemaking (53 FR 24018) states, "The intent of the rule is to provide the necessary guidelines with regard to use of decommissioning i alternatives in a manner which protects the public health and safety." In the 1983 rulemaking, provisions for deferring dismantlement are applicable only to power reactors where up to a 60 year period is specifically allowed. Deferred decomissioning for materials licensees and non-power reactors is not i specifically allowed.
The supporting analyses in the " Generic Environmental Impact Statement on Decomissioning Nuclear Facilities" (GEIS), PUREG-0586, indicates that there j may be cases for materials licensees where ceferred decommissioning may be the
- most protective of public health and safety. In Chapter 14 of the GEIS, it is
- stated that deferred dismantlement could be a preferred option for source
- manufacturers which use short-lived nuclides that decay within a few weeks or 7 months. However, longer SAFSTOR periods are not discussed as being suitable.
In comparison to the utilities, the financial stability of many materials licensees is uncertain. Therefore, by providing decomissioning financial assurance below a level that would fund complete remediation of the facility at any time during the SAFSTOR period, the public taxpayer would be forced to accept a decomissioning obligation that substantially exceeds the proposed level of funding.
As presented in your plan, SAFSTOR is equivalent to decay-in-storage. Current NRC policy limits authorization for decay-in-storage to radionuclides with half-lives no greater than 120 days. NRC considers storage of radio.ac.tive waste with half-lives greater than 120 days as extended interim storage.
Extended interim storage requires specific authorization. Furthermore, NRC policy states that extended interim storage of low level waste should not be a substitute for disposal to a licensed waste facility if access is available.
1 Therefore, unless a materials licensee does not have access to a disposal facility, all radioactive waste with half-lives exceeding 120 days should be shipped off-site. As stated in our October 31, 1995, letter regarding your application for renewal, we feel strongly that AMS should take the opportunity to ship its radioactive waste to Barnwell.
Table 3 to your Conceptual Decommissioning Plan entitled " Manpower and Cost Estimates" lacks the specificity the NRC needs to verify your cost estimate.
A cost estimating teble that organizes and provides an acceptable format to j
t D. Cesar t the NRC for determining decommissioning cost components and activities is l
illustrated in Appendix F to Regulatory Guide 3.66 (enclosed). It provides an -
- extensive checklist of decommissioning activities that must be included in a decommissioning cost estimate. Resubmit your cost estimating table using the format provided in Appendix F. ~
We will continue our review of your application upon receipt of the 1 information requested in this letter. Please reply in duplicate, within l 30 days, and refer to Control Number 98507.
If you have any questions or require clarification on any of the information stated above, you may contact us at (708) 829-9887.
l Sincerely, i
Original Signed By John R. Madera, Chief
. Nuclear Materials Licensing Branch
! License No. 34-19089-01 Docket No. 030-16055
[
Enclosures:
As stated
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DOCUMENT NAME: M:\03016055.DE6 Ta seesive a espy of this dooument.indk. ate in the boa: *C' = copy without attactwnent/ enclosure *E" = copy with ettectwnent/ enclosure 'N' = No copy 0FFICE DNMS/RIII c D,NMS/RRI& f NMSS lC. DNMS/RIK [t l NAME KGNull:brt K d 1 111FWebbr(WM br FCombs \W v!t, JRMade % )n DATE 03/lt /96 \ 03/ /6 796 03/ /96 +W 03/ (f (f96 OFFICIAL RECORD COPY fyUD S 6h
y Advanced Medical Systems,Inc.
1020 London Rd.
Cleveland, Ohio 44110 216-692-3270 gh Tf-' \
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l April 12,1996 I h Mr. John R. Madera, Chief -
4 Nuclear Materials Licensing Section U. S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Re: Conceptual Decommissioning Plan for Advanced Medical Systems Inc. (License No. 34-19089-01, Control No. 98507 1
Dear Mr. Madera:
i Advanced Medical Systems, Inc. (AMS) is in receipt of your March 20,1996 letter to David Cesar wherein comments on our Conceptual Decommissioning Plan were provided. Enclosed are our responses to your comments, along with a description of our proposed follow-up actions.
Once you have approved these comments, the Plan will be funded by the corporation and reviewed for continued applicability at the agreed-upon schedule. In the meantime, if you have any questions or if I can provide you with additional information, please call me at (216) 692-3270.
Sincerely, -
fJ (ddsg .
Robert Meschter, R. S. O.
cc: D. Cesar D. A. Miller, Esq. - Stavole & Miller C. D. Berger, C.H.P. - IEM \gh RECEIVED APH 171996 REGION III APR 171996 j%"
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1 RESPONSE TO USNRC COMMENTS ON Tile AMS CONCEPTUAL DECOMMISSIONING PLAN I Agency Comment: The cost estimate and financial assurance instrument must cover the decommissioning
] costs if decommissioning began today, as opposed to a projected decommissioning date in the future.
(t( .
j AMS Response: The Conceptual Decommissioning Plan forwarded to you on October 3,1995 was based upon the SAFSTOR decommissioning methodology. The intent of the Conceptual
[8 l Decommissioning Plan, in concert with the deconunissioning funding requirement of 10 CFR c' i 40.36, is that the USNRC would implemen: a similar decommissioning methodology
, _ forced to draw on the financial assurance.
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Included in the cost estimate (Table dollars dedicated to weekly facility surveillance and maintenance for the duration of the safe y r storage period. 'Ihe eventual goal of SAFSTOR is release of the site for unrestricted use. M Therefore, the cost of on-going surveillance / maintenance, eventual decontamination and waste Y
' disposal is included in the cost estimate shown in Table 3 of the conceptual Decommissioning Plan.
S -2 Because these funds are already dedicated, there would be no additional financial burden to the wiP '4 W taxpayers of the state in the u3ikely ev'e'nt of an AMS default during the term ofits license. I lY \/ \
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Action Taken: No additional action required. !
- i l Agency Comment: The amount of financial assurance required should be based upon the quantity of i material authorized on a license.
I h AMS Response: Concur. However, on November 9,1995, AMS submitted a revised license I j To date, the
, Yg #e k.[f
< renewal USNRC application has taken no action on wherein this application.a materials The current license limit limit is for' 300,000 Co Ci, but of it 93,110 has C j
) Y. f been at least three (3) years since AMS has had in excess of 100,000 Ci of material in site.
i Therefore, it is inappropriate to require AMS to provide financial assurance for an inventory that j[\A,)hNd'",%
is significantly above the likely inventory at any point in time simply because action has not yet l
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!w S been taken on AMS's application to modify the limit.
l t< Action Taken: No additional action required. However, timely USNRC action on our November l l 9,1995 renewal application would be greatly appreciated.
j Agency Comment: Please submit an evaluation of the radiological conditions of the soil under the basement and WHUT room floors or justify why the three core samples should be considered representative of the current radiological condition.
AMS Response: N4S maintains that the soils upon which the lendon Road building was constructed have 19.; same radiological character now as they did before the 1995 flood. The following are our reasons for this position:
' The regened limit was set to ec=" possession and sale of scaled sources as well as the radioactivity that exists in solid waste and residual radioactivity on building surfaces.
I
1 (1) Throughout the period of time that the basement of the lamdon Road flooded due to the NEORSD's intentional blocking of all discharge paths AMS maintained a minimal pressure ditterential between the inside and outside water levels in order to minimize uplift on the floor slab and eliminate the possibility of "back flow" of contaminated water to areas outside of the building. I AMS's pumping efforts clearly provided the necessary level of pressure control. In fact. USNRC I Inspection Report No. 030-16055/95006(DNMS) stated that, with the exception of one location on the second floor of the building, "the reinforced concrete core structure of the 1958 building that forms the hot cell, the WIIUT room, the original radiography room, the source garden and the front and back basements was found to be in good condition" Furthermore, the inspector found "no additional signs of distress" on the basement stab, and concluded that "there was no observable significant impact on the structural integrity of the 1958 building as a result of the basement flooding event" Therefore, the structural evidence supports our that the radiological ,
conditions of the soil under the basement and the WiiUT room have not changed since the three i core samples were taken in 1994 (e.g., before the flooding). l l
(2) During the 1995 sewer remediation project, AMS determined that the shale layer upon which f the building is built and which formed the base of the existing footer drains, did not contain detectable radioactivity. In fact, no detectable activity was identified during the remediation other
/ Nl.Mgbg~ than that m the Misting (drain (Ile andbaterial upon which they rested Therefore, the radiological evidence from the remediation project supports our that the radiological conditions of A the soil under the basement and the W11UT room are equivalent to the pre-tk>od conditions. !
(3) Between the 1995 completion date of the sewer remediation project and the date of this letter, over 80,000 gallons of water have been pumped from the foundation drainage system, confirmed to be " clean" through laboratory analyses, and discharged? This indicates that no mobile
\W contamination is under the basement or ia the new drainage system. NC M bu umn Wu. La 2 dt ga , (4) included herein as Attachment 1 is a Registered liydrogeologist's report wherein he concludes 9
[y - thatthat theit tinlikely new at oundation contaminationdrainmigratedis hydraulically from connected the basement to these soils. to the soils under t In summary, the findings of the USNRC Inspection Report, the fact that the water being pumped from the foundation drains is radiologically benign, and the hydraulic connection between the sotis under the building and the foundation drain all serve to suppott our position that the soils were not contaminated from the basement flood. Until the basement has been fully decontaminated, 7 attempts _to_ breach the integrity of the floor for the sole purpose of securing additional confirmation hv'd ] {uns the risk of injecting contaKnaticipinto the sub-basement environment where none currently 4 y 't., appears to exist.
- sag > W Jf a Action Taken: Page 8, line 14 of the Conceptual Decommissioning Plan will be modified to read:
g p". . . did not occur. liowever, if information is obtained at some time in the future to invalidate M this assumption (e.g., if contamination is detected in the remediated foundation drainage system),
7 Cobalt-60 was identified in one 3,000-gallon batch (e.g., hold-up tank No. 880), as I reported in my letter of February 26,1996 to Cynthia Pederson, USNRC Region III. liowever, the source of this material was the tank itself, which was used as a process tank during the water treatment project. The residual cobalt-60 that was in the tank when the foundation drain water was transferred to it was later removed by filtration.
2
this Plan will be revised to include the cost of addressing the additional contamination during decommissioning."
Agency Comment: The deferment of decommissioning through implementation of SAFSTOR is only applicable to power reactors. The GEIS (NUREG-0586) indicates that deferred dismantlement could be a preferred option only for radionuclides that decay within a few weeks or months. By providing decommissioning financial assurance below a level that would fund complete remediation of the facility at any time during the SAFSTOR period, the public taxpayer would be forced to accept a decommissioning i
obligation that substantially exceeds the proposed level of funding. !
AMS Response: AMS takes exception to this comment for the following reasons:
(1) The GEIS shows that SAFSTOR cceptable decommissioning alternative for "short lived p ^
radionuclides" at power reactor (as welt) for materials licensees ((Ee page 0-4, section 0.2.4 asp kp/
Qa;[e 144, section_t4.3.2% Furthermore, obage G-8 of the GEIS, the definition of short-lived radionuclides is given as "those radioactive isotopes with half-lives less than about 10 years" Since the "Co at AMS, a materials licensee, has a radiological half life of approximately five (5) years, the_GEIS is sunnnrtim nf. decommissioning by the methodology of SAFSTOR for materials y licensees.
f *%. ,p, MwM oc A M (2) De GEIS does state that use of a (afe storage period of a few davs in a few monnBomay allow the radioactivity to decay to low enough levels that no further decontamination required" (see page 14-9, section 14.3.2.2) for a reference sealed source and radiochemical manufacturer. But the GEIS also states that while generic criteria were used for development of the report, "each facility /
can present problems that are unique to its decommissioning" (see page 14-4, section 14.2). The reference facility used to derive the findings for sealed source production was a generic manufacturer of sealed wrm A a * "out their operations in small batches in glove boxes, amination outside these structures is limited almost s" (see pages 14-4 and 14-5, section 14.2), ne
' different since there is extensive area contamination, iation of the old sewer system, and there is a facility ;
torization of the USNRC (e.g., the WHUT Room). I recommendations for the reference sealed source l ers is inappropriate.
, y E .m . .
m .s jfg N. J.2Qt,> Q %ac w.m s:s, there are considerations that go beyond immediate
.b.*
, .y v , .w:. ScT41hW,'$syfMN unrestricted use. Both DECON and SAFSTOR will um ..oc. nuwever, the GEIS clearly states that the overwhelming advantage of SAFSTOR at a facility like AMS is the reduction in occupational exposure and the quantities of radioactive waste from radioactive decay. De ALARA analysis shown on page 15 of the Conceptual Decommissioning Plan further demonstrates this advantages.
- U. S. Nuclear Regulatory Commission, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" NUREG4586, January 3
(4) The mission of the USNRC is to ensure adequate protection of the public health and safety.
the common defense and security, and the environment from the use of nuclear materials in the United States. The USNRC and its licensees share a common responsibility to protect the public health and safety. Once a facility like AMS has reached the end of its uselbl life, there is no question that it must be decommissioned. Ilowever, decommissioning means that the facility must be placed in a condition such that there is no unreasonable risk to public health and safety. It would be contrary to the mission of the USNRC to categorically reject the SAFSTOR option as a decommissioning alternative for AMS. Furthermore, since the eventual goal of SAFSTOR is release of the site for unrestricted use, and since the cost of on-going surveillance maintenance, as well as eventual decontamination and waste disposal is included in the cost estimate for the Conceptual Decommissioning Plan, there would be no additional fmancial burden to the taxpayers of the state.
(5) The USNRC, in its October 20,1988 letter to Dr. Seymour S. Stein (AMS), conct.rred with AMS's February 8,1988 and July 6,1988 request to delay decontamination of the WHUT Room until personnel exposure rates are reduced significantly. (In the July 6th letter, AMS stated that:
"To move this material from its present safe concealment through the general public envir.onment merely to deposit it at another safe concealment presents unreasonable and unnecessary man-rem exposure and risk to the public heahh and safety at an unjustifiable exposure".) Since the Conceptual Decommissioning Plan that is the subject of this letter was developed with similar concerns in mind, AMS respectfully requests that the USNRC reconsider its current position on SAFSTOR in light of its previous position that " isolation can be carried out safely with some benefit in the reduction in occupational exposure and waste requiring disposal" (see page 1 of the October 20,1988 letter from A. Bert Davis to Dr. Stein).
Action Taken: None required.
Agency Comment: Table 3 to your Conceptual Decommissioning Plan entitled " Manpower and Cost Estimates
- lacks the specificity the NRC needs to verify your cost estimate. Resubmit your cost estimating table using the format provided [ citation given].
AMS Response: Concur.
Action Taken: Included herein as Attachment 2 is additional cost information for the SAFSTOR l option. This information is presented in the same format as Appendix F of USNRC Regulatory Guide 3.66, " Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30,40,70 and 72" (June,1990). '
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ATTACHMENT 1 ;
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(' Solutions, Inc. I
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! April 11,1996 i' i
-l Ms. Caol D. Berger i' integrated Environmental Management, Inc.
- 1680 East Guide Drive J
j Suite 305. j
- Rockville, Maryland 20850 'l l
- Dew Caol
! I have reviewed the letter dated March 20, 1996 from the U. S. Nuclear Regulatory. .
! Corr.,v.' ksi (NRC) to your customer, AMS, regarding the Conceptual Decommissioning l i Plan of the AMS Facidty. It is my opinion that, based upon the effect of the hydraulic j gradient in the vicinity of the basement when the basement contained water, the i additional sampling of soils below the basement and the WHUT room floors should not .
3 be required. According to the evidence, it is unlikely that contamination migrated from l j the building to these soils, and, therefore, conditions in the soils would not have '
f changed due to the flooding of the basement referenced in the NRC's letter. .i l
Following is a brief recap of the evidence and the historical events: .j
- 1. Prior to the flooding, three core samples were obtained from native soils under the basement in the vicinity of the WHUT room. Contamination was not discovered in any of the samples:
- 2. Based upon a suspected discharge of rad'coctive contamination. the outfall of the AMS Building basement drainage system was plugged by the local sewer authority.
As a result, ground water that normally was carried off site by tlw drainage system began to occumulate and enter the basement:
- 3. Prior to the removal of the water from the basement, monitoring records show the water elevation in the drainage system to be higher than the water level in the basement. Additionally, during the removal of water from the basement, the surfooo elevation of the basement water was intentionally maintained below the waterelevationin the drain system:
- 4. Sinoe the flooding, the basement drainage system was closed in place and has been replaced with a new subsurface perimeter 4ain system: and,
- 5. The new drain system is utluzad to remove ground water from the soils around the basement by pumping collected water into aboveground storage. Contamination has not been discovered in the removed water, and the water has been dscharged to the local sewer. Since the initiation of the pumping, the basement has been dry. .
Cosporate Office 134 Holiday Coust, Suite 306. Annapolis, MD 21401 Telephooe. (410)841-5552 Fax- (410)266-5588
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Quality Environmental Solutions. Incorporated Carol D. Berger
. April 11,1996 Page 2 My conclusion that soil conditions did not change during the period when the basement was flooded is based upon the following:
- 1. The original drainage system created a local sink, collecting ground water from the basement vicinity and maintaining the ground water level below the basement floor. The water level observed in the drain is representative of conditions in the surrounding soils. In addition to intercepting ground water flowing toward the basement, the new drainage system is also hydraulicolly connected to the soils surrounding the basement floor:
- 2. The differential water levels between the drainage system and the basement during the period in which the basement conicined water indicate a positive hydraulic ,
I gradient from the surrounding soils toward the basement. Water would not leak out of the basement under these conditions: and, if water was leaking from the basement, contamination could be expected to show ;
up in the water that is collected by the new drain system. Therefore, the lack of i contamination in the removed water otso indicates that the ground-water flow was toward the basement during its flooded .. viod.
Thank you for the opportunity to be of servi , on this project. Please coli me at 410-841-5552 if you have any questions regarding this letter.
elf, I
h Donald E. n . P.G.
! Registered H ogeologist I-
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ATTACHMENT 2 6
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l Cost Estimating Table - SAFSTOR Alternative
~ (USNRC Regulatory Guide 3.66, Appendix F)
Table 1 Planning and Preparation Task Work Days Total Cast Supervisor Fortsman HP Clerical Total ($)
- Preparation of Documernation for Regulatory 4 4 2 0.5 10.5 4560 Agencies Sutunitial of Decommissioning Plan to NRC 10 10 10 1 31 14*;d when required by 10 CFR 30.36 '
Development of work plans 10 10 10 1 31 14360 Procurement of Special equipment - 2 2 0 0.5 4.5 1680 Staffiraining i 1 1 0.5 3.5 1620 Claracterization of radiological condition of,he 20 20 5 2 47 19520 facility (including soil asui tailings analysis t t '
groundwater analysis,if applicabic)
Other 0 0 0 0 0 0 Total 47 47 28 5.5 127.5 56400 l
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Table 2 I Position Unit Cost for Workers Worker Cost / year ($)
Basic Salaries ($/yr) Overhead Rate (%) y Supervisor 60000 100 120000 Foreman 40000 '100 80000 I CraAsman 30000 100 60000 Technician 30000 100 60000 Heahh Physicist 80000' 100 160000 I
' Laborer 30000 100 60000 Clerical 20000 100 40000 1
j Decose-imaria= and/or dismantling of Radioactive Facility consponents 'i No. Dian==< No. Discusions I Glove Boxes 0- n/a Amount of Floor -
200 m2 Space Fume Hood 0 n/a Ventiladon -
50 m ductwort
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Hot Cells ' 1 27 m' Amount of Wall -
3100 m' Space Lab Benches 0 ' n/a Other - -
Sink and Drain 2 25 m ' ~ -
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Work Days Total Task Cost .
Super Forem Techai flP Crafts Labor Total ($)
nsor an cians men er 4
l Decon/ dismantle major components and/or 10 10 20 2 0 15 57 17680 processing storage tanks (llot cell S AFSTOR and decon after SAFSTOR)
Decon/ dismantle laboratorica, fume tuxxis, glove - - - - - - - -
boxes, bencies, etc.
Decon/dismantic waste areas (radwaste area, scrap 3 12 15 3 0 15 48 14400 recovery, other) WilUT room Decon/ dismantle service facilities (maissenance 14 55 65 8 22- 65 229 65920 shop, decontamination areas, ventilation systems, other) includes llEPA synem and misc. Areas Decon/ dismantle waste treatment facilities arul - - - - - - - -
storage areas on site (including exhume and package contamimted soil and tailings, if any)
Monitor for compliance, reclean and monitor, if 2 8 10 2 0 10 32 9600 necessary Other (e.g., contractor fees) 80 0 0 0 0 0 80 38400 Table 4
' Equipment / supply Quantity Cost Personnel protective equipment I tot 18000 Misc. Decon supplies I tot 20000 Security system upgrade SAFSTDR Iea 2000 Office supplies, misc. other i lot 2000 Survey equipment i lot 4000 4 Decan equipment rental 4 mo. 20000 Misc. items for 50 yr. SAFSTUR I lot 50000 Total I16000 9
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l' 1 i Table 5 Waste type Vohune (m') No. Of containers Type of Container Unit Cast of Cost of Container Container l
11W 2.83 i B-25 500 500 Asbestos 0.59 4 Drum 35 140 l Total 3.42 5 - -
640 Table 6 ta==:=
Distance shipped 2525 (miles)
Unit Cost for shipment 2.65 (3/ mile / truckload)
Additional Charges . Overweight 0 ($/ mile)
Additional Charges - Surcharge 0 (Vmile)
Waste Type No. Of shipments Unit Cost for Distance Shipped Surcharge ($) Transportation shipping (t) (miles) Cost ($)
LLW I 2.654 700 0 1855 Asbestos 1 2.65 1825 0 4836 Total 6691 Table 7 Burial Charges 340 ($/A')
Surcharges - Per container 0 ($)
Surcharges - Disposal 0 ($/n')
Waste Type Burial Volume (A*) Unit Cost of Burial Surcharge ($)- Burial Cost ($)
($/ft')
Class A LLW 100 340 0 34000 l
Asbeatos 21 150 0 3150 i Total 37150 10 1
Table R l
i Restoration of Contaminated Areas on Fr.cility Ground Task Work Days Total Cost ($)
Supervisor Foretuan llP Clerical Total !
Dackfill am 0 0 0 0 0 0 restore site Table 9 Final Radiation Survey ,
Task Work Days '
Total Cost ($)
Supervisor Foreman llP Clerical Total Outdoor release 36 40 20 87 1 43040 survey Building release 12 15 6 0.5 33.5 14480 survey Total 48 55 26 f.5 130.5 57520 l
Tahle 10
_ > une Site Stabilization, Img-Term Surveillance (if applicable)
Task Work Days TotaiCost CD Supervisor Foreman llP Clerical Total On-going 125 600 62.5 125 912.5 312000 buildirig maintenance and y yt @ yd , my; 11