ML20202B796

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Advises of Agreement to Provide Necessary Funds to Decontaminate Facility to Be Released for Unrestricted Use
ML20202B796
Person / Time
Site: 07000371
Issue date: 06/06/1986
From: Diederick G
UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.)
To: Crow W
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
27077, NUDOCS 8607100417
Download: ML20202B796 (12)


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Mr. W. T. Crow, Acting Chief M

Fuel Processing and Fabrication Branch 4

3 Division of Fuel Cycle and Material Sataty

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U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Subj ect:

Financial Surety for Decommissioning Montville Plant License SNM-368

Reference:

1) Letter W. F. Kirk to W. T. Crow dated January 22, 1986 (NIS 86-1-9)

Dear Mr. Crow:

By Reference (1) UNC Naval Products Division of UNC Resources, Inc.

submitted its cost estimate and financial surety plan for decontamination of the Montville Plant in-event of termination of fuel processing at that location and of the subject NCR license.

UNC Resources, Inc. agrees herewith to provide the necessary funds to decontaminate the facility so that it may be released for unrestricted use.

Very truly yours, d

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UDC DAVAL PRODUCTS R. Gregg G. Amy Teiec,one rosis48 isR. Guest Uf1C

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67 saney oeseri noso Uncasene. Connecticut 06382 098i n u unevriuiv st' Memorandum NIS-86-3-23

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cate March 28, 1986 MAY 2 81986 T

R. Messenheimer W. F. Kirk j[

sveiect Financial Surety for Decommissioning From

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The Montville Plant;NRC License SNM-368 Enclosed is a marked up copy of the previous letter submitted to the NRC concerning UNC's financial commitment to decommissioning.

Would you send me an equivalent letter for my transmittal to NRC. As an officer of the Corporation, you could sign the letter.

The NRC has just made this request in response to our renewal request.

I have also enclosed for your information, a copy of the proposed.

decommissioning plan which we have recently submitted to the NRC as part of our license renewal application.

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UGC DRVAL PRODUCTS

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R. Gregg G. Amy Uf1C

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s7 saney oeseri noaa Teie:,one 203/e48 i58. Guest Uncasvdte Connecticut 06382 o981

-I Memorandum NIS-86-3-23 7

R. Messenheimer care March 28, 1986 W.F. Kirk.,'f[

s 4 ect Financial Surety for Decommissioning From j?

The Montville Plant;NRC License SNM-368 Enclosed is a marked up copy of the previous letter submitted to the NRC concerning UNC's financial commitment to decommissioning.

Would you send me an equivalent letter for my transmittal to NRC. As an officer of the Corporation, you could sign the letter.

The NRC has just made this request in response to our renewal request.

I have also enclosed for your information, a copy of the proposed,

decommissioning plan which we have recently submitted to the NRC as part of our license renewal application.

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UNITED NUCLEAR CORPORRTIOn

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Ur)CCrescent Plaza 7700 leesburg Pike Falls Church, Virginia 22043 0 03) 821 7900

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S ;;d er 2^, -l^O Mr. W. T. Crow fdCb7 Fuel Processing and Fabrication Branch Division of Fuel Cycle and Material Safety I

U.S. Nuclear Regulatory Conunission Washington, D.C. 20555

Subject:

Financial Surety for Deconunissioning Montville Plant License SNM.368.

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Reference:

1) 4E W 4 4M M M G O # MM fp/g//$>Tf 2 t., J9/4" (NIS SbN~V) t

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Dear Mr. Crow:

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By Reference (1), ".it;d ".ci:: p"mommu.< oe owc As~*"sc.

and financial surety plan for decontamination of the Montville Plant in-7^m event of termination of fuel processing at that location and of the subject NRC license.

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to provide the necessary fuAds boy -

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^""a"""^a. agrees herewith h facility so that it may be released for unrestricted use t

Very truly yours, l/M C-L""'"" '4830U)tlCArQ' '/JVC-

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x Vic;e President and C;.. ::ller

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UNITED nUCLERR g

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CORPORATIOr1 I

Unc Crescent Plaza John V. Okulski 7700 Leesburg Pike vice President Fa!!s Church Virginia 22043 4

and Controller (703) 821 7900 November 21, 1978 W. F. Kirk United Nuclear Corporation Naval Products Division 67 Sandy Desert Road Uncasville, Connecticut 06382

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Dear Mr. Kirk:

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Enclosed is letter to the U.S. Nuclear Regulatory Commission re financial surety for decommissioning Montville Plant, License SNM-368, per the request of R. C. Johnson's memo of November 11, 1978.

Very truly yours, lb 1

wry rs;sq J n V. Okulski V

e President and Controller

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Enclosure 6h.%,

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UNC NA'.'AL FRODUCTS

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License SNM-368 Chapter 7 Page 7-1 Date:l/22fS6 Docket No.70-371 Rev.0 i

CHAPTER 7 - DECOMMISSIONING PLAN 7.1 General Provision for decommissioning will be made should UNC decide to terminate this license. The facilities and site shall be decontaminated so that release for unrestricted use may be made in compliance with Tabre 7.1.

We have hay prior experience in decommissioning a similar, but mere extensive facility in 1975-1976 with no unexpected problems.

7.2 plan Only a small' portion of the plant facilities (approx. 10%) is operated with any contamination present that would require cleanup upon,

decommissioning. The contamination is alpha type from non-irradiated enriched uranium.

Present sa:pling of the sanitary field shows that the requirenon:c of Table 7.1.9 Cptien 1 are met. Reference letter W. F. Kirk to W.

T.

Or:w dated Cctober 29, ;955..

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Plant areas requiring decentamination for radioactive material at the time of decc :issicning cf the plant shall be handled in ac:Ordance with the felicwing plan.

1.

Establish centaminated equipment / utilities / f acilities listing.

2.

Review listing fer pctentia; criticality / health physics hara:is.

3.

Using experienced persenne;/ existing decon facilities.

e a.

Decontaminate useable equipment.

b. Decontaminate unuseable equipment-dispose.

4.

Disasse=ble/ cut up ventilation system. Watch for any accumulati0n beyond a specific volume. Decon and/or ship for burial (NRC approved sites) if uneconcaical to clean.

5.

Disassembic/ cut up drain / rad. waste systems. Watch for any accumulation beyond a specific volume (collect sludge). Dec.-

and/or ship for burial.

6.

Decon the buildings (walls, roofs) and/or tear down, cut up and dispose by burial.

7.

Decon and/or tear up floors, foundations, cent. minated ear;h and

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ship for burial.

Page 7-1

T ab le. l.:

A. ACCEpTAHI L tilRf ACL t.r 0 7)ll CoritAtilitAlluti Lly[tj 1:UCl.1 DE*

C AVERACE JtA XIllU!

REMOVABLE "-

2 2

2

-nat, U-235 U-238, and 5,000 dpn a/100 cm 15,000 dpn a/100 en 1,000 dpa a/100 cm ssociated decay products 2

2 2

ransuranics, Ra-226, Ra-228, 100 dpm/100 cm 300 dpn/100 cm 20 dpa/100 cm h-280, Th-228, Pa-231, c-227, 1-125, 1-129 h nat, Th-232, Sr-90, 1,000 dpm/100 cm 3,000 dpm/100 en 200 dps/100.ca 2

a-223, Ra-224, U-232,

-126, 1-131, I-133

.ta-Camma Emitters (nuclides 5,000 dpm BY/100 cm 15,000 dpm By/100 cm 1,000 dpa Sy/100 cm 2

2 ith decay modes other than tipha entssion or spontaneous

!ssion) except Sr-90 and ithers nnted above.

here surface contaninatio,n by both alpha-and beta gnnna emitting nucitdes exists, the limits established for alpha-and beta gamma-emitting nuclides should apply independently.

'As used in this table, dpm (disintegrations per rainute) nenns the rate of emicston by radioactive material as determined by correcting the counts per minute observed by nn appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

Teacurcacnts of average contaninant should not be averngcel over mnre than I square ceter. For objects of less f,,

curface area, the averaCc should be derived f or each such object.

1 C) e 2

The eaximum contamination level applies to en nrea of not note than 100 cm.

"The amount of renovable radioactivo material per 100 en of surface area should be determined by wiping that area with dry illter or soft absorbent paper, applying moderate precoure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.

When removable contamination on objects of less surface area is determined, the* pertinent levela should be reduced proportionally and the entire surf ace should be wiped.

The average and maximum radiation icvels associated with surface contaninntion resulting f rom beta gamma emitters "f

should not exceed 0.2 mrad /hr at I cm and 1.0 nrnd/hr at I cm, renpcettvely, mensured through not more than 7 E

n1111grans per square centineter of total absorber.

ROM.

Re-ulatory cuide 1.86,,," Termination of. Operstdng License for tiucicar Reactors", Revicion 0, July, 1982.

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UNC NAVAL PRODUCTS d(

License SNM-368 Chapter 7 Page 7-3 Date : l/ 2 2,* E 6 Docket No.70-371 Rev.0 TABLE 7.1 S.

SUMMARY

OF SOIL DISPOSAL OPTIONS 1.

Disposal of acceptably low concentrations (which meet EPA cleanup standards) of natural uranium, depleted or enriched uranium, and uranium ores with no restriction on burial method.

The concentrations specified for this option are acceptably 1cw withoUt restricting the method of burial. It is expected, however, that currently licensed operations will be conducted in such a manner as to minimize the possibility of soil contamination and when or if such occurs the contamination will be reduced to levels as low as reasonably achievable.

2.

Disposal of certain low concentrations of natural uranium 2nd depleted or enriched uranium (with no daughters present) when buried under prescribed conditions with no land use restrictions and no continuing NRC licensing of the material.

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Under this cptien, burial will be permittcd enly if it can be

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denenstrated that the buried materials will be stabilized ir place and not be transported away from the site. Acceptability cf the site for disposal will depend on tcpographical, geolegit-1, hydrolegical and meteoroicgical characteristics cf the site. At a ninimum, burial depth will be at least fcur feet belew the surface.

Disnesal Cetiqcs (pC,/gn)

Kind of "aterial la 2b Natural Uranium (U-238 + U-234) 10 with daughters present and in equilibriun Ocpleted Uranium Soluble 35 100 Insoluble 35 300 Enriched Uranium Soluble 30 100 Insoluble 30 250 a

Based on EPA cleanup standards.

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b Concentrations based on limiting individual doses to 170 mrem /yr.

Page 7-3

J UNC NAVAL PRODUCTS 4

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License SNM-368 Chapter 7 Page 7-4 Date:l/22/56 Docket No.70-371 Rev.0 d

8.

During above operations, contain/ sample any runoff (rain, snow, water, etc.) or gaseous effluent as necessary.

9.

Decon equipment, tools, clothing, etc. and disassemble decon area. Collect sludge, dust, etc.

10.

Sample remaining earth, water (ponds, wells, pipes, etc.) waste disposal systems going off site. Statistically evaluate to requirement. Prepare report.

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11.

Review with Federal, State, local agencies as required.

7.3 Cost Estimate UNC has experience in decommissicning and decontamination for unrestricted use of a similar facility. Its former care manufacturing shcps in New Haven, Conne :icut, were decontaminated i: 1975-1976 and released for unrestricted use by the U.S.

Nuclear Regulat:ry Cenmission en April 22, 1976.

Based en this recent actual experience, UNC estimates the cest, measured in current dollars, will not exceed $1,150,:00.

The New Haven decontamination w:rk included 9 truc}.1:2ds cf piping, Obsclete equipment, concreto, earth and ducting. In zur est'=ato f:r the M:n:ville program, we have provided for 18 truckl: ads, thcugh we expe:: it to be less than 6 truckloads.

Cos Preakdown a

Item Cost 18 truckloads (including burial) 5720,C:0 Contractor 15 0, 0 ". :

UNC Expenses 150,;CO Centingency 160<0C*

Total

$1,150,000 No irradiated material is involved in the contamination, only natural uranium which has been enriched in the U-235 isotope.

This estimate is believed to be conservative because of the

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following factors:

Fage 7-4

UNC NA"AL PROOUCTS

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License SNM-368 Chapter 7 Page 7-5 Da t e : 1/ 2 2.' 9 6 Docket No.70-371 Rev.0 1.

UNC's decontamination experience.

2.

The fact that the New Haven operation had included processes no longer used and which created more severe contamination in the floor areas.

3.

The fact that the Montville Plant was designed for its purpose initially, with design features intended to minimize spread of contamination and facilitate cleanup on both a routine basis and final decommissioning. The New Haven buildings pre-existed and at were adapted to nuclear material manufacture.

The New Haven decontamination was performed by UNC employees under UNC supervisien.

7.4 Financial Assurances UNC considers that its depreciaticn policy, initiated in 1972 at tinc of its decision to consclidate Civision cperations in Men:ville.

provides full security f:r cost cf decc missioning.

Oopreciation for the facility is en an accelera cd basis, with the main buildings to be depreciated to a 201 residual value in 20 years under the terms of UNC's supplemental agreement with the Department of Energy of April 6,

1972. At the expiratien of the 20 year pericd.

straight line depreciatien will be charged until the boek value ;2 reduced to zero.

The facility is of =cdcrn, ene-s:Ory ccnstruction with excellent rail and highway access. Ecplacement ccst for the Montville bu;1 dings 1:

March 31, 1978 was $25,314,000 and net bcok value was $5,509,000. *NC considers that the excess of replacement cost cvor bco? "ilte pr:vides an ample suroty for the S1,180,000 decommissioning ccst, and that the accelerated depreciation =ethod, with book value to be reduced ::

zero, will provide continuing assurance of assets well in excess f

the small decommissicning cost.

i Page 7-5

s' Docket No.

70- 31}

T0:

William 0. Miller, License Fee Management Branch

SUBJECT:

MATERIALS LICENSE AMENDMENT CLASSIFICATION APPLICANT:

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License No:

S MM %%

Fee Category:

Application Dated: 3 0 # t.

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Received:

1.

The above application for amendment has been reviewed by NMSS/ REGIONAL 0FFICE in accordance with 5170.31 of Part 170, and will require an amendment to the license.

2.

The application is not subject to fees because it was filed (a) pursuant to written NRC request and the mandment-is-being-issued-for-the-convenience-of-the-Gomirssionr-or (b)

Other (State reason)

Signature U

Date "5090 2.5,,19 k b O

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