ML20245A664

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Rev 0 to Decommissioning & Closure Plan
ML20245A664
Person / Time
Site: 07001113
Issue date: 05/01/1989
From:
GENERAL ELECTRIC CO.
To:
Shared Package
ML20245A590 List:
References
NUDOCS 8906220111
Download: ML20245A664 (68)
v • d • e


Text

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GE NUCLEAR ENERGY NUCLEAR FUEL & COMPONENTS MANUFACTURING WILMINGTON, NORTH CAROLINA l

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DECOMMISSION.NING AND CLOSURE PLAN l

O MAY 1, 1989 l

3 NRC LICENSE SNM-1097 DOCKET 70-1113 O

DOC '

13 B

PDC 3

TABLE OF CONTENTS O

Section Title Page

1.0 INTRODUCTION

1-1 2.0 FACILITY DESCRIPTION 2-1 2.1 Site Location and Layout 2-1 2.2 Plant and Operations 2-6 2.3 Operational Features Relevant to 2-13 Decommissioning and Closure 3.0 GENERAL DECOMMISSIONING AND CLOSURE GUIDELINES 3-1 4.0 PLANT-SPECIFIC DECOMMISSIONING AND 4-1 CLOSURE ASSUMPTIONS 5.0 DECOMMISSIONING AND CLOSURE ORGANIZATIONAL 5-1 STRUCTURE 6.0 DECONTAMINATION, DISMANTLEMENT AND CLEAN-UP 6-1 METHODOLOGY 6.1 Wet Uranium Process Areas 6-1 6.2 Dry Uranium Process Areas 6-4 6.3 Indoor Contained-Uranium Process /

Storage Areas 6-8 6.4 Outdoor Contained-Uranium Storage Areas 6-9 6.5 Uranium-Bearing Process / Storage Tank Areas 6-11 6.6 Uranium-Bearing Lagoon Areas 6-15 6.7 Hazardous Waste Material Areas 6-18 7.0 RADIOLOGICAL AND INDUSTRIAL SAFETY 7-1

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TABLE OF CONTENTS O

Section Title Page 8.O GENERAL DECONTAMINATION AND CLEANING METHODS 8-1 9.0 WASTE MANAGEMENT 9-1 10.0 DECOMMISSIONING AND CLOSURE SCHEDULE 10-1 1

11.O FINAL RELEASE 11-1 12.0 DECOMMISSIONING AND CLOSURE COST ESTIMATE _S_

12-1 S

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13.O FINANCIAL ASSURANCE AND RECORD KEEPING 13-1 I

14.O REFERENCES 14-1 i

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l GE-WILMINGTON PAGE DATE 5/01/89 PAGE i,viGISSIONING AND CLOSURE PLAN REVISION 0

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LIST OF FIGURES Figure Title Page 2-1 Plant Site - State and County Locations 2-2 2-2 New Hanover County and Adjacent Counties 2-3 2-3 Plant Site (Heavy Outline).and Environs

.2-4' 2-4 Principal Buildings and Facilities 2-7 2-5 Plant Entrance 2-8 2-6 Simplified Process Flow 2-9 2-7 Process Liquid Waste Treatment 2-12 5-1 Site Organization for Decommissioning and Closure 5-2 6-1 Removal and Decontamination Sequence for Wet 6-3 Uranium Process Areas 6-2 Removal and Decontamination Sequence for Dry 6-6 Uranium Process Areas 6-3 Decontamination and Disposal Sequence for Dry 6-7 Uranium Process Areas 6-4 Decontamination and Disposal Sequenca for Indoor 6-10 O

Contained-Uranium Process / Storage Areas 6-5 Disposal Sequence for outdoor Contained-Uranium 6-12 Storage Areas 6-6 Decontamination and Disposal Sequence for Process /

6-14 Storage Tanks 6-7 Decontamination and Disposal Sequence for the 6-17 Uranium-Bearing Lagoons and Equipment 10-1 Decommissioning and Closure Schedule 10-2 13-1 Corporate Commitment Letter 13-2

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LIST OF TABLES Table Title Page 2-1 Uses of Developed Areas of the Plant Site 2-5 3-1 Acceptable Surface Contamination Levels 3-2 l

8-1 Typical Tools and Equipment for Dismantlement 8-3 l

l 12-1 Decommissioning and Closure Cost Estimates 12-2 O

h GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 9

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1.0 INTRODUCTION

O General Electric's nuclear energy business, known as GE Nuclear Energy, is headquartered in San Jose, California, with the manufacturing facility located in Wilmington, North Carolina.

For the purpose of this document, the Wilmington facility, currently known as Nuclear Fuel and Components Manufacturing, is identified as GE-Wilmington.

The manufacturing of nuclear fuel, and reactor components is conducted at GE-Wilmington.

In addition, the GE-Wilmington site also includes.a plant for manufacturing GE aircraft engine parts that are shipped to other sites for assembly.

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The Decommissioning and Closure Plan is prepared and submitted as evidence of GE-Wimington's compliance with Chapter 7 of Special Nuclear Materials License SNM-1097.

It is written in conformance to the " Guidelines for Decontamination of Facilities and Equipment Prior to O

Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material,"

(NRC. August 1987), and 10 CFR 70, and to demonstrate financial capability to support decommissioning and closure activities.

The Decommissioning and Closure Plan also addresses site closure requirements as specified in the Resources Conservation and Recovery Act (RCRA), 40 CFR 265, Subpart G.

Decommissioning and closure activities will include the cleaning and removal of radioactive and hazardous waste contamination which may be present on materials, equipment and structures.

Cleaning effectiveness will be assured by verification.

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GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION O

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The Decommissioning and Closure Plan provides information concerning the plant, the types of items to be decontaminated, the disposition of facilities used for hazardous materials, the assumptions upon which the cost of decommissioning and closure is derived, and an estimated schedule of time it will take for decommissioning and closing the facility.

Financial considerations are also included.

Currently there are several studies and programs in progress to terminate the use of process lagoons and to recover the waste from these lagoons.

The Decommissioning and Closure Plan for GE-Wilmington is predicated upon removal'of lagoon sludges and other slightly contaminated materials (e.g.,

calcium fluoride) from the site prior to initiating decommissioning and closure activities.

It is the intent of GE-Wilmington to decommission and close the facility so as to reduce the level of radioactivity remaining in the facility to residual levels acceptable for release of the facility for unrestricted usage and for NRC license termination.

i It is important to recognize that GE-Wilmington has been in operation since 1969.

This facility has procedures, personnel, instrumentation, equipment, and funding to assure nuclear and industrial safety.

The plant is experienced in techniques for decontaminating discrete j

items and areas, and in verifying the degree to which cleaning has been accomplished.

The technology is available to decontaminate the facility; people know-how is present; and management has developed safe practices GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0

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through years of experience.

GE-Wilmington is capable i

and competent to decommission and close the plant in l

accordance with the Decommissioning and Closure Plan.

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>^os DECOMMISSIONING AND CLOSURE PLAN REVISION O

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2.0 FACILITY DESCRIPTION

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2.1 Site Location and Layout l

GE's plant at Wilmington, North Carolina, is situated on a 1,664-acre site in New Hanover County, approximately 6 miles north of the City of Wilmington.

.(Refer to maps, Figures 2-1 through 2-3.)

New Hanover County is located in the southeastern corner of the state, in the coastal plains. region.

New Hanover County is bounded by the Atlantic Ocean and by Pender and Brunswick Counties.

The region around the site is sparsely settled, and the land is characterized by heavily' timbered tracts occasionally penetrated by short roads.

Farms, single-family dwellings, and light commercial activities are located chiefly along the highways.

The major portion of the site is bordered on the east by U.S. Highway 117 and on the west by the Northeast Cape Fear River.

Fourteen acres lie to the east of U.S. 117 and are undeveloped except for water wells, an employee park, and a leased portion of the property used as a transportation terminal. The northern and southern boundaries, marked by fences, are surveyed lines through undeveloped forest and marsh lands.

Of the total 1,664 acres, only 342 acres have been developed.

The developed portion is used as shown in Table 2-1.

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GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0

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i FIGURE 2-1 PLANT SITE - STATE AND COUNTY LOCATIONS i

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FIGURE 2-2 NEW HANOVER COUNTY AND ADJACENT COUNTIES

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FIGURE 2-3 PLANT SITE (HEAVY OUTLINE) AND ENVIRONS O CASTLE HAYNE ""'&'}" g' s ?? mW o n-g \\ s s \\ \\ e C' \\ '\\ Q ) e/ ,i. m s,sogvo,LuNTcca _ '; (g sf WILMINGTON POLICE D TMEN .b, . _4 L Ne n s v, %.p.7( . ' ~ j NEW HANOVER COUNTY SHERIFFSW "O ~~ ,f' - g(;,1 y c .v-j

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TABLE 2-1 ) _USES OF DEVELOPED AREAS OF THE PLANT SITE { \\ DEVELOPED AREA Acres Manufacturing Buildings 24 l Support Buildings 3 l Waste Treatment Facilities 26 l Paved Roads, Outside Storage Areas and Parking 46 Landscaped Areas 231 Employee Recreation Area 12 O Total 342 i l l O oz-wztx1xoron rice D^TE seo1 89 rAoE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-5

2.2 Plant and Operations 2.2.1 External Appearance Figure 2-4 is an aerial photograph showing principal buildings and facilities of the developed plant area. During site development, particular attention was given to building orientation and arrangement and to landscaping. Large trees have been left standing and supplemented with more than 9,000 new tree plantings, understructure plantings, and ground cover. Parking l lots and roadways are designed to minimize adverse effects and to complement the aesthetic value of the area. Entrances to the plant have been cleared of foliage only as necessary to provide safe entrance to and from the highway (Figure 2-5); much of the natural and woods ground cover were retained. l 2.2.2 Nuclear Operations k i The fuel manufacturing process produces fuel for nuclear reactors. The process begins with the receipt of low enriched uranium hexafluoride (UF ). Conversion of UF, to uranium dioxide (UO,) powder utilizes a wet process and/or a dry direct conversion process. The UO, is pressed into pellets which are sintered, grou.nd to size and loaded 'into tubes. Loaded tubes are welded with end cap closures and asseinbled into bundles. The fuel fabrication process is outlined in the process flow diagram shown in Figure 2-6. t llk GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-6

FIGURE 2-4 PRINCIPAL BUILDINGS AND FACILITIES v;y,. .5 i' ,yT ,,,. i, i :4.0 .g -,. c, 3 n 7r pr 4 4 .+. s i. rtprwg7:n zsyyggp' <pertmwis w + y.7*7 *

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FIGURE 2-5 PLANT ENTRANCE O. 4 Ws e. .M

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FIGURE 2-6 SIMPLIFIED PROCESS FLOW RECEIVED UF L10UID WASTE a l \\ WASTE TREATMENT f URAN!UM WET DRY REC 0VERY PROCE$$ PROCESS l URAN!UM 4 RECOVERY l COLLECTION LAGOON 7 NITRATE REUSE OFFSITE POWDER PRODUCTION FLUCRIDE DISPOSAL 7 CaF OFFSITE Of5P05AL g POWDER 4 PREPARAT!DN ( LAUNDRY g WATER PELLET PRES $!NG FINAL PROCESS 4 LAGOON g ( PELLET 7 DUST 51NTERING COLLECT g DAM t g PELLET + O GRINDING g RIVER RCD LOAD l SOLID WASTE RCD CLOSURE g DECONTAMINATE!0N NON ROOM COMBUST!BLE

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g l RCD ASSEMBLY e e FABRICATION g CLEAN ~ ^ COMBUST!8LE CX10ATION PACKAGING 4 g g l g + U SC#N URAN!UM g DISSOLUTION S M I P P ! 'c G RECOVERY c' WASTE g OX10ATION-U RECOVERY REDUCTION OR SHIP TO SOLVENT BURIAL EXTRACTION PRECIPITATION BURIAL l CENTRIFUGE POWOER RELEASE FOR l PRODUCTION UNRESTRICTED

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2.2.3 Non-Nuclear Operations In addition to the fuel manufacturing operations described above, other activities at the site include' l the manufacture of. auxiliary equipment for nuclear reactors, the fabrication of-zirconium components for fuel assemblies, and the machining of aircraft engine l rotating parts. These activities are typical of conventional metalworking plants and are performed in facilities physically separate from the fuel' manufacturing building. 2.2.4 Effluent and Waste Handling Systems 2.2.4.1 Storm Waters A surface drainage system controls storm water runoff. This storm system drains runoff from the site via a natural channel creek, which empties into the Northeast O Cape. Fear River. This creek lies entirely within the site property. 2.2.4.2 Sanitary Wastes l Wastes originating in washrooms and sanitary facilities are routed to a sanitary. waste treatment system. The treated effluent from the system is discharged into the Northeast Cape Fear River. In addition to the main sanitary treatment system, seven small septic tank systems handle sanitary wastes at facilities which are remote from the main buildings. lk GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-10

2.2.4.3 Process Liquid Wastes O Process liquid wastes originating from the site operations are collected and then either treated in tne process waste treatment systems prior to release so that the resultant combined discharge to the river meets government regulatory requirements or are sent to a licensed or permitted off-site disposal site. A flow diagram of the process liquid waste treatment is.shown in Figure 2-7. The waste collection systems are designed to collect chemically compatible wastes for the subsequent treatment processes and to prevent entry of incompatible wastes into these systems. 2.2.5 Solid Wastes I Waste materials include packaging, used shop clothing, s tools, scrap material, and process equipment. Waste material is collected (and stored pending disposal) according to two primary classifications: (1) contaminated with uranium or (2) not contaminated with l uranium. The contaminated material is further l segregated between combustible and noncombustible. Contaminated noncombustible wastes (includes filters I from the air cleaning system, pumps, motors, valves, metal containers, segments of process piping, various filter and centrifuge sludges) are either decontaminated or collected in boxes for ultimate burial off-site-at a j l low-level radioactive waste disposal facility. l l () GE-WILMINGTON PAGE DATE 5/01/89_ PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-11

FIGURE 2d PROCESS LIQUID WASTE TREATMENT FUEL MANUFACTURING FUEL COMPONENTS SERVICES COMPONENTS OPERATION OPERATION OPERATION AND AIRCRAFT ENGINES I l SPENT SPENT ETCH SOL TlON ^%AS RECOVERED SPENT USED SODIUM AMMONIA HYDROX1DE NITRIC AClD 0 e SOLUTION SOLUTION i TREATED 4 RADWASTT-NITRATE 4: WASTE WAST OFFSITE FS USE TREATMENT AND o e DISPOSAL @ EATMEN) @ EATMEN ) O Cof2 a a WASTE TREATMENT FACluTY. NITRATE l LAGOONS SLUDGE SLUDGE i Eh;3%Q OFFSITE SITE OFFSITE DISPOSAL USE TREATMENT & DISPOSAL O TREATED SANITARY WASTE TREATMENT WASTE WATER AND FACluTY FLUORIDE STORM WATER LAGOONS [ Q ADJUST h^0 N P FINAL Tl g 4 AER O BASIN 3 J PROCESS LAGOONS DAM l ^m TO RIVER GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-12

Contaminated combustible items such as wood, paper, cloth, and plastic are_ reduced to ash in a specially designed and licensed waste oxidation-reduction facility. The offgas is treated by water scrubbing and filtration. The ash is sampled and analyzed for uranium and either reprocessed or buried off site in a low-level, radioact1ve waste disposal facility. Noncontaminated waste materials that are not hazardous are removed by a local waste disposal contractor to an approved sanitary landfill. ~Non-radioactive waste materials that are hazardous (RCRA) are disposed of by I burial in an off-site landfill permitted for handling these wastes. 2.3 OPERATIONAL FEATURES RELEVANT TO DECOMMISSIONING AND CLOSURE ( 2.3.1 Procedures l Since startup in 1969, GE-Wilmington has established effective operational controls for safety in normal and abnormal situations, many of which could have application to decommissioning activities. Controlled l document systems are in place to integrate operational organizations with those responsible for nuclear safety and radiation protection. Administrative procedures and operating instructions constitute a communication I hierarchy which assures that management directives are communicated to individuals at all levels. Procedures provide for personnel, environmental, and nuclear material monitoring for routine and nonroutine operations. () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-13.

In addition, numerous maj or f acility modifications made since plant startup have resulted in the establishment (l) of procedures and controls for proper conduct of contra.-f oi personnel in nuclear activities. Abnormal operations, not covered by routine procedures, require Radiation Work Permits which specify the special safety requirements for the specific unique work to be done. 2.3.2 Organization Nuclear safety responsibilities are assigned to an organization whose charter includes the engineering and evaluation of criticality and radiological controls for all aspects of the GE-Wilmington business. Ongoing radiation protection activities are carried out by an organization, independent of production, which routinely monitors and reports radiological conditions ll) for all operations in the f.cility. A traffic / transportation organization routinely arranges for the safe transportation of nuclear material to customers and disposal sites. Each of the above functions has established operating routines to govern the conduct of work at the plant site to assure safe and compliant operations in routine and nonroutine situations and would be applicable to decommissioning activities. 2.3.3 Equipment i Air sampling systems and criticality / radiation alarm systems are available to provide information concerning airborne uranium concentration and radiation levels. These systems provide data for radiation exposure GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-14

evaluations of personnel working inside radiation control areas and continuously monitor the site for a P criticality incident. The fuel manufacturing building air filtration system which consists of HEPA filters and scrubbers provides a high degree of environmental safety and control during plant operations. Stack sampling systems provide continuous monitoring for assurance that no contamination above regulatory limits are released to the environment. These systems will remain operational during decommissioning'and closure. l The on-site laundry facility will be maintained to provide cleaning facilities for protective clothing and respirators used during decommissioning and closure activities. Equipment in the laundry also provide the capability for decertifying respiratory protection equipment and filters prior to use as a part of the O-respiratory protection program. Radiation protection equipment currently used to measure and evaluate radiological samples will be available during decommissioning and closure. The GE-Wilmington fire protection system will be available throughout the deco;amissioning and closure j operations. This consists of fire alarm boxes, sprinkler systems, hoses, extinguishers, pumps, and a water supply provided through the site water tower or the emergency fire water pond. Personnel fire protection equipment such as self-contained breathing apparatus (SCBA) equipment and rain gear will be I () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-15 1 w

maintained and a.ailable. Additionally, fire response capability by outside agencies is available as needed. g The in-plant communication systems consisting of public address, telephone, and radio will be maintained during decommissioning and closure. O i I l l GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 2-16

3.0 GENERAL DECOMMISSIONING AND CLOSURE GUIDELINES O kJ The design basis surface contamination levels, which will be used as standards in the decontamination and survey of surfaces of premises and equipment prior to disposal or release for unrestricted use, are listed in Table 3-1. General guidelines for the decommissioning i and closure effort will be:

  • A reasonable effort will be made to eliminate residual contamination.
  • Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other covering material unless contamination levels are below the limits specified in Table 3-1 prior to applying the covering.
  • The radioactivity on the interior surfaces of pipes,

(- k drain lines, and ductwork shall be determined by making measurements at all traps, and other j J appropriate access points, provided that contamination j at these locations is likely to be representative of contamination on the interior of the pipes, drain ) lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or location that the surfaces are inaccessible for purposes of measurement shall be presumed to be contaminated in excess of the limits.

  • Special requests may be made to the NRC to authorize the release of premises, equipment, or scrap having surfaces contaminated with materials in excess of the

() GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 3-1

l i TABLE 3-1 O i l TABLE 1 l 1 ACCtpTAKE SURFACE CONTAMINATION LEVELS ) NUCL10t3' AvtRAGtb c f mng!,gpqb d f AlpevABLgb e f U. net. U-235. U.238. and ) assectated decay products 5.000 dpa e/100 cut 15.000 dps e/100 on2 1.006 dem s/100 cm2 Transuranic. te.!!6. As.228 Th.230. Th.!!8. p4*231, 100 den /100 on! 300 dps/100 cm2 20 don /100 cm2 Ac.227. 1 125. 1 129 Th-nat. Th.232. Sr.90. I ka.!!3. ta.224. U.232. 1 126 C 3 dpe/100 cw2 3000 dpe/100 cm2 200 dpa/100 cm2 j l.131. I.133 { beta. game eettters (nucitdes cith eecay modes other than i elpha estssten er spontaneous $000 den py/100 cm2 15.000 dpa sy/100 cm2 1000 dpa py/100 cm2 ] fission) except $r.90 and others noted abovc. 8.fhere surface contaetnetten by b0th alpha. and beta.gasma.estiting nuC11 des eXista, the Itatts estabitshed for a1$a. and bete.gasse smitting nucIldes should apply independently. b s used in this table. dem (dtsintegrettens per etnute) means the rate of emissten by radioactive esterial as determined by correcting the A counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentatten. l 1 l Cnessurements of everage contastaant should not be averaged over more than 1 square meter. For objects of less surface area. the average j should be derived for each such object. 8The maatmum contaminattee level appites to en area of not more than 100 cm2, 'The amount of tomovable r6dioactive asterial per l'00 cm2 of surface area should be deterutned by wiping that area with dry filter er seft I chsereent paper, applying moderete pressure, and assetsing the amount of radioactive estarial en the wipe with an appropriate instrument of known efficiency. When removable contamination se objects of less surface area is determined, the pertinent levels should be reduced. i proportionally and the entire serface should be wiped. f7he average end maximum red 14tta levels associated with surface contaminatten resulting from beta. gamma emitters should not exceed 0.2 erad/hr at 1 cm and 1.0 ared/hr at I am, respectively, measured through not more than 7 milligrams per square centimeter of total absorber. I l Ref: " Guidelines for Decontamination of Facilities and Equipment I Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material." (NRC, August 1987). i l 1 h GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION O 3-2 1

limits specified. This may include, but may not bc limited to, special circumstances such as razing of 73 \\-) buildings or transferring of premises or equipment to another organization continuing work with radioactive materials.

  • Special requests may be made to the NRC to authorize special disposal methods pursuant to 10 CFR 20.

Such methods may include, but are not limited to, on-site disposal of soil which may contain licensed material in acceptable levels. I

  • Radiation exposure limits shall be consistent with allowable limits specified in 10 CFR 20, " Standards for Protection Against Radiation."

i

  • Shipments of radioactive materials associated with decommissioning and closure shall conform with the j

i regulations of Title 49 Codes of Federal Regulation s. for transporting hazardous materials. )

  • Prior to release for unrestricted use, a comprehensive radiation survey will establish that contamination is l

I 1 within the limits specified in Table 3-1. A copy of the survey report shall be filed with the Director, Division of Low-Level Waste Management and Decommissioning, Office of Nuclear Material Safety & Safeguards, NRC, Washington, D.C. 20555, and the Director of the Regional Office of the Office of Inspection and Enforcement, NRC.

  • The site will be closed in a manner that minimizes the need for further maintenance and controls to the

() GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 3-3

extent necessary to protect human health and the environment. Independent reviews of the premises will be made to verify that hazardous waste and radioactive contamination have been removed to acceptable levels and that the premises meet regulatory release limits. l l O I GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 3-4

4.0 PLANT-SPECIFIC DECOMMISSIONING AND CLOSURE ASSUMPTIONS O The on-sit,e waste oxidation-reduction facility, the As decontamination facility, and the waste uranium recovery operation will significantly decrease the amount of material required for off-site burial at the time of decommissioning and closure. The availability of these facilities and other assumptions which contribute to the decommissioning and closure activities are as follows:

  • The plant will have had normal operations in the l

interim prior to decommissioning and closure, i.e., no unplanned events have occurred to perturbate the condition of the facility at the time of decommissioning and closure.

  • All in-process production uranium will have been removed from the site prior to the initiation of decommissioning and closure activities.
  • Ey the time decommissioning and closure of the plant j

will take place, the NRC will have established by j regulation de minimis levels of special nuclear material (low-enriched uranium, specifically) i authorized for transfer to recipients not specifically licensed by the NRC and acceptable residual levels of SNM in soil.

  • An off-site facility will be available to accept uranium during decommissioning and closure.

Off-site, low-level radioactive waste burial facilities will be available. l () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION O 4-1

  • Decommissioning and closure activities will be performed by personnel 'amiliar with plant operations ggg

,and radiation protection procedures.

  • Safety control practices in place for plant operations will be utilized for decommissioning and closure activities.
  • Non-contaminated equipment and facilities will be disposed of by standard corporate practices.
  • Dismantling will be programmed and time phased to maintain waste oxidation-reduction, decontamination and uranium recovery capabilities for as long as required.
  • Uranium-bearing sludges which are incompatible with the uranium recovery process will have been removed or handled prior to the commencement of decommissioning (g) and closure activities.
  • All hazardous waste will be removed to eliminate the need for long-term monitoring.
  • Decommissioning and closure activities will result in NRC and EPA approval to use the site for unrestricted, non-nuclear purposes.
  • Decommission and closure activities will include reevaluating the latest technology for decontamination l

techniques and equipment in order to utilize those features that are the most cost effective and efficient. GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 4-2

5.0 DECOMMISSIONING AND CLOSURE ORGANIZATIONAL STRUCTURE O' Although plant personnel will perform the decommissioning and closure task, the organization structure during decommissioning and closure will differ from the current production-oriented structure. The l work will be accomplished under a project manager who will have key experienced professional support in safety related areas, safeguards, shipping, environmental protection, security, planning and operations. A typical site organizational structure identifying the functions planned for decommissioning and closure is provided in Figure 5-1. l Important functions that will be available throughout the decommissioning and closure operations are:

  • The project manager will have overall responsibility gg for all facets of the operation.

The project manager kl will be responsible for assuring that the various facets of decontamination, material handling, dismantlement, shipping, and final clean-up are done orderly, safety, and completely. j

  • The safety function will have responsibility for the l

following activities; environmental, criticality j safety, radiation protection, industrial safety and licensing activities. l

  • Criticality safety will be responsible for criticality l

safety of the uranium removal process and activities where uranium will be collected, stored or recovered. l l 1 l () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION O 5-1 I i

FIGURE 5-1 g SITE ORGANIZATION FOR DECOMMISSIONING AND CLOSURE (TYPICAL) SITE PROJECT MANAGER OECRETARY SECURITY SAFETY ENGINEERING OPERATIONS FINANCE SHIPPING FUNCTION FUNCTION FUNCTION FUNCTION FUNCTION - CRITICALITY SAFETY O - INDUSTRIAL SAFETY - RADIATION PROTECTION - ENVIRONMENTAL - LICENSING & NUCLEAR MATERIALS MANAGEMENT l GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 5-2

  • Radiation safety will be responsible for exposure control and radiological safety parameters for the es

( ) \\/ work being performed. An in-vivo lung counting facility will be used as a part of a comprehensive bioassay program to provide internal monitoring capabilities for total dose assessment.

  • Radiation protection will be responsible for working-area measurements to assure the radiation safety of employees by determining the cleanliness (lack of l

l radioactive contamination) of materials, by conducting I contamination measurements of shipments, and by nuclear release of materials to sell or use ] d elsewhere. I

  • A licensing and nuclear materials management person will be responsible for bookkeeping activities for any i

uranium inventory generated during the decommissioning i and closure activities in addition to associated f- \\ licensing activities.

  • Environmental protection will be responsible for l

evaluating sample analyses to assure the protection of I the health and safety of the public. It will assure that samples are taken and analyzed, and nondestructive measurements are made as required to verify that release criteria limits have been met for hazardous and other non-radioactive materials.

  • Industrial safety will be responsible for overseeing the industrial safety of operations which include l

l equipment usage and operations, air quality, protective equipment, and for coordinating efforts of l () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 5 -3 l l b J

( 1 l outside support agencies (fire, police, and hospital) l in the event of an emergency.

  • The operations function will be responsible for all operational activities which involve contractors, l

maintenance and craft employees. It will report directly to the project manager and will be responsible for assuring that decommissioning and closure is carried out as planned.

  • A shipping specialist will schedule trucks, coordinate loading, provide documentation, and arrange for shipments of materials to the various sites and burial facilities.
  • A facilities / process engineering function will be responsible for decontamination and decommissioning processes, including effluent treatment processes, facilities upkeep, and operation of the HVAC systems during decommissioning and closure activities.
  • The financial operations function will handle worker payroll cards, purchases, contracts, and the overall financial status of the operation.

{

  • A minimal security force will be available to provide security to equipment and to control access to the site while decommissioning and closure is underway, i

l 1 GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 5-4

6.0 DECONTAMINATION, DISMANTLEMENT AND CLEAN-UP METHODOLOGY O Archival records of modifications and/or incidents relative to radioactive or hazardous materials contamination will be reviewed to identify additional information important to the decommissioning and closure activities. I 6.1 Wet Uranium Process Areas There are a number of areas where uranium has been processed in liquid solutions such as the ADU conversion process (from UF, vaporization through hydrolysis, centrifuging and calcination), the rad waste system, the centrifuge room at the waste treatment facility, the decon facility, the uranium recovery system, uranium liquid transfer systems, sludge recovery systems, and i the waste oxidation-reduction facility. Elements of the wet uranium processing areas will include, but may not be limited to, the following types of equipment, materials and items: Containments & Hoods Process Ecuipment Curbing Pipes l Drains Pumps i Filters Resins Floor Grating Scrubber Systems Hoses Sludges Pipes Tanks ) l All items, such as carts, work tables, buckets, etc., ] that are not needed for the decommissioning and closure GE-WILMINGTON PAGE DATE 5/01/89 PAGE i DECOMMISSIONING AND CLOSURE PLAN REVISION O 6-1 i _--_-_-_a

process will be removed, transferred to the decon room for decontamination or placed in containers for off-site ggg burial. The removal and decontamination sequence for wet uranium process areas is shown in Figure 6-1. The plan for decontamination of the wet uranium process areas will be to first remove the equipment. Particular attention will be given to process lines where material could be held up. Recovered material will be processed in the waste management system until dismantlement of that system is required. All curbing will be kept intact until the potential for spillage is removed thus minimizing the spread of contamination. Work will then progress from areas with the greatest potential for contamination to areas with the least potential for contamination. Piping will then be removed and, based upon the economics of decontamination versus burial, will either ggg be moved to the decon room for uranium recovery or placed in containers for off-site burial, i l Tanks, columns, resin containers containing uranium will ] be internally cleaned to the extent possible to recover I material, reduce the volume of uranium, and prepare the iten, for disposal. In some cases it will be necessary to reduce the volume of containers by sectioning them l with torches. Attention will be paid to potential ( airborne material; evacuation of etntainments with 1 portable trunks and blowers, and re.ipiratory equipment j will be used as appropriate. Equiph.ent such as the l centrifuges, dump stations, and containments will be I ( dismantled and transferred to the decon room for I cleaning. After an initial evaluation, a determination b i GE-WILMINGTON PAGE DATE 5/01/89 PAGE j DECOMMISSIONING AND CLOSURE PLAN REVISION O 6-2 j I

l l FIGURE 6-1 REMOVAL AND DECONTAMINATION SEQUENCE FOR WET URANIUM PROCESS AREAS: l (TYPICAL) -l L 4 WORK TABLES, CONSOLES,' FURNITURE' 4 PROCESS LINES l 4 TANKS, EQUIPMENT PUMPS -] 4 i CURBING 4 CONVEYORS l 4 ( CABLE CARRIERS 4 FILTERS / VENTILATION /DUCTWORK 4- ') CEILING RAFTERS 4 WALLS 4 FLOORS, DRAINS ] l l ) (f GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-3 1 I

will be made whether to fully decontaminate it for reuse, ship to another licensee, or prepare it for g off-site burial. Conveyors, cable racks, elevators, and other like materials will be similarly dismantled and decontaminated as appropriate. After stripping the inside of the area, work will commence on building utilities and shell. Overhead piping, conduit, lights, etc. will be decontaminated or removed. Ventilation ductwork will be removed when appropriate, maintaining negative pressure until decontamination efforts in the area are complete. The i ceilings, walls, and floor will be washed, chipped, scraped and/or removed until acceptable release limits are achieved. 1 l l l l 6.2 DRY URANIUM PROCESS AREAS These are the areas where powder is blended, pressed into pellets, ground, and/or loaded into open-ended fuel rods. Also scrap is collected and processed into forms suitable for direct recycle or for feed to the uranium j recovery process. Elements of dry uranium process areas will include, but not be limited to, the following types i of equipment, materials and items: i Blenders Grinders Can Storage Loading Stations l i l Carts Pellet Presses Containments Pellet Storage Conveyors Process Equipment Desk / Work Tables Storage Cabinets Dump Stations Tile Floor GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-4

False Ceilings Ventilation Ductwork Filters Welders Furnaces Work Tables The plan for decontamination of the dry uranium process areas is to remove and decontaminate the most contaminated items first, working from the most to least contamination, maintaining all safety related items, such as ventilation, air monitoring, and radiation monitoring, through the last phase of decontamination. The removal and decontamination sequence for dry uranium process areas is shown in Figure 6-2. As with the wet uranium process equipment, after an initial evaluation, a determination will be made whether to fully decontaminate, ship to another licensee, or prepare the item for off-site burial. Large equipment to be scrapped will be dismantled and/or sectioned to facilitate decontamination or burial. The decontamination and disposal sequence for dry uranium process areas is shown in Figure 6-3. All ceiling structures (e.g., beams, support members, conduit, light fixtures, and sprinkler lines) will be systematically evaluated for contamination and cleaned or removed as necessary. It is anticipated th'at l extensive surveys will be required to evaluate the effectiveness of decontamination activities. Materials or structures found that cannot be cleaned to acceptable release limits will be removed and buried as 1 contaminated. lll GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-5 l

\\ FIGURE 6-2 REMOVAL AND DECONTAMINATION SEQUENCE FOR DRY URANIUM PROCESS AREAS (TYPICAL) BOATS, CANS 4 DESK, FILES, WORK TABLES 1 PROCESS EQUIPMENT 4 CONTAINMENTS STORAGE CABINETS 4 CONVEYORS O CEILING / RAFTERS 1 FILTERS / VENTILATION DUCTWORK 4 WALLS 1 FLOORS / SUMPS ) l i 1 i l GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-6 I i Z-- l

FIGURE 6-3 DECONTAMINATION AND DISPOSAL SEQUENCE FOR h DRY URANIUM PROCESS AREAS (TYPICAL) EQUIPMENT l PERFORM GROSS EXTERNAL DECONTAMINATION NO YES YES SOLD SURVEY / ACCEPTABLE PACKAGE FOR -SHIP TO ESTABLISH HOLDUF SHIPMENT BUYER 0 DISMANTLE PRO NO FOR SCRAP / PACKAGE FOR -> SHIP TO SALE BURIAL BURIAL SITE t YES DECONTAMINATE SURVEY FOR RELEASE NO CLEAN [ > NOT CAPABLE OF BEING s/ DECONTAMINATED YES DISPOSE g GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-7

Decontamination efforts on concrete floors will be directed towards anchor holes, crevices and cracks in ggg the floor and towards areas with higher levels of contamination. Concrete flooring will be removed as necessary to achieve acceptable release limits. Walls will be cleaned and/or removed as necessary to achieve acceptable release limits. 6.3 INDOOR CONTAINED-URANIUM PROCESS / STORAGE AREAS There are areas inside the buildings where radioactive material is stored and/or handled in sealed containers. Typically these areas are rod storage, bundle assembly, bundle, powder, and pellet packing, site shipping and site receiving. Fuel rods and fuel bundle assemblies are processed or stored in the fuel bundle area prior to shipment. In the powder / pellet packing areas, sealed cans c f powder or pellet boxes are stored prior to ggg shipmeat. Shipping and receiving areas include inspection, loading, and unloading facilities. The integrity of the fuel product handled in these areas is such that the probability of contamination is negligible and not expected. None of these areas are generally contaminated as proven by routine survey programs which monitor for contamination on containers, vehicles, and work areas. Elements of an indoor contained-uranium process / storage area may include the following equipment, materials and items: 3arrels Outer Containers Fixtures and Tools Overhead Cranes Fork Lifts Pallets l GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-8

Inner Containers Process Equipment Insulating Material Scales Li.ft Straps Locking Rings The areas will have been cleared of packed powder, pellets, fuel rods, bundles, and other radioactive materials prior to the beginning of decommissioning activities. Systematic radiation and contamination surveys will be made to verify the absence of contamination or that it is below release limits. The decontamination and disposal sequence for indoor contained-uranium process / storage areas is shown in Figure 6-4. 6.4 OUTDOOR CONTAINED-URANIUM STORAGE AREAS There are areas outside the buildings where containers with uranium are stored. Normally these areas consist of asphalt or marl pads containing (1) boxes of material to be sent to burial sites, to be processed at the waste-oxidation reduction facility, or being stored for later use, (2) 55-gallon drums of waste, oil, etc., awaiting disposal, (3) shipping containers of fuel bundles, pellets and powder, (4) 3 or 5 gallon cans of scrap powder, and (5) UF, cylinders. Elements of an outdoor contained-uranium area may include, but may not be limited to, the following types of equipment, materials and items: 3 or 5-Gallon Cans Metal Shipping 55-Gallon Drums Containers l BU Type Drums Sea Vans GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-9 J

l FIGURE 6-4 DECONTAMINATION AND DISPOSAL SEQUENCE FOR INDOOR CONTAINED-URANIUM PROCESS / STORAGE AREAS (TYPICAL) i l l l I REMOVE ALL CONTAINERS 1 SURVEY FOR RELEASE A NO CLEAN DECONTAMINATE PACKAGE FOR > SHIP TO y BURIAL BURIAL SITE YES 1 RELEASE l l l l GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-10

Chocks Tie Downs Cylinders Wooden Pallets Hard Surfaces (Asphalt) Wooden Shipping Marl Surfaces Containers All containers of material stored on outdoor pads are designed to prevent or minimize the potential for leakage. Liquids are stored in lined cans, lined metal drums or plastic drums: UF, is stored in shipping cylinders; and dry contaminated materials are stored in plastic bags within wooden or metal containers. The storage pad areas are routinely surveyed to monitor for contamination and, if contamination is found, it is immediately cleaned up. Protective clothing is not worn when moving materials on the storage pads. The storage areas will be cleared of all containers as indicated in Figure 6-5. Surveys will be performed with instrumentation capable of detecting surface contamination above release limits. In addition, core samples will be taken at intervals across the pads and around its edge into the soil to monitor for any contamination. Prior to release of the pads, contamination will be reduced to releasable levels or recovered and shipped for burial. 6.5 URANIUM-BEARING PROCESS / STORAGE TANK AREAS These areas contain large storage tanks and are located near the fuel manufacturing building, at the waste l 1 treatment facility and within the uranium process areas. In these areas uranium-bearing liquid material is treated, stored or processed. GE-WILMINGTON PAGE DATE 5/01/89 PAGE i DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-11

FIGURE 6-5 DISPOSAL SEQUENCE FOR OUTDOOR CONTAINED-URANIUM STORAGE AREAS (TYPICAL) REMOVE ALL CONTAINERS 1 SURVEY FOR RELEASE I NO CLEAN DECONTAMINATE PACKAGE FOR > SHIP TO BURIAL BURIAL SITE YES 1 RELEASE I 1 GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-12

Elements of a uranium-bearing process / storage tank area may include the following equipment, materials or items: Curbing Sumps Dry Wells Storage tanks Manholes (up to 100,000 gal) Piping Valves Pumps 1 Normally the tanks are filled with liquids containing trace concentrations of uranium. These tanks will have l l been emptied as far as practical prior to the start of I decommissioning and closure activities. A ve.Ssel will be identified and used to handle liquids generated j during the decon process. When work begins on these tanks the inspection ports will be opened and an evaluation will be made whether the tanks may be decontaminated or whether dismantlement O is necessary. The clean-up sequence will be from the process tanks to the pumps and piping, and will end with i the tanks at the waste treatment facility. This will l preserve the capability to treat cleaning solutions used in the decommissioning and closure activities. The decontamination'and disposal sequence for process / storage tanks is shown in Figure 6-6. If possible, decontamination efforts will permit the tanks to be kept intact. Sensitive radiation instruments will be used and swipe surveys will be made to assess the effectiveness of decontamination efforts, to provide information for estimating the relative value of continued decontamination efforts or to establish that the tanks may be released. 1 () l GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION O 6-13 u__________-__ _ - - - - _ - -

FIGURE 6-6 DECONTAMINATION AND DISPOSAL SEQUENCE FOR PROCESS / STORAGE TANK,S, (TYPICAL) INSPECTION NO CUT UP OR PACKAGE FOR SHIP TO DECON-TAMINATE TAKE OUT BURIAL > BURIAL SITE t 4 YES OR PROCEED TO EITHER CLEAN t O SURVEY FOR > CONTAMINATION CLEAN 4 YES l 1 RELEASE GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-14

4 i It is probable that piping will be sectioned, cleaned and then packaged for burial. Cutting, cleaning, and packaging will be performed under the cognizance of the radiation protection function to provide continued evaluation to assure the radiological safety of the workers, to prevent any spread of contamination, to evaluate the effectiveness of the cleaning operations, I l and ultimately to release the area. 6.6 URANIUM-BEARING LAGOON AREAS There are lagoons on the plant site which contain uranium-bearing liquids and sludges. The liquids, which have been treated in the waste treatment facility prior to rele.ase to the lagoons, contain very low-level concentrations of uranium. The resultant sludges should be removed prior to commencing decontamination activities. Elements of a uranium-bearing lagoon area may include l some of the following equipment, materials, and items: l Asphalt Liners Pumps, Valves and Controls Buried Pipes Safety Lines Fencing / Covers Safety Rings Floats Uranium-Bearing Sludge Liners and Liquid Sludge Processing Equipment The pipelines, pumps, and other equ.'pment associated with the lagoons will be thoroughly flushed chemically and rinsed with water. Pipes, pumps, and valves will be disposed of where contamination cannot be accomplished () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-15

or the item cannot be verified to be " clean." Other items such as the safety lines, floats, rings, and fence g covers will be appropriately disposed of after removal. The lagoons will be emptied and flushed with water or cleaning solutions. After cleaning, the liquids will be allowed to evaporate. The sludge remaining in the lagoons will be stripped, stored for on-site uranium recovery and/or neutralized and disposed of in a manner authorized by the NRC. The Hypalon liners will be cleaned with high pressure water and detergent, and rinsed. Sections that cannot be decontaminated to release levels will be removed and prepared for burial or waste oxidation-reduction, or disposed of in a manner authorized by the NRC. Soil under the lagoons will be . tested for uranium contamination and removed, if necessary, for burial. Material and liquids collected while cleaning the lagoons could be evaporated and solidified, and stored in containers for burial. In all ggg cases the material will be assayed to determine contamination levels. Soil may be brought in to backfill the excavations and contour the areas. Lagoons involving radioactive materials or hazardous waste will be treated in a like 47 manner. l The decontamination and disposal sequence for the uranium-bearing lagoons and equipment is shown in Figure 6-7. GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-16 l l

FIGURE 6-7 DECONTAMINATION AND DISPOSAL SEQUENCE FOR THE URANIUM-BEARING LAGOONS AND EQUIPMENT (TYPICAL) CLEAN PIPES, TANKS, ETC. \\ NO CLEAN lYES 1 DRAIN SOLIDS PROCESS YES DISPOSE LAGOON SOLIDS CLEAN OF ON PROPERTY LIQUIDS 4 NO PACK & EVAPORATE SHIP FOR LIQUIDS BURIAL f OR YES DISPOSE IN CLEAN RELEASE MANNER AUTHORIZED BY NRC NO CUT OUT PREPARE > SHIP TO EQUIPMENT FOR BURIAL BURIAL SITE t NO CLEAN/ YES BACKFILL WITH ' CLEAN SOIL AND CONTOUR lll GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 6-17

6.7 HAZARDOUS WASTE MATERIAL AREAS Hazardous waste materials, as defined by RCRA, are liquids, solids or sludges which pose a potential threat to the public health and safety if released to the environment Undesirable characteristics of hazardous waste are: corrosiveness, toxicity (metals), ignitability, and reactivity. The GE-Wilmington RCRA program has identified hazardous waste areas and has established control procedures to monitor on-going storage, treatment and shipment activities. Elements of a hazardous waste material area include the following equipment, materials and items: Storage Tanks Portable Transfer Tankers g Pumps, Valves, Controls Small Storage Drums or Reservoirs at Generation Point Process Area Where Chemicals Are Used Protective Wet Gear Fencing Spill Containment Prior to initiating decommissioning and closure activities, all hazardous wastes will be shipped off-site for disposal. Storage tanks will be cleaned for reuse or dismantled for shipment off-site to an appropriate disposal site. All equipment at generation stations will be cleaned and made available for other uses as deemed appropriate. I GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION O 6-18

7.0 RADIOLOGICAL AND INDUSTRIAL SAFETY h During decommissioning and closure activities, employee exposures and potential release pathways will be controlled and monitored in accordance with internal procedures, license conditions and regulatory requirements. Many aspects of current programs used for production will be maintained. The criticality monitcring system which provides real-time monitoring wherever bulk quantities of uranium is handled or stored on the plant site will continue to be operationally maintained to assure that the system will i provide an alarm in the unlikely event a criticality occurs. The system currently provides remote readout capability at the emergency control center which will remain active as long as the monitoring system is needed. An interim emergency response plan will be prepared prior to the start of the decommissioning and closure activities. A centralized air sampling system is currently used to monitor airborne uraniun concentrations in the fuel manufacturing controlled areas. This system will be modified as appropriate and used to monitor routine and abnormal activities as necessary. Removal of this system will be delayed until only the shell of the building remains and the potential for airborne uranium approaches zero. Another safety system which will be essential during decontamination is the fire alarm system with fire alarm boxes strategically placed throughout the site. Once triggered, the system currently sends out a coded alarm ll) GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 7-1

l which identifies the area of the fire. Activities during decommissioning and closure such as cutting, gg) dismantling and nonroutine trash accumulation will make this safety system essential. Necessary environmental monitoring programs established during the operation of the plant will continue during the decommissioning and closure activities to assure that contaminants are being contained. Samples currently are taken at the stack release points, from soil around the site, at the dam or discharge point, and from wells around the site. These samples will.be analyzed for specific contaminants. A history of data has been generated to provide a reference point for the i evaluation of the effectiveness of the environmental monitoring program during decommissioning and closure. Radiation exposure to employees will be monitored through existing programs, such as issuance of personnel lll monitoring devices, air sampling of airborne contamination, and routine bioassays. These programs will continue to be maintained to meet the regulatory requirements specified in 10 CFR 20, " Standards for Protection Against Radiation." Employees trained in ra.diation protection practices and contamination control techniques will perform decontamination activities. Protective clothing utilized in the facility will be available in sufficient quantities to allow for personnel contamination control. Various types of respirators will be available to provide the degree of protection necessary for the decontamination job being performed ranging from half-mask respirators to supplied air hoods or masks. GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 7-2

l 1 For jobs requiring dismantlement of heavily contaminated items, isolation tents with portable blowers and HEPA filters may be utilized. Tenting techniques may also-be employed for decontamination activities where j significant dusting potential exists. I I I l l O l f l i GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 7-3

8.0 GENERAL DECONTAMINATION AND CLEANING METHODS

  1. t']

Removal of radioactive material from contaminated surfaces will be accomplished in three ways: (1) physical cleaning of the surface, (2) using chemicals to dissolve surface films containing radioactive materials or (3) removing the surface of the structure itself. Physical cleaning methods include sweeping, vacuuming, handwiping, sandblasting, and washing with various cleansin agents. Chemical decontamination methods use acid or basic solutions to dissolve residual contamination from surfaces; this technique is usually applied to wet processing systems, such as pumps, piping, storage tanks, etc. If physical cleaning and chemical decontamination techniques do not reduce contamination levels on equipment and/or building surfaces to acceptable radioactivity release levels, or es are unfeasible, it will be necessary to either use more extensive methods, such as sandblasting or scraping that physically removes surface layers, or to remove the item for burial. i Removal of contamination from sealed porous surfaces, such as painted walls and floors, asphalt, tank exteriors, etc., will be accomplished using a variety of techniques. For loose contamination, vacuuming or simple sweeping compounds are often effective. For more difficult contaminations, various cleansing compounds combined with handwiping, handscrubbing, and/or power scrubbing techniques will be utilized. Degreasing agents may be used in removing contamination films from surfaces. Organic solvents have an advantage () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 8-1

l i l l l of not being corrosive to equipment and electrical ggg connections. Variable pressure., high or low-velocity liquid jets can be effective for some types of decontamination work. The device can be operated by one person, at pressures l up to 30,000 psi, using a hand-held jet lance. Typical 1 tools and equipment used for dismantlement and decontamination are listed in Table 8-1. Chemical solutions identified as decontamination agents l and compatible with the available waste treatment processes and with materials used in the system may be used during decontamination. Consideration will be given to cost and environmental impact. l Concrete surfaces in the plant which are contaminated to a depth of a few centimeters and that cannot be cleaned to an acceptable release level by surface wiping or gg) washing techniques will be physically removed and packaged for disposal. Several criteria will be considered in selecting a concrete removal method. The selected method will facilitate control of airborne contamination and minimize the potential for personnel i exposure to radioactivity. The size and weight of l removed materials will be controlled to facilitate l packaging and shipping for disposal. l l l GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 8-2

TABLE 8-1 TYPICAL TOOLS:AND EQUIPMENT i FOR DISMANTLEMENT Oxyacetylene Torch j Guillotine Pipe Saw Tube Cutter i Ratcheting Pipe Cutter l Reciprocating Saw Nibbler Assorted Tools (Impact Wrenches, Bolt Cutters, etc.) High-Velocity Liquid Jet Low-Velocity Liquid Jet Hydraulic Concrete Surface Spalling Device Concrete Drills Electric / Pneumatic Hammers Portable A Frames Portable Wash Tanks Portable Greenhouse Erection Kit Portable Spray Cleaning Booth Portable Power Brushes Portable Abrasive Blasting Unit l 1 1 l l l l l ( )- GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 8-3 l

9.0 WASTE MANAGEMENT l ) O 1 Large quantities of contaminated material will have to l be removed during the decommissioning and closure of the plant. If these materials cannot be treated or decontaminated to acceptable levels, they will be properly packaged and shipped to an authorized disposal site or disposed of in a manner authorized by the NRC. ) l Contaminated waste materials that will be generated I during decommissioning and closure include: ) l Process equipment, tanks, and hoods Piping, ducts, and fixtures ] HEPA and roughing filters Concrete rubble i Lagoon liners l Soil Misc. noncombustible materials (pumps, motors, etc.) l All shipments of radioactive material will be made in compliance with federal, state, and local regulations. Federal transportation regulations of DOT and NRC establish container requirements, dose rate limits and handling procedures to ensure the safety of the public and transportation workers during shipment of radioactive materials. Current federal regulations applicable to the transport of radioactive materials are: Total 49 Code of Federal Regulations Part 170-179 (40 CFR 170-179) - Department of Transportation regulations governing the transport of hazardous materials. l () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 9-1 l

~ 10 CFR 71 - NRC regulations governing the packaging and shipment of radioactive materials. O In addition, for highway transport, state agencies regulate vehicle sizes and weights and, in some cases, transportation routes and times of travel. All hazardous waste will be packaged in safe containers commensurate to the hazard involved to meet regulatory packaging, shipping, and burial requirements. Materials handling will be done according to procedures for transfer, storage, preparation and shipping. O lh GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 9-2 1

10.0 DECOMMISSIONING AND CLOSURE SCHEDULE \\- Upon completion of final process cleanout and removal of the uranium inventory, the decommissioning and closure activities will commence. The schedule for the decommissioning and closure activities is presented in Figure 10-1. These activities will include: The areas close to the powder storage warehouse and UF, cylinder storage areas will be cleared first to provide staging areas for the storage, packaging, and j shipment of decontaminated equipment and materials from the plant. Plant areas will then be decontaminated, generally in the order of decreasing amount of contamination, i.e., from the most contaminated to the least contaminated. i The outdoor lagoon areas system will be dismantled and decontaminated upon completion of liquid processing. 1 The hot maintenance, rad waste, waste oxidation-1 reduction facility, uranium recovery system, and the ventilation system will be decontaminated near the end of the project so they can support the decommissioning and closure operations. The laundry room and change rooms will be the final areas to be decontaminated. The hazardous waste areas will be cleaned concurrent with decontamination activitfas. Cleaning will () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 10-1 l

FIGURE 10-1 DECOMMISSIONING AND CLOSURE SCHEDULE O HIRING /$TAFFING TRAINING i i WET URANIUM PROCES$1NG i i DRY URAN!UM PROCES$1NG AREAS i i URANIUM BEARING PROCES$/ i i $TORAGE TANKS INDOOR CONTAINED URANIUM i i STORAGE AREAS DUTD00R CONTAINED-URAN!UM i i STORAGE AREAS HAZARDOUS MATERIALS i a l FINAL CLEANING / SURVEY OF i j l .e, _ FINAL $1TE SURVEY AND CLEANUP l j l INSPECTION AhD RELEASE g 1 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 l Time Weeks l l l l h GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 10-2

~ l i i progress from the services components building, to the fuel component operations, to fuel areas and then to outside areas. A thorough radiation and hazardous materials survey of all areas in and around the plant will be { conducted prior to the final inspection and release i by the applicable regulatory agencies, A systematic survey plan will be developed using acceptable guidelines such as NUREG/CR 2082 " Monitoring for Compliance with Decommissioning Termination Survey Criterda." l l I) 4 J l l l i i () GE-WILMINGTON PAGE DATE S/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 10-3 i

11.0 FINAL RELEASE ( As areas / buildings are being decontaminated, contamination surveys will be made to determine the I degree to which decontamination is being achieved. Upon i completion of all decommissioning and closure activities, a detailed health and safety analysis will 1 be performed to determine the level of residual material. It is intended to demonstrate that there is l no risk to the health and safety of the public, that limits are within those specified by regulatory agencies, and that the premises may be released for unrestricted use by any industry. A detailed survey report will be prepared which identifies the premises, describes the scope of the survey, and reports the findings of the survey in specified units. A copy of this survey report will be submitted to the NRC and the State of North Carolina requesting release of the site for unrestricted occupancy. When decommissioning and closure of the facility is completed (i.e., removal of hazardous waste and sludge, equipment cleaned or removed, and storage areas or tanks i free from any hazardous waste contaminants), GE-Wilmington will submit to the RCRA Regional Administrator certification by the project manager and an independent registered professional engineer that the facility has been closed in accordance with the specifications of the appproved closure plan. 1 i i () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION O 11-1 l

12.0 DECOMMISSIONING AND CLOSURE COST ESTIMATES The estimated. total cost for the decommissioning and closure of the GE-Wilmington facility is 38.7 million-(1989) dollars. The cost breakdown is shown in. Table 1. This estimated total cost includes the cost of special-purpose equipment, materials, labor, site support services, waste packaging, transportation, burial, and other miscellaneous owner expenses..The estimated total cost assumes an efficient decommissioning and closure activity but a 25% contingency is added to allow for unforeseen problems which might arise during the activity. The estimated total cost is based on the assumptions stated in Section 4 of this Plan. The estimated costs shown in Table 12-l' ~j were developed using estimates provided by responsible and knowledgeable personnel in the various GE' functions and off-site support groups. { O Burial cost estimates are based upon the current (1989) cost of $47.22 per cu. ft. (Chem' Nuclear, Inc.). It is I s most likely that this cost will increase faster than other factors due to the forthcoming closure of the. Barnwell facility in favor of Regional Compact burial I 1 sites. l l Transportation costs assume burial at Beatty, Nevada, a j i site selected to provide some conservatism and j flexibility since the quantity for burial is large and burial sites have been limiting the quantity allowed for burial. The cost for a license review, approval, ongoing inspections and final review releasa for decommissioning i () GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION O 12-1 l 1

TABLE 12-1 DECOMMISSIONING AND CLOSURE COST ESTIMATES h (1989) (x 000) Preplanning 150 Site Services Telephone 162 Utilities 5,306 Taxes 500 Insurance 250 Licensing / Inspection NRC 250 Burial (163,955 cu. ft.) 7,742 Transportation (100 Trucks) 470 l Equipment For Decontamination 2,388 Manpower l Salaried 2,416 l Labor Contract 11,154 l Consultation Inspection 100 Lab Fees (Analysis) 50 Subtotal 30,938* 25% Contingency (NUREG 0278) 7.735 Total 38,673 1

  • Does not include credit for sale of equipment or for uranium recovered.

i l h GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 12-2

the site is estimated to be $250,000 based on the current routines established by the NRC, Nuclear liability insurance for a facility being decommissioned has not been determined. An allowance of $250,000 is included for the annual insurance premium for both nuclear and conventional insurance. RCRA regulations specify that an outsida consultant who is a registered engineer must perform an independent survey to determine that cleanup activities have been performed per procedure, the measurements are representative of the actual situation, and the total site is free of hazardous materials. A written report must then be submitted to the state certifying the plant is " clean." It is estimated that this fee will b,e $100,000. O O az-wItxINorON race Dire se01/89 rios DECOMMISSIONING AND CLOSURE PLAN REVISION 0 12-3

13.O FINANCIAL A3SURANCE AND RECORD KEEPING O The decommissioning and closure cost for the GE-l Wilmington plant including the full fabrication facility { is estimated to be 38.7 million (1989) dollars. This f cost is considered to be small compared to the total j assets of the General Electric Company. Therefore, it is unlikely GE would be unable to meet the financial 4 ) commitment generally associated with the decommissioning ] and closure activities outlined and estimated above. The Corporate commitment to provide.the reac xces for the decommissioning and closure of the plant when and if necessary is documented in Figure 13-1. Commencing in 1988 GE-Wilmington has taken steps to assure applicable drawings and records of modifications l to areas where hazardous materials and/or radioactive materials are handled, used, or stored are being archived and maintained. Records of incidents, spills or releases to the environment are also being archived and maintained until the end of plant life in order to provide additional information for the decommissioning I and closure activities. O os-w1talNorot< rios o^rs.s/o1 89 rios DECOMMISSIONING AND CLOSURE PLAN REVISION O 13-1 ---_______----__________________J

FIGURE 13-1 CORPORATE COMMITMENT LETTER GE Nuclear Energy Bertrem WoHe Geneo Electnc Cornoony nce Presioent and General Manager 175 Curtner Avenue. San Jose. CA 95125 408 925 4900 April 4, 1989 Diractor, Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety & Safeguards g U.S. Nuclear Regulatory Commission m Washington, D.C. 20555 g

Reference:

NRC License SNM-1097, Docket #70-113 O

Dear Sir:

This letter is to inform you that the General Electric Company will have available, at the time of decommissioning, the resources deemed necessary to satisfy its obligation to decommission its nuclear fuel manufacturing plant in Wilmington, North Carolina. Very truly yours, Bertram Wol Vice President & General Manager GE Nuclear Energy e9 GE-WILMINGTON PAGE DATE 5/01/89 PAGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 13-2

14.0 REFERENCES

O 10 CFR 20, " Standards for Protection Against Radiation." 10 CFR 70, " Domestic Licensing of Special Nuclear Material," includes decommission funding and termination of license requirements. NUREG-0586, " Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," August 1988. l NUREG/CR-1266 Volumes 1 & 2, " Technology, Safety & Costs of Decommissioning a Reference Uranium Fuel Fabrication Plant," October 1980. E NUREG/CR-2082, " Monitoring for Compliance with Decommissioning Termination Survey Criteria," June 1981. O GE-wItMINGTON exGE DiTE 5,01,89 exGE DECOMMISSIONING AND CLOSURE PLAN REVISION 0 14-1 _._}}

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