ML22293A269

Us Dept of Commerce, National Institute of Standards & Technology (Nist), Transmittal of Decommissioning Funding Plan

ML22293A269
Person / Time
Site:	07000398
Issue date:	09/27/2022
From:	Locascio L US Dept of Commerce, National Institute of Standards & Technology (NIST)
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
TAC L32643
Download: ML22293A269 (19)

Text

UNITE STATES DEPARTMENT OF COMMERCE National Institute of Standards and Technology Gaithersburg, Maryland 20888 OFFICE OF THE DIRECTOR STATEMENT OF INTENT U.S. Nuclear Regulatory Commission ATTN: Document Control Desk License No. SNM-362 Director, Office of Nuclear Material Safety and Safeguards Docket # 70-398 Washington, DC 20555-0001 TAC NO. L32643

Dear Sir,

As Director of the National Institute of Standards and Technology (NIST), I exercise authority and responsibility to request from the Congress of the United States of America, through the U.S. Department of Commerce and the Office of Management and Budget, funds for decommissioning activities in NIST facilities pursuant to a decision to discontinue operations authorized in those facilities by U.S. Nuclear Regulatory Commission Material License No. SNM-362. Authority is established by 15 U.S.C § 272b, 31 U.S.C.§§1105 and 1108, Department of Commerce Administrative Order 203-1, and NIST Suborder Radioactive Material at Gaithersburg NIST S 7201.01.

I am advising pursuant to 10 CFR 30.35(e) and 10 CFR 70.25(e) of my intent within this authority to request that funds be made available, when necessary, in the amount of$10.55 million for decommissioning NIST laboratories housing radioactive material and accelerator facilities with residual structural activation located on the NIST campus at 100 Bureau Drive, Gaithersburg, Maryland. This funding level is based on the revision to the NIST Decommissioning Funding Plan (enclosed) which reflects the regulatory conditions, licensed activities, and economic conditions as of calendar year 2022. I intend to request and obtain these funds sufficiently in advance of decommissioning to prevent delay of required activities. Appropriate escalations will be applied as necessary to accommodate future conditions when decommissioning is required.

Sincerely, LAUR IE ( Digitally signed by LAURIE LOCASCIO LOCASCIO . ,, ~~1~~~022.os.2? 16:35:10 Laurie E. Locascio, Ph.D.

Under Secretary of Commerce for Standards and Technology &

Director, National Institute of Standards and Technology Enclosure NIST Decommissioning Funding Plan, September 2022 cc: 0. Siurano-Perez, NMSS, NRC E. Mackey, OSHE M. Mejias, RSD, OSHE A. Thompson, Chair, IRSC NlSI

Decommissioning Funding Plan September 2022 National Institute of Standards and Technology Gaithersburg, MD

License No. SNM-0362 National Institute ofStandards and Technology Septem her 2022 Decommissioning Funding Plan Page 2 of 18 Contents I ;0 Executive Summary ................................................................ ;......................................................... 4 2.0 Objectives ...........................................................................................................................................6 3 .0 Process ........................................ ,.. ,........ '. .......................................................................................... 6 4.0 General Assumptions . ..................................................................................................................... 8 4.1

• Radioactive Waste Materials ................................................................................... ;.......;............. 8 4.2 Sealed Sources .............................. '. ................................................................................................ 9 4.3 Unsealed Sources ..................................................................... ;.................................................... 9 5.0 Release Criteria ............................................................................................................................... 11 6.0 Review of Previous Clearance Surveys........................................................................................... 13 7.0 Decommissioning Process and Cost Estimate Details .................................................................... 13 7.1

• Detailed Descriptions of Facilities and Equipment .............................. ;...................................... 14 7.2 Planning and Preparation............................................................................................................. IS 7.3 Decontamination or Dismantling of Radioactive Facility Components ...................................... IS 7.4 Restoration of Contaminated Areas ............................................................................................ 16 7.5 Final Radiation Survey ................................................................................................................ 16 7.6 Site Stabilization and Long-Term Surveillance .......................................................................... 16 7.7 Total Days by Labor Ca~egory ............................., ...................................................................... 16 7.8. Worker Unit Cost Schedule.............................. :.......................................................................... 16*

7.9 Total Labor Costs by Major Decommissioning Task .................................................................. 16 7."10 Packaging, Shipping, and Disposal of Radioactive Wastes ........................................................ 16 7.11 Equipment Supply and Costs (excluding containers) ........................................................... '. ...... 17 7.12 Laboratory Costs ......................................................................................................................... 17

7. t 3 Miscellaneous Costs ................................................................. :.................................................. 17 8.0 Periodic Updates to Decommissioning Cost Estimate .................................................................... 17

License No. SNM-0362 National Institute of Standards and Technology Septem her 2022 Decommissioning Funding Plan Page3 of18 ACRONYM LIST CFR Code of Federal Re11:ulations DAW Dry Active Waste D&D Decontamination and Decommissioning DCE Decommissionine: Cost Estimate DCGL Derived Concentration Guideline Level DFP Decommissionine: Fundine: Plan DOE United States Deoartment of Energy dom disintegrations oer minute DSV Default Screenin11: Value HEPA High-Efficiency Particulate Air MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MD Maryland NIST National Institute of Standards and TechnoloRV NMSS Nuclear Materials Safetv and Safeguards NRC

• U.S. Nuclear Reu:ulatorv Commission NUREG Nuclear Regulatory Commission Guidance Document OES Occuoational Emolovment Statistic PAB Performance Assessment Branch RESRAD Residual Radioactive RSO Radiation Safety Officer SNM Soecial Nuclear Material SOI Statement oflntent

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 4of 18 1.0 Executive Summary In a letter dated September 23, 2019 (ML19269B774), U.S. Department of Commerce National Institute of Standards and Technology (NIST) submitted its triennial decommissioning funding plan (DFP) update for the statement of intent (SOI) regarding its Special Nuclear Material (SNM) license, SNM-362. On February 4, 2020, Office of Nuclear Material Safety and Safeguards submitted a request for additional infonnation (RAJ). On February 28, 2020, NIST staff replied to the before mentioned RAI. On Aril 3, 2020, the Office of Nuclear Material Safety and Safeguards completed its technical review and subsequent approval of NIST's DFP submittal.

Pursuant to IO CFR 30.3 5(e) and* IO CFR 70.25(e), this report addresses the three-year resubmission of the decommissioning funding plan, considering adjustments necessary to account for changes in cost and the extent of contamination.

As required by 10 CFR 30.35(e) (2) and 10 CFR 70.25(e) (2), this report specifically considers the effect of the following events on decommissioning costs:

i. Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

Minor spills occurring over the last three years have been cleaned/decontaminated to pre-spill conditions with the exception ofone laboratory in building 245. The residual radioactivity is embedded in the.floor tiles and will be remediated as part ofthe building modernization project. The residual radioactivity does not change the designation of the room as "impacted" and does not increase the total liability.

ii. Waste inventory increasing above the amount previously estimated.

No significant increases in waste inventory since the last evaluation.

iii. Waste disposal costs increasing above the amount previously estimated.

No significant changes in waste disposal costs since the last evaluation. The liability is decreasing with the disposal ofthe Co-60 pool irradiator sources disposal earlier in FY22. OSHEIRSD continues to work with NIST leadership to perform additional special waste disposals over the next three years. No changes to the total liability are expected at this time.

iv. Facility modifications.

The building 245 Modernization impacted this category in FY22 as new laboratories were commissioned and old laboratories were decommissioned The net change was a reduction of2943 sqft of lab space.from the restrictedfootprint, but no changes to the

. total liability are expected at this time.

v. Changes in authorized possession limits.

There has been no change in possession limits for the SNM-362 license this last year.

Thus, no impact to the total liability is expected

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Pages of IS vi. Actual remediation costs that exceed the previous cost estimate.

Actual remediation costs that exceed the previous cost estimate: No significant remediation costs changes identified.

vii. Onsite disposal.

Non-applicable as NIST is not authorized to perform this activity.

viii. Use of a settling pond.

Non-applicable as NIST is not authorized to perform this activity.

Laboratory facilities are expected to be completely decontaminated and remediated at the time termination of operation is expected. This work will consist of removing all radioactive material, decontamination of contaminated building surfaces, and remediation or removal of volumetrically-cC?ntaminated materials. Laboratory facilities will then be surveyed and released for unrestricted use in accordance with NUREG 1575, Multi-Agency Radiation Site Survey and Investigation Manual (MARSSIM),

Radioactive accelerator components, waste, and non-structural material will be removed and disposed of as radioactive waste. Accelerator facilities contain activated structural material that cannot be safely removed without demolishing the entire building, which in most cases consists of several stories. Such activities would be extremely costly and would subject personnel to unnecessary risks during the decommissioning process. Furthermore, the NIST property is U.S.

Government owned and is expected to remain long after the facility is decommissioned. For those reasons, a limited release followed by long-term monitoring is the preferred avenue for estimation of decommissioning costs.

Cost estimates were developed using conservative "middle of the road" assumptions regarding likely extent and duration ofremediation activities. Remediation was assumed to proceed to levels suitable for unrestricted release of the site. Cost estimates were prepared in accordance with and in the format of NUREG 1757 "Consolidated NMSS Decommissioning Guidance" Volume 3. Per NUREG 1757, a contingency of 25% is required to be added to decommissioning estimates to address unidentified and unanticipated conditions.

Table 1.1 provides the revised estimate for the Gaithersburg facility:

Table 1.1 NIST Gaithersburg, MD Facilities D&D Cost Estimate 2022 Estimate 25% Contingency Subtotal Laboratory Areas $4,476,667 $1,119,167 $5,595,834

$3,960,208 $990,052 Accelerator Areas $4,950,260 TOTAL $8,436,875 $2,109,219 $10,546,094.

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 6 of18 Cost estimate details were provided previously as attached spreadsheets included as appendices in our September 2016 submission. These spreadsheets have been updated to reflect current cost estimates. Additionally, the scoping survey of the accelerator spaces that was conducted in 2010 had also been included as an appendix previously. The scoping survey and our conclusions provided in our last submission have not changed.

Nothing in this document should be construed as binding at the time of final decommissioning.

The survey methods, release limits, radionuclides of concern, and facility configurations described are based on conditions observed during the site visit, historical documentation, sample analysis, and professional opinion as to the process of the final decommissioning and survey.

2.0 Objectives The principal objectives of this analysis are to: I) develop updated revised estimate of total facility decommissioning costs for NIST's Gaithersburg operations, 2) provide a documented inventory of facility features and characteristics, and 3) describe the steps that will need to be taken to effect complete decommissioning of the site.

3.0 Process Estimating the amount of remediation that would be required and the amount of material that would be handled as radioactive waste was perfonned in a similar manner as would be used for estimating a decommissioning job. A schedule of equipment, features, and characteristics was originally developed to capture the size of each space and key features relevant to developing decommissioning cost estimates. Specifically, facility floor plans were reviewed, and the changes ofprincipal features and equipment of each laboratory were inventoried and categorized from the last DFP submission. Any significant changes were incorporated into the estimate. The process, as described below, continues to be the paradigm used in formulating the DFP. For this estimate, the previous estimate submitted in 2019 was reviewed and updated as appropriate.

In 201 0_, Philotechnics was hired by the NIST to perform a comprehensive initial DFP assessment. Historical records and databases were reviewed to assess the isotopes, activities, and source uses in each laboratory. Existing records of routine radiological monitoring were also used. Philotechnics personnel performed independent surveys and measurements in all laboratory spaces to verify that the conditions were as indicated in the established records. This information was then used to estimate the degree of remediation and the fraction of material that would be generated as radioactive waste.

Following review of the records, facility drawings, physical and radiological data used to determine the amount of material that would potentially need disposal as radioactive waste, Philotechnics evaluated the potential alternatives of decontamination, re-monitoring, and free release instead of radioactive waste disposal. The approach of decontaminating the area versus removing contaminated portions of the area for disposal as radioactive waste was evaluated from.

an economic perspective. This evaluation formed the final basis for determination of the labor and disposal costs for this decommissioning cost estimate.

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 7 of 18 As indicated previously, the NIST radioactive materials database was reviewed to detennine the radionuclides of concern in each* laboratory area. NIST Radiation Safety personnel routinely perform weekly contamination smear surveys, which are analyzed on a gas proportional counter or liquid scintillation, arid direct reading measurements for dose rate and/or count rate in the unsealed source use laboratories. NIST Radiation Safety personnel also perfonn quarterly surveys in the sealed source use and* storage areas. NIST management provided the existing routine

• contamination survey data from November 2007, March 2008, and September 2008 to Philotechnics to use as guidance to detennine the likely extent of contamination in laboratory areas. Contractor personnel performed subsequent confirmatory surveillance of all identified unsealed radioactive materials laboratories. In many laboratories, direct contamination measurements using count rate monitoring instruments were impossible due to the presence of radioactive materials. In these areas the results of the NIST routine contamination monitoring smear results were used.

Samples of structural materials and shielding were collected in spaces affected by accelerator operation to detennine the radionuclides present and estimate the extent of activation. Historical records were reviewed including the radioactive materials license, previous DCEs, and laboratory closure surveys. NIST management was consulted regarding past and present operations and their effect on future decommissioning.

The work scope and activity sequence to support license termination were developed. Cost estimates for projects were based on anticipated Time and Materials rates for goods, labor, and services necessary to complete each project. It became clear that unrestricted release of accelerator facilities would be expensive and dangerous work because many of those areas are activated throughout the volume of structural materials and possibly into the soil. Some of those areas are below the water table, rendering safe handling of radioactive material and control of the spread of i:adioactivify virtually impossible while those structures are being dismantled and removed. For those reasons, after consultation with NRC personnel, it was decided to pursue restricted release combined with long-term surveillance for those areas.

Labor estimates were derived from the work scope and a project plan outline. A project plan outline was developed for each facility detailing the sequence of tasks required to decommission the facility arid terminate its radioactive material license. An overall project schedule was estimated that considered work to be performed, material flow paths, optimal number of crews and crew size and constraints (i.e., bottlenecks) in the D&D process. Crew sizes and task durations were estimated based on the numbers and locations of tasks to be performed.

Marketplace rates were obtained for each element of the project including project labor, materials, supplies, sampling, and waste packaging, processing, and disposal. NUREG 1757 requires the cost estimate to assume an independent contractor performs the work. Salaries for the

• appropriate labor categories were used based on 2021 data from the U.S. Department of Labor, Bureau of labor Statistics - the last year for which data is available. These salary values are updated annually and incorporated into the DCE. Where available, salaries local to the Washington..;Gaithersburg area were used. In cases where no local data was provided, the data from the nearest high-priced geographical area was used. The unit rates were extended through the estimated quantities to determine total cost for each line item.

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page8 of18 Radioactive waste estimates were based upon the volume of material in the laboratories, storage areas, and supporting systems. For D&D purposes, contaminated equipment was assumed to be disposed of as radioactive waste rather than being decontaminated and released. This is due to the cost of labor required to decontaminate and survey equipment typically exceeding the cost of disposal. Material that is not likely to be contaminated above release limits is assumed to be surveyed for unconditional release in accordance with Regulatory Guide 1.86. Activated shielding, structural material and equipment, and debris from remediation of contaminated surfaces will be handled and disposed of as radioactive waste.

4.0 General Assumptions Overall, "middle of the road" assumptions were made concerning the likely extent and duration of necessary remedial activities. For labc;>ratories, remediation to unrestricted levels (i.e., the facility could be released for any future use without restrictions) was assumed, meaning there are no long-term costs associated with site surveillance and monitoring following decommissioning:

Some accelerator facilities will require surveillance and monitoring after license tennination as discussed later. It is assumed decommissioning activities will begin within a few months after accelerator operations cease such that short-lived activation products will have decayed to negligible levels.

4.1 Radioactive Waste Materials In developing estimates of volume of radioactive waste, overall outside dimensions were used for equipment, components, and furnishings. These overall volumes were assumed to be size reduced somewhat on site, so they were multiplied by an average density of 15 lb.lft:3 Dry Active Waste (DAW) and 20 lb./:ft:3 (metal) to determine the total mass of waste. For example, a standard office desk would be estimated as 5 ft wide by 2.5 ft. deep and 2.5 ft. tall with an overall volume of3l

.25 ft3 and an estimated mass of 470 lbs. A waste fraction was then applied based on the anticipated percentage of equipment expected to be contaminated. Consumables used in the D&D process showed up in waste estimates under DAW.

The accelerators and directly affected equipment such as targets, beam dumps, and shielding are assumed to be radioactive and will be disposed as radioactive waste.

Ventilation system waste estimates were based on dimensions of components. Ventilation up to and including the HEPA filters is considered in this report.

Waste mass is multiplied by marketplace rates for waste processing and disposal. Packaging and transportation costs were estimated by volume and were added to the total waste disposal figure. Potential overestimates ofcomponent volumes as a result of using overall dimensions were offset by smaller pieces of equipment that were not individually estimated. Actual volume of waste expected to be removed from the site was considered in the cost estimate. No credit was given for reuse at other facilities or possible resale value. Waste processing

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 9 of 18 activities were assumed to take place at a licensed facility in Tennessee, with a one-way travel distance of°S25 miles.

4.2 Sealed Sources According to the Health Physics database, NIST possesses approximately 332 sealed sources (233 of which are greater than 1uCi) that will need to be packaged and shipped for disposal or storage. This is a slight decrease from the previous DFP submitted in 2019.

• Since the closure of Barnwell, no disposal option exists for many sources. NIST is critical to the success of a technological society, and it is difficult to imagine a scenario whereby it is completely eliminated. Decommissioning of the Gaithersburg site would most likely be associated with construction of a new facility elsewhere and most sources would be moved and put into service in the new facility. Still, complete decommissioning.and disposal of all sources remains a remote possibility and some cost should be attributed to it. Rather than itemize individual sources and weigh hypothetical transfer/disposal/storage options, we will assume for now that sealed sources will be transferred to the U.S. Department of Energy.

Discussions with DOE personnel indicated $500,000 may be reasonable. The sources will be shipped as a Type B shipment to Nevada, a distance of 2400 miles. Additional costs are

$ I 00,000 for a Type B package and shielding, $84,000 for transportation to Nevada, and

$60,000 for-security and administration oflncreased Controls at NIST during the decommissioning project.

Only sources belonging to NIST and having activity greater than 1 µCi are considered here.

Sources belonging to other licensees will be returned to them. NIST enters into Cooperative Research and Development Agreements and Inter-Agency Agreements in which ownership is clearly established as a responsibility for the customer for a small number of sources. NIST does not in these agreements seek to obtain credit and thereby to reduce the financial liability.

Sources less than or equal to 1 µCi will be included with other waste and shipped to a waste processor for treatment and/or disposal.

4.3 Unsealed Sources The health physics database was used to estimate the amount of radioactive material in the form of unsealed sources on site. The total activity of those sources is approximately 3.SEI I Bq. Some of this activity is contributed by nuclides of short half-life and therefore the total activity will be reduced accordingly. Unsealed material can be mixed with other low-level .waste for disposal. All sources in NIST's inventory are included in this estimate; non-NIST sources will be returned to the customer. This is a slight decrease from the previous DFP submitted in 2019.

Labor Estimates: Labor cost estimate are based on the 2021 Bureau of Labor Statistics (BLS)

Occupational Employment and Wage Estimates data and are provided in Table 4. Where .

possible, the labor rates in the table reflect those applicable to the Occupational Groups in the Washington, DC metropolitan area. If the BLS data tables did not list the Washington, DC metropolitan area as a reference, NIST used the table indicating the "Top Five Salary States" and

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 10of18 chose Maryland (if listed) or the state closest to Maryland. Contractor profits are included in the 75% overhead.

All labor estimates are expressed in workdays. Workdays are actual days on the job. Project schedules were based on 5-day workweeks excluding weekends, holidays, etc., consisting of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per day. *

,Labor estimates for Planning and Preparation include time for document preparation, decommissioning plan submittal to regulatory agencies, work plan development, equipment procurement, staff training and mobilization. Pre-planning labor estimates assume.

straightforward internal and external document, plan and procedure reviews and approvals. The duration of field activities for decontaminating and dismantling the facilities were estimated based on the task sequence and project schedule.

Crew sizes and number of workers were limited to those that could be efficiently utilized in the field. The size of the work force size will vary. At its peak, it is assumed to consist of one Project Manager directing the activities of two crews. Each crew will consist of one Supervisor; two Health Physics Technicians; four Skilled Craftsmen, and four Unskilled Laborers. Additionally, one shipper and one administrative assistant will report directly to the Project Manager.

The duration of activities for remediation of facilities and grounds was based on the expected level of remediation that would be required to return the facility to unrestricted release conditions.

Similarly, estimates for the level of effort required for the final radiation survey were based on previous experience with facilities of comparable complexity.

For non-accelerator facilities, the assumed endpoint is license tennination and unrestricted release of the facility. For accelerator facilities that are below grade, the assumed endpoint is restricted release with monitoring for a period of time, followed by unrestricted release. This was previously described in our previous submission.

Annual labor (Table 4.1) rates were estimated for the project manager, a project supervisor, a health physicist, a shipper, health physics technicians, radiation workers and administrative

. support. Labor rates included base salary and fringe benefits (e.g., vacation, health insurance, etc.). A rate of75% was applied for overhead costs and contractor profit. The base annuai labor rate plus the overhead expenses was divided by the number of workdays per year (taken as 260) to detennine a daily cost for eact:i category of employee.

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan

• Page 11 ofl8 Labor categories used are:

Table 4.1 -Occupational lnfonnation and Labor Rates, May 2021 Occupational Occupation Value Occupational Employment Statistic (OES)

Title Code, Reference Location Project 11-9021, MD $117,520 http://www.bis.gov/oes/current/oes 119021.htm Manager Supervisor 47-IOI I, MD $79,060 http://www.bls.gov/oes/current/oes47 l O11.htm Shipper 53-I047, MD $59,680 http://www.bls.gov/oes/current/oes53 I 04 7.htm HP Technician 19-4099, MD $67,690 http://www.bls.gov/oes/current/oesl 94099.htm Skilled- 47-4041, MD $51,340 http://www.bls.gov/oes/current/oes47404 l .htm Laborer Unskilled 47-2061, MD $41,640 http://www.bls.gov/oes/current/oes472061.htm Laborer Admin 43-6014, $48,680 http://www.bls.gov/oes/current/oes436014.htm MD Living expenses were taken from allowable government per diem rates - $258 per day for Montgomery County, MD. Project management, supervision and technical staff are paid the daily living allowance since they are assumed to be from-outside the local area. Radiation workers (laborers) and administrative support staff were assumed to be local hires and are not paid a living allowance. The daily living expenses were multiplied by 7 days per week then divided by 5 workdays per week to correctly incorporate living expenses into the daily wage rate.

5.0 Release Criteria The ultimate release criteria are specified in IO CFR20. I402. Pathways applicable to such an occupant include external dose, inhalation, soil ingestion, and drinking water from radioactivity that migrates to ground water.

Tools, materials, and removable equipment will be surveyed for unconditional release as applicable using applicable regulatory for the radionuclides of concern.

Building surfaces and installed equipment will be surveyed using the guidance contained in NUREG 1575, Multi-Agency Radiological Site Survey and Investigation Manual (MARSSIM).

Areas adjacent to one another having similar radiological characteristics will be grouped together as applicable into survey units. Contamination release limits will be derived from a number of sources. For planning purposes, the radionuclide known to be present or shown in the database as

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 12 of18 having been used that is associated with the lowest release limit will be used according to the following guidance:

Default screening values listed in NUREG 1757, Appendix B, are used where listed.

For radionuclides not listed in NUREG 1757, the release limit will be derived using the NRC D and D Ver. 2.1 software code default parameters.

At the time of actual decommissioning and License termination, future site usage may be more stringent; in that case the RESRAD family of codes may be used.

Actual radionuclides of concern and the relative abundance of each will be determined early in decommissioning, during the characterization phase; that process will yield accurate derived concentration guideline limits (DCGLs). Therefore, the limits derived in support of this DCE are thought to be quite conservative.

• In this DCE (Table 5.1 ), the following values are limiting, assuming no more than ten percent of the total activity is removable:

Table 5.1 - Limiting Radionuclides Default Screening Value Radionuclide(s) (dpm/100 cm 2)

• Basis Beta-gamma emitters except H-3 and C-14 7,100 Co-60 Transuranics 23 Am-241 Uranium 88 U-238 H-3 1.2E+07 10% of screening value C-14 3.7E+06 Screening value For activated building components, the major dose pathway is external exposure from gamma emitting radionuclides. Default screening values (Table 5.2) for contaminated surface soil listed in NUREG 1757, Appendix B are used. They are:

Table 5.2 - Surface Soils DSVs DSV Radionuclide Ci/g Co-60 3.8 Eu-152 8.7

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 13of18 6.0 Review of Previous Clearance Surveys Since our last reporting period there has been notable changes to the decommissioning footprint. Table 6.1 shows the total change in square feet for the past 3 years. The markable increase in footprint in 2020 comes from the commissioning oflaboratories in the NIST's newly constructed H-Wing expansion to building 245.

Philotechnics believes laboratories previously released from radiological controls will require some type of follow-up survey, described in following sections. Many previously-used rooms have been completely gutted and remodeled; others are now offices; still others had adjoined other radiological laboratories and the wall separating them was removed. Rather than list every previously-used room individually; time and resources are allotted to performing follow- up surveys in all previously-used rooms as a group.

Table 6.1 Decommissioning Footprint Changes by year Year Footprint Cban2e (Sq Ft) 2019- 2020 0 2020- 2021 +27.319 2021-2022 - 2,943 7.0 Decommissioning Process and Cost Estimate Details Since the last submission of the DFP in 2019, 24,376 square feet have been added to the total decommissioning footprint. This accounts for approximately 8% of the total area under consideration and had was calculated to determine the appropriate decommissioning cost. The work crew consists of:

Project Manager (I)

Project Supervisor (2)

Shipper (I)

• Health Physics Technicians (4)

. Skilled Laborers (2)

Unskilled Laborers (2)

Administrative Assistant (I)

The time required to complete the project is approximately 150 days on site: 90 days for the laboratories and 60 for the accelerators. This is less than the maximum limit of 180 days per calendar year to work under reciprocity with the U.S. NRC. Therefore, one reciprocity fee of

$1800 will cover both aspects of the work.

Following is a description of the assumptions made and data entered into individual worksheets to calculate the potential cost of decommissioning. Two sets of spreadsheets were developed for this

License No. SNM-0362 National Institute of Standards and Technology Septem her 2022 Decommissioning Funding Plan Page 14 ofl8 cost estimate. One set of spreadsheets pertains to laboratory areas and the other to the accelerator areas.

7.1 Detailed Descriptions of Facilities and Equipment In addition to the accelerators, Building 245 also houses most of the active radiological laboratories.

Laboratories vary in size, configuration, materials, and equipment according to their function.

Each individual laboratory that was inventoried for this DCE. The inventory lists, as a minimum, room dimensions, amount of furnishings and equipment used and stored in the room, the radionuclide(s) currently or previously used, and the expected MARSSIM class based on current use and survey data.

Initial assignment of MARS SIM class for final status surveys is as follows:

Table 7.1 - Previously Cleared Laboratories or Rooms CLASS 1 Current use of unsealed material. Some remediation may be Current or previous use of expected Some radwaste may be neutron sources. expected - fraction inversely Areas adjacent to accelerators. proportional to release 'limit.

Areas with uncertain history. Accelerator facilities will have a lot of radwaste.

Some rooms are not listed in the database as ever having radioactive materials - so ifwe don't know what was used, we assume the worst.

CLASS2 Accelerator support areas Verification that materials are not separated by shielding. activated or contaminated.

Previous use or unsealed TRU, U, Removable contamination Ra, or Th sources and clearance surveys previously performed surveys were done (many have cannot detect alpha emitters been gutted and remodeled). belowDCGL.

No remediation is expected.

No radwaste (except sources)*is exoected.

CLASS3 Current use of sealed beta, No history of leaking sources.

gamma, or alpha sources. Removable contamination Previous use of unsealed beta- surveys previously performed gamma sources but clearance should detect most beta-gamma

• surveys were done. emitters.

Restrooms and hallways No remediation is expected.

"upstream" of personnel No radwaste (except sources) is contamination monitors. expected.

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 15 of18 There are approximately 100 previously-used rooms not specifically listed in the inventory.

Average dimensions of 20 feet by 25 feet with 15-foot ceilings. They are assumed to be 50%

CLASS 2 and 50% CLASS 3. Since the last submission of the DFP in 2016, no credit has been assessed for the clearance of rooms.

7.2 Planning and Preparation Planning and preparation includes filing for reciprocity to conduct the decommissioning, preparation of work plans including the Decommissioning Plan, site-specific training for workers, and mobilization to the site. The Project Manager develops work plans and submits reciprocity applications. The laborers and administrative assistant are assumed to be local hires and no time is required for mobilization; the other workers need a full day to mobilize to the site. The Project Manager also must secure a contract for a crane a:nd crew.

Characterization: is perfonned to detennine the radionuclides present in each area and the extent of contamination.. Health physics technicians will enter each area where radioactive materials have been used, collect sampies, scan surfaces, segregate potentially radioactive material from non-radioactive, and identify any mixed waste.

In most cases, the health physics database maintained by NIST identifies current and historical use of radionuclides in each room. The time estimated to characterize the room is based on that a

infonnation. For instance: if room contained transuranics, uranium, radium, beta-gamma

. emitters and 1-129, the room will be scanned three times. A beta-gamma probe (floor monitor for large floor areas and BP19 or equivalent for other surfaces will be used to measure contamination from most beta-gamma emitters. An alpha-sensitive probe will be used to measure contamination from alpha emitters. A very slow scan rate of only an inch or so per second is required. Finally, a probe sensitive to gamma and very low energy beta emitters (such as the GP-13 or equivalent) will be used to measure contamination from 1-129, Co-57, and similar difficult-to-detect radionuclides. Smears will be collected and counted for gross alpha and gross beta and analyzed on a liquid scintillation counter. Samples will be sent to an independent laboratory for radionuclide identification.

• 7.3 Decontamination or Dismantling of Radioactive Facility Components The removal and packaging of radioactive material such as contaminated equipment and preparation for transport to a licensed processor or disposal facility. Most material is neither contaminated nor activated and will be surveyed for unconditional release Labor hours are allotted for those unconditional release surveys as well as to move, remove, and break down equipment as necessary to facilitate release surveys or make areas accessible for MARSSIM surveys.

The order in which various buildings will be decommissioned is unknown; however, in Building 245, laboratory areas will be decontaminated and decommissioned before accelerator facilities for a number of reasons: accelerators contain short-lived byproduct material and delaying work allows for some decay; most accelerator spaces are below laboratory spaces and it makes sense to start at upper floors and work down; labo.ratories will be fully decontaminated and remediated

License No. SNM-0362 National Institute of Standards and Technology Septem her 2022 Decommissioning Funding Plan Page 16 of18 while some accelerator spaces will be locked shut and subject to long-term surveillance.

7.4 Restoration of Contaminated.Areas Based on existing survey data, surface scans performed during the site visit, and interviews with

. knowledgeable individuals, very few laboratory areas will require any remediation.

Accelerator facilities (described separately) will require extensive remediation of floor, walls, equipment, and structural materials. The Time-of-Flight Facility is above grade and remediation efforts will result in partial demolition of the building. Other activated accelerator spaces are below grade. Many are below the water table, such that demolition of those structures would increase the likelihood of releasing radioactive materials to the environment.

Many of the most highly activated areas are load-bearing or exterior walls. Complete remediation would therefore require complete demolition of all of Building 245 - a costly endeavor. For reasons of cost reduction, worker safety and protection of the environment,

. those areas will be remediated to the extent practicable and then re-evaluated.* Sub basements containing those accelerators will be secured, and long-term monitoring instituted, until -

activation products decay to levels acceptable for unconditional release.

7.5 Final Radiation Survey The final radiation survey is performed by health physics technicians, with guidance from the project manager and project supervisors and administrative support. In cases where no decontamination or remediation was required, the characterization survey may be used as the final status survey for a particular area.

7.6 Site Stabilization and Long-Term Surveillance Because the goal is unconditional release of the laboratory facilities, there are no long-term surveillance requirements associated with th.em.

7.7 Total Days by Labor Category This is the sum of person-days calculated.

7.8 Worker Unit Cost Schedule Worker mean nationwide salaries are taken from the Bureau of Labor Statistics and are adjusted to account forttie cost of fringe benefits. A 75% multiplier is also added to account for profit to the contractor performing the* decommissioning work. Workers who are not local hires are paid the government per diem rate of$258 daily for the Gaithersburg area.

7.9 Total Labor Costs by Major Decommissioning Task The cost of each major task multiplied by the daily labor cost for each worker identified in Table 4.1 above.

7.10 Packaging, Shipping, and Disposal of Radioactive Wastes This reflects the qostliest component of the facility decommissioning. It is assumed waste is

License No. SNM-0362 National Institute of Standards and Technology September 2022 Decommissioning Funding Plan Page 17 of18 shipped to a licensed waste processor in Oak Ridge, Tennessee, a distance of approximately 600 miles.

7.11 Equipment Supply and Costs (excluding containers)

The approximate costs of personnel protective clothing and respirators, rental ofspecialty equipment including health physics survey instruments, and consumables required to complete the decommissioning.

7.12 Laboratory Costs The total of all samples to be collected and sent out for analysis. It is assumed all samples will be analyzed for gamma emitters, Sr-90, H-3, C-14, and alpha emitters such as uranium, plutonium, and americium isotopes. Samples collected from accelerator facilities will be analyzed for gamma emitters.

7.13 Miscellaneous Costs Other costs not specifically captured elsewhere. It is assumed the decommissioning contractor will perform the work under reciprocity agreement with the U.S. NRC at a cost of $1800.

Liability insurance and state/local taxes are included at the rate of 6 percent and 1_0 percent, respectively, of the on-site labor costs. The cost of shielding materials needed for accelerator spaces is included here. These costs are based on an actual quote including shipping charges.

8.0 Periodic Updates to Decommissioning Cost Estimate This cost estimate was prepared using the tables and instructions provided in NUREG 1757.

Tables were converted to Excel spreadsheets and modified as necessary to enhance their applicability to the NIST site and to facilitate updating costs in the future. As areas are decommissioned from radiological use or new areas are added, that information may be changed in the spreadsheet. Labor and per diem rates are likely to change in the future. That information may be updated in the. spreadsheet to reflect future lab.or costs. Transportation costs including mileage, fuel surcharges, overweight/oversize charges; costs of shipping Containers, and disposal, site access and license costs may be updated by inserting applicable values into the spreadsheet.

For reference, Table 8.1 below shows expected escalation of decommissioning costs over the next 8 years. The annual escalation rate was estimated as the average annual United States rate ofinflation between 1946 (the first full year after World War II) and 2008

. according to the U.S. Consumer Price Index. That rate is 4.1 percent.

License No. SNM-0362 National Institute of Standards and Technology .

Septem her 2022 Decommissioning Funding Plan Page 18 of18 Table 8.1 - Projected Cost from Inflation Estimates Escalation Laboratory Accelerator 25%

Year Factor Areas Areas Contingency TOTAL 2022 NA $4,476,667 $3,960,208 $2,109,219 $10,546,094 2023 0.041 $4,660,210 $4,122,577 $2,195,697 $10,978,484 2024 0.041 $4,851,279 $4,291,602 $2,285,720 $11,428,601 2025 0.041 $5,050,181 $4,467,558 $2,379,435 $11,897,174 2026 0.041 $5,257,239 $4,650,728 $2,476,992 $12,384,958 2027 0.041 $5,472,786 .$4,841,408 $2,578,548 $12,892,742 2028 0.041 $5,697,170 $5,039,905 $2,684,269 $13,421,344 2029 0.041 $5,930,754 $5,246,541 $2,794,324 $13,971,619 2030 0.041 $6,173,915 $5,461,650 $2,908,891 $14,544,455