ML23012A058

Enclosure 1: Unified Decommissioning Funding Plan for the Pennsylvania State University

ML23012A058
Person / Time
Site:	07000113
Issue date:	12/22/2022
From:	Shannon King, Wilmot A Hershey Medical Center, Pennsylvania State Univ, University Park, PA
To:	Office of Nuclear Material Safety and Safeguards
References
Download: ML23012A058 (1)

Text

Enclosure 1:

Unified Decommissioning Funding Plan For The Pennsylvania State University Encompassing Radiation-Related Facilities At University Park, Hershey Medical Center, And Commonwealth Campus Locations December 22, 2022 Prepared by:

Aaron Wilmot Radiation Safety Officer, University Park Steve King Radiation Safety Officer, Hershey Medical Center

Enclosure 1: Introduction and. Executive Summary Intl'oduction and Executive Summary These decommissioning funding plans (DFPs) were prepared using NUREG-1757 Volume 3 Rev 1 (2012) as a guidance docmnent. The section designations correspond to the mmibering system used in Appendix A.3 of the NUREG.

The Pennsylvania State University comprises 23 major campuses spread across the state as shown in Figme 1 (note that the Penn College of Technology is not under Penn State' s Environmental Health and Safety oversight and thus is not counted in the list of supported campuses shown on the map). However, the use of radioactive materials is currently limited to the following 4 locations by either a Pennsylvania Department of Environmental Protection (PA DEP) issued license or by a Nuclear Regulat01y Commission (NRC) issued license:

I. University Park Campus (UP) - the main campus (PA and NRC licenses)

2. Penn State Breazeale Nuclear Reactor (PSBNR) at UP (NRC license)

3. Harrisburg Campus (UP PA license)

4. Penn State Hershey Medical Center (PSHMC) (PA license).

Of these four locations, only three regularly utilize radioactive material: University Park, the Hershey Medical Center, and the Breazeale reactor. The Harrisburg campus, while an authorized place of use under the UP PA state license, has only one laboratory that has utilized P-32 occasionally since the previous update of this DFP package 2019.

There are five licenses that are held by Penn State University:

License Issuing Enclosure Number 1

PA-0100 PADEP 2 PA-0127 PADEP 3 PA-0127A PADEP 4 SNM-95 NRC 5 R-2 NRC 6 Because of the disparate geographic.al and radioactive material usage differences between the licenses, each has been separated into a self-contained Enclosure. Enclosures 2, 3, and 4 are submitted for review by the PA DEP. Enclosures 5 and 6 are submitted for NRC review.

The method for estimating decommissioning costs was changed in December 2012 when an update to 10 CFR 30.35.(e).(1).(i).(A) now requires costs estimates to be based on the cost of an independent contractor to perfo1m all decommissioning activities. The cost estimates in this DFP reflect this change.

Records of information important to the decommissioning of Penn State' s licenses are retained at the University Park Envirornnental Health and Safety offices and at the Health Physics offices at the Page 2 of ?

December 2022

Enclosure 1: Introduction and Executive Summary Hershey Medical Center. Facility descriptions, including currently active buildings, nlllilbers of active lab, and most used radioisotopes have been given in the Section A.3.4 Facility Description of each attachments.

Detailed room number and isotopes used in each room and dates are included in the building deconnnissioning rep01ts that are submitted to Pa DEP or NRC for review. In addition, Historical Site Assessment resource lists have been given in Section A.3 .6 Planning and Preparation of each attachment.

Figure 1. Geographical Depiction of Penn State University Campus Locations within Pennsylvania The decommissioning cost estimates for each license, individually and combined, are as follows :

Penn State Universi Unified Decommissionin Cost Estimate License T e Enclosure Estimated Cost s p - $4.104.436 PA-0127 3 $3,668,984 PA-0127A 4 $369 391 SNM-95 5 $341 700 R-2 6 $18,541 ,855 Penn State Universi TOTAL $27 026 366 Page 3 of 7 December 2022

Enclosure I : Introduction and Executive Summary Basic Assumptions Common to All DFPs Several assumptions must be made to estimate the cost of decommissioning the facilities under each license. The assumptions common to all licenses are listed below while assumptions specific to a license are contained in that license ' s Enclosure.

1. Compliance with 10 CFR 20.1402.

The operations plans and the cost estimates are based upon meeting the release limit of IO CFR 20.1402. This release limit requires that "residual radioactivity that is distinguishable from background radiation results in a total effective dose equivalent (TEDE) to an average member of the critical group that does not exceed 25 mrem per year."

2. One license is terminated at a time.

It is very unlikely that multiple, or all, licenses would be terminated at the same time. Because of shifts in the focus of research utilizing radioactive material over time, it is much more probable that only one license would be terminated at any one time. Normally Penn State staff would be available for decommi ssioning work in these instances ; however, this DFP assumes an independent contractor will perform all work.

3. Decommissioning estimates are based on current inventory and use locations.

While each license may allow a larger selection of isotopes and activities than presently in use, this DFP is based on current inventories and use locations. As required by NRC regulations, the DFP will be updated every three years to reflect the future status of inventori es and locations.

4. Penn State University will continue a "clean operations" policy.

In accordance with 10 CFR 20.1406(c), Penn State will continue its long-standing policy of maintaining use locations free of contamination. This means that whenever a room, area, or major piece of equipment becomes contaminated, it is cleaned or disposed of, as appropriate, soon after discovery. Penn State can support this assumption by review of many years of survey data that show our laboratories do not have significant contamination issues. This "clean operations" policy is also in effect at the Hershey Medical Center.

5. No remodeling costs are included.

Decommissioning costs do not include removal or disposal of non-radioactive structures or materials beyond that necessary to terminate the radioactive material license. Costs are not included for replacing hoods or bench-tops that were removed due to contamination. No follow-up costs for remodeling and renovation are included in these estimates.

6. No credit for salvage.

No credit is taken for salvage of equipment or materials that would likely be sold or transferred to another licensee, nor is credit taken for sale of non-radioactive use items.

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Enclosure 1: Introduction and Executive Summary

7. No license amendments required.

No license amendments are expected for decommissioning. All activities are within the normal scope of tasks currently performed on a regular basis in accordance with established written procedures. If these tasks are performed by Penn State employees or by an outside group, the tasks are expected to be commensurate with normal activities.

8. Vendors will ship Type B materials.

Large activity sources that require Type B shipping containers will be shipped by outside vendors in accordance with the disposal methods currently used. No costs are included for Penn State to write and document a quality assurance plan. The outside vendor(s), specifically licensed to perform this work will perform the packaging and shipping of the material.

9. Decommissioning of buildings.

Buildings in which" ... no principal activities under the license have been conducted for a period of24 months ... " are decommissioned in accordance with 10 CFR 30.36.(d).(3). Generally, it is infrequent that a building that had radioactive material labs is decommissioned because labs do not terminate their use often. When a building is decommissioned its hoods, ducts, and sinks are checked for contamination, all labels and tags are removed, and a report is filed confirming compliance with 10 CFR 20.1402. This building report relies heavily upon the agglomeration of individual room decommissioning reports and is available for inspection. Buildings and spaces previously released by the NRC and PA DEP are not included in these DFP estimates.

10. A licensed radioactive waste site is available.

This DFP must be based upon the assumption that the shipment of radioactive waste is possible.

Penn State currently has the ability to store waste for about six years prior to shipping, but decommissioning can only be acco~plished if a low-level radioactive waste disposal facility is available.

11. The Department of Energy (DOE) will accept the return of their materials.

Certain sources and materials must be returned to the DOE for disposal. If the DOE refuses to receive this material then long-term storage costs may be significant; these costs are not included in these DFP estimates.

Basic Assumptions Common to Only PA Broad Scope License DFPs Additional assumptions have been incorporated into the DFPs for Pennsylvania Department of Environmental Protection issued broad scope licenses.

1. Waste ' On-hand ' equals one year' s waste generation.

This DFP assumes that one year' s worth of normal operations waste is already ' On-hand ' and waiting disposal at the start of decommissioning. Added to this amount will be the decommissioning waste so that the total amount of radioactive waste will be slightly larger than .

just from decommissioning activities on ly.

Page 5 of7 December 2022

Enclosure 1: lnlroduction and Executive Summary

2. A portion of prior licensee decommissioned use locations are included due to the potential need for additional verification slll.veys.

Related to assumption 2 above, laboratories and use locations which are no longer authorized for radioactive material work are surveyed and inspected by Radiation Safety staff. Location owners are required to have all radioactive material removed and to clean their facilities and equipment to background levels. Radiation Safety staff then perfonn a more detailed smvey (compared to standard quarterly smveys) to verify the space is releasable. The space is then de-posted and allowed to be used as unrestricted space.

When an entire building no longer has any radioactive material users, it has been Penn State practice over the past several years to then invite the PA DEP to inspect and officially release the building. However, this current practice does not take into account buildings which are not currently being used where the PA DEP has not had the opportunity to perform independent analysis. The1*efore, it is possible that a portion of the historical previously released spaces will need additional swvey work to verify cleanliness. An assumption is made that up to 25% of licensee-released laboratories that are not yet officially released by the PA DEP will require additional slll.vey work. Tue cost for these additional smveys is included in both broad scope license DFPs.

Reasons for the Differences in Cost Estimates with this DFP The difference in cost estimates between this 2022 DFP and the 2019 DFP are due to these factors:

1. All costs have been updated to 2022 values.

2. The number and status of laboratories has been updated to reflect that of cun-ent University operations and research.

3.

4.

5. For the Breazeale Reactor Facility, although the facility-specific DFP cost estimate, Enclosme 6.,

is in agreement with other reactors, the Georgia Institute of Technology decommissioning cost Page 6 of7 December 2022

Enclosure 1: Introduction and Executive Summary continues to be the worst case scenario and thus Penn State will continue to use that cost for this DFP.

6. The method used to establish decommissioning cost escalations over time has been modified.

The method used previously was to assume a constant, 5%/year cost escalation rate. The method used in this report employs an escalation rate that matches that of the Construction Cost Index (CCI) published by Engineering News-Record. Additional details are provided in Enclosure 6.

Page 7 of7 December 2022