ML25084A281

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Updated 2025 Decommissioning Costs and Funds, March 21, 2025, Redacted
ML25084A281
Person / Time
Site: Aerotest
Issue date: 03/21/2025
From: Slaughter D
Aerotest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML25084A281 (1)


Text

AEROTEST OPERATIONS, INC.

  • (925) 866-1212
  • FAX (925) 866-1716 March 21, 2025 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.

ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 1555 Rockville Pike Rockville, MD 20852-2738 RE: Termination request of the $300,000 cash secured Letter of Credit and moving the cash backing the Letter of Credit to Decommissioning Trust Fund letter November 14, 2024, Adams ML24324A347 and December 9, 2024, Response to Letter of Credit Termination Request Ladies and Gentlemen:

Per December 9, 2024, Response to Letter of Credit Termination Request. I am submitting the updated Decommissioning Cost Estimate and Decommissioning Trust fund in 2025 dollars. I have enclosed the full update to the cost estimate for decommissioning the ARRR reactor. The estimate includes detailed breakdown of project costs, methodologies employed, and assumptions made in calculating the overall financial requirements for safely decommissioning the reactor. A summary of technical and financial changes is provided outlining the completed work and cost updates to the remaining items.

I am not asking for a review of the plan/estimate, it is provided for the updated 2025 costs, so, we can terminate the Letter of Credit and move the $300,000 backing the Letter of Credit to the Decommissioning Trust Fund.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 21, 2025.

Respectfully, David M Slaughter, PhD AO President, Reactor Administrator, General Manager. NRC-RO and Manager CEO Nuclear Labyrinth LLC.

Attachments: Decommissioning Cost Estimate-Revision 3-17-2025 Trust Fund Balances cc:

Chris Allen, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards

Prepared for:

United States Nuclear Regulatory Commission (NRC)

NRC Reactor License R-98 Docket No. 50-228 This document provides a comprehensive dismantling methodology and cost estimate for the decommissioning of the Aerotest Radiography and Research Reactor (ARRR) facility located in San Ramon, California. The estimate includes detailed breakdowns of projected costs, methodologies employed, and assumptions made in calculating the overall financial requirements for safely decommissioning the reactor.

The following sections outline the crucial components of the decommissioning process, ensuring compliance with NRC regulations and guidelines, while maintaining the highest standards of safety and environmental stewardship.

NRC Reactor License R-98 Docket No. 50-228 Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Aerotest Operations, Inc Revision 3-17-2025 Prepared by:

David M. Slaughter, PhD AO President r

7

Summary of Technical Changes Revisions Summary of Technical and Financial Changes 1 through 6 Updated the ARRR facility D&D cost estimate to reflect the requirement to decommission the reactor components tank, and contaminated/activated areas.

What is not included in the D&D effort are buildings and components that are not activated/contaminated but remain useful. Thus, radioactive waste and general waste streams were adjusted down from the initial assessment in 2012, 2017, and 2018. The strategy and the cost assessment for decommissioning the tank and reactor components (in the tank) remain basically the same. Unrelated tasks mentioned in previous plans/estimates that are not necessary to the termination of the NRC license have been completed or removed from consideration in the 2025 decommissioning plan/estimate.

The removal and disposal of maintenance and chemical storage buildings have been complete. The secondary cooling tower was dismantled and removed from the site. The garage and vacuum/compressor buildings were cleaned and surveyed with no contamination present. The tagging room was cleaned and cleared of useless equipment and supplies. No contamination was detected during dismantling and removal. Equipment throughout the facility that was useful was surveyed and the remaining others were disposed of after being cleared. A local metal salvage company accepted nonactivated metal equipment and components, including our lead shielding materials. The concrete blocks surrounding the reactor and those placed outside will be donated to avoid disposal costs. A shared transportation cost is currently being negotiated.

The updated decommissioning estimate reflects the cost of the remaining activities in January 2025 dollars. The new cost estimates cover dismantling, packaging, transportation, and burial services for the activated/contaminated waste. Unit prices for services are shown in Tables 6.7 and 6.8. An annual inflation rate of 2.5% will be applied in the upcoming 3 years.

The estimate contains revised tables, appendices and text references that contain cost information and revised other radioactive waste information, such as waste volume, where applicable.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 TABLE OF CONTENTS Section Page Page 4 of 83 LIST OF APPENDICES................................................................................................................. 5 LIST OF FIGURES........................................................................................................................ 6 LIST OF TABLES.......................................................................................................................... 7 1.0 ACRONYMS AND ABBREVIATIONS........................................................................... 9 2.0 EXECUTIVE

SUMMARY

.............................................................................................. 10

3.0 INTRODUCTION

............................................................................................................ 11 3.1 Purpose.................................................................................................................. 11 3.2 Scope..................................................................................................................... 12 3.3 Assumptions and Bases......................................................................................... 13 4.0 GENERAL SITE DESCRIPTION................................................................................... 14 4.1 Current and Assumed Facility Status.................................................................... 14 4.2 Proposed Action.................................................................................................... 15 4.3 Administrative Controls........................................................................................ 15 5.0 DECOMMISSIONING CRITERIA................................................................................. 23 5.1 Radionuclides of Interest...................................................................................... 23 5.2 Radiological Criteria for License Termination..................................................... 25 5.3 Facility Description............................................................................................... 27 5.3.1 Reactor Building....................................................................................... 27 5.3.2 Building Addition 1.................................................................................. 32 5.3.3 Tagging Area Building............................................................................. 34 5.3.4 Demineralizer Building............................................................................. 34 5.3.5 Heat Exchanger Building.......................................................................... 34 5.3.6 Cooling Tower.......................................................................................... 35 5.3.7 Compressor Building................................................................................ 35 5.3.8 Class 1.1 Explosive Storage Container..................................................... 35 5.3.9 Storage Building....................................................................................... 35 5.3.10 Waste Storage Sump................................................................................. 35 5.3.11 Land Area.................................................................................................. 35 5.4 Relation of the ARRR to Other TRIGA reactors.................................................. 36 5.5 Outside Areas........................................................................................................ 36 6.0 ESTIMATION METHODS.............................................................................................. 60 6.1 Cost Modifying Factors........................................................................................ 61 6.2 Radioactive Waste Volume Estimates.................................................................. 65

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 5 of 83 6.3 Radioactive Waste Disposal Costs........................................................................ 65 6.3.1 Clive, Utah Radioactive Waste Direct Disposal Costs............................. 65 6.3.2 Radioactive Waste Processing and Burial Costs...................................... 65 6.4 Remediation Methods........................................................................................... 66 6.5 Radioactive Waste Volume Reduction Costs....................................................... 66 6.6 Unit Costs.............................................................................................................. 67 6.7 Final Surveys........................................................................................................ 68 7.0 FACILITY, CONDITIONS AND DECOMMISSIONING SCENARIO........................ 69 7.1 Remediation Summary.......................................................................................... 69 7.1.1 General Area Cleanup............................................................................... 70 7.1.2 Non-Reactor Remediation........................................................................ 70 7.1.3 TRIGA Reactor......................................................................................... 70 7.1.4 Demineralizer and Heat Exchange Buildings........................................... 70 7.1.5 Reactor High Bay Area............................................................................. 71 7.1.6 High Bay Mezzanine Area........................................................................ 71 7.1.7 Other Buildings......................................................................................... 72 7.1.8 Outdoor Areas........................................................................................... 72 7.2 License Termination Surveys............................................................................... 74

8.0 REFERENCES

................................................................................................................. 74

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 6 of 83 LIST OF APPENDICES Section Page Appendix A-1 Contaminated Waste Volume Summary............................................................... 75 Appendix A-2 Contaminated Waste Disposal Cost...................................................................... 76 Appendix A-3 Waste Shipping Container Cost............................................................................ 76 Appendix A-4 Waste Disposal Support Labor Estimate.............................................................. 77 Appendix A-5 Radioactive Waste Container, Cask and Labor Summary...77 Appendix A-6 Building Survey Labor Summary.78 Appendix A-6 Building Survey Labor Summary..78 Appendix A-7 Outdoor Area Survey Labor Summary..79 Appendix A-8 Instrument Lease Charges..80 Appendix A-9 Equipment Lease Charges..81 Appendix A-10 Consumable Costs...82

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 7 of 83 LIST OF FIGURES Figure Page Figure 4-1: Aerotest Operations Site Location............................................................................. 17 Figure 4-2: Aerotest Aerial Image................................................................................................ 18 Figure 4-3: ARRR Local Area View............................................................................................ 19 Figure 4-4 General ARRR Arrangement Plan.............................................................................. 20 Figure 4-5 Plan Layout of ARRR Reactor Building..................................................................... 21 Figure 4-6: Cross Section of ARRR High Bay Reactor Building................................................ 22 Figure 5-1: Reactor & N-Ray Area with Shielding in Place........................................................ 37 Figure 5-2: ARRR Core and Support Structure............................................................................ 38 Figure 5-3: ARRR Reactor Tank Cutaway and N-Ray Facility................................................... 39 Figure 5-4: ARRR In-Core Irradiation Capsule............................................................................ 40 Figure 5-5: ARRR Machine Shop................................................................................................. 41 Figure 5-6: ARRR Chemistry Lab................................................................................................ 42 Figure 5-7: ARRR Preparation Lab.............................................................................................. 43 Figure 5-8: ARRR Mezzanine Sheet Metal Fabrication Area...................................................... 44 Figure 5-9: ARRR Mezzanine Sheet Metal Fabrication Area & HVAC Unit............................. 45 Figure 5-10: ARRR Mezzanine Storage Area.............................................................................. 46 Figure 5-11: ARRR Mezzanine Instrument Calibration Area...................................................... 47 Figure 5-12: ARRR Electronics Lab............................................................................................. 48 Figure 5-13: ARRR Shipping & Receiving.................................................................................. 49 Figure 5-14: ARRR N-Ray Setup Area........................................................................................ 50 Figure 5-15: Office Space............................................................................................................. 51 Figure 5-16: Customer Viewing Area........................................................................................... 52 Figure 5-17: Quality Control Room.............................................................................................. 53 Figure 5-18: Computer and Counting Room................................................................................ 54 Figure 5-19: Tagging Area............................................................................................................ 55 Figure 5-20: Tagging Area Back Room........................................................................................ 56 Figure 5-21: Cooling Tower......................................................................................................... 57 Figure 5-22: Storage Building...................................................................................................... 58 Figure 5-23: Waste Storage Tanks................................................................................................ 59

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 8 of 83 LIST OF TABLES Table Page Table 5-1: List of Expected Radionuclides................................................................................... 23 Table 5-2: Acceptable License Termination Screening Values of Common Radionuclides for Building Surface Contamination................................................................................................... 26 Table 6-1: Decommissioning Cost Summary - ARRR................................................................ 60 Table 6-2: Personnel Protective Equipment Protection Summary............................................... 62 Table 6-3: Hazardous and Toxic Waste Productivity Factors: Light Work................................. 63 Table 6-4: Hazardous and Toxic Waste Productivity Factors: Heavy Work................................ 64 Table 6-5: ARRR Unprocessed Radioactive Waste Summary..................................................... 65 Table 6-6: Decontamination Methodology Comparison.............................................................. 66 Table 6-7: Volume Reduction/Treatment Methods Cost Information.......................................... 67 Table 6-8: Decommissioning Cost Estimate Selected Unit Cost Factors..................................... 67 Table 7-1: ARRR Planned Remediation Activities...................................................................... 69

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 9 of 83 1.0 ACRONYMS AND ABBREVIATIONS

° Degrees

°F Degrees Fahrenheit Aerotest Aerotest Operations, Inc.

AGN Aerojet-General Nucleonics AGNIR Aerojet-General Nucleonics Industrial Reactor ARRR Aerotest Radiography and Research Reactor CA State of California CDPH California Department of Public Health Ci Curies Co Cobalt COC Contaminants of Concern DOE U.S. Department of Energy HSA Historical Site Assessment L

Liter MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual mCi millicuries mR/hr MilliRoentgen per hour NRC U.S. Nuclear Regulatory Commission N-Ray Neutron Radiography pCi picocuries pCi/g picocuries per gram pCi/L picocuries per Liter RHB California Radiologic Health Branch (California Department of Health)

TRIGA Teaching Research Isotope General Atomic (reactor)

TS Technical Specification USNRC U.S. Nuclear Regulatory Commission

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 10 of 83 2.0 EXECUTIVE

SUMMARY

Energy Solutions performed the initial independent cost estimate for decommissioning the Aerotest Radiography and Research Reactor (ARRR) located in

, California. Its cost estimate was originally prepared in 2012 at the request of Aerotest Operations, Inc., (Aerotest) and has been used as the foundation of estimate updates in 2017, 2018 and 2021 with this revision dated 2025 to reflect the current status of the ARRR, and adjust cost estimates reflecting 2025 dollars.

This decommissioning cost estimate (DCE) was developed using a systematic approach, in accordance with applicable industry and regulatory guidance. Decommissioning regulatory criteria and guidance were identified and ARRR historical survey data were reviewed. Specific and general information regarding equipment and structures was used in determining decontamination and demolition methodologies in order to minimize overall decommissioning costs.

This estimate includes itemized costs for labor and equipment resources, radioactive waste and debris packaging, radioactive waste and debris shipping, radioactive waste burial activities, and the performance of final status surveys for buildings, property and structures. The estimated decommissioning cost is $1,970,250 in terms of 2025 dollars. The cost was adjusted down with the removal of 3 exterior buildings, auxiliary cooling tower and associated assets in tagging, chemistry, calibration, electronic laboratories etc. This estimate does not include the costs associated with removal of fuel and transport from ARRR to the Department of Energy (DOE).

However, ARRR has paid the fee to DOE for the disposal of the spent nuclear fuel generated by ARRR (U.S. Department of Energy Contract Amendment to DE-CR01-83NE44484).

A significant portion of the overall decommissioning costs is attributed to the disposal of radioactive waste. The radioactive waste disposal rates used for most of the waste in this estimate are based on shipping to a licensed disposal site at Clive, Utah. California allows for the disposal of radioactive material disposal in either (or both) Texas or Utah disposal sites. When fuel is removed, a decommissioning bid for tank, reactor structure and associated tank contents will be sought from both parties.

The focus of this estimate is to identify quantitatively the real radioactive and/or contaminated waste streams and eliminate the costs associated with non-radiative facilities and assets that have been cleared, removed, and disposed of. Building infrastructure and/or assets that are not radioactive or contaminated will not be removed for disposal.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 11 of 83

3.0 INTRODUCTION

3.1 PURPOSE Aerotest Operations has provided Neutron Radiographic (N-Ray) Inspection Services since 1969, using the ARRR for the source of neutrons, mainly for neutron radiography. Aerotest Operations, Inc., (Aerotest) is the holder of Facility Operating License No. R-98 for the ARRR, located in

, California. If a decision is made to decommission the ARRR, the basic steps needed to complete decommissioning are explained in this section.

As with other facilities of this nature, the ARRR Facility contains varying amounts of radioactive material and small amounts of hazardous material. Decontamination and Decommissioning (D&D) of the ARRR would eliminate the potential for future inadvertent environmental releases and other potential liabilities. The goal of the D&D activities would be termination of the ARRR TRIGA Reactor Nuclear Regulatory Commission (NRC) License R-98, Docket No. 50-228 and release of the ARRR site for "unrestricted use." The term "unrestricted use" means that there will be no future restrictions on the use of the site, other than local ordinances such as the City of zoning ordinances. ARRR also maintains Radioactive Materials License number 2010-07 with the State of California. This license governs possession and use of radioactive materials independently of the reactor. The State of California, as an Agreement State, has regulatory authority and responsibility for these specific radioactive materials. The state is the primary authority responsible for oversight and approval of decommissioning the Site with respect to these materials. In addition, the State of California is authorized to implement RCRA requirements, and through these means can implement more restrictive cleanup requirements for the ARRR decommissioning than required by the NRC. The State rules for termination of a Radioactive Materials License are provided in Title 17 California Code of Regulations, Division 1, Chapter 5, Subchapter 4, Section 30256. Currently there are no radiation dose-based release criteria for licensed facilities in California, but instead, case by case evaluations are performed of Decommissioning Plans by the California Department of Public Health (CDPH). Experience indicates that release limits that equate to a few millirem/year (mrem/yr) from residual radioactivity are generally accepted.

The cost estimate includes those activities and associated cost factors required to terminate the ARRR Nuclear Regulatory Commission (NRC) License R-98, Doc. No. 50-228 and State of California Radioactive Materials License number 2010-07 for release of the facility for "unrestricted use." It should be understood that the estimate does not include costs for removal and disposition of remaining uncontaminated facility infrastructure, such as concrete and asphalt that remain at the site. Disposal of this remaining infrastructure will fall under the jurisdiction of the State of California and/or local rules and regulations, if applicable.

The cost estimate provided in this report is based on prompt decommissioning (within the next several years), costs are in terms of 2025 dollars. This cost estimate is intended to be used for funding and budgetary purposes.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 12 of 83 3.2 SCOPE The scope of this 2025 report is to present the estimated costs derived for decommissioning the ARRR. The buildings and outdoor areas have been surveyed and found no activated and/or contaminated materials. Until the final survey the buildings and outdoor areas will remain covered by this estimate. Specific areas include:

TRIGA Reactor TRIGA Reactor Shield and N-Ray Components Buildings Outdoor Areas This estimate has been prepared to provide a budgetary DCE and to support the requirements of 10 CFR 50.82(b), Termination of License for Non-Power Reactor Licensees (Ref. 8.1). This estimate addresses activities related to the removal of hardware, structural materials, and miscellaneous materials as necessary to reduce levels of residual radioactivity to below the guideline values in the NRC criteria for license termination contained in Subpart E of 10 CFR Part 20 (Ref. 8.2).

The current NRC guidance for acceptable license termination screening values (meeting the 10 CFR 20.1402 criteria) of common radionuclides for building surface contamination and surface soil contamination are presented in NUREG-1757, Consolidated NMSS Decommissioning Guidance, Decommissioning Process for Materials Licenses, Appendix B, (Ref. 8.3). For the purposes of this estimate, it was assumed that license termination screening values of 12%

(3/25th) of the 10 CFR 20.1402 criteria would be acceptable to California (equivalent to 3 mrem/yr above background versus the NRC allowed 25 mrem/yr above background).

Decommissioning costs are directly related to the degree of remediation required and the amount of radioactive waste generated. The extent of remediation is based on radiological data, and proven decontamination processes. The volume of radioactive waste was estimated based on data provided from facility drawings, equipment sizes, Characterization Surveys, routine facility radiological data, and proven volume reduction processes. Costs associated with the performance of Final Status Surveys were estimated based on the size of the various areas being decommissioned and their prior radiological history.

The cost estimate for ARRR utilizes a combination of unit price estimates and task-based estimates to arrive at a total cost in 2025 dollars for decommissioning affected areas. The unit cost methodology is modeled after the method used in the Means Building Construction Cost Data (Ref. 8.4). The decommissioning work is first divided into units of work, such as removing a 2-inch pipe run, and then the unit cost per foot for pipe removal is multiplied by the total feet of pipe to arrive at the cost. A similar method is used for decontamination work, such as the decontamination of a concrete floor. The unit cost per square foot for concrete floor decontamination is multiplied by the total square feet of floor area to arrive at the cost. These estimates includes the craft labor, supervision, health physics support, waste disposal, materials and equipment necessary to actually perform this task. Other work is priced using the task based methodology which is modeled after the method used by the Pacific Northwest Laboratory (PNL) to prepare the estimates presented in NUREG/CR-1756, Technology Safety and Costs of

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 13 of 83 Decommissioning Reference Nuclear Research and Test Reactors, March 1982 (Ref. 8.5). The work is divided into various tasks, such as decontaminating pool walls, and then an estimate is generated for each task. The various costs derived from the two methods are combined and a project schedule is developed which defines the duration and man-loading for the project. The schedule and man-loading information were used in the development of costs for on-site project management, travel and living for non-local workers, equipment rental, home office support, and owner oversight.

3.3 ASSUMPTIONS AND BASES The following assumptions and bases were utilized in developing the cost estimate.

The reactor fuel will have been removed and transported from ARRR to the DOE or placed in storage outside the pool prior to the start of decommissioning; costs for these activities are not included in this estimate.

ARRR will be decontaminated, all radioactive waste will be removed, and the facility will be released for unrestricted use.

Some of the uncontaminated materials and equipment located throughout the facility have a high intrinsic value and may be sold or moved to another facility prior to decommissioning. No credit has been taken for the sale of any items.

The use of radioactive materials at the ARRR has been well controlled and contaminated areas are minimal and well defined. Contamination outside of the defined areas is not anticipated and costs for remediation outside of currently contaminated areas are not included in this estimate.

Contaminated material will, for the most part, be shipped directly to a licensed radioactive waste disposal site. Some material may be shipped to a volume reduction or treatment facility (e.g., contaminated lead) for processing prior to disposal.

It is assumed for this cost estimate that some equipment and materials that have minimal contamination based on surveys (i.e., contamination below the applicable release limits) will be sent for disposal. Waste will be managed per Reference 8.11.

Aerotest will provide security for the site, electrical power and water will be available, and ARRR staff and management will be on site during decommissioning.

Radioactive dry active waste (DAW) with low specific activity will be sent to the licensed facility in Clive, Utah for disposal. It is assumed that contaminated concrete, protective clothing waste and miscellaneous DAW generated by D&D activities will qualify for disposal at Clive, Utah.

Local decontamination technicians and supervisors will be used to staff this project; therefore, no travel and living funds are included for local personnel.

Construction labor rates were obtained from the Means Building Construction Cost Data (Ref. 8.4) for Oakland, California, adjusted for inflation.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 14 of 83 4.0 GENERAL SITE DESCRIPTION The property, on which the ARRR is situated, was designated for construction in 1963. The ARRR was constructed between 1963 and 1964. The ARRR site configuration is shown in Figure 4-1, Figure 4-2 and Figure 4-3. The land area is well defined, as there is a fence around the facility, except for the facility parking lot. The Reactor Building footprint is about 3,200 square feet and has two floor levels, and the total footprint for all buildings is 9,250 square feet.

Figure 4-4 provides a layout of the ARRR buildings, Figure 4-5 provides a plan view of the High Bay Reactor Building and Figure 4-6 provides a cross section view of the Reactor Building.

The areas listed in this section of the ARRR DCE include all rooms in all buildings, whether remediation could be required or not, based upon the characterization study and survey performed in May 2011.

In 1963 Aerotest began construction of a facility to house the TRIGA Reactor, and supporting systems (e.g., Instrumentation and Control Systems, Forced Cooling System, Water Demineralization System, Ventilation/Exhaust System, Radiation Monitoring Systems, etc.).

Following construction and reactor hardware installation, the TRIGA Reactor was brought to initial criticality in July of 1964. The TRIGA was routinely operational from that date until October 2010. Some anticipated facility conditions applicable to decommissioning are listed in the following section.

4.1 CURRENT AND ASSUMED FACILITY STATUS The following conditions are currently in place:

ARRR utility services required for facility operation and maintenance under POS status conditions will remain active.

Manually actuated and automated fire alarm systems in the ARRR will remain operational.

All building utility services required for facility operation and maintenance are active and will be available as needed.

The license-required radiological monitoring and instrumentation systems will remain operational.

Existing physical security and material control and accounting plans approved by the Nuclear Regulatory Commission (as may be amended) will continue to be implemented.

The water demineralization system serving the ARRR is currently operational, although the status may change depending on requirements that are implemented by future license amendments.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 15 of 83 4.2 PROPOSED ACTION The Proposed Action (Modified SAFSTOR) allows the Aerotest Reactor to be placed and maintained in a condition to be safely stored and subsequently decontaminated to a USNRC and/or state of California level permitting eventual unrestricted release of the property. This would involve retention of the fuel onsite until the Department of Energy (DOE) is able to take the spent fuel. This action would involve maintaining:

o The facility reactor operating license o Personnel to support facility maintenance and surveillance o Surveillance and maintenance of Reactor Pool Water Level, Purity and pH o The Reactor Facility Physical Security Plan The reactor tank still contains fuel and activated hardware items with gamma radiation levels (estimated 500 R/hr on contact in 2011). The reactor tank does not have a history of leakage.

Implementation of the Proposed Action would include retention of the fuel on site until the DOE is able to take the spent fuel. This could probably be accomplished using one of two scenarios:

(1) storing the fuel in the pool where it is currently located and/or (2) removal of the reactor fuel from the tank to an on-site dry storage container.

The scenario where the fuel is maintained in the pool may include the following tasks:

Storage of the fuel in storage racks on the pool floor or on the pool walls.

Continued presence of water and operation and maintenance of the pool water demineralizer and cooling systems.

Optional removal of the pool water, demineralizer and cooling systems including heat exchanger and cooling tower.

4.3 ADMINISTRATIVE CONTROLS To minimize the risks of inadvertent exposure, contamination and/or radioactive releases, all decommissioning operations will be implemented in accordance with appropriate technical and administrative controls, including:

Performance of all project work pursuant to approved procedures implementing a USNRC-approved Decommissioning Plan. ARRR will continue to be responsible for assuring and demonstrating compliance with USNRC licenses, as well as other applicable federal, state or local laws, regulations, licenses and/or permits.

Application of ALARA principles by emphasizing radiation protection for workers and the general public, employing personnel and area dosimetry, using personal protective equipment and clothing, and conducting work through approved Radiological Work

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 16 of 83 Permits. The term "ALARA" means as low as is reasonably achievable, taking into account the state of technology and the economics of improvements in relation to the benefits to public health and safety, and other societal and socioeconomic considerations.

ARRR Health Physics staff will have the authority to stop any operations that they believe may involve unusual, unnecessary or excessive radiological risk to the worker, the public or the environment.

Maintenance of security access control to the work site and facility to restrict unauthorized individuals from the work area.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Figure 4-1: Aerotest Operations Site Location Revision 2-10-2025 Page 17 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Figure 4-2: Aerotest Aerial Image Revision 2-10-2025 Page 18 of 83

Decommissioning Cost Estimate for the Page 19 of 83 Figure 4-3: ARRR Local Area View

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 20 of 83 Figure 4-4 General ARRR Arrangement Plan

Decommissioning Cost Estimate for the Page 21 of 83 Figure 4-5 Plan Layout of ARRR Reactor Building

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 22 of 83 Figure 4-6: Cross Section of ARRR High Bay Reactor Building

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor 5.0 DECOMMISSIONING CRITERIA Revision 2-10-2025 Energy Solutions radiological engineers visited ARRR in San Ramon, California in May of 2011 to gather physical and radiological data for characterization of the facility. Facility sketches, building drawings, and radiological characterization data for affected areas and potentially affected areas were obtained.

5.1 RA.DIONUCLIDES OF INTEREST The baseline radioactive material quantities were obtained from the estimate provided in NUREG/CR-1756, (Ref. 8.5). There are additional radionuclides repo1ted in the characterization smvey report (Ref. 8.6) that were not included in NUREG/CR-1756 and, therefore, do not have estimated quantities. After reactor shut down and for some time after, 6°Co and, to a smaller extent, 65Zn are the principal contributors to radiation dose from the reactor core and vessel.

Most(> 95%) of the radionuclide invento1y at the facility is found in the reactor pool. Excluding fuel, this amounts to about 34 Ci of neutron activation and fission products at the time of shutdown. The radionuclides that potentially exist in the ARRR along with estimated inventories as of September 2012 are presented in Table 5-1.

Table 5-1: List of Expected Radionuclides Nuclide Half-Life Inventory (yr)

Ci 3H

  • 12.28

<28.7 l°Be 1,510,000 7.25 X 10-7 i*c 5,730 6.48 X 10-3 22Na 2.60 1.67 X 10-2 3ss 0.2392 2.99 X 10-4 36CI 301,000 2.85 X 10-4 37Ar 0.0960 1.85 X 10-5 39Ar 269 2.61 X 10-7 41Ca 103,000 l.l0x 10-4

  • sea 0.446 2.54 X 10-3 46Sc 0.233 2.04 X 10-5 SICr 0.0759 1.03 X 10-4 S4Mn 0.86 2.26 X 10-3 ssFe 2.73 0.385 S9fe 0.1222 1.56 X 10-4 ssco 0.194 1.00 X 10-4 60Co 5.27 0.896 S9Nj 76,000 1.34 X 10-4 63Ni 100 1.75 X 10-2 6Szn 0.67 0.203 Page 23 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Nuclide Half-Life (yr) 90Sr 29.1 93'"Nb 13.6

"'Nb 20,000 9,Mo 4,000 95Zr 0.175 9sNb 0.0961 95'"Nb 0.0099 lOSAg 4.51 X 10-6 10811!.Ag 418 109mAg 1.26 X 10-6 ll0Ag 7.80 X 10-7 llOmAg 418 109Cd 1.27 lB"'Cd 14.1 llS"'Cd 0.122 lBmln 0.000189 113Sn 0.315 ll9mSn 0.803 121Sn 0.00309 12lm$n 55 123Sn 0.354 124Sb 0.16 125Sb 2.76 123mTe 0.328 125mTe 0.157 134Cs 2.7 137Cs 30.17 133Ba 10.51 139Ce 0.377 141Ce 0.0890 144Ce 0.78 1s2Eu 13.48 154Eu 8.8 1ssEu 4.96 1s,Gd 0.659 mw 0.332 iasw 0.206 20,Hg 0.128 2°"fl 3.78 Revision 2-10-2025 Inventory Ci 0.454 3.68 X 10-9 2.15 X 10-8 1.19 X 10-8 1.21 X 10-2 1.36 X 10-2 9.54 X 10-7 1.39 X 10-2 0.159 1.76 X 10-3 1.19 X 10-2 0.878 0.120 1.07 X 10-3 8.13 X 10-6 6.74 X 10-4 6.74 X 10-4 2.17x 10-2 2.19 X 10-5 2.82 X 10-5 2.40 X 10-4 8.51 X 10-3 3.00 X 10-3 3.69 X 10-5 7.31 X 10-4 9.16 X 10-7 0.283 6.17xlO-4 6.94 X 10-9 1.11 X 10-8 0.185 1.59 0.161 1.73 X 10-2 8.93 X 10-5 1.12 X 10-7 5.12 X 10-7 4.42 X 10-6 5.82 X 10-5 Page 24 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Nuclide Half-Life (yr) 2osPb 15,3000,000 210p0 0.3791 233Pu 87.7 239/"°J>u 24,110 241Pii 14.35 241Am 432.2 2*2em 0.446 Revision 2-10-2025 Inventory Ci 9.80x 10-5 1.75 X 10-2 4.35 X 10-4 6.95 X 10-4 1.32 X 10-2 3.59 X 10-3 5.62 X 10-4

  • Argon is a gas that will dissipate and will have an inventory close to zero. Tritium migrates easily and most of it will dissipate. The tritium inventory without dissipation is shown with a less than sign.

The list of expected radionuclides provided above is based on the assumption that operation of the ARRR has resulted in the neutron activation of reactor core components and other integral hardware or strnctural members which were situated adjacent to, or in close proximity to, the reactor core during operations. Specific items which are considered to have been exposed to neutron flux that produced activation include materials composed of aluminum, steel, stainless steel, graphite, cadmium, lead, concrete and possibly others. In addition, the activity in spent resin was estimated based on analytical results and an estimated spent resin invento1y.

5.2 RADIOLOGICAL C RITERIA FOR LICENSE T ERMINATION The overall objective of the ARRR decommissioning is to remediate the facilities to a condition that con esponds to a calculated dose to the public of less than 3 mrem/year from applicable pathways. It is assumed that the facilities may then be released for unrestricted use. A 25 mrem/year dose limit appears in 10 CFR 20.1402, Radiological Criteria for Unrestricted Use (Ref. 8.7) but this was reduced to 3 mrem/year for projected State of California requirements.

The Derived Concentration Guideline Level (DCGL) is defined in MARSSIM (Ref. 8.8) as the radionuclide-specific concentration within a smvey unit con esponding to the release criterion.

The DCGL is dependent upon several factors including the radionuclides of interest, applicable dose pathways, area occupancy and the future use of the facility. DCGLs assume a relatively unifo1m level of residual radioactivity across the smvey unit.

For the ARRR it was assumed that the site qualified for a screening analysis to develop the DCGLs, which is generally conse1vative. A screening analysis can be based on one or more of cmTently available screening tools: (1) building surface contamination and surface soil contamination screening criteria are presented in NUREG-1757, Appendix B (Ref. 8.9), or (2) screening levels derived using the software DandD, Version 2.0 (Refs. 8.9 and 8.10), for the specific radionuclides using the code default parameters. The assumed DCGLs for ARRR were based on 12% of the look-up tables in NUREG-1757, Appendix H (Ref. 8.9), which is equivalent to a potential dose of 3 mrem/year from residual contamination. Table 5.2 shows the NRC acceptable screening values and the State of California screening levels that are assumed to be acceptable, for the major radionuclides of concern at the ARRR.

Page 25 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Buildings with surface contamination below 12% of the screening tables in NUREG-1757, Appendix B will be assumed to be acceptable for release for unrestricted use, provided that the following conditions are met:

Residual radioactivity has been reduced to levels that are "as low as is reasonably achievable" (ALARA),

The residual radioactivity is contained in the top layer of the building surface (i.e., there is no volumetric contamination), and The fraction of removable surface contamination does not exceed 0.1.

Table 5-2: Acceptable License Termination Screening Values of Common Radionuclides for Building Surface Contamination1 Radionuclide Symbol NRC acceptable California acceptable screenin2 levels1 for screening levels3 for unrestricted release unrestricted release

( dpm/100 cm2) 2 (dpm/100 cm2)

Hydrogen-3 3H l.2E+08 1.4E+07 (Tritium)

Carbon-14 14C 3.7E+06 4.4E+05 Sodium-22 22Na 9.5E+03 1.1E+03 Sulfur-35 3ss 1.3E+07 1.6E+06 Chlorine-36 36Cl 5.0E+05 6.0E+04 Manganese-54 54Mn 3.2E+04 3.8E+03 Iron-55 ssFe 4.5E+06 5.4E+05 Cobalt-60 6oco 7.1E+03 8.8E+02 Nickel-63 63Ni l.8E+06 2.2E+05 Strontium-90 9osr 8.7E+03 l.0E+03 T echnetium-99 99Tc l.3E+06 l.6E+05 Iodine-129 1291 3.5E+04 3.4E+03 Cesium-137 137Cs 2.8E+04 2.8E+04 Iridium-192 192Ir 7.4E+04 8.8E+03 1 Screening levels are based on the asswnption that the fraction of removable surface contamination is equal to 0.1. For cases when the fraction of removable contamination is undete1mined or higher than 0.1, users may assume, for screening purposes, that 100% of surface contamination is removable, and therefore the screening levels should be decreased by a factor of 10. Alternatively, users having site-specific data on the fraction of removable contamination ( e.g., within the 10% to 100% range) may calculate site-specific screening levels using DandD Version 2.

Page 26 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 27 of 83 2 Units are disintegrations per minute per 100 square centimeters (dpm/100 cm2). One dpm is equivalent to 0.0167 Becquerel (Bq). The screening values represent surface concentrations of individual radionuclides that would be deemed in compliance with 12% of the 0.25 mSv/yr (25 mrem/yr) unrestricted release dose limit in 10 CFR 20.1402. For radionuclides in a mixture, the sum of fractions rule applies; see 10 CFR Part 20, Appendix B, Note 4 for an explanation. Refer to NUREG-1757 for further information on application of the values in this table.

3 For the purposes of this estimate, it was assumed that license termination screening values of 12%

(3/25th) of the 10CFR20.1402 criteria would be acceptable to California (equivalent to 3 mr/yr above background).

5.3 FACILITY DESCRIPTION The ARRR facility includes the reactor building and support buildings, as well as several support buildings that were added since the reactor was constructed. Figure 4-4 provides a layout view of the ARRR buildings and Figure 4-2 provides an overhead view of the site.

5.3.1 Reactor Building The reactor building is made of steel with internal rooms built of fire-resistant framing and sheetrock covering. An automatic sprinkler system covers the entire building. The building has airflow control from the standpoint that certain rooms are maintained at a positive pressure relative to the reactor room. The building as a whole is not sealed or contained and requires no airlocks. The reactor control room and certain offices are housed in a single building. The control room and offices are in areas where fresh air intake is used to maintain the positive pressure relative to the reactor room.

The floor in the N-Ray area is covered with an industrial grade carpet.

Figure 4-5 provides a plan view of the reactor building; Figure 4-6 provides a cross section view of the Reactor Building and Figure 5-1 is a photograph of the Reactor and N-Ray Area with shielding in place.

5.3.1.1 Reactor Tank and Core The ARRR was designed and constructed by Aerojet General Nucleonics (AGN) in 1964.

Figure 5-6 shows the ARRR Core and Support Structure. The reactor fuel elements, reflector elements, control rods, control rod drive mechanisms, and control rod drive controls were purchased from General Atomics and were incorporated without any significant changes. A standard G ring core grid plate design was provided by General Atomics and manufactured by Aerojet. All other components were designed and constructed by Aerojet or their subcontractors.

Figure 5-2 shows the ARRR Core and Support Structure.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 28 of 83 The basic nuclear design and core geometry follow General Atomics TRIGA reactor design characteristics. The original core was comprised of all aluminum clad fuel elements; however, new fuel elements are stainless steel clad. The original fuel elements are enriched to 8 weight %

U-235 and the stainless steel clad fuel elements are 12 weight % U-235.

The principal characteristics of the ARRR are as follows:

(1)

Fuel: < 20% enriched U-235.

(2)

Moderator: zirconium hydride and water.

(3)

Reflector: demineralized water and graphite.

(4)

Coolant: demineralized water.

(5)

Control: 1 safety rod, 1 shim rod, 1 regulating rod, all boron carbide.

(6)

Structural material: aluminum and stainless steel.

(7)

Shield (principal materials): demineralized water, concrete, lead, and wood.

(8)

Active core dimensions: 19.44 inches diameter (nominal) by 14 inches high for aluminum clad elements and 15 inches high for stainless steel elements.

5.3.1.2 Experimental Facilities (1)

The N-Ray Facility (Figure 5-3) consists of two parts: a vertical beam tube and the radiography facility. Note that this image does not show the additional concrete and wood biological shielding that was added at a later time. The vertical beam tube is a hollow sealed tube, located adjacent to the core on the east side of the reactor, which extends from the floor of the reactor tank to above the reactor tank water surface. This vertical beam tube, by providing a path that does not contain the water that acts as a shield, allows a beam of neutrons from the core to reach the radiography facility located above the reactor.

The vertical beam tube consists of a two-section tapered tube with a rectangular cross section with the weight supported directly by the bottom of the reactor tank. The vertical beam tube has a total length of approximately 23 feet. The top of the beam tube terminates at the bottom of the reactor bridge structure. The external dimensions of the beam tube are about 8 inches by 10 inches near the base and tapers to 22 inches by 34 inches at the top. The top of the vertical beam tube is supported laterally at the top of the pool.

The lower 48 inches of the lower section of the vertical beam tube is filled with graphite for moderation of fast neutrons. The upper section of the vertical beam tube is filled with helium which is a better medium for collimated neutrons than air which scatters the neutrons. Both the upper and lower sections of the vertical beam tube are

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 29 of 83 equipped with fill and drain lines that are used to remove water or purge the vertical beam tube.

The lower 84 inches of the vertical beam tube is covered with lead for gamma shielding. This lead shield is 3 inches thick on the reactor side and 1 inch thick on the other three sides. The lead is protected from the pool water by welded sheets of aluminum. All components contacting the pool water are fabricated from aluminum or stainless steel.

The vertical beam tube includes an upper open/close pneumatically operated shutter and a lower electrically operated shutter mechanism that offers a selection of 5 aperture settings to provide varying depths of field or resolution. The lower aperture is located near the bottom of the vertical beam tube just above the graphite.

The neutron radiography facility is integrated into the shielded enclosure directly above the vertical beam tube. The shielded enclosure consists of 20-inch-thick concrete block shielding stacked to a nominal height of 80 inches above the floor that surrounds the entire top of the reactor water tank. The neutron radiography facility is supported by 10-inch steel I beams that transmit the weight of the shielding to beams imbedded in the floor of the reactor building. This shielding supports the 11 inch thick wood (fir) beams that cover the reactor enclosure. This shielding provides an additional shielding for operating personnel.

This shielding enclosure is penetrated at the north and south ends on the east side of the reactor by the neutron radiography facility. Access to the top of the vertical beam tube is through openings on both the north and south ends with cross sectional dimensions of approximately 37 inches wide by 18 inches high. The facility was designed to allow neutron radiography of contained detonating cords having lengths in excess of 25 feet. Concrete blocks in the shield structure may be moved as necessary to accommodate taller objects.

The top of the vertical beam tube is covered by a movable radiation shield called the neutron beam catcher. The beam catcher shield is wood that is 48 inches by 47 inches by 16.5 inches and has wheels that roll on tracks attached to the tunnel. The wheels allow the beam catcher shield to be rolled to the south end to radiograph large items on the north end. The beam catcher shield reduces the radiation level due to neutrons and gammas within the reactor room and at the exclusion area fencing.

Figure 5-1 is a photograph of the radiography facility with biological shielding in place.

(2)

The Graphite Thermal Column (Figure 5-3) is a large block of graphite, encased in aluminum, containing five rows of seven vertical holes through the graphite block.

The vertical holes allow specimens to be inserted into the graphite block for irradiation. The five rows of irradiation holes (A through E) are six inches apart with each row at an increasing radius from the core. The increasing radius of each row

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 30 of 83 allows samples being irradiated to be subjected to different ratios of thermal to fast neutrons.

There are seven irradiation holes in each row. The irradiation holes are 1.5 inches in diameter, similar to the reactor core grid plate, which allows the same capsules or devices that are inserted into the core to be inserted into the graphite thermal column.

The thermal column graphite block measures 4 feet along the radial axis of the core and is 2 feet wide and 2 feet deep. It is located on the south side of the reactor and positioned adjacent to the core. The thermal column is positioned using tapered pins and is bolted to the bottom of the reactor pool tank. Installation and removal of the whole assembly is accomplished with the facility crane and remote handling tools.

(3)

The Central Core Irradiation Facility is a hexagonal section that can be removed from the center of the upper grid plate to allow insertion of specimens into the core region of highest flux. Use of the central core irradiation facility requires prior relocation of the central fuel element and the six elements from the B-ring. Technical Specifications limit the size of the central core irradiation facility to 16 square inches.

The facility will accommodate specimens up to about 4.4 inches in diameter.

(4)

The Triangular In-Core Irradiation Facilities consist of two sections cut out of the upper grid plate, each of which encompasses one D-ring and two E-ring holes. When fuel elements are placed in these locations, their lateral support is provided by special aluminum pieces. With the aluminum spacers removed, each of these triangular sections allows the insertion of circular experiments to a maximum of 2.35 inch diameter or triangular experiments to a maximum of 3.0 inches on a side.

(5)

The Beam Port was never finished but the ARRR was designed to facilitate future installation of a horizontal beam port. The ARRR reactor tanks concrete embedment includes one penetration consisting of one 24 inch outside diameter pipe about 13 feet long that butts up against the outside of the reactor tank on the center line of the core.

The pipe sleeve was provided so that a horizontal beam port could be installed without having to break through the concrete around the tank. However, the beam port facility was never installed and the reactor tank wall is not cut open at this location.

5.3.1.3 Coolant System The ARRR cooling system is comprised of three basic parts: the reactor water tank, the cooling system, and the demineralizer system. The pool water provides convection cooling, neutron and gamma shielding and neutron moderation. The cooling system provides heat removal to a cooling tower via a heat exchanger. The demineralizer system maintains the purity of the water.

A fourth component is the reactor water tank makeup system. This system is comprised of a small ion exchange column connected to the city water supply and redundant level control valves for the reactor water tank. Figures 5-21 and 5-22 show the locations of the demineralizers, the heat exchanger and the cooling tower.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 31 of 83 5.3.1.4 Radioactive Material Storage Area The ARRR generates very little radioactive waste. Most of the induced radioactivity is short half-life material and can be stored until the radioactivity decays. The Radioactive Material Storage Area is a locked room with restricted access and it is used to store contaminated demineralizers, contaminated Personal Protective Equipment, radioactive sources, used filters, contaminated or irradiated materials removed from the reactor during repairs and modifications, and miscellaneous contaminated or irradiated items.

5.3.1.5 Machine Shop and Office Supply Room The Machine Shop is currently little utilized but it was used to machine repair parts and parts for new experimental facilities. The Office Supply Room is located against the south wall of the reactor building as shown on the general layout drawing in Figure 4-4. It is used to store office supplies and has a concrete floor and no false ceiling. Figure 5-9 is a photograph of a portion of the Machine Shop.

5.3.1.6 Control Room The Control Room contains the reactor operating console and lies at the end of the western utility trench. The floor is carpeted; there is a false ceiling, a viewing window into the N-Ray area and a locked door entry into the N-Ray area. No records indicating radiological or chemical use or storage were identified.

5.3.1.7 Chemistry Lab The Chemistry Lab is a small room on the mezzanine that contains two work bench cabinets, a fume hood and two sinks, the Cold Sink which drains to the sewer and the Hot Sink which drains to an outdoor waste holdup and sampling tank. Figure 5-6 is a photograph of a portion of the Chemistry Lab including the Cold Sink.

5.3.1.8 Preparation Lab The Preparation Lab is a small room on the mezzanine that contains a worktable, marble weighing table and non-radioactive waste disposal drum. Figure 5-7 is a photograph of a portion of the Preparation Lab.

5.3.1.9 Bioshield Hallway The Bioshield Hallway is a small room on the mezzanine across from the Preparation Lab. The hallway leads to the top of the bioshield.

5.3.1.10 Mezzanine Storage Area The Mezzanine Storage Area is an open-topped portion of the mezzanine. This area contains the control room HVAC system, a storage area for spare mechanical parts of all sorts, and wall mounted cabinets just off the mezzanine and over the bioshield that are used to store reactor pool

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 32 of 83 tools. Figure 5-8 is a photograph of the northern portion of the Sheet Metal Fabrication Area and Figure 5-9 is a photograph of the Sheet Metal Fabrication Area and HVAC System.

5.3.1.11 Sheet Metal Fabrication Area The Sheet Metal Fabrication Area is an open topped portion of the mezzanine that is just an extension of the Mezzanine Storage Area.

Figure 5-10 is a photograph of the Mezzanine Storage Area.

5.3.1.12 Instrument Calibration Area The Mezzanine Storage Area is an open-topped portion of the mezzanine that is next to the Chemistry Lab and Preparation Lab. This area is used for instrument calibrations. It contains a drawing table used for reviewing drawings and calibrating instruments at fixed distances from sources, drawing storage drawers and files, and miscellaneous other equipment and HVAC components. Figure 5-11 is a photograph of the Instrument Calibration Area.

5.3.1.13 Electronics Lab The Electronics Lab is a small room on the mezzanine that is next to the Instrument Calibration Area. This area contains spare electrical parts of all sorts. No records indicating radiological use or storage were identified. Figure 5-12 is a photograph of the Electronics Lab.

5.3.1.14 Offices and Restroom Areas The Restrooms and Offices in the reactor building are as shown on the general layout in Figure 4-4. Rooms 14 and 15 are restrooms that connect to the city sewer system. Room 17 is the General Managers Office, Room 18 is a hallway and the Business Office, and Room 19 is the Accounting Office. These offices have floors covered with industrial-grade carpet and they have false ceilings. No records indicating radiological or chemical use or storage were identified.

5.3.2 Building Addition 1 Building Addition 1 is a 45 foot by 60-foot steel structure with internal rooms built using fire resistant framing and a double layer or sheetrock. An automatic sprinkler system covers the entire building. The building as a whole is not sealed or contained and requires no airlocks. This area provides essential support functions for the N-Ray operation. This building contains shipping and receiving, N-Ray Setup Area, Counting Room, office space, film viewing room for customers, Quality Control Room, Dark Room, Explosive Storeroom & Safe, and the Film Storage Room as shown on the general layout in Figure 4-4.

5.3.2.1 Shipping & Receiving The Shipping and Receiving area is sometimes referred to as the garage as it has a garage type rollup door. This area has large metal shelves and a high ceiling, is approximately 25-foot by 14.5-foot by 13 foot tall. It includes a bare concrete floor and the doorway into the Film Storage area. No records indicating radiological use or storage were identified.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 33 of 83 Figure 5-13 is a photograph of the Shipping & Receiving area.

5.3.2.2 N-Ray Setup Area The N-Ray setup area includes a large portion of the Building Addition 1 structure, approximately 38.5 foot by 34-foot. The floors are bare concrete, the ceilings are over 13 feet in height and there are doorways to the outside, and operating areas. This area also includes several heavy duty work tables that are used to set up the exposure trays for N-Ray radiography work.

No records indicating radiological use or storage were identified. Figure 5-14 is a photograph of the N-Ray Setup Area.

5.3.2.3 Film Storage Room The Film Storage Room is a 9.8-foot by 6-foot by 8-foot-tall room located at the end of the Shipping & Receiving area as shown in Figure 5-13. There is also space between the roof of the Film Storage Room and the ceiling of the building 1 Addition that is used for temporary storage of miscellaneous items. This room was used as a second explosive storage safe when two non-compatible explosives needed to be stored in-house at the same time.

5.3.2.4 Explosive Storage Safe The Explosive Storage Safe is a 9.8-foot by 6-foot by 8-foot-tall room located at the northeast corner of the Shipping & Receiving area as indicated in the layout drawing shown in Figure 4-4.

Some of the items that are radiographed contain explosive initiators and that are temporarily stored in this room before and after radiography. No records indicating radiological or chemical use or storage were identified.

5.3.2.5 Offices and Film Handling Areas There is a hallway, Office Space area, a Customer Viewing Room, a Quality Control Room and a Dark Room located along the eastern wall of building 1 Addition. The Office Space area is a 16-foot by 13-foot by 8-foot-tall room with carpeted floor and drywall finished walls and ceiling that includes desks and worktables for staff use as shown in Figure 5-15. The film viewing room for customers (Customer Viewing Room) is a 16-foot by 10-foot by 8-foot tall room with carpeted floor and drywall finished walls and ceiling that includes facilities for clients to view completed radiographs as shown in Figure 5-16. The Quality Control Room is a 16-foot by 9-foot by 8-foot room with tiled floor and drywall finished walls and ceiling. This room includes film processing equipment, facilities for temporary storage of radiographs, and equipment for viewing radiographs as shown in Figure 5-17. The Dark Room is a 16-foot by 11-foot by 8-foot-tall room with vinyl tiled floor and black drywall walls and ceiling, as shown on the general layout in Figure 5-1. There were no other indications of radiological use or storage.

5.3.2.6 Computer and Counting Room The Computer and Counting Room is an 11-foot by 7.5-foot room located at the southwest corner of the N-Ray Setup area as indicated in the layout drawing shown in Figure 4-4. This room has a shielded cave with sodium iodide detector and instrumentation and supplies for

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 34 of 83 counting samples as well as exempt sources for performing instrument response checks.

Figure 5-18 is a photograph of the Computer and Counting Room.

5.3.3 Tagging Area Building The Tagging Area Building is a 20 foot by 40 foot steel structure with internal rooms built of fire resistant framing and sheetrock covering except for the wall toward the Reactor Building which is a cinderblock wall. An automatic sprinkler system covers the entire building. The building as a whole is not sealed or contained and requires no air-locks. It contains the Tagging Area, the Tagging Area Back Room, and an entry vestibule as shown on the general layout in Figure 4-4.

5.3.3.1 Tagging Area The Tagging Area includes a 35-foot by 19-foot portion of the Tagging Area Building as shown in Figure 4-4. The floors are bare concrete, the ceiling is over 12 feet in height and there are doorways to the outside, and operating areas. This area also includes many heavy duty work tables that are used to setup the exposure trays for N-Ray radiography work. No records indicating radiological use or storage were identified. Figure 5-19 is a photograph of the Tagging Area with the entry vestibule shown at the back.

5.3.3.2 Tagging Area Back Room The Tagging Area Back Room is a portion of the tagging operation that was walled off and contains several pieces of equipment used in the tagging operations. No records indicating radiological use or storage were identified. Figure 5-20 is a photograph of the Tagging Area Back Room.

5.3.3.3 East Entrance Hallway The East Entrance Hallway is a 4.5 by 8 by 8-foot room that connects to the outside, the Reactor Building, and the Tagging Area, as shown in Figure 4-4. It has a concrete floor with drywall on walls and ceiling. No records indicating radiological or chemical use or storage were identified.

5.3.4 Demineralizer Building The Demineralizer Building is a 7.5-foot by 3.6-foot by 7-foot tall, small metal structure on the east side of the Reactor Building as shown in general layout Figure 4-4. It contains the demineralizer system which includes a pump, demineralizer bed, filters, gauges, valves and typically a used resin bed left in the building for decay prior to removal of the resin for disposal.

5.3.5 Heat Exchanger Building The Heat Exchanger Building is a 12-foot by 4-foot by 7-foot-tall metal structure built with a shallow concrete basin for the floor. It is located at the east side of the Reactor Building as shown in Figure 4-4. It contains a stainless-steel shell and tube heat exchanger, a primary side stainless pump with 5-HP motor, a flow switch and various valves. This building also contains a water monitor (radiation detector) and a check source.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 35 of 83 5.3.6 Cooling Tower There is one cooling tower located close to the Heat Exchanger Building. The tower is approximately 6-foot by 5.5-foot by 8-foot tall with a painted steel shell, blower on top and galvanized steel packing on the interior as shown on Figure 5-18.

Located in the area near the Heat Exchanger building is the heat exchanger secondary side (iron and bronze) pump with 5-HP motor, piping and valves. No records indicating radiological use or storage were identified.

5.3.7 Compressor Building The Compressor Building is a 14-foot by 8-foot-tall metal structure on the south side of the Operations Building. It contains two conventional piston type air compressors and three oil-filled vacuum pumps. No records indicating radiological use or storage were identified.

5.3.8 Class 1.1 Explosive Storage Container Class 1.1 Explosive Storage Container is a 6-foot by 4-foot by 4-foot tall metal box on skids located on the northeast corner of the Storage Building. It has not been used. No records indicating radiological or chemical use or storage were identified.

5.3.9 Storage Building The Storage Building also known as the forklift garage is an un-insulated 24 foot by 26 foot steel structure built of fire resistant framing and metal walls and ceiling. The Storage Building is not connected to any other buildings and it has a garage door that opens to the east and a personnel door that opens to the south. It is used for forklift parking, equipment and supply storage, and fabrication area. The interior of this building is shown in Figure 5-23.

5.3.10 Waste Storage Sump The former steel Waste Storage Tanks have been removed and disposed of and new polypropylene tanks have been installed in a secondary containment. The below grade sump is located on the south end of the Reactor Building as shown on Figure 4-4.

5.3.11 Land Area All of the 0.9 acres that make up the site are fenced in with a chain link fence. The fence has a truck gate that allows access to the Shipping and Receiving area and a personnel gate that enters the Reactor Building near the Control Room. Most of the outside area is paved as can be seen in Figure 4-2, Aerial View of ARRR Site. There are seepages of groundwater upward through cracks in the pavement on the north end of the site that are collected and drained by a ditch just outside the north site fence.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 36 of 83 5.4 RELATION OF THE ARRR TO OTHER TRIGA REACTORS The design of the ARRR fuel is similar to those of approximately 50 TRIGA type reactors currently operating worldwide with 24 in the United States.

The reactor and associated equipment will be decommissioned by removing the core, removing the water from the vessel, and removing activated and contaminated materials from the reactor.

Once this has been completed, the structure will be surveyed using a license termination survey with any additional decontamination performed in conjunction with the surveys.

5.5 OUTSIDE AREAS There is no history of any spills of radioactive materials outside the identified building process areas. Based on current survey data, it is not anticipated that any soil remediation will be required. There is a discharge from the Reactor Building to the sanitary sewer system which runs near the building.

The ARRR is between two watersheds: Alameda Creek and Walnut Creek. The surrounding area slopes gently downward to the north and to the south. The site storm water runoff is to the north and west toward Walnut Creek. San Ramon Creek is the principal local drainage, with Bollinger Creek and San Catanio Creek being tributary. San Ramon Creek meanders northward through Danville and Alamo, and ultimately joins Walnut Creek, which discharges into Suisun Bay near Martinez. There is a drainage ditch located just past the site boundary to the north of the facility.

The sanitary sewer and nearby storm sewers will be surveyed at accessible locations downstream of the site. In addition, soil sampling and license termination surveys of paved areas and unpaved areas will be performed in areas adjacent to the ARRR in accordance with current regulatory requirements.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 37 of 83 Figure 5-1: Reactor & N-Ray Area with Shielding in Place

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 38 of 83 Figure 5-2: ARRR Core and Support Structure

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 39 of 83 Figure 5-3: ARRR Reactor Tank Cutaway and N-Ray Facility

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 40 of 83 Figure 5-4: ARRR In-Core Irradiation Capsule LEAD BALLAST SEAL IRRADIATION VOLUME

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 41 of 83 Figure 5-5: ARRR Machine Shop

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 42 of 83 Figure 5-6: ARRR Chemistry Lab

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 43 of 83 Figure 5-7: ARRR Preparation Lab I

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 44 of 83 Figure 5-8: ARRR Mezzanine Sheet Metal Fabrication Area

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 45 of 83 Figure 5-9: ARRR Mezzanine Sheet Metal Fabrication Area & HVAC Unit

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 46 of 83 Figure 5-10: ARRR Mezzanine Storage Area

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 47 of 83 Figure 5-11: ARRR Mezzanine Instrument Calibration Area

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 48 of 83 Figure 5-12: ARRR Electronics Lab

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 49 of 83 Figure 5-13: ARRR Shipping & Receiving

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 50 of 83 Figure 5-14: ARRR N-Ray Setup Area

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 51 of 83 Figure 5-15: Office Space

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 52 of 83 Figure 5-16: Customer Viewing Area

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 53 of 83 Figure 5-17: Quality Control Room

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 54 of 83 Figure 5-18: Computer and Counting Room

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 55 of 83 Figure 5-19: Tagging Area

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 56 of 83 Figure 5-20: Tagging Area Back Room

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 57 of 83 Figure 5-21: Cooling Tower

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 58 of 83 Figure 5-22: Storage Building

Decommissioning Cost Estimate for Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 59 of 83 Figure 5-23: Waste Storage Tanks

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 6.0 ESTIMATION METHODS The estimated cost to decommission the ARRR is $1,970,250 in 2025 dollars. This section of the cost estimate repo1t provides an overview of the considerations and factors that influenced the DCE. Appendix tables provide basic info1mation that culminated in the results displayed in Table 6-1.

Table 6-1 provides a suilllllaty of the costs associated with each area of the facility.

Table 6-1: Decommissioning Cost Summary -ARRR Operation Labor Hrs Labor Conti-acts,

\\Vaste Total Reactor 4,286 Shielding/ Component included Buildings 0

Outdoor 0

Areas D&D Plan 40 Char surveys 40 Final Surveys 714 Training 100

/Oversight Sub Totals 5,180 Contingency Total Ti-anl/lhing equip/supplies Ship/dispose

$600,000

$120,500

$562,000 Included

$ 40,000

$125,000

$0

$0

$0

$0

$0

$0

$ 5,600

$0

$0

$ 5,600

$500

$0 100,000

$2,000

$0

$15,000

$0

$0

$726,200

$163,000

$687,000

$1,282,500

$ 165,000

$0

$0

$ 5,600

$ 6,100

$102,000

$ 15,000

$1,576,200

$ 394,050

$1, 970, 250 Page 60 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 61 of 83 6.1 COST MODIFYING FACTORS There are modifying factors that significantly affect the overall cost for remediation. One of these factors is an adjustment for productivity related to personnel protection requirements and working temperatures. The degree of protection required depends upon the extent of contamination and specific activities to be performed in a given area. As the level of personnel protection increases, so does the impact on individual productivity and task duration.

Adjustments were made to account for the implementation of personnel protective measures where applicable. This estimate used the standardized levels of personnel protection described in Table 6-2. The Productivity Factors related to these levels of personnel protection are provided in Table 6-3 for Light Work and in Table 6-4 for Heavy Work.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Table 6-2: Personnel Protective Equipment Protection Summary Protection Level Personnel Protective Equipment Requirement Level A:

The highest available level of respirat01y, skin, and eye protection The highest level of respirato1y protection, but less skin Level B:

protection than Level A. Level B is the minimum level reco1mnended for initial site entries, or for other entiy conditions dealing with unknown hazards.

Level C:

The same level of skin protection as Level B, but a lower level of respirat01y protection.

Level D Modified:

Skin protection siinilar to or the same as Level C, without respiratory protection.

Level D:

Standard work unifo1m suitable for construction work: no respiratory protection and minimal skin protection.

Page 62 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-25 Table 6-3: Hazardous and Toxic Waste Productivity Factors: Light Work Variables U/M Level A Level B Level C Level D Modified Level D T<70 70<T T>85 T<70 70<T T>85 T<70 70<T T>85 T<70 70<T T>85 T<70 70<T T>85 A. Standard losses Min.

160 160 160 140 140 140 128 128 128 76 76 76 32 32 32 B. Scheduled/heat stress breaks Min.

60 90 120 43 65 86 35 63 101 30 47 63 30 33 44 C. Dexterity losses Min.

78 69 60 74 69 64 55 51 44 4

4 3

5 5

5 D. Total time lost per 8-hr. WD Min.

298 319 340 257 274 290 218 242 273 110 127 142 67 70 81 E. Productivity time per 8-lu. WD Min.

182 161 140 223 206 191 262 238 207 370 353 338 413 410 399 F. Productivity time on clean site Min.

430 430 430 430 430 430 430 430 430 430 430 430 430 430 430 G. HTW Produc.tivity Factor 0.42 0.37 0.33 0.52 0.48 0.44 0.61 0.55 0.48 0.86 0.82 0.79 0.96 0.95 0.93 Notes:

Standard delays account for all time losses independent of temperature variations. They include safety meetings, instmctions, putting on and taking off of PPE, decontamination, switching air supply/filters, monitoring delays, and cleanup.

Scheduled/heat stress breaks account for all paid rest periods pe1* workday.

Dexterity losses are based on subjective opinions of the percentage that PPE slows down a 1101mal worker because of factors such as discomfort, clumsiness, weight, and restricted breathing and conumu1ication. The numbe1* of minutes actually worked is reduced by the percentage representing the average response for that particular PPE level.

Values for A, B, and C were derived by averaging the survey responses for each PPE level. Responses that varied greatly from the average were subject to omission at the author's discretion.

Total paid time = 480 minutes.

50-minute delay on clean site = IO-minute safety meeting and instmctions + IO-minute cleanup+ 30-minute breaks.

Calculations:

D= A+B+C U/M = unit of measure E = 480 - D WD = workday F = 480 - 50 Min. = minutes G = E/F T = temperature (Fahrenheit)

Level A-protection is used in extreme emeni:encv situations onlv. Productivity factors for Level A should be used with caution because thev were extrapolated from 2 data points.

Page 63 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-25 Table 6-4: Hazardous and Toxic Waste Productivity Factors: Heavy Work Va1iables U/M Level A Level B Level C Level D Modified LevelD T<70 70<T T>85 T<70 70<T T>85 T<70 70<T T>85 T<70 70<T T>85 T<70 70<T T>85 A. Standard losses Min.

220 220 220 204 204 204 135 135 135 76 76 76 28 28 28 B. Scheduled/heat stress breaks Min.

60 105 150 50 75 123 64 131 178 30 90 165 30 45 60 C. Dexterity losses Min.

80 62 44 52 46 35 44 34 26 28 24 18 11 10 10 D. Total time lost per 8-hr. WD Min.

360 387 414 306 325 362 243 300 339 134 190 259 69 83 98 E. Productivity time per 8-hr. WD Min.

120 93 66 174 155 118 237 180 141 346 290 221 411 397 382 F. Productivity time on clean site Min.

430 430 430 430 430 430 430 430 430 430 430 430 430 430 430 G. HTW Productivity Factor 0.28 0.22 0.15 0.40 0.36 0.27 0.55 0.42 0.33 0.80 0.68 0.51 0.96 0.92 0.89 Notes:

Standard delays account for all time losses independent of temperature variations. They include safety meetings, instmctions, putting on and taking off of PPE, decontamination, switching air supply/filters, monitoring delays, and cleanup.

Scheduled/heat stress breaks account for all paid rest periods per workday.

Dexterity losses are based on subjective opinions of the percentage that PPE slows down a normal worker because of factors such as discomfort, clumsiness, weight, and restricted breathing and communication. The nmnber of minutes actually worked is reduced by the percentage representing the avernge response for that particular PPE level.

Values for A, B, and C were derived by averaging the smvey responses for each PPE level. Responses that varied greatly from the average were subject to omission at the author's discretion.

Total paid time = 480 minutes.

50-minute delay on clean site = 1 -minute safety meeting and in.stmctions + 10-m.inute cleanup+ 30-minute breaks.

Calculations:

D= A+ B +C U/M = unit of measm*e E = 480 - D WD = workday F = 480 - 50 Min. = minutes G = E/F T = temperatm*e (Faliren.heit)

Level A-protection is used in extreme emergency situations only. Productivity factors for Level A should be used with caution because they were extrapolated from 2 data points.

Page 64 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor 6.2 RADIOACTIVE WASTE VOLUME E STIMATES Revision 2-10-2025 The volume of radioactive waste requiring treatment and/or disposal can be a ve1y significant factor due to the high costs of radioactive waste disposal. For the ARRR decommissioning, the cost for radioactive waste processing, shipping, and disposal is anticipated to be about 31 % of the total decommissioning cost. This is a typical fraction for relatively clean radioactive facilities. Radioactive waste volume estimates that result from decommissioning are discussed in the following section. m 2017 a significant amount legacy waste (total volume of 1,920 cubic feet) was shipped offsite for disposal, which reduced the waste volume, transpo1tation and disposal costs compared to previous estimates. Table 6-5 provides a volume summa1y for each area of the ARRR.

Table 6-5: ARRR Unprocessed Radioactive Waste Summary*

Gene1*ated Dec.on Direct Clive Clive Clive Total Disposal Disposal Disposal Disposal Volume Volume Volume Volume Area Description (ft"3)

(ft"3)

(ft"3)

(ft"3)

TRIGA Reactor 64 0

349 413 TRIGA Bioshield & N-Ray Components 0

0 285 285 Buildin~s 0

0 0

0 Outdoor Areas 0

0 0

0 Pool Water 0

0 0

0 Lead 2

0 6

8 TOTALS 66 0

640 706 6.3 RADIOACTIVE WASTE DISPOSAL C OSTS A significant po1tion of the overall decommissioning cost is generally attributed to the transpo1t, treatment and disposal of radioactive waste. This cost estimate includes radioactive waste processing that is followed by disposal and direct radioactive waste disposal at Clive, Utah. The following sections describe the pricing for each option.

6.3.1 Clive, Utah Radioactive Waste Direct Disposal Costs The costs to transport low level radioactive waste to the Clive, Utah disposal site is based on a transpo1t distance of 609 miles, at a rate of $6.00 per mile. The cost to dispose of the waste at the Utah site is based on a disposal fee of $145 per cubic foot for low level waste debris and

$253 per cubic foot for transp01tation and disposal of demineralizer resin from the pool water clean-up and lead that must be encapsulated prior to burial.

6.3.2 Radioactive Waste Processing and Burial Costs The costs to transport waste to a volume reduction/waste processing facility in Oak Ridge or Erwin, Tennessee are based on transpo1t distances of 2437 and 2561 miles respectively, at a rate Page 65 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 of $3.77 per mile. However, waste processing and volume reduction were not included in this estimate because there was not a significant cost advantage.

6.4 REMEDIATION METHODS The goal in choosing remediation methods if necessaiy is to select the minimum cost option to accomplish a task. There are many factors which need to be considered when selecting a method such as contamination levels, degree of penetration of contamination into substrate material, equipment cost, support equipment costs, material and chemical costs, the generation of secondaiy waste volumes (waste in addition to the removed contaminated material), processing rates, labor requirements, and applicability to various tasks. Typical decontamination processes are smnmai*ized in Table 6-6. For each decontamination method, this table shows application infonnation, the process cost per square foot of ai*ea decontaminated, and the amount of secondaiy waste generated. These unit factors may be applied to specific areas or equipment requiring remediation to detennine the most cost-effective process.

Table 6-6: Decontamination Methodology Comparison Penetration Proc.ess Sec.ondary depth Crew Cost Waste Volume Methodology Application (in)

Size

($/ft2)

(ft3 /1,000 ft2)

McDonald U-5 Scabbier Floor concrete 1/4 2.0

$1.42 0

McDonald U-5 Scabbier Floor concrete 1/2 2.0

$2.51 0

McDonald 3WCD Scabbier Wall concrete 1/8 2.0

$5.69 0

Blastrac 1 OD Shot Blaster Floor concrete 1/16 1.1

$0.49 0.53 Blastrac 1 OD Shot Blaster Floor concrete 1/8 1.1

$0.63 0.53 L TC 10-60Pn Special All surfaces 1/32 1.3

$2.55 0.53 Vacuum Blaster L TC 10-60Pn Special All surfaces 1/16 1.3

$4.22 0.53 Vacuum Blaster CO2 Blasting All Surfaces 0

2.0

$5.21 0

Hydrolaser (5-10,000 psi)

All Surfaces 0

2.0

$1.08 9.07 Hands-on-Decou Non-Porous 0

1.0

$2.47 8.33 surfaces 6.5 RADIOACTIVE WASTE VOLUME REDUCTION COSTS The volume reduction and waste treatment processes analyzed for use are smnmarized in Table 6-7. For each volume reduction method, the table shows application info1mation, transportation container type, and the total process cost per unit weight. These unit factors may be applied to specific items of equipment requiring disposal to dete1mine the most cost-effective process. The radioactive waste generated at the ARRR facility will include itTadiated hardware, activated concrete, HEP A ventilation systems, fume hoods, steel, lead, and seconda1y waste generated Page 66 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 during the decontamination work, such as protective clothing and materials used during manual decontamination work Table 6-7: Volume Reduction/Treatment Methods Cost Information Transport Total Cost VR Methodology Applicability Container Type

($/lb)

Super Compaction D1y active waste B-25 for Clive Utah

$7.12 20 lb/ft.3 Disposal Lead Decontamination Bricks and Sheet Custom Box

$5.56 Survey & Release Low Density Waste 55 Gal Thum

$2.74 Low Density Drnms Survey & Release Waste at greater than B-25 Box

$1.46 Medium Density Boxes 20 7< 60 lb/ft' Survey & Release Waste at greater than B-25 Box

$1.06 High Density Boxes 60 lb/ft.3 6.6 UNIT C OSTS A number of unit cost factors were used to generate the total decommissioning cost estimate.

The main unit cost factors are listed in Table 6-8, so that individual decommissioning costs can be updated when required and the effects of revised unit costs can be evaluated.

Table 6-8: Decommissioning Cost Estimate Selected Unit Cost Factors Unit Cost Factor Unit Cost Rate Units Low Level Radioactive Waste Disposal at Clive, Utah

$145.00 cubic foot Resin and Lead Disoosal at Clive Utah

$280.00 cubic foot Waste Transpo1iation to Clive, Utah

$6.00 mile Transpo1iation Distance to Clive, Utah 609 miles B-25 Waste Disposal Container Cost

$2,530.00 each Management and Supervision

$159.60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> Engineer

$125.40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Radiation Protection Supervisor

$129.00 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> Laborer Foreman

$85.00 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> Administrative Assistant

$41.12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Instiument Technician

$81.51 hour5.902778e-4 days <br />0.0142 hours <br />8.43254e-5 weeks <br />1.94055e-5 months <br /> Radiation Protection Technician

$81.51 hour5.902778e-4 days <br />0.0142 hours <br />8.43254e-5 weeks <br />1.94055e-5 months <br /> Laborer

$78.69 hour7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br /> Fee 15%

Page 67 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 68 of 83 6.7 FINAL SURVEYS Final survey costs are estimated based on the facility radiation survey information presented in NUREG-1757, NMSS Decommissioning Standard Review Plan (Ref. 8.9). The number of sample points for the various areas being surveyed and the type of survey being performed were determined. The time to perform each of these surveys is estimated, and the product of these two items is the labor time to perform the surveys. Equipment and material cost to perform the surveys is added along with staff support costs to determine a total cost. The survey requirements are based on NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) Ref. 8.8). A spreadsheet was developed which incorporates facility dimensions, labor rates and support cost ratios to estimate the final survey cost. The facility buildings survey labor estimate is summarized in Appendix A-6 and the open land and miscellaneous areas survey labor estimate is summarized in Appendix A-7.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 7.0 FACILITY, CONDITIONS AND DECOMMISSIONING SCENARIO Decommissioning of the ARRR requires that residual radioactive materials be removed from the site to allow removal of the decommissioned facilities from the NRC license and State of California License. For the pmposes of this cost estimate, the end of the decommissioning project occms when the ARRR has been remediated to release limits and the Final Status Smvey has been completed, documented and the smvey results submitted to the NRC and the State of California.

7.1 REMEDIATION

SUMMARY

Remediation will be required for only necessa1y ARRR buildings and systems, but it is not anticipated that remediation of sewers and outdoor areas will be required. Table 7-1 below is a brief summruy of the anticipated remediation activities, with applicable assumptions and bases.

Additional facility infonnation, radiological info1mation, and decommissioning plans are presented in greater detail in the document sections that follow.

Table 7-1: ARRR Planned Remediation Activities Building or Area Remediation Activities General Area Perfo1m a general facility clean up to remove incidental equipment and materials, which includes both radioactive and non-radioactive waste on site prior to decommissioning. This activity is perfo1med as pa1t of preparntion activities and is ongoing and will be completed before deco1mnissioning.

Non-Reactor Remove if necessa1y, equipment and materials not associated with Remediation operation of the reactor. This includes equipment used in the prepru*ation for N-Ray activities and the N-Ray components outside the reactor tank.

This activity is perfo1med as prut of prepru*ation activities and is ongoing and will be completed before decommissioning.

TRIGA Reactor Empty water from the reactor tank. Remove the activated reactor core, vessel internals, bridge, and reactor vessel. Remove Beam catcher, bioshield wood and bioshield blocks. Remove N-Ray components including neutron guide, exposme tray and shields. Leave beam poli in place, as it is unused and not activated. Cut out activated concrete surrounding the reactor tank and dispose of as radioactive waste.

Demin. & Heat Remove, if necessa1y, the Demineralizer and Heat Exchange Systems, Exchange Systems decontruninate if necessary, the concrete pads in each building.

Reactor High Bay Remove contaminated po1tions of the HV AC system, if any. No Building contamination has been found to date.

Other Buildings Remove only activated or contruninated equipment. No contamination has been found to date.

Outdoor Areas Remove only activated or contruninated equipment. No contamination has been found to date.

Page 69 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 70 of 83 7.1.1 General Area Cleanup A general facility cleanup is ongoing and to remove, if necessary, incidental equipment and non-radioactive materials. The goal is to dispose of items and materials not required for reactor operation and maintenance using existing staff and current procedures.

7.1.2 Non-Reactor Remediation Remove, if necessary, equipment not associated with operation and maintenance of the reactor.

This includes equipment used in the preparation of items for N-Ray, N-Ray components outside the reactor tank, equipment in the Tagging Area, Chemical Lab, Machine Shop, Quality Control Room, Dark Room, Etc. These activities are performed as part of preparation work that can be completed prior to reactor decommissioning to save money and speed up the decommissioning if desired. These remediation activities are discussed further by specific areas in the sections below.

7.1.3 TRIGA Reactor Remove beam catcher and wood shield over reactor tank, characterize them and ship them for disposal.

Remove concrete blocks around reactor tank area, decontaminate them and survey them for disposal as clean waste.

Remove the reactor core, core stand, thermal column, fuel racks, vertical beam tube, and other items inside the reactor pool and ship them for disposal.

Remove reactor tools, characterize them and ship them for disposal.

The reactor bridge and items attached to the bridge will be removed and shipped for disposal.

The reactor pool will be emptied and the water processed for disposal as non-radioactive waste.

The reactor pool tank will be decontaminated and the tank left in place. The tank and concrete will not be contaminated. Any Co-60 in the tank walls have decayed to insignificant levels and the activity in the concrete behind the aluminum tank will also have decayed.

The unused beam port is not activated and will be left in place.

The reactor pool trenches will be decontaminated and the concrete left in place.

7.1.4 Demineralizer and Heat Exchange Buildings The Demineralizer and Heat Exchange Systems if contaminated will be removed, characterized and shipped for disposal.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 71 of 83 The lead shielding in the Demineralizer Building will be sent offsite for processing and disposal. The spare demineralizer in the building will be characterized and shipped offsite as radioactive waste. The concrete pads in the Demineralizer and Heat Exchanger if contaminated will be decontaminated by concrete surface cleaning.

7.1.5 Reactor High Bay Area If necessary, equipment in the Reactor High Bay Building that is not part of the structure or utilities will be removed for disposal. It is anticipated that this activity will include the following items:

Radwaste Room: The room waste will be characterized and sent offsite for disposal as radioactive waste. The lead will be sent offsite for processing and disposal. The floor and walls will be decontaminated by hand wipe downs.

Machine Shop: if necessary, the remaining small tools, supplies cabinets and tables will be surveyed and removed from site. The large equipment including Drill Press, Milling Machine and Lathe will also be surveyed and remain or removed from site.

Office Areas, Locker Room and Supply Room: Any remaining furniture, supplies cabinets and tables will be surveyed and remain or removed from site.

Restrooms: In general, these rooms do not require any remediation. Any items and materials in the supply closet in the mens restroom will be surveyed and remain or removed from site.

Control Room and Lunchroom: The control room cabinets will be surveyed and remain or removed from site. Any remaining furniture, monitors, supplies, sink, cabinets and tables will be surveyed and remain or removed from site.

Main High Bay Area: The HVAC ductwork and heating and cooling units will be surveyed and any contaminated items removed for disposal as radioactive waste. The roof insulation material will be surveyed and removed for disposal if any contamination is found. In addition, the overhead lights will be surveyed and removed for disposal if any contamination is found.

7.1.6 High Bay Mezzanine Area Reactor hallway, Preparation Lab, Hallway and Chemical Lab: In the Chemical lab the hood and support bench along with the lab benches and sinks will be surveyed and retained or removed from site. In the Preparation Lab, the marble weighing benches will be surveyed and retained or removed from site. Any remaining equipment, furniture, supplies, and cabinets in any of these rooms will be surveyed and remain or removed from site.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 72 of 83 Sheet Metal Fabrication Area, Storage Area, Calibration Area and Electronics Lab; Any remaining equipment, furniture, supplies and cabinets in any of these areas will be surveyed and remain or removed from site.

7.1.7 Other Buildings Tagging Building: Any remaining equipment, furniture, supplies and cabinets in the room will be surveyed and retained or removed from site.

Storage Building: The Storage Building is sometimes referred to as the Forklift Garage.

The materials and supplies in this building have not been in a radioactive material area and will be retained or removed from site..

Compressor Building: The compressors and vacuum pumps have never been in a radioactive materials area. The compressors will be surveyed and retained or removed from site. The vacuum pump oil will be sampled to ensure that the vacuum pumps are not contaminated internally and they will be surveyed and retained or removed from site.

7.1.8 Outdoor Areas Cooling Tower: The cooling tower with associated pumps and controls has never been used with contaminated water and is maintained outside of radioactive materials areas.

The cooling tower and the rest of the system will be retained or removed from site.

Waste Sump: The Waste Sump pump, valves, and controls will be characterized and retained or shipped from site.

Shield Blocks: There are quarter circle shield blocks in the vicinity of the waste tanks and the demineralizer system that were used to shield the fence line from high dose rates.

These blocks were never in a contaminated area and will remain or shipped offsite.

The sanitary and storm sewers will be surveyed at accessible areas and released for continued use.

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 73 of 83 Figure 7 1: ARRR Activated Concrete Activated concrete near core removed Activated concrete below core removed --------- _

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 74 of 83 7.2 LICENSE TERMINATION SURVEYS License termination surveys, or final status radiation surveys, will be performed in the applicable areas of the site using the guidance provided in NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), (Ref. 8.8). The surveys will be performed in accordance with plans and procedures specifically developed for the ARRR facility. Appropriate survey instruments with check and calibration sources will ensure sensitivity is sufficient to detect the identified nuclides at the minimum detection.

8.0 REFERENCES

8.1 10 CFR 50.82, TERMINATION OF LICENSE, PART (B) FOR NON-POWER REACTOR LICENSEES, USNRC, NOVEMBER 2014 8.2 10 CFR 20 SUBPART E, RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION, USNRC, AUGUST 2007 8.3 NUREG 1537, GUIDELINES FOR PREPARING AND REVIEWING APPLICATIONS FOR THE LICENSING OF NON-POWER REACTORS, USNRC, FEBRUARY 1996 8.4 MEANS BUILDING CONSTRUCTION COST DATA, 2011, 69TH ANNUAL EDITION, R.A.

MEANS COMPANY, INC., SEPTEMBER 2010 8.5 NUREG/CR-1756, TECHNOLOGY SAFETY AND COSTS OF DECOMMISSIONING REFERENCE NUCLEAR RESEARCH AND TEST REACTORS, USNRC, JULY, 1983 8.6 CS-HP-PR-008, CHARACTERIZATION REPORT FOR THE AEROTEST RADIOGRAPHY &

RESEARCH REACTOR,

, CALIFORNIA, ENERGYSOLUTIONS, OCTOBER 2011 8.7 10 CFR 20.1402, RADIOLOGICAL CRITERIA FOR UNRESTRICTED USE, USNRC 8.8 MULTI-AGENCY RADIATION SURVEY AND SITE INVESTIGATION MANUAL (MARSSIM),

REVISION 1, NUREG-1575, EPA 402-R-97-016, DOE/EH-0624, USEPA, U.S. NRC, U.S.

DOE, AND U.S. DOD, AUGUST 2000 8.9 NUREG-1757, CONSOLIDATED NMSS DECOMMISSIONING GUIDANCE, DECOMMISSIONING PROCESS FOR MATERIALS LICENSES, USNRC, SEPTEMBER 2006 8.10 NUREG/CR-5512, "RESIDUAL RADIOACTIVE CONTAMINATION FROM DECOMMISSIONING:

PARAMETER ANALYSIS, VOLUME 3, USNRC, OCTOBER 1999 8.11 STATE OF CALIFORNIA EXECUTIVE ORDER D-62-02, 9/13/2002

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 75 of 83 Appendix A-1 Contaminated Waste Volume Summary Table A-1 Contaminated Waste Volume Summary

ARRR,

, CA Generated Decon Direct Burial Total Area Waste1 Waste2 Waste All Waste Description ft3 ft3 ft3 ft3 TRIGA Reactor 64 0

349 413 TRIGA Bioshield & N-Ray Components 0

0 285 285 Buildings 0

0 0

0 Outdoor Areas 0

0 0

0 Pool Water 0

0 0

0 Lead 2

0 6

8 TOTALS:

66 0

640 706 1-Generated waste includes protective clothing and equipment generated by site operations 2-Decon waste is volume generated by decontamination processes (includes items such as sand blasting grit, etc.)

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Appendix A-2 Contaminated Waste Disposal Cost TableA-2 Waste Disposal Cost ARR CA Revision 2-10-2025 Area Description Generated Decon Direct Total Waste Waste Waste Burial

\\Vaste Reactor

$8, 000

$0

$442, 000

$450, 000 Bioshield/components

$0

$0

$120, 000

$120, 000 Buildings

$0

$0

$0

$0 Outdoors

$0

$0

$0

$0 Totals

$8, 000

$0

$562, 000

$570, 000 Appendix A-3 Waste Shipping Container Cost Table A-3 Waste Shipping Container (B-25) Costs ARRR

-CA Total B-25 Waste Waste Waste Container Area Description Volume Containers Costs (ft3)

(Each)*

($)

TRIGA Reactor 403 5

12,650 TRIGA Bioshield & N-Ray Components 285 4

10,120 Bldg. lead

<50 1

2,530 Outdoor Areas 0

Totals 738 10 25,300

  • Number of containers rounded to next whole number Page 76 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 77 of 83 Appendix A-4 Waste Disposal Support Labor Estimate Table A-4 Waste Disposal Support Labor and B-25 Containers Costs

ARRR,

, CA B-25 Waste Waste Waste Shipment Area Description Containers (ea)

Shipments Labor (Man-hours)

TRIGA Reactor 5

1 14 TRIGA Bioshield & N-Ray Components 4

1 82 Buildings 0

0 0

Outdoor Areas 0

0 0

Pool Water 0

N/A 0

Lead 1

1 10 Totals:

10 3

106 Notes:

Number of waste shipments rounded up to next whole number Does not include cask shipments (see below)

Waste Disposal Support Labor, Cask Rental & Transportation Costs

ARRR,

, CA Liners/Cask Cask Rental &

Cask Support Area Description Rental (ea)

Transport Costs Labor (Man-hours)

TRIGA Reactor 0

0 TRIGA Bioshield & N-Ray Components 1

$ 38,560 72 Buildings 0

0 Outdoor Areas 0

0 Totals:

1

$ 38,560 72 Notes:

Transportation costs include truck rental and driver costs

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Appendix A-5 Radioactive Waste Container, Cask and Labor Summary Table A-5 Radioactive Waste Container, Cask and Labor Summary ARRR, -

CA Area Description Total B-25 Cost Cask

\\Vaste

\\Yaste

\\Yaste Containers

/Container Shipments Shipment Vol (ft3) labor Labor cost man-hrs Reactor 413 5

$12,000 13

$1,200 Bioshield/ components 285 3

$45,000 82

$7,000 Buildings 0

0 0

0 0

Outdoors Areas 0

0 0

0 0

Pool Water 0

0 0

0 0

Lead 8

1

$ 200 0

0 Totals 706 9

$57,200 95

$8, 200 Page 78 of 83

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 79 of 83 Appendix A-6 Building Survey Labor Summary IMPACTED BUILDING AREA SURVEY Table A-6

ARRR, California SURVEY UPPER GAMMA PACKAGE AREA AREA AREA FLOOR + U. WALL +

FLOOR +

WALL +

SURVEY SURVEY DIRECT BUILDING ROOM AREA REQRD WIDTH LENGTH HEIGHT L. WALL CEILING Survey L. WALL CEILING ROOF or PKG SURVEY LOC NAME NUMBER DESCRIPTION

?

SURVEY SURVEY Sketchs SURVEY SURVEY SURVEY SMEAR PREP LABOR CODE (Y/N)

(ft)

(ft)

(ft)

CODE CODE (each)

POINTS POINTS POINTS POINTS (hrs)

(hrs)

Exterior Exterior 3

N-Ray 9

Computer & Counting Room Y

7.33 10.8 13.7 1

4 1

45 30 49 4

14 3

Reactor 10 Lunch Room N

12.75 20.3 9.5 1

4 1

99 30 84 14 3

Reactor 11 High Bay N-Ray Exp Area Y

20.92 25.5 22.5 1

4 2

162 30 126 4

24 3

Reactor 12 Reactor Enclosure N

25.50 25.8 22.5 1

4 1

189 33 145 22 3

Reactor 13 Control Room Y

12.75 26.0 9.5 1

4 1

119 30 98 4

20 3

Reactor 14 Men's Room N

6.92 8.3 9.5 1

4 1

37 30 44 9

3 Reactor 15 Ladies Room N

5.75 8.33 9.5 1

4 1

33 30 41 9

3 Reactor Entry Hallway N

4.17 13.7 9.5 1

4 1

41 30 47 10 3

Reactor 16 Employee's Lockers N

8.67 9.5 9.5 1

4 1

46 30 49 10 3

Reactor 17 Sandy's Office Y

10.33 13.2 9.5 1

4 1

63 30 61 4

15 3

Reactor 18 Business Office N

10.33 23.4 9.5 1

4 1

97 30 83 14 3

Reactor 19 Accounting Office N

9.83 11.3 9.5 1

4 1

55 30 56 11 3

Reactor 20 Machine Shop Y

11.67 12.7 9.5 1

4 1

66 30 63 4

16 3

Reactor 21 Office Supply Room N

11.42 13.8 8.0 1

4 1

70 30 65 12 3

Tagging Bldg 22 Tagging Area Y

18.67 35.3 12.3 1

5 3

194 30 146 4

30 3

Reactor 23 South End Radiography N

10.33 17.4 7.0 1

4 1

77 30 70 13 3

Maintenance 25 Maintenance Building N

9.33 12.4 7.0 1

4 1

57 30 57 11 3

Tagging Bldg 29 Safe N

2.83 6.5 4.0 1

4 1

30 30 39 9

3 Reactor Stairs to Mezzanine N

4.00 12.0 22.5 1

4 1

37 30 44 9

3 Reactor Mezzanine Hallway N

4.00 21.1 16.0 1

4 1

59 30 58 11 3

Reactor 31 N-Ray Gauge Office Y

8.67 9.0 8.0 1

4 1

44 30 48 4

14 3

Reactor 32 Preparation Lab N

8.50 10.1 8.0 1

4 1

47 30 50 10 3

Reactor 33 Chemical Lab N

10.50 11.2 8.0 1

4 1

57 30 57 11 3

Reactor 34 Sheet Metal Fabrication Area N

18.00 24.4 12.0 1

4 1

142 30 112 18 3

Reactor 35 Instrument Calibration Area N

15.25 20.5 12.0 1

4 1

111 30 92 15 3

Reactor 36 Storage N

13.33 61.6 12.0 1

4 1

256 30 187 27 3

Reactor 37 Electronics Lab N

8.83 20.5 8.0 1

4 1

80 30 72 13 3

Reactor 45 LLRW Storage room Y

8.17 8.6 12.0 1

4 2

41 30 47 4

14 TOTALS 2,356 843 2,090 32 404 NON-IMPACTED BUILDING AREA SURVEY Table A-6

ARRR, California SURVEY PACKAGE AREA AREA AREA FLOOR + U. WALL + ENTER FLOOR +

U. WALL +

SURVEY DIRECT BUILDING ROOM AREA REQRD WIDTH LENGTH HEIGHT L. WALL CEILING Survey L. WALL CEILING ROOF TOTAL PACKAGE SURVEY LOC NAME NUMBER DESCRIPTION

?

SURVEY SURVEY Sketchs SURVEY SURVEY SURVEY SMEAR PREP LABOR CODE (Y/N)

(ft)

(ft)

(ft)

CODE CODE (each)

POINTS POINTS POINTS POINTS (hrs)

(hrs) 3 N-Ray Setup Building Exterior Exterior Y

45.0 60.7 13.7 2

5 2

10 10 30 50 4

13.4 3

Tagging Area Building Exterior Exterior Y

18.7 39.8 12.7 2

5 2

10 10 30 50 4

13.4 3

Storage Building Exterior Exterior Y

24.0 24.3 11.0 1

4 2

10 10 30 50 4

10.6 3

Maintenance Office Exterior Exterior Y

9.3 12.4 7.0 1

4 2

10 10 30 50 4

10.6 3

Compressor Building Exterior Exterior Y

7.7 14.2 8.0 1

4 2

10 10 30 50 4

10.6 3

High Bay Reactor Building Exterior Exterior Y

40.2 81.9 22.5 2

5 2

10 10 30 50 4

13.4 3

N-Ray Setup Building 1

Office Space Y

13.0 16.1 8.0 1

1 1

10 10 20 4

6.3 3

N-Ray Setup Building 2

Customer Viewing Rm N

10.3 16.1 8.0 1

1 1

10 10 20 2.3 3

N-Ray Setup Building 3

Quality Control Room N

8.9 16.1 8.0 1

1 1

10 10 20 2.3 3

N-Ray Setup Building 4

Dark Room N

10.8 16.1 8.0 1

1 1

10 10 20 2.3 3

N-Ray Setup Building 5

Explosive Strg & Safe N

6.0 9.8 8.0 1

1 1

10 10 20 2.3 3

N-Ray Setup Building 6

Film Storage N

6.0 9.8 8.0 1

1 1

10 10 20 2.3 3

N-Ray Setup Building 7

Shipping & Receiving N

14.5 25.3 13.7 1

2 1

10 10 20 2.8 3

N-Ray Setup Building 8

N-Ray Setup Area N

33.8 38.5 13.7 1

2 1

10 10 20 2.8 3

Compressor Building 28 Compressor Building Y

7.7 14.2 8.0 1

2 1

10 10 20 4

6.8 3

Storage Building 42 Storage Building Y

24.0 24.3 11.0 1

2 1

10 10 20 4

6.8 TOTALS 160 160 180 500 36 109

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 80 of 83 Appendix A-7 Outdoor Area Survey Labor Summary NON-IMPACTED PAVED AREA SURVEY Table A-7

ARRR, California SURVEY PACKAGE AREA AREA Number Random Random SURVEY 10%

SURFACE AREA REQRD WIDTH LENGTH No. of No. of No. of of Survey Survey PACKAGE SURVEY LOC TYPES DESCRIPTION

?

SURVEY alpha beta gamma Exp Rate Sketchs Sketch PREP LABOR CODE (Y/N)

(ft)

(ft)

BLOCKS Scans Scans Scans Msrmnts (each)

Hours (hrs)

Hours 4

Asphalt East Paved Area Y

22 142 5

0.50 0.50 0.5 0.5 2

0.67 4

4.7 4

Asphalt North Paved Area Y

50 110 8

0.80 0.80 0.8 0.8 2

0.67 4

4.7 4

Asphalt West Parking Lot Y

50 203 14 1.40 1.40 1.4 1.4 2

0.67 4

4.7 TOTALS 27 3

3 3

3 6

2.0 12 14.1 NON-IMPACTED UNPAVED AREA SURVEY Table A-7 ARRR,!

California ENTER SURVEY ENTER ENTER ENTER BELOW ENTER ENTER PACKAGE AREA AREA Number Number Random Random SURVEY 10'/4 OPTIONAL SURFACE AREA REQRD WIDTH LENGTH Number of of Survey Survey PACKI.GE SURVEY LOC TYPES DESCRIPTION

?

BELOW BELOW SURVEY of Exp Rate Soil Sketchs Sk~chs PREP LABOR CODE BELOW BELOW jYINI lltl lltl BLOCKS Scans Msrmnts Samples jeachl Hours (hrs)

(hrs) 4 I Shrubs& Trees IFrontlandscapedArea I

y I

271 105 4

0.4 0.4 0.4 1

0.33 4

4.5 4

I Grass&Mulch ISouthYard I

y I

251 80 3

03 03 03 1

0.33 4

4.5 I

I I

I I

TOTALS 7

1 1

1 2

0.7 8

9.0 Table A-7 ARRR, :-

California CATCH BASIN & CLEAN-OUT SURVEY BASIN SURVEY DURATION (hrs):

4 BASIN SURVEY CREW SIZE (men):

1 ENTER ENTER SURVEY BELOW ENTER BASIN PACKAGE SURVEY OPTIONAL AREA DIAMETER REQRD PACKAGE SURVEY LOC DESCRIPTION BELOW

?

PREP LABOR CODE BELOW (ft)

(YIN)

(hrs)

(hrs) 4 Waste Sump 5.0 y

4 8.0 4

Manhole on Storm Sewer 5.0 N

4.0 TOTALS 4

12 DRAIN PIPE SURVEY PIPE SURVEY RATE (ft/hr):

40 PIPE SURVEY CREW SIZE (men):

3 ENTER ENTER ENTER SURVEY OPTIONAL ENTER PIPE PIPE PACKAGE SURVEY LOC AREA DIAMETER LENGTH REQRD PACKAGE SURVEY CODES DESCRIPTION BELOW BELOW

?

PREP LABOR BELOW BELOW (fl)

(ft)

(Y/N)

(hrs)

(hrs) 4 storm Drain 24 150 y

4 15.3 4

Sanitary Sewer 24 150 y

4 15.3 TOTALS 8

31

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 81 of 83 Appendix A-8 Instrument Lease Charges Table A-8 4 D&D Months Duration 1.0 Final Survey Months Duration 0.5 Characterization Survey Months Duration CHAR SURVEY D&D FINAL SURVEY D&D D&D CHAR SURVEY D&D FINAL SURVEY NUMBER NUMBER NUMBER FULL ALTERNATE INSTRUMENT INSTRUMENT INSTRUMENT ITEM INSTRUMENT MONTHLY INSTRUMENTS INSTRUMENTS INSTRUMENTS PROJECT MONTHLY LEASE LEASE LEASE NUMBER DESCRIPTION RENTAL RATE REQUIRED REQUIRED REQUIRED DURATION DURATION COST COST COST PORTABLE RADIATION PROTECTION INSTRUMENTATION 22 Ludlum MicroR Meter, Model 19

$120 1

1 1

Y

$60

$479

$120 25 Ludlum Alarm Ratemeter, Model 177

$103 1

3 3

Y

$51

$1,231

$308 32 Ludlum Data Logger, Model 2350-1

$239 3

3 3

Y

$359

$2,873

$718 RADIATION DETECTORS FOR PORTABLE INSTRUMENTATION 6

44 Ludlum 50cm2 Alpha Scintillator, Model 43-5

$86 1

2 2

Y

$43

$684

$171 47 Ludlum 125cm2 Gas Proportional Detector, Model 43-68

$46 1

3 3

Y

$23

$547

$137 52 Ludlum Gamma Scintillator Detector, Model 44-10

$103 1

2 2

Y

$51

$821

$205 SUPPORT EQUIPMENT FOR RADIATION PROTECTION INSTRUMENTA 58 Ludlum Floor Monitor Cart, Model 239-1F

$120 1

2 2

Y

$60

$958

$239 SEMI-PORTABLE RADIATION PROTECTION INSTRUMENTATION 69 Overhoff Tritium Monitor, Model 357

$1,197 LABORATORY & ANALYTICAL COUNTING INSTRUMENTATION 73 Ludlum Model 2929 Scaler with Dual Alpha/Beta 43-10-1 Sample Counter

$274 1

1 1

Y

$137

$1,094

$274 4

q 68 GAMMA SPECTROSCOPY EQUIPMENT 82 Canberra In-Situ Object Counting System (ISOCS) including: HPGe Detector (GC4020 or RE5020 available), Inspector-2K MCA, Big-MAC Dewar, 1" or 2" Lead Collimator/Shields, Mobile Cart or Tri-Pod.

$7,695 1

1 1

Y

$3,848

$30,780

$7,695 83 Canberra Laboratory Gamma Spectroscopy System with Dip Stick HPGe Detector, Laboratory Dewar, Digital MCA, Low Background Shield/Table, PC, and Genie-2K Software 84 GC3020 Detector (30% Relative Efficiency)

$2,822 87 Canberra Portable Gamma Spectroscopy System with Intregal HPGe Detector/Dewar, Inspector MCA, Laptop Computer, and Genie-2K Software 90 EG&G Laboratory Gamma Spectroscopy System with Dip Stick HPGe Detector, Laboratory Dewar, DSpec MCA, Low Background Shield/Table, PC, and Gamma Vision Software 92 GEM-35190-P Detector (35% Relative Efficiency)

$2,565 93 EG&G Portable HGPe Gamma Spectroscopy System with PopTop HPGe Detector, Portable Dewar, NOMAD MCA, Laptop Computer, and Gamma Vision Software 95 GMX-45220-P-S (45% Relative Efficiency)

$3,078 IN-SITU PIPE MONITORING EQUIPMENT AND DETECTORS SEALED SOURCES AND COUNTING STANDARDS 105 Tc-99 47mm, Beta Source

$103 1

1 1

Y

$51

$410

$103 106 Th-230 47mm Alpha Source

$103 1

1 1

Y

$51

$410

$103 109 Mixed Gamma, 250 ml Sand Marinelli, 133N

$239 1

1 1

Y

$120

$958

$239 113 Mixed Gamma, 47mm Filter Paper

$239 1

1 1

Y

$120

$958

$239 PORTABLE INDUSTRIAL HYGEIGENE FIELD INSTRUMENTATION 118 TSI Portacount Plus Respirator Fit Tester and Accessories, Model 8020

$1,026 SEMI PORTABLE DECONTAMINATION EQUIPMENT TOTAL INSTRUMENT LEASE COST

$3,769

$41,823

$11,219

ARRR, California INSTRUMENT COSTS

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 82 of 83 Appendix A-9 Equipment Lease Charges Table A-9 4 D&D Months Duration 1.0 FINAL SURVEY Months Duration D&D FINAL SURVEY D&D D&D D&D FINAL SURVEY MONTHLY NUMBER NUMBER FULL ALTERNATE EQUIPMENT EQUIPMENT ITEM COMMERCIAL ITEMS ITEMS PROJECT MONTHLY LEASE LEASE NUMBER DESCRIPTION RENTAL RATE REQUIRED REQUIRED DURATION DURATION COST COST DECON EQUIPMENT 10 NORCLEAN Triple Head Electric HEPA Vacuum :

$1,345 1

Y

$5,381 OFFICE EQUIPMENT 11 Data Analysis Computer System :

$182 12 Download Notebook Computers :

$135 1

1 Y

$538

$135 SAMPLING EQUIPMENT 14 FISHER SCIENTIFIC -Top Loading Scale, 0-3 kg Model XE4100 :

$171 1

1 Y

$684

$171 15 FISHER SCIENTIFIC - Class F S.S. Weight Set, 1mg-2kg CAT.# 0221531 :

$40 1

1 Y

$160

$40 16 FISHER SCIENTIFIC - Oven, ISOTEMP 5.0 120VAC CAT.# 13247750G :

$277 1

1 Y

$1,108

$277 23 Portable Multigas Monitor

$156 1

1 Y

$625

$156 26 3/4" x 50' Air Hose

$40 5

Y

$798 159 40'-45' Electric,Articulating Boom lift

$2,394 1

N 2

$4,788 193 25 Ton Crane Truck.10 cents per mile over 50 Day/200Week/800Month

$7,068 1

N 1

$7,068 TOTAL EQUIPMENT LEASE COST

$32,817

$888 EQUIPMENT COSTS

ARRR, California

Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor Revision 2-10-2025 Page 83 of 83 Appendix A-10 Consumable Costs Table A-10 4 D&D Months Duration

ARRR, California 1.0 Final Survey Months Duration 0.5 Characterization Survey Months Duration CHAR.

D&D FINAL SURVEY ITEM ITEM UNIT UNITS UNITS UNITS CHAR.

D&D FINAL SURVEY NUMBER DESCRIPTION RATE REQUIRED REQUIRED REQUIRED COST COST COST 0 PPE/Consumables 27 Electrical tape

$5 16 2

$0

$77

$10 40 Smears with peal back envelope, 250 per box

$38 16 8

$0

$613

$307 41 Planchets, aluminum C5A, 100 per bag

$29 40 20

$0

$1,150

$575 42 Tritium Smears

$13 4

2

$0

$51

$26 43 Tritium/C-14 counting vials (500/case)

$180 80 50

$0

$14,436

$9,022 44 Liquid Scintillation cocktail (4L/case)

$493

$0

$0

$0 45 DI WATER, 500 ml Bottle

$63 2

1

$0

$126

$63 48 Marinelli beaker, 250 ml sample container, 100 per case w lids

$559 5

2

$0

$2,796

$1,118 49 Cotton swab, with 6" or 8" wood shank, 100 per pack

$5

$0

$0

$0 50 PETRI DISHES, Ea

$182 48 24

$0

$8,731

$4,365 51 ZIP-LOCK FREEZER BAGS, 25 per Box

$8 20 20

$0

$153

$153 52 Hefty EZ Foil Giant Lasagna Pan 11 x 9 x 3

$4 40 25

$0

$178

$111 53 LIQUID NITROGEN, 160 liter

$153 12 4

$0

$1,840

$613 54 P-10 GAS, INSTRUMENT GRADE, 80 cf

$259 24 4

$0

$6,228

$1,038 55 Batteries, D Cell (Case of 72)

$88 5

1

$0

$439

$88 56 Tygon Tubing 1/8"+1/4"x 50'

$92 4

2

$0

$367

$184 57 TWEEZERS / FILTER FORCEPS, VWR PT. # 30033-042 OR EQUAL, Ea

$23 2

1

$0

$47

$23 60 Eberline, soil, Gamma Scan (HPGe) gammma)

$160 20

$0

$0

$3,194 66 Eberline, soil, Full Envirocare analysis

$3,762 1

2

$0

$3,762

$7,523 67 Asbestos Analysis

$80 10

$0

$799

$0 68 1/4" Sieve stainless Sample Prep

$222 4

1

$0

$887

$222 0 H&S Supplies and Equipment

$0 95 8' Fiberglass Step Ladder

$332 2

1

$0

$664

$332 103 PRINTER/COPIER PAPER

$51 4

1

$0

$204

$51 104 LOG BOOK, 8.5" X 11"

$6 4

1

$0

$22

$6 105 NOTE PADS, POCKET SIZE, Ea

$12 24 2

$0

$279

$23 106 LEGAL PADS, 8.5"X 11", Ea

$10 24 2

$0

$241

$20 107 SHARPIES, Box

$18 8

2

$0

$147

$37 108 Sawzall

$319 2

$0

$639

$0 109 2-inch Vacuum Hose (25-ft)

$241 4

$0

$966

$0 110 Minuteman/Hako X839 HEPA Vacuum

$1,301 1

$0

$1,301

$0 111 Vacuum Tool Kit for Minuteman System

$292 1

$0

$292

$0 112 HEPA Filter for Minuteman/HAKO Vacuum

$458 1

$0

$458

$0 113 Cloth Filter Bag for Minuteman/HAKO

$227 4

$0

$907

$0 114 Extension Cords Heavy Duty (50-ft sections)

$63

$0

$0

$0 115 2' 12/3 SJTW Yellow Jacket GFCI

$86

$0

$0

$0 116 Angle lock box (45 cubic foot)

$1,916 4

2

$0

$7,665

$3,832

$0

$93,841

$37,547 CONSUMABLE COSTS

_