ML26014A181

Enclosure 1 - Executive Summary of Pennsylvania State Universitys Unified Decommissioning Cost Estimates

ML26014A181
Person / Time
Site:	07000113
Issue date:	12/22/2025
From:	Wilmot A Pennsylvania State Univ
To:	Stephen Poy NRC/NMSS/DFM/FFLB
References
Download: ML26014A181 (0)

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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Executive Summary of the Pennsylvania State Universitys Unified Decommissioning Cost Estimates Encompassing Radiation-Related Facilities At University Park, Hershey Medical Center, And Commonwealth Campus Locations December 22, 2025 Prepared by:

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

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Executive Summary of the Pennsylvania State Universitys Unified Decommissioning Cost Estimates Page 2 of 7 December 2025 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Introduction and Executive Summary These decommissioning cost estimates (DCEs) were prepared using NUREG-1757 Volume 3 Rev 1 (2012) as a guidance document. The section designations correspond to the numbering system used in Appendix A.3 of the NUREG.

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

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

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

3. Harrisburg Campus (UP PA license)

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

5. Penn State Health - Hampden Medical Center (PA license).

6. Penn State Health - Lancaster Medical Center (PA license).

Of these six locations, only five regularly utilize radioactive material: University Park, the Hershey Medical Center, and the Breazeale reactor. The Harrisburg campus, while an authorized place of use under the UP PA state license, has only one laboratory that has utilized P-32 occasionally since the previous update of these estimates (2022).

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

License Number Issuing Agency Brief Description and Campus Location Enclosure Executive Summary of Unified DCE 1

PA-0100 PA DEP Broad scope byproduct materials, UP & others 2

PA-0127 PA DEP Broad scope byproduct materials, PSHMC campus 3

SNM-95 NRC Special Nuclear Materials, UP campus 4

R-2 NRC Research and Test Reactor license, UP campus 5

Because of the disparate geographical and radioactive material usage differences between the licenses, each has been separated into a self-contained Enclosure. Enclosures 2, and 3 are submitted for review by the PA DEP. Enclosures 4 and 5 are submitted for NRC review.

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

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Executive Summary of the Pennsylvania State Universitys Unified Decommissioning Cost Estimates Page 3 of 7 December 2025 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Records of information important to the decommissioning of Penn States licenses are retained at the University Park Environmental Health and Safety offices and at the Health Physics offices at the Hershey Medical Center. Facility descriptions, including currently active buildings, numbers of active lab, and most used radioisotopes have been given in the Section A.3.4 Facility Description of each attachments.

Detailed room number and isotopes used in each room and dates are included in the building decommissioning reports that are submitted to Pa DEP or NRC for review. In addition, Historical Site Assessment resource lists have been given in Section A.3.6 Planning and Preparation of each attachment.

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

Penn State University Unified Decommissioning Cost Estimate License Type Enclosure Estimated Cost ($)

PA-0100 Broad Scope 2

$4,059,383 PA-0127 Broad Scope 3

$3,329,569 SNM-95 Special Nuclear Materials 4

$413,272 R-2 Reactor 5

$22,263,085 Penn State University TOTAL

$30,065,309

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Executive Summary of the Pennsylvania State Universitys Unified Decommissioning Cost Estimates Page 4 of 7 December 2025 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Basic Assumptions Common to All DCEs Several assumptions must be made to estimate the cost of decommissioning the facilities under each license. The assumptions common to all licenses are listed below while assumptions specific to a license are contained in that licenses Enclosure.

1. Compliance with 10 CFR 20.1402.

The operations plans and the cost estimates are based upon meeting the release limit of 10 CFR 20.1402. This release limit requires that residual radioactivity that is distinguishable from background radiation results in a total effective dose equivalent (TEDE) to an average member of the critical group that does not exceed 25 mrem per year."

2. One license is terminated at a time.

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

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

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

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

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

5. No remodeling costs are included.

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

6. No credit for salvage.

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

7. No license amendments required.

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Executive Summary of the Pennsylvania State Universitys Unified Decommissioning Cost Estimates Page 5 of 7 December 2025 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION No license amendments are expected for decommissioning. All activities are within the normal scope of tasks currently performed on a regular basis in accordance with established written procedures. If these tasks are performed by Penn State employees or by an outside group, the tasks are expected to be commensurate with normal activities.

8. Vendors will ship Type B materials.

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

9. Decommissioning of buildings.

Buildings in which no principal activities under the license have been conducted for a period of 24 months are decommissioned in accordance with 10 CFR 30.36.(d).(3). Generally, it is infrequent that a building that had radioactive material labs is decommissioned because labs do not terminate their use often. When a building is decommissioned its hoods, ducts, and sinks are checked for contamination, all labels and tags are removed, and a report is filed confirming compliance with 10 CFR 20.1402. This building report relies heavily upon the agglomeration of individual room decommissioning reports and is available for inspection. Buildings and spaces previously released by the NRC and PA DEP are not included in these DCEs.

10. A licensed radioactive waste site is available.

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

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

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

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

12. The best method used to estimate the rise in decommissioning cost escalations over time is to an employ an escalation rate that matches that of the Construction Cost Index (CCI) published by Engineering News-Record, as the CCI index most closely reflects commodities and rates of the most relevance to radioactive and nuclear material decommissioning projects.

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Executive Summary of the Pennsylvania State Universitys Unified Decommissioning Cost Estimates Page 6 of 7 December 2025 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Basic Assumptions Common to Only PA Broad Scope License DCEs Additional assumptions have been incorporated into the DCEs for Pennsylvania Department of Environmental Protection issued broad scope licenses.

1. Waste On-hand equals or exceeds one years waste generation.

This DCE assumes that one years worth of normal operations waste is already On-hand and waiting disposal at the start of decommissioning. Added to this amount will be the decommissioning waste so that the total amount of radioactive waste will be slightly larger than just from decommissioning activities only.

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

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

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

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Executive Summary of the Pennsylvania State Universitys Unified Decommissioning Cost Estimates Page 7 of 7 December 2025 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Revisions to This DCE Submittal The difference in cost estimates between this 2025 DCE and the previous DCE (2022) are due to these factors:

1. All costs have been updated to 2025 values.

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

3. The PA-127A license is removed from consideration.

4. Consideration of the costs to decommission the R-2 research reactor license have been expanded to consider a larger facility and additional equipment that makes up the Small Angle Neutron Scattering (SANS) instrumentation being installed in the facility expansion.