ML13358A299

Enclosure 1, Unified Decommissioning Funding Plan for Pennsylvania State University Radiation Facilities at University Park

ML13358A299
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Site:	Pennsylvania State University
Issue date:	12/18/2013
From:	Shannon King, Leavey J Pennsylvania State Univ, University Park, PA
To:	Office of Nuclear Material Safety and Safeguards
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ML13358A287	List: ML13358A298 ML13358A299
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Enclosure 1 Unified Decommissioning Funding Plan For The Pennsylvania State University Radiation Facilities At University Park, Hershey Medical Center, And Related Campuses December 18, 2013 Prepared by Jeffrey Leavey Radiation Safety Officer, University Park Steve King Radiation Safety Officer, Hershey Medical Center 12/18/2013 Executive Summary Page I of 6

M Introduction and Executive Summary This decommissioning funding plan (DFP) was 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 State's Environmental Health and Safety oversight and thus is not counted in the list of supported campuses shown on the map). However, the use of radioactive materials is limited to the following 6 locations by either a PA state license or by an NRC license:

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

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

3. Altoona Campus (UP PA license)

4. Harrisburg Campus (UP PA license)

5. Penn State Electro-Optical Center, Freeport (UP PA license)

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

Of these six locations, only three regularly utilize radioactive material: University Park, the Hershey Medical Center, and the Breazeale reactor. The Harrisburg campus, while an authorized place of use under the UP PA state license, has only one laboratory that has only ever utilized P-32 once in the month of November 2013. The Altoona campus has only one laboratory using nanocurie amounts of A1-26 and they have been inactive for the past few years.

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

License Number Issuing Agency Brief Description and Campus Location DFP Appendix PA-0100 PA DEP Broad scope byproduct materials, UP & others A PA-0127 PA DEP Broad scope byproduct materials, PSH\MC campus B PA-0127A PA DEP Self-shielded irradiator license, PSHMC campus C SNM-95 NRC Special Nuclear Materials, UP campus D R-2 NRC Research and Test Reactor license, UP campus E Because of the disparate geographical and radioactive material usage differences between the licenses, each has been separated into a self-contained appendix to this document. The Pennsylvania Department of Environmental Protection Bureau of Radiation Protection (PA DEP) will want to review Appendix A, B, and C. The Nuclear Regulatory Commission will want to review Appendix D and E.

The method for estimating decommissioning costs was changed in December 2012 when an updateto 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 DFP reflect this change.

Records of information important to the decommissioning of Penn State's licenses are retained at the University Park Environmental Health and Safety offices and at the Health Physics offices at the Hershey Medical Center.

12/18/2013 Executive Summary Page 2 of 6

The decommissioning cost estimates for each license, individually and combined, are as follows:

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

PA-0100 Broad Scope A $3,605,705 PA-0127 Broad Scope B $3,537,176 PA-0127A Irradiator C $455,623 SNM-95 Special Nuclear Materials D $356,776 R-2 Reactor E $16,031,304 Penn State University TOTAL $23,986,584 Basic Assumptions Common to All DFPs Several assumptions must be made to estimate the cost of decommissioning the facilities under each license. The assumptions common to all licenses are listed below while assumption specific to a license are contained in that license's appendix.

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 TEDE to an average member of the critical group that does not 12/18/2013 Executive Summary Page 3 of 6

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 DFP assumes an independent contractor will perform all work.

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

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

4. Prior decommissioned use locations are not included.

Related to assumption 3, 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. Once verified by Radiation Safety staff to be releasable, the space is de-posted and allowed to be unrestricted space. These locations are not included in this DFP.

5. 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 in "un-restricted release" condition. This means that whenever a room, area, or major piece of equipment becomes contaminated, it is cleaned or disposed of, as appropriate, soon after discovery. Penn State can support this assumption by review of many years of survey data that show our laboratories do not have significant contamination issues. This "clean operations" policy is also in effect at the Hershey Medical Center. This policy will reduce the actual costs of decommissioning.

6. 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.

7. 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.

8. No license amendments required.

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

12/18/2013 Executive Summary Page 4 of 6

9. 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 writing and documenting a quality assurance plan. The outside vendor(s), specifically licensed to perform this work, will perform the packaging and shipping of the material.

10. 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 materials 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.

11. A licensed radioactive waste site is available.

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

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

12. DOE will accept the return of their materials.

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

13. Waste on hand equals one year's waste generation.

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

Reasons for the Differences in Cost Estimates With This DFP The difference in cost estimates between this DFP and prior DFPs are due to these factors:

1. The current DFP is now required to be based on a third party contractor performing all work.

Prior DFPs assumed that Penn State HP staff would be available to perform surveys, waste handling, and record keeping activities.

2. Prior UP and PSHMC DFPs assumed that only a small fraction of labs and/or facilities would need decontamination based on Penn State's policy of"no contamination".The current UP and PSHMC DFPs assumes that all labs and facilities will require decontamination efforts and 12/18/2013 Executive SummaryP Page 5 of 6

generate the associated wastes.

3. New and conservative costs for irradiator disposal at UP were taken from 2013 estimates of irradiator disposal at PSHMC.

4. In prior DFPs labor rates were based on Penn State staff salaries covering labor costs. With the change to a third party contactor, higher labor rates based on current market conditions were used in the current DFP.

5. Following the outline of NUREG-1757 Volume 3 Rev 1 (2012) Appendix A.3 caused additional costs to be included that were not included in prior DFPs.

6. For the Breazeale Reactor Facility, although the facility-specific cost estimate (see DFP Appendix E) is in agreement with other reactors, the Georgia Institute of Technology decommissioning cost continues to be the worst case scenario and thus Penn State will continue to use that cost for this DFP.

12/18/2013 Executive Summary Page 6 of 6

I-- M APPENDIX E -- University Park R-2 NRC Reactor License Section A.3.4 Facility Description License Numbers and Types The Pennsylvania State University maintains license number R-2 issued by the Nuclear Regulatory Commission as a license for the Penn State Breazeale Nuclear Reactor (PSBNR) as a test and research reactor at the University Park Campus.

Types and Quantities of Materials Authorized The following are the licensed materials and quantities permitted under R-2:

Table 1 - PSBNR R-2 License Details Lte Isotope Form Allowed Quantity

• I -I

• U Description of How Licensed Materials Are Used The Penn State Breazeale Nuclear Reactor (PSBNR) is a IMW water cooled natural convection reactor using TRIGA fuel that has been in operation since 1955. It is the center piece of the Radiation Science and Engineering Center (RSEC) and the Nuclear Engineering Department, and is used for teaching, research, and training in reactor physics, nuclear science and engineering. The reactor is also used as a test reactor for activities such as irradiation and neutron testing of components, archeological artifacts, and the production of isotopes for use at the University Park campus.

Routine surveys are performed by Radiation Protection staff weekly to assure that safe working conditions are maintained. Normal operating procedures require that radioisotope laboratories minimize contamination. Typically, surveys show no removable contamination above background (approximately

< 50 dpm/100cm 2) on surfaces and equipment using liquid scintillation counting (LSC) and Geiger meters. Penn State maintains a "no contamination"policy and any finding above background is promptly addressed and decontaminated.

Because of this continuous characterization of the radiation environment, normal decommissioning typically requires only the removal of the fuel, core components, moderating and cooling water, the pool structure, miscellaneous activated support components, and radioactive waste consisting of paper, 12/18/2013 Appendix E Page I of 20

plastic, and glass lab ware followed by appropriate surveys of the facility and equipment.

All fuel is owned by the Department of Energy (DOE) and is assumed that the DOE will take back all fuel. All fuel disposal costs, other than shipping, are assumed to be covered by the DOE.

Description of Facilities Table 2 - PSBR Buildings and Rooms Number of Campus Building Use Rooms UP Breazeale Reactor I UP Breazeale Reactor I UP Breazeale Reactor I UP Breazeale Reactor 2 UP Breazeale Reactor I UP Breazeale Reactor 2 TOTAL Rooms 8 Within any given approved laboratory space, researchers are encouraged to limit work with radioactivity to as small an area as possible, i.e. one bench top. Individual instruments and equipment that are used to store or process radioactive samples are labeled with a Caution Radioactive Material label.

The decommissioning costs of this license are difficult to quantify therefore the costs from similar facilities will form the basis for estimating Penn State's future costs. Cost and labor estimates were obtained from the Georgia Institute of Technology for the decommissioning of their 5 MW reactor in 2001, from the University of Virginia for the decommissioning of their 2 MW reactor in 2002, the decommissioning plan estimates of the AFRRI TRIGA reactor found in AFRRI Report TR89-2 (similar to the Oregon State University TRIGA reactor), and the Cornell University Ward Nuclear Center TRIGA reactor in 2006.

Radioactive Waste On-Hand Before Decommissioning All wastes with less than or equal to 120 day half-life are held for decay for at least 10 half-lives, then 12/18/2013 Appendix E Page 2 of 20

surveyed and released as non-radioactive waste. Liquid wastes with half-lives greater than 120 days are disposed via sanitary sewer by Radiation Protection staff to ensure that legal release limits are not exceeded. All other long lived wastes are shipped to an appropriate waste disposal facility.

All radioactive waste generated by the PSBR facility is processed by the Radiation Protection Office and comingled with waste from other laboratories in one waste handling facility. As stated in the general assumptions, one year's worth of waste is assumed to be in hand prior to the start of decommissioning and for the past several years one shipment per year has been done. Using the prior three years of waste shipment data, the volumes, isotopes, and costs are shown here:

Table 3 - Waste History Total Total Number of Year Containers Isotopes Activity Volume Weight Shipment (mCi) Cost H-3, C-14, 5 Cardboard U(Nat), Fe- 78 ft' 2011 Boxes 55, Cs-137, 72.6 mCi (15.6 ft3 per 581 lb (DAW) Co-60, Na- box) 22, Zn-65, Ca-45 5 Fiber 20.5 fi3 Drums Fe-55 0.02 mCi (4.1 ft3 per 293 lb (30 gal) (LSC Vials) drum)

H-3,C-14,Cs-I Drum 137,Co-60, (55 gal) Ni-63, Cr- 1.8 mCi 7.4 ft3 206 lb $6,403 drum 51, Co-58, Mn-54, Zn-65, activated metals H-3, C-14, Co-60,Cs-137, Fe-55, 8 Cardboard U(Nat), Zn- 125 ft 3 2012 Boxes (DAW) 65, 154, Eu-152, 9.4 (15.6bx ft3 per 980 lb (Eu- 155, Eu-Ra-226, box)

U-238, Sr-90 I Drum Co-60, Cs- 1.7 mCi 7.4 ft3 143 lb (55 gal) 137, Eu-152, 12/18/2013 Appendix E Page 3 of 20

drum Eu- 154, activated metals 3 Fiber 12.3 ft3 Drums Fe-55 0.02 mCi (4.1 ft3 per 197 lb $6,900 (30 gal) (LSC Vials) drum) 12 C-14, H-3, Fe-55, 187 ft3 2013 Cardboard U(Nat), Zn- 12.2 mCi (15.6 ft3 per 1,140 lb Boxes 65, Co-60, box)

(DAW) Cs-137 3 Fiber 12.3 ft3 Drums Fe-55 0.2 mCi (4.1 ft3 per 148 lb (30 gal) (LSC Vials) drum) 3 Fiber H-3 3.6 ft-Drums (Animal 0.2 mCi (1.2 ft3 per 58 lb $8,500 S(10 gal) carcasses) drum) I The cost per waste type for the past three years is:

Table 4 - Waste Cost History Year Waste Type Cost per Cubic Foot Cost per Pound 2011 Dry Active Waste $40.22 $5.40 Ecology Services, Inc. (DAW)

Activated Metals $181.33 $6.60 LSC Vials $92.93 $6.50 2012 Dry Active Waste $35.12 $4.48 Ecology Services, Inc. (DAW)

Activated Metals $133.47 $7.00 LSC Vials $116.10 $7.25 2013 Dry Active Waste $34.22 $5.61 Ecology Services, Inc. (DAW)

LSC Vials $81.46 $6.77 Animal Carcasses $306.11 $19.00 For easier analysis, the unit costs table above has been rearranged as follows:

Table 5 - Cost per Cubic Foot Year DAW Metals LSC Animals 2011 $40.22 $181.33 $92.93 2012 $35.12 $133.47 $116.10 2013 $34.22 $81.46 $306.11 12/18/2013 Appendix E Page 4 of 20

Table 6 - Cost per Pound Year DAW Metals LSC Animals 2011 $5.40 $6.60 $6.50 2012 $4.48 $7.00 $7.00 2013 $5.61 $6.77 $19.00 The waste on-hand will be assumed to be the largest amount of all types of waste for the past three years. The cost of disposal will be the greatest per pound unit cost of the past three years plus 5%.

Therefore, the waste on-hand for this DFP is:

Table 7 - Waste On-Hand At Start of Decommissioning DAW Metals LSC Animals Pounds 1,140 206 293 58 Cost per Pound $5.89 $7.35 $7.35 $19.95 Total $6,715 $1,514 $2,154 $1,157 Grand Total $11,540 Volume of Contaminated Subsurface Materials The PSBR is a pool type reactor using 71,000 gal of ultra-pure water for neutron moderation and cooling. Throughout the operating history of the facility, pool water leaks have occurred to varying degrees and at varying times. Most recently, in early October of 2007 a pool water leak was detected with the release of an estimated 12,300 gal (based on integrating the reported variable leak rates contained in the NRC inspection report, accession number ML073480163, over the 43 days of the event). At the time of the incident and for 3 months following (into December 2007), well water was sampled at 5 locations near the PSBR facility. The data showed a maximum well water concentration of slightly less than 600 pCi/L with a 1000 pCi/L minimum detectable activity (MDA).

When decommissioning does occur, soil sampling will be performed to assess radiological condition under the facility. Because no significant levels of tritium were found in wells due to the last event, it is assumed that any radionuclides that may be present from pool leaks have remained under the facility. A

• worst scenario would be the removal of a volume of soil the size of the reactor bay to a depth of 5 feet.

Section A.3.5 Number and Dimensions of Facility Components Type of Space: Reactor, bay, rooms, and components.

Average Size: Not Applicable 2 Level of Contamination: < 100 dpmn/100 cm Table 8 - Reactor Components Component I Number of Components Dimensions of Component Reactor Pool Structure 1 17 W x 45 L x 24 D feet 12/18/2013 Appendix E Page 5 of 20

Reactor Core Structure 1 3 x 3 x 5 feet Reactor Suspension Tower 1 2 x 2 x 24 feet Control Rods 10 0.2 x 0.2 x 5 feet Reactor Bridge 1 17 W x 4 D x 8 H feet D20 Tank 1 2.5 Dia x 1.5 H D20 Water 1 55 gal (210 L)

Pool Water 1 71000 gal Circulating Pumps 2 2 x 6 x 2 feet Water Purification 1 3 x 3 x 10 feet Heat Exchanger 1 3 x 3 x 12 feet Moderator/Coolant Piping 1 600 ft2 Evaporator Shed 1 10x20x 8 feet Underground Tanks/Piping 2 1000 gal Hot Cell 2 10 x 8 x15 feet Bulk Equipment:

Waste Containers 3 1.5 x 1.5x2.5 feet Hand Items (Misc tools, etc.) 100 Section A.3.6 Planning and Prenaration (Work Davs)

Current Conditions A third party contractor will be utilized for the decommissioning effort. It is assumed that normal operations continue up until the date the contractor comes on site. The contractor will need to first familiarize themselves with the facility and define the scope of work.

The Radiation Protection Office (RPO) and/or PSBR maintain all records pertinent to the use of radioactive materials under the licenses. These include receipts, stock vial inventory, locations of use or storage, waste inventory, personnel, and sealed sources. The records are kept electronically in a database and updated as the record is generated (i.e. inventory is updated as stocks are received; lab survey data is updated soon after the survey is completed, etc.) Radiological surveys are performed on at least a weekly basis and paper records kept for at least three years; therefore, a review of these documents will demonstrate the recent levels of contamination which may be expected.

Historical Site Assessment The following records are available in the RPO and/or PSBR with regard to historical use of radioactive materials:

A) Paper survey reports of the facility where radioactive material has been used for the past three years.

Survey reports are not to scale, but represent the pertinent fixtures and equipment used for radioactive materials work. Surveys may extend to non-use areas and equipment that may be in a particular location.

12/18/2013 Appendix E Page 6 of 20

Survey reports typically record the radionuclides recently used and may not reflect all historical uses in a particular location; however, historical purchase records are available.

B) A listing of all locations by user, nuclides, building and room number where radioactive materials were ever authorized under state license.

C) A listing of locations where radioactive materials are currently authorized.

D) A database of all radioactive waste currently being held in storage, whether for decay-in-storage, or ship-out.

E) Scale floor plans of buildings are maintained by Facilities Management but survey maps used by the RPO show major room components.

F) Annual summaries of discharges to the sanitary sewer system by the RPO are available.

Other Activities Based upon the current level of use, Penn State's "no contamination"policy, and a review of past surveys showing no contamination in the general facility, it can be concluded that radiological conditions are already within the release criteria for the bulk of the facility.

The contractor will prepare the actual decommissioning plan for regulatory review. This will define the scope of work, the radiological conditions of the site, and provide a plan for action. Upon approval by the regulator, a working plan will be developed to include a strategy for systematic decommissioning surveys along with manpower and equipment requirements.

Some estimates are from decommissioning plans for Georgia Institute of Technology, University of Virginia, the AFRRI TRIGA (AFRRI Report TR89-2), and the Cornell reactor facility as these were facilities similar to the PSBR. Note that not all of these past facilities had data that is directly comparable to the detailed breakdowns suggested in NUREG-1757; most offered only lump-sum cost data and these will be address in the last section of this DFP.

The following table summarizes the work days associated with planning activities:

Table 9 - Planning and Preparation Work Person-Days Waste Health HP Clerical Construction Wast Civil/Mech/QA Project Activity Physicist Technician / Admin Laborer Supervisor Mgmt Engineer Manager

((3) Specialist (1) (2) (1) (1) (1)

Prepare documentation 60 20 30 0 0 60 30 30 for regulatory agencies Submittal of decommissioning 5 0 10 0 0 5 5 5 plan 12/18/2013 Appendix E Page 7 of 20

Development of 90 20 120 0 90 90 90 120 work plans Procurement of equipment and 10 0 5 0 15 10 10 10 supplies Staff training 5 10 0 15 5 5 5 5 Characterization of radiological 40 90 30 15 0 40 0 45 conditions Other Otion 5 10 5 15 5 5 5 (mobilization) 5 Total 215 150 200 45 115 215 Person-Days 145 220 Assume 260 work days per year.

Section A.3.7 Decontamination or Dismantling of Components (Work Days)

Based upon the continuous survey and decontamination efforts conducted during the normal radiation safety surveillance program, there are few components which need to be addressed in this category.

Activated items - Specific items to be considered exposed to neutron activation include materials composed of aluminum, steel, stainless steel, graphite, cadmium, lead, concrete, reactor core structure, suspension tower, miscellaneous metal items, beam tubes, D2 0 tank, and possibly others. All reactor confinement structure, equipment, and materials will be surveyed and designated as contaminated or uncontaminated. Uncontaminated equipment and materials will be released for unrestricted use or disposed as clean waste. Contaminated equipment will be decontaminated and handled as other uncontaminated material or removed and packaged for processing and direct disposal as radioactive waste.

Reactor pool structure - After removal of the pool water and all items in the pool, the interior surfaces will be decontaminated by hydro-lazing the waterproof coating. Reactor components and activated pool hardware will be removed for disposal as low level radioactive waste. Piping embedded in the concrete pool walls and floors will be surveyed and decontaminated, as necessary, and left in place if clean.

Surface and core samples of the pool concrete walls will be performed to determine the extent of the contaminated areas. Contaminated material will be removed and packaged. The structural integrity of the pool will be augmented as necessary if it is threatened because of removal of material.

Reactor pool water - Pool water will be analyzed for contaminates other than tritium (known to be present) and then disposed via sanitary sewer in a controlled method to remain within discharge limits.

D20 water - This water is known to contain tritium but is owned by the DOE. It will be drummed and then all D20 will be held for transfer back to the DOE.

12/18/2013 Appendix E Page 8 of 20

Water purification / demineralizer - The resin will be collected and disposed of. The tank and related piping will be wiped down.

Hot Cells - The two hot cells and manipulators are not in use, currently not contaminated, and do not hold unsealed materials; the cells are currently uged to store sealed discrete sources. The cells are not included in this version of the DFP.

Type of Space: Reactor, bay, rooms, and components.

Average Size: Not Applicable 2 Level of Contamination: < 100 dpm/100 cm Table 10 - Decontamination or Dismantling Clerical of Components Work WastePerson-Days Construction Wast Civil/Mech/QA Project Decon HP HP Tech / Laborer Supervisor Engineer Manager Component Method

______l)__________ (1) (2) Admin (3)(I) uei (I ) Specialist Ege (1) Mng(1)

Reactor Pool Hydro-laze, 30 120 40 360 120 120 120 120 Structure Disposal Reactor StructureCore Disposal 40 180 80 120 40 240 30 40 Reactor Suspension Tower Disposal 10 40 40 120 10 60 15 10 Control Rods Disposal 10 20 10 10 10 120 15 10 Reactor ReatorBrige Bridge Down Wipe 15 20 40 60 20 15 15 20 D20 Tank Disposal 10 20 10 15 10 120 15 10 Drum, D20 Water hold for 5 15 10 15 5 15 5 5 DOE Pool Water Disposal 10 15 40 15 10 120 5 10 Cirulain Pups Circulating Pumps Down Wipe 10 30 40 120 10 40 20 10 Water Purification Wipe 10 15 20 45 10 40 10 10 Down Hea Exhaner HeatExchanger Down Wipe 10 15 20 30 10 20 10 10 Moderator/Coolant Wipe 20 20 20 90 20 20 10 20 Piping Down Evaporator Shed Disposal 10 20 5 30 10 15 5 10 Underground 10 Tanks/Piping Disposal 10 30 5 60 10 20 10 Waste Containers Wipe Down 5 10 5 5 5 10 5 5 Hand Items (Misc Wipe 15 30 60 10 15 40 15 15 tools, etc.) Down 5 3 6 1 I 4 1 1 12/18/2013 Appendix E Page 9 of 20

Potrso-as 220 600 445 1105 315 1015 305 315 Assume 260 work days per year.

Section A.3.8 Restoration of Contaminated Areas (Work Days)

Assuming the worst case that there are radionuclides in the soil under the pool structure and underground tanks that will require removal, an estimated soil volume of 4,200 ft3 (20 x 40 x 5 fi) under the reactor pool footprint and 600 ft3 (approx. four times the volume of 2 tanks) will be used for this DFP. It is also assumed that should soil removal be required, access to the soil will be from inside the pool by removal of the pool floor; no other structural demolition is assumed.

Table 11 -Restoration of Contaminated Areas Work Person-Days HP HP Clerical / Laborer Construction Waste Mgmt Civil/Mech/QA Project Manager Tech Admin Supervisor Specialist Engineer (1)

A t(2) () (3) (() (1)

Removal ofPool 30 60 10 120 30 30 20 30 Floor Soil Excavation 15 40 5 120 40 40 40 20 Backfill 5 5 5 90 30 5 30 20 Excavate Tanks 10 20 5 30 10 30 10 10 Soil Excavation 5 10 5 30 10 20 10 10 Backfill 5 10 5 30 5 5 10 10 Total Ponay 70 145 35 420 125 130 120 100 Person-Days Section A.3.9 Final Radiation Survey (Work Days)

Table 12 - Final Radiation Survey Work Person-Days Activity HP (P HP Tech Clerical Admin / Laborer Construction Waste Mgmt Civil/Mech/QA Project (1)

Manager A tvt(2) () (3) Supervisor Specialist

() Engineer

()

Final Characterization 20 40 10 5 5 20 5 20 Survey Final Report 15 20 15 5 5 15 5 15 Total Ponay 35 60 25 10 10 35 10 35 Person-DaysIII Section A.3.10 Site Stabilization Long Term Surveillance (Work Days)

There are no known areas requiring stabilization or long term surveillance for this license.

12/18/2013 Appendix E Page 10 of 20

Section SetoI..1Toa A.3.11 Total Work okDy Davs Bv Labor Cate2orvI By LaorCae Table 13 - Total Work Days By Labor Person-Days HP eHP Clerical Laborer Construction Waste Mgmt Civil/Mech/QA Project Manager Aciiy() () Tech (2)) Admin (I) ()

(3) Supervisor (1) Specialist (1) Engineer()

(1))

Planningand 215 150 200 45 115 215 145 220 Prep Decontamination 220 600 445 1105 315 1015 305 315 Restoration of 70 145 35 420 125 130 120 100 Contam Areas I FinalRad 35 60 25 10 10 35 10 35 Survey Site Stabilization 0 0 0 0 0 0 0 0 Total Ponay 540 955 705 1580 565 1395 580 670 Person-D ays II IIIIII Section A.3.12 Worker Unit Cost Schedule Salary and labor rate data for Pennsylvania May 2012 was obtained from:

http://www.bls.gov/oes/current/oes pa.htm# 19-0000 Life, Physical Social Sci - nuclear technician = $78,250 Construction Supervisor - construction managers = $109,540 Office admin support - info and records clerks = $39,600 Construction laborers = $35,470 Waste Mgmt - nuclear engineer = $98,280 Civil/Mech/QA - civil engineer = $78,190 Project Mgmt - general and ops managers = $115,050 Salary data for CHPs for 2012 was obtained from:

http://www.hps.org/documents/2012 chp salary survey.pdf Median CHP salary for the Northeast = $116,250 12/18/2013 Appendix E Page I!I of 20

Travel and Per-Diem $175 $175 $175 $175 $175 $175 $175 $175 per Day Total Cost per Person- $884 $652 $417 $391 $843 $775 $652 $877 Day *

• Based on 260 work days per year Section A.3.13 Total Labor Costs by Major Decommissioning Task Table 15 - Total Labor Costs Clerical / Const Waste CiMech/ Project HP HP Tech Admin (3)Labo Superv Engineer Activity (1) (2) (1)

Manager Totals (1) Scl (g) (1)

Planning and Prep $190,060 $97,800 $83,400 $17,595 $96,945 $166,655 $94,540 $192,940 $939,935 Decontamination $194,480 $391,200 $185,565 $460,785 $265,545 $786,625 $198,860 $276,255 $2,759,315 Restoration of $61,880 $94,540 $14,595 $175,140 $105,375 $100,750 $78,240 $87,700 $718,220 Contamn Areas Final Rad Survey $30,940 $39,120 $10,425 $3,910 $8,430 $27,125 $6,520 $30,695 $157,165 Site Stabilization 0 0 0 0 0 0 0 0 0 Total Cost $477,360 $622,660 $293,985 $657,430 $476,295 $1,081,155 $378,160 $587,590 $4,574,635 Section A.3.14 Packing, Shipping, and Disposal of Wastes Note: Labor costs for waste processing is included in this section and not in the above analysis.

Packaging Material Costs Packing costs are based only on the items in Table 10 that are for disposal. The pool water is not included here because it may be disposed via the sanitary sewer and there for only labor costs are shown for this item. To be conservative, soil disposal is included. The demineralizer uses ion exchange resin and is assumed to require disposal in five (5) 55-gal drums.

Because of the "no contamination"policy, there would be a minimal amount of waste generated from decommissioning. There are no areas in which protective clothing, other than gloves, need to be worn.

Note that no labor costs are associated with packing materials needed.

Table 16 - Packing Material Costs Total Pac Number of Type of Container Waste Type volume Containers Container Unit Cost Packaging Costs Reactor Pool 1,0 B-25 90 ft3 Floor Rubble 1,600 18 Metal Box * $1200 $21,600 Reactor Core 90 ft3 1 Custom Box $5000 $5000 12/18/2013 Appendix E Page 12 of 20

Reactor Suspension 20 ft3 I Custom Box $1000 $1000 Tower (Cut up)

Control Rods 10 ft3 I Custom Box $2000 $2000 D20 Tank 10 ft3 1 Custom Box $500 $500 D20 Water 55 gal 2 55 gal Drum $45 $90 Pool Soil 4,200 ft3 47 B-25 90 ft3 $1200 Metal Box * $56,400 Demineralizer 37 ft3 5 55 gal Drum $45 $225 Resin Evap Shed Custom Box $5000 $5000 (Demolished)

Tanks (Cut up) 20 ft3 1 Custom Box $1000 $1000 0ft3 7B-25 90 ft$2 Tank Soil 600 7 Metal Box *$1200 $8,400 Existing 30 gal 12 Fiber Box $0 $0 Wastes Existing 30 gal 3 Drum $0 $0 Wastes Existing 10 gal 3 Drum $0 $0 Wastes Total $101,215

• See for example: http://www.lingo-netalfab.com/containers.htrnl Shipping Costs Once the facility has been decommissioned, there is labor cost associated with the collection of the waste containers, documenting the shipment, and packing the truck. These costs are addressed below. To calculate the number of standard 40 foot semi-truck loads needed, the volume of a 40 foot trailer (http://www.yrc.co-n/shippers/semi-trailer-dimensions.html ) is 3083 ft3. The total volume to be shipped is:

Table 17 - Shipping Volume of Wastes ALL Labs Container Unit Number of Containers Total Volume Waste Type Volume (Decomm + On-hand) ( t 3) 3 Reactor Pool Floor 90 ft 18 1620 Rubble Reactor Core 90 ft3 1 90 Reactor Suspension 20 ft3 1 20 Tower Control Rods 10 ft3 1 10 D 2 0 Tank 10 ft3 1 10 Pool Soil 90 ft3 47 4230 Demineralizer Resin 7.4 ft3 (55 gal) 5 37 12/18/2013 Appendix E Page 13 of 20

Evap Shed 325 ft3 1 325 (Demolished)

Tanks (Cut up) 20 1?3 1 20 Tank Soil 90go 7 630 Existing Wastes 15.6 ft3 12 187 Existing Wastes 4 ft3 (30 gal) 3 12 Existing Wastes 1.2 ft (10 gal 3 4 Existing Wastes 7.4 ft3 (55 gal) 1 8 Total 7,203 Therefore three (3) 40 foot trucks (two full and one partial) will be needed to ship all wastes. The labor costs for preparing, packing, handling containers, and packing the truck are:

Table 18 - Shinning Labor Work Person-Days PThClrcl/

Clerical HP /ConstLaborer Cont gmt Waste QA Civ/Mech/ Project Admin Superv Manager Totals (1) (2) (1) (3) (1) Specialist Engieer ()

Pool Rubble 10 20 5 30 10 20 10 10 115 Core 15 30 10 45 15 30 10 10 165 Tower 5 10 5 15 5 10 5 10 65 Control Rods 10 20 5 15 10 15 5 5 85 D 20 Tank 5 10 5 15 5 10 5 5 60 Pool Soil 20 40 10 60 20 20 20 10 200 Evap Shed 10 10 5 30 10 10 10 10 95 Tanks 10 10 5 30 10 10 5 10 90 Tank Soil 10 20 5 30 10 10 5 10 100 Total e otal 95 170 55 270 95 135 75 Person-Days 80 975 Table 19 - Shipping Labor Cost Clerical / Const Mmaste Q Project Activity HP HP Tech Admin Laborer Superv Mgmt QA Manager Totals

() (2) (( Specialist Engineer (1)

Activity(1 (112)()) I Pool Rubble $8840 $13040 $2085 $11730 $8430 $15500 $6520 $8770 $74,915 Core $13260 $19,560 10 $18765 $12645 $23250 $6520 $8770 $102,780 Tower $4420 $6520 $2085 $6255 $4215 $7750 $3260 $8770 $39,065 Control Rods $8840 $13040 $2085 $6255 $8430 $11625 $3260 $4385 $57,920 D 20 Tank $4420 $6520 $2085 $6255 $4215 $7750 $3260 $4385 $38,890 Pool Soil $17,680 $26080 $4170 $25020 $16860 $15500 $13040 $8770 $127,120 Evap Shed $8840 $6520 $2085 $11730 $8430 $7750 $6520 $8770 $60,645 Tanks $8840 $6520 $2085 $11730 $8430 $7750 $3260 $8770 $57,385 Tank Soil $8840 $13040 $2085 $11730 $8430 $7750 $3260 $8770 $63,905 Total Cost $83,980 $110,840 $18,775 $109,470 $80,085 $104,625 $48,900 $70,160 $622,625 12/18/2013 Appendix E Page 14 of 20

Shipping costs were provided by Ecology Services, Inc. Note that normal rad waste would ship to Energy Solutions in Oak Ridge, TN (705 miles) and to EnviroCare in Utah (1800 miles) for a total of 2500 miles.

Table 20 - Total Shipping Costs Waste Number of Unit Cost Surcharges Overweight Distance Labor Total Waste Numberofd UnmitCost Surcharges Charges Shipped Cost Shipping Type Truckloads ($/mile/load) (S/mile) ($/mile) (miles) M Costs All 3 $3.60 $0.50 $0 2500 $30,750 Truck renta 3 $2500 $7,500 Rental _ _

Labor $622625 $622,625 Total $660,875 Waste Disposal Costs All wastes are assumed to be low level rad waste and not require any special handling or disposal methods. Historically, the cost per pound is more consistent year to year so this DFP will estimate disposal cost by weight 3 rather than volume. The following densities are assumed for each waste type:

Concrete = 150 lb / ft 3

Reactor core, tower, and D2 0 tank, underground tanks - stainless steel = 490 lb / ft Control rods = 2003 lb total Soil = 100 lb /ft Ion exchange resin = 3000 lb 3 Shed material - aluminum = 171 lb/ft For the reactor core, tower and D20 tank, these are not solid stainless steel items so the weight to be disposed has been adjusted for the air space.

Table 21 - Waste Disposal Costs Waste Type Total Weight (lb) Unit Cost Surcharges Total Disposal

($/Ib) ($/Ib) Cost Reactor Pool Floor 240,000 $7.35 $0 $1,764,000 Rubble 24,00_7_5$0$,7_,0 Reactor Core 1,000 $7.35 $0 $7,350 Reactor Sension 4,000 $7.35 $0 $29,400 Suspension Tower Control Rods 200 $7.35 $0 $1,470 D 20 Tank 50 $7.35 $0 $370 Soil 420,000 $5.89 $0 $2,473,800 Demineralizer 3,000 $5.89 $0 $17,670 Resin__ _ _ _ _ _ _ _ _ _________ __________ _______ __

Evap Shed 55,575 $5.89 $0 $327,336 Tanks 9,800 $7.35 $0 $72,030 12/18/2013 Appendix E Page 15 of 20

Tank Soil 60,000 $5.89 $0 $353,400 Existing Wastes - $11,540 All (Table 7)

Total $5,058,366 Section A.3.15 Eauipment and Suoolv Costs The only supplies anticipated will be gloves, smears, vials, scintillation fluid. An allowance of $5000 will be included for these.

No other equipment costs are necessary as Penn State has a sufficient number of survey meters (GM, Nal, alpha, LSC, and neutron) to supply the decommissioning team.

Table 22 - Equipment and Supply Costs Equip / Supplies Quantity Unit Cost Total Survey Supplies $5000 Rigging Equip 1 $3000 $3000 Backhoe 4 weeks $2000/week $8000 Total $16,000 Section A.3.16 Laboratory Costs Any analyses will be performed by independent third party laboratory.

Table 23 - Laboratory Costs Equip / Supplies Quantity Unit Cost Total Sample Analysis - soil 50 $300 $15000 radionuclide Sample Analysis - well 20 $300 $6000 water radionuclide Total $21,000 Section A.3.17 Miscellaneous Costs Present methods of waste disposal are through a waste broker and no special licenses or site permits are necessary. Contractors provide proof of insurance before being awarded contracts. The work associated with decommissioning is not taxable by Pennsylvania.

The Nuclear Regulatory Commission will bill for regulatory oversight efforts to include final status survey reports, confirmatory survey efforts, department lab, or contractor fees and oversight of license termination activities. An estimate of these costs is included in the following table.

12/18/2013 Appendix E Page 16 of 20

Table 24 - Miscellaneous Costs Cost Item Total License fees, insurance, taxes, other $0 NRC oversight $50000 Total $50,000 Section A.3.18 Total Decommissioning Costs The total decommissioning costs are shown in Table 25. This estimate does not take credit for any salvage value that might be realized from the sale of potential assets.

A comparison to other reactor facilities is shown in Tables 26 to 29. As these represent actual decommissioning costs, they are a more reliable estimate of the costs to decommission the PSBR. The highest estimate will be used for this DFP after adjusting for 5% cost increases per year from the time of the original data to today.

This DFP has an estimated total cost of $13,102,364 which is in good agreement with cost-adjusted estimates from other reactors.

The highest cost estimate is the Georgia Institute of Technology decommissioning estimate of

$16,031,304. This value will be used for this DFP.

12/18/2013 Appendix E Page 17 of 20

Table 25 - Total Decommissioning Costs Task/Component Cost Percentage Planning and Preparation (Table 15) $939,935 9%

Decontamination/Dismantling (Table 15) $2,759,315 26%

Restoration (Table 15) $718,220 7%

Final Rad Survey (Table 15) $157,165 2%

Site Stabilization (Table 15) $0 0%

Packing Material Costs (Table 16) $101,215 1%

Shipping Costs (Labor and transport) (Table 20) $660,675 6%

Waste Disposal Costs (Table 21) $5,058,366 48%

Equipment Costs (Table 22) $16,000 0.2%

Laboratory Costs (Table 23) $21,000 0.2%

Miscellaneous Costs (Table 24) $50,000 0.5%

Subtotal $10,481,891 100%

25% Contingency $2,620,473 Total Decommissioning Cost Estimate $13,102,364 12/18/2013 Appendix E Page 18 of 20

Comparison to Other Reactor Facilities The costs for decommissioning of the Georgia Institute of Technology 5 MW reactor were provided by Bill Miller, project manager in 2001.

Table 26 - Georgia Institute of Technology 5 MW reactor Decommissioning Costs Basic Tasks Cost Consultant Support & Characterization $242,100 Decommissioning Contract $5,948,282 Executive Engineer $728,682 ALARA Allowance $39,171 Special Costs* $161,718 Resident Inspector $21,511 Total $7,141,464 Assumed Cost Increase per Year 5%

N = Elapsed Years from 2001 to Present 12 Adjusted Cost to Present Dollars = (2001 Est)*(1.05)N $12,825,043 25% Contingency $3,206,260 Present Day Total Cost $16,031,304 4ýHealth Physicist Overtime, video record, relocate rad storage area.

Estimates for decommissioning of the University of Virginia research reactor were provided by Paul E.

Benneche in 2003.

Table 27 - University of Virginia Reactor Decommissioning Estimates (Included parts of other licenses)

Basic Tasks Cost Outside consultant site characterization and plan preparation. $250,000 External contract for decommissioning the facility (initial $4,500,000

$3.5M, current estimate of $4.5M.)

• Internal costs (This includes about 10 - 15 person years for overseeing UV's program and complying with reactor license requirements.) $1,656,000 (Assuming $80,000

• 1.38 (for benefits)

• 15 years = 1,656,000)

Total $6,406,000 Assumed Cost Increase per Year 5%

N = Elapsed Years from 2003 to Present 10 Adjusted Cost to Present Dollars = (2003 Est)*(1.05))N $10,434,670 25% Contingency $2,608,668 Present Day Total Cost $13,043,338 12/18/2013 Appendix E Page 19 of 20

M

• As described in a personal communication from Paul Benneche, the internal costs to UV were not well documented. However he estimated 10 - 12 person-years for UV to oversee the decommissioning.

AFRRI Report TR89-2 was published in 1990 for the decommissioning cost estimates of a TRIGA reactor. Costs from Table 5, page 8 of the report in 1990 dollars.

Table 28 - AFRRI TRIGA Reactor Basic Tasks Cost Energy use $5,600 Labor costs (all) $1,929,300 Waste disposal costs $589,179 Contingency/other $631,000 Site demolition and restoration $376,800 Total $3,531,879 Assumed Cost Increase per Year 5%

N = Elapsed Years from 1990 to Present 23 Adjusted Cost to Present Dollars = (1990 Est)*(I.05)N $10,848,250 25% Contingency $2,712,062 Present Day Total Cost $13,560,313 Cornell University decommissioned their reactor in 2006 using an outside contractor for the demolition work but performed the preparation and planning work internally and self-managed the project. The contractor performed demolition, waste disposal, and radiation safety functions for a lump-sum amount of $2,700,000. Cornell estimated that had the contractor performed all duties, the cost would have been double at $5,400,000. It should be noted that the reactor was shut down in 1996 and fuel was removed and shipped to DOE in early 2000. The reactor pool tully protruded into the high bay and was completely demolished. An additional approximately 2 feet of soil directly under the reactor was also removed. The project started in March 2006 and lasted for 8 months.

Table 29 - Cornell University Reactor Basic Tasks Cost Contractor lump-sum for all activities $5,400,000 Total $5,400,000 Assumed Cost Increase per Year 5%

N = Elapsed Years from 2006 to Present 7 Adjusted Cost to Present Dollars = (2006 Est)*(1. 0 5 )N $7,598,342 25% Contingency $1,899,585 Present Day Total Cost $9,497,928 12/18/2013 Appendix E Page 20 of 20