ML23136B278

Decontamination and Decommissioning Cost Estimate (Dce) for the National Institute of Standards and Technology

ML23136B278
Person / Time
Site:	07000398
Issue date:	04/25/2023
From:	Jones P US Dept of Commerce, National Institute of Standards & Technology (NIST)
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML23136B277	List: ML23136B278 ML23136B279 ML23136B280 ML23136B281 ML23136B284 ML23136B285 ML23136B286 ML23136B287 ML23136B288 ML23136B289 ML23136B290
References
TAC L32643, EPID L-2022-DFA-0010
Download: ML23136B278 (1)

Text

Decontamination and Decommissioning Cost Estimate (DCE)

for the

National Institute of Standards and Technology

ReNuke #NIST-TR 003

(Perma-Fix #144276-RPT-003)

National Institute of Standards and Technology (NIST) 100 Bureau Drive Gaithersburg, MD

REVISION: Orig inal

Approvals:

Prepared By: __________________________ ________________________ 04/25/2023 Paul Jones, RRPT Date

Reviewed By: __________________________ _________ _______________ 04/25/2023 Jeffrey Knight, RRPT Date

Reviewed By: __________________________ _________ _______________ 04/25/2023 Ryan Larochelle, RRPT Date

Approved By: __________________________ ________________________ 04/25/2023 Ian Howard Date ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

TABLE OF CONTENTS

1.0 EXECUTIVE

SUMMARY

...............................................................................................1

2.0 OBJECTIVES....................................................................................................................3

3.0 PROCESS...........................................................................................................................3

4.0 GENERAL ASSUMPTIONS............................................................................................4 4.1 Radioactive Waste Materials...................................................................................4 4.2 Sealed Sources.........................................................................................................5 4.3 Unsealed Sources.....................................................................................................9 4.4 Labor Estimates.......................................................................................................9 5.0 RELEASE CRITERIA....................................................................................................10

6.0 PROGRESSION OF NIST FACILITIES DCE IMPACT...........................................11 6.1 DCE Additions (since 2009)..................................................................................12 6.2 DCE Subtractions (withdrawn since 2009)............................................................12 6.3 Impacted Laboratory Facilities..............................................................................14 6.4 Impacted Accelerator Facilities.............................................................................16 7.0 DECOMMISSIONING PROCESS AND COST ESTIMATE DETAILS..................16 7.1 Tab 3.5, Detailed Descriptions of Facilities and Equipment.................................17 7.2 Tab 3.6, Planning and Preparation.........................................................................18 7.3 Tab 3.7, Decontamination or Dismantling of Radioactive Facility Components..18 7.4 Tab 3.8, Restoration of Contaminated Areas.........................................................19 7.5 Tab 3.9, Final Radiation Survey............................................................................19 7.6 Tab 3.10, Site Stabilization and Long-Term Surveillance.....................................19 7.7 Tab 3.11, Total Days by Labor Category..............................................................19 7.8 Tab 3.12, Worker Unit Cost Schedule...................................................................19 7.9 Tab 3.13, Total Labor Costs by Major Decommissioning Task............................20 7.10 Tab 3.14, Packaging, Shipping, and Disposal of Radioactive Wastes..................20 7.11 Tab 3.15, Equipment Supply Costs (excluding containers)...................................20 7.12 Tab 3.16, Laboratory Costs....................................................................................20 7.13 Tab 3.17, Miscellaneous Costs..............................................................................20 8.0 PERIODIC UPDATES TO DECOMMISSIONING COST ESTIMATE..................20

LIST OF APPENDICES Appendix A : Facility Laboratory Cost Estimating Worksheets Appendix B : Accelerator Component and Area Cost Estimating Worksheets

April 2023 License No. SNM-362 ii ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

LIST OF ACRONYMS

ALARA As Low As Reasonably Achievable CFR Code of Federal Regulations cm2 square centimeter cpm counts per minute D&D Decontamination and Decommissioning DAW Dry Active Waste DCE Decommissioning Cost Estimate DCGL Derived Concentration Guideline Level DOE U.S. Department of Energy dpm disintegrations per minute DSV Default Screening Value FSS Final Status Survey ft foot ft3 cubic foot g gram HEPA High-Efficiency Particulate Air lb pound Ci microcurie MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual mCi millicurie mSv millisievert N IST National Institute of Standards and Technology NMSS Nuclear Materials Safety and Safeguards NRC U.S. Nuclear Regulatory Commission NUREG Nuclear Regulatory Commission Guidance Document pCi picocurie Perma-Fix Perma-Fix Environmental Services, Inc.

RAM Radioactive Materials ReNuke ReNuke Services, Inc.

TEDE Total Effective Dose Equivalent TRU Transuranic

April 2023 License No. SNM-362 iii ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

LIST OF TABLES

Table 1: NIST Gaithersburg, Maryland Facilities Overall D&D Cost Estimate...........................1 Table 2: NIST D&D Annual Cost Estimate..2 Table 3: NIST Inventory of Sealed or Encapsulated Sources.......................................................5 Table 4: Limiting Radionuclides.................................................................................................11 Table 5: Surface Soils Default Screening Values (DSVs)..........................................................11 Table 6: Newly Added Rooms to DCE.......................................................................................13 Table 7: Rooms Investigated and found to have no Impact to DCE...........................................13 Table 8: Rooms no longer impacting the DCE as accounted for in 2009...................................14 Table 9: Rooms from 2009 DCE continuing to impact the DCE................................................14 Table 10: Forecasted MARSSIM Class Determination Guidelines for Future Demolition......17

April 2023 License No. SNM-362 iv ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

1.0 EXECUTIVE

SUMMARY

The National Institute of Standards and Technology (NIST), headquartered in Gaithersburg, Maryland, contracted Re Nuke Services, Inc. who teamed with Perma-Fix Environmental Services to develop facility decommissioning cost estimates (DCEs) for their non -reactor radiological facilities in Gaithersburg. Such facilities include particle accelerators and laboratories operated under U.S. Nuclear Regulatory Commission ( NRC) License No. SNM-362. Per NISTs request, ReNuke Services team developed detailed bottom -up cost estimates based on review of facility design features, current and historical radionuclide use, present radiological conditions, and physical waste inventory. The ReNuke Services team also evaluated decontamination and decommissioning (D&D) work approaches and task sequences to estimate labor, materials, and supplies.

This report describes the overall process applied to developing the cost estimate, the general assumptions regarding facility D&D, general assumptions regarding radioactive waste processing and disposal, and specific assumptions and calculations with respect to this facility. Included in the report are abbreviated decommissioning plans for laboratories and accelerator facilities.

Cost estimates were developed using conservative middle of the road assumptions regarding likely extent and duration of remediation activities. Remediation was assumed to proceed to levels suitable for unrestricted release of the site. Cost estimates were prepared in accordance with and in the format of Nuclear Regulatory Commission Guidance Document ( NUREG) 1757 Consolidated NMSS Decommissioning Guidance Volume 3. Per NUREG 1757, a contingency of 25% is required to be added to decommissioning estimates to address unidentified and unanticipated conditions.The overall estimate for the Gaithersburg facili ty is:

Table 1. NIST Gaithersburg, M aryland Facilities Overall D&D Cost Estimate Facility Estimate 25% Contingency Subtotal Laboratory Areas $3,444,914 $861,228 $4,306,142 Accelerator Areas $2,631,766 $657,942 $3,289,708 TOTAL : $6,076,680 $1,519,170 $7,595,850

In accordance with 10 Code of Federal Regulation ( CFR) 30.35 and 10 CFR 70.25, this decommissioning cost estimate (and associated DFP) should be evaluated in three years and revised to account for any changes in the costs required for decommissioning activities. For a general comparison to the 2009 DCE, reference section 6.

This report describes the thought process and methodologies used to estimate decommissioning costs. Cost estimate details are included in the attached spreadsheets as appendices.

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

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

April 2023 License No. SNM-362 1 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Decommissioning Cost Escalation The expected increase in the DCE for the next 20 years is presented in Table 2. This forecast assumes an increase of 4.1% per year. The Congressional Budget Office Economic Outlook for 2023 to 2033 shows overall inflation returning next year to historical ave rages between 2 and 3%.

Because a decommissioning estimate is a very narrow slice of the overall economy and has some unique cost elements, we have been conservative in applying a 4.1% factor.

Part of the analysis, of course, is disposal cost. There are only two, and perhaps for NIST, only one realistic outlet for the higher curie waste. The radioactive waste disposal price over the past 30 years has shown a steady increase in rates at or exceeding overall price escalation nationwide.

With limited disposal volumes available and several large nuclear facility decommissioning projects underway or anticipated, we forecast that trend continuing because of supply and demand pressures. Nevertheless, absent some significant unforeseen economic upset, such as we experienced in 2020 and 2021 with COVID-19, the ReNuke team is confident the assigned escalation will be sufficiently conservative.

Table 2. D&D Annual Cost Estimate Escalation

Escalation Factor 4.1%

Annual Annual 25% Annual Year Accelerator Laboratory Contingency Combined Year Since DCE DCE Total DCE DCE

$2,631,766 $3,444,914 $1,519,170 $7,595,850 2023 0

$2,739,668 $3,586,155 $1,581,456 $7,907,280 2024 1

$2,851,995 $3,733,188 $1,646,296 $8,231,478 2025 2

$2,968,927 $3,886,249 $1,713,794 $8,568,969 2026 3

$3,090,653 $4,045,585 $1,784,059 $8,920,297 2027 4

$3,217,369 $4,211,454 $1,857,206 $9,286,029 2028 5

$3,349,281 $4,384,123 $1,933,351 $9,666,756 2029 6

$3,486,602 $4,563,872 $2,012,619 $10,063,093 2030 7

$3,629,553 $4,750,991 $2,095,136 $10,475,680 2031 8

$3,778,364 $4,945,782 $2,181,037 $10,905,183 2032 9

$3,933,277 $5,148,559 $2,270,459 $11,352,295 2033 10

$4,094,542 $5,359,650 $2,363,548 $11,817,739 2034 11

$4,262,418 $5,579,395 $2,460,453 $12,302,267 2035 12

$4,437,177 $5,808,151 $2,561,332 $12,806,660 2036 13

$4,619,101 $6,046,285 $2,666,347 $13,331,733 2037 14

$4,808,484 $6,294,182 $2,775,667 $13,878,334 2038 15

$5,005,632 $6,552,244 $2,889,469 $14,447,345 2039 16

$5,210,863 $6,820,886 $3,007,937 $15,039,686 2040 17

$5,424,509 $7,100,542 $3,131,263 $15,656,314 2041 18

$5,646,913 $7,391,664 $3,259,644 $16,298,222 2042 19

$5,878,437 $7,694,723 $3,393,290 $16,966,450 2043 20

April 2023 License No. SNM-362 2 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

2.0 OBJECTIVES

The principal objectives of this analysis are to:

1) develop reliable, estimated total facility decommissioning costs for NISTs Gaithersburg operations,

2) provide a documented inventory of facility features and characteristics,

3) Provide an estimate of waste volume and cost,

4) Provide an estimate of projected duration and labor to complete and

5) D escribe the steps that will need to be taken to complete decommissioning of the site.

3.0 PROCESS

Upon completion of the HSA and Scoping, all a ffected licensed rooms and systems were accounted for. A schedule of equipment, features, and characteristics was developed to capture the size of each space and key features relevant to developing decommissioning cost estimates.Specifically, facility floor plans were reviewed, and the principal features and equipment of each laboratory were inventoried and categorized.

Each active laboratory was inspected, and radiation and contamination surveys were reviewed. In some laboratories, direct contamination measurements were impossible due to the presence of radioactive materials. NIST management advised us to use existing routine contamination surveys to determine the likely extent of contamination in laboratory areas.With the NIST RSD team, t he radioactive materials databases were reviewed to determine the radionuclides of concern in each area.

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

Impacted Systems (i.e.,v entilation, vacuum, drainage,and process lines) ar e evaluated on a case-by-case basis in accordance with their historical use and known conditions. These systems can have a major impact on the DCE and thus, depending on their radiological impact, require sampling, and waste volume estimations to include additional costs. Some of these additional costs can include building containments, additional ventilation utilized to decommission these systems and thus additional waste generation in the form of PPE and HEPA systems. Possible chemical and water treatment, other hazardous material mitigation and many more added costs to be accounted for in this DCE.

The work scope and activity sequence to support license termination were developed. Cost estimates for projects were based on anticipated t ime and m aterials rates for goods, labor, and services necessary to complete each project. Realistically, the unconditional release of accelerator

April 2023 License No. SNM-362 3 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

facilities would be expensive and dangerous work because many of those areas are activated throughout the volume of structural materials and possibly into the soil. Some of those areas are below the water table, rendering safe handling of radioactive material and control of the spread of radioactivity virtually impossible while those structures are being dismantled and removed. For those reasons, after consultation with NRC personnel, it was decided to pursue restricted release combined with long-term surveillance for those areas.

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

Marketplace rates were obtained for each element of the project including project labor, materials, supplies, sampling and waste packaging, processing, and disposal. NUREG 1757 requires the cost estimate to assume an out-of-state contractor performs the work, therefore nationwide mean salaries for the appropriate labor categories were used based on the latest available data from the U.S. Department of Labor, Bureau of labor Statistics. The unit rates were extended through the estimated quantities to determine total cost for each line item. Costs were summed by each element of the project to determine sub-total by element. Element sub-totals were summed to total project cost.

Radioactive waste estimates were based on the volume of material in the laboratories storage areas and supporting systems. For D&D purposes, contaminated equipment was assumed to be disposed of as radioactive waste rather than being decontaminated and released. This is due to the cost of labor required to decontaminate and survey equipment typically exceeding the cost of disposal. Material that is not likely to be contaminated above release limits is assumed to be surveyed for unconditional release in accordance with Regulatory Guide 1.86. Activated shielding, structural material and equipment, and debris from remediation of contaminated surfaces will be handled and disposed of as radioactive waste.

4.0 GENERAL ASSUMPTIONS

Overall, middle of the road assumptions were made concerning the likely extent and duration of necessary remedial activities. For laboratories, remediation to unrestricted levels (i.e., the facility could be released for any future use without restrictions) was assumed, meaning there are no long-term costs associated with site surveillance and monitoring following decommissioning. Some accelerator facilities will require surveillance and monitoring after license termination as discussed later. It is assumed decommissioning activities will begin within a few months after accelerator operations cease such that short-lived activation products will have decayed to negligible levels.

4.1 Radioactive Waste Materials

In developing estimates of volume of radioactive waste, overall outside dimensions were used for equipment, components, and furnishings. These overall volumes were assumed to be size reduced somewhat on-site, so they were multiplied by an average density of 15 lb/ft3 (dry active waste April 2023 License No. SNM-362 4 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

[DAW]) and 20 lb/ft3 (metal) to deter mine the total mass of waste. For example,a standard office desk would be estimated as 5 ft wide by 2.5 ft deep and 2.5 ft tall with an overall volume of 31.25 ft3 and an estimated mass of 470 lb. A waste fraction was then applied based on the anticipated percentage of equipment expected to be contaminated. Consumables used in the D&D process showed up in waste estimates under DAW.

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

Ventilation and drainage system waste estimates were based on dimensions of components.

Ventilation up to and including the high-efficiency particulate air (HEPA) filters are considered in this report.Drainage systems up to and including the holding tanks are considered in this report.

Waste mass is multiplied by marketplace rates for waste processing and disposal. Packaging and transportation costs were estimated by volume and were added to the total waste disposal figure.

Potential overestimates of component volumes because of using overall dimensions were offset by smaller pieces of equipment that were not individually estimated. Actual volume of waste expected to be removed from the site was considered in the cost estimate. No credit was given for reuse at other facilities or possible resale value. Waste processing activities were assumed to take place at a licensed facility in Tennessee, with a one -way travel dista nce of 525miles.

4.2 Sealed Sources

According to the health physics database, NIST possesses 320 sealed or encapsulated sources that will need to be packaged and shipped for disposal or storage. Table 3 provides a list of the current sources at the facilities associated with this license, along with their activity and location at the site.

Table 3. N IST Inventory of Sealed or Encapsulated Sources Current Storage Current Storage Nuclide Activity Location Nuclide Activity Location (Ci) (Ci)

Co-60 6.62E+02 245/B142 Am-241 1.72E-07 245/H220 Pm-147 1.58E-04 245/H015 Am-241 4.45E-07 245/H220 Kr-85 2.09E-02 245/H015 Pu-238 6.00E-07 245/H220 Sr-90 1.67E-02 245/H015 Am-241 3.47E-06 224/A262 Fe-55 4.44E-05 217/D104 Sr-90 2.12E-02 245/H113 Cf-252 2.77E-03 245/B23 Co-57 7.81E-05 223/B125 Co-60 1.17E-08 245/H113 Co-57 7.81E-05 223/B125 Cs-137 3.24E-03 245/H113 Cs-137 2.70E-02 245/H113 AmBe 9.57E-01 245/B143 Ni-63 9.48E-03 221/B157 RaBe 1.98E-01 245/B143 Cs-137 6.15E-07 245/A018 RaBe 4.91E-01 245/B143 Kr-85 5.92E-03 220/A26 Ni-63 1.24E-02 227/B111 MBYP 3.00E-06 245/H113-4 MBYP 1.00E-06 245/H113 MBYP 3.00E-06 245/H113-4 Co-60 1.50E-09 245/H220 MBYP 3.00E-06 245/H113-4 Sr-90 3.23E-08 245/H220 MBYP 3.00E-06 245/H113-4 Tl-204 4.43E-10 245/H220 C-14 5.56E-08 245/H113-4 April 2023 License No. SNM-362 5 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Current Storage Current Storage Nuclide Activity Location Nuclide Activity Location (Ci) (Ci)

Pm-147 4.22E-11 245/H220 H-3 8.25E-08 245/H113-4 H-3 8.65E-09 245/H220 C-14 1.88E-08 245/H113-4 Pu-238 5.22E-08 245/H220 H-3 2.52E-08 245/H113-4 Cf-252 8.24E-04 245/B23 Ba-133 1.11E-05 245/H221 U-238 2.95E-08 245/H113-4 Ba-133 1.11E-05 245/H120 Fe-55 6.65E-06 221/C11 Ni-63 9.44E-03 217/C118 Cs-137 6.91E+01 245/A10E Ni-63 9.44E-03 217/C118 Pu-238 1.72E-06 245/H220 Co-60 5.49E+03 245/H007-1 Kr-85 1.00E-03 217/C121 Ge-68 1.11E-10 245/H225 Pu-239 1.49E-09 245/H220 Gd-148 1.66E-08 245/H220 Co-60 4.62E+02 245/B140 Gd-148 2.07E-07 245/H220 Np-237 2.60E-05 245/H113-4 Cm-243 2.92E-08 245/H220 Co-60 1.57E+02 245/B036 Pu-238 2.35E-07 245/H220 Cf-252 1.91E-04 245/B23 Pu-238 1.83E-07 245/H220 Ra-226 4.82E-05 245/H223 Pu-238 9.91E-08 245/H220 Am-241 1.99E-07 245/H220 Cf-252 5.03E-05 245/H113-2 Am-241 1.53E-06 245/H220 Po-210 1.66E-10 227/B311 Pu-238 6.81E-06 245/H220 Pu-238 5.48E-07 245/H220 LEU (U-235) 1.63E-05 245/H113-2 Ni-63 1.41E-02 245/H114 Cf-252 5.82E-05 245/B23 Th-230 1.41E-08 245/H220 Co-60 1.19E+02 245/B140 Cs-137 3.61E-08 221/A58 Cf-252 1.99E-05 245/B23 Ni-63 9.33E-03 217/C118 SpFuel 1.05E-01 245/H113-2 Ra-226 6.91E-06 220/A26 SpFuel 1.05E-01 245/H113-2 Ni-63 9.33E-03 227/A126 Sr-90 3.12E-03 245/H113 Kr-85 4.90E-03 423/X100 Cf-252 1.47E-05 245/B143 Ni-63 1.40E-02 227/B119 Kr-85 2.99E-04 217/C121 Cf-252 8.95E-06 245/H113-2 Kr-85 1.16E-04 221/B255 DU 3.03E-08 227/B151 Ra-226 4.90E-05 245/B127 Cf-252 6.68E-06 245/H113-2 Ra-226 9.81E-05 245/H223 Cd-109 1.56E-07 245/C019 Kr-85 1.07E-04 221/B255 Co-57 2.93E-09 245/C019 Sr-90 3.10E-03 245/H113 Co-57 3.77E-09 245/C019 Kr-85 4.69E-04 217/C121 Mn-54 9.89E-09 245/C019 Cf-252 6.27E-06 245/B143 Mn-54 1.06E-08 245/C019 Ra-226 9.79E-05 245/H223 Cf-252 7.26E-08 245/B143 Co-60 1.18E-08 245/A018 Cf-252 7.26E-08 245/B143 Sr-90 2.82E-04 245/H113 C-14 1.35E-08 245/H113-4 Cf-252 1.47E-06 245/B143 Sr-90 1.04E-08 245/H113-4 Cf-252 1.47E-06 245/B23 Am-241 1.39E-08 245/H113-4 Cf-252 7.89E-07 245/B23 I-129 5.00E-08 245/B127 Cf-252 8.73E-08 245/B23 Ni-63 1.38E-02 227/B111 Cs-137 1.20E-03 245/H113-2 Ni-63 2.78E-02 217/D119 Cs-137 1.43E-03 245/H113-2 Pm-147 4.93E-02 231/A267 Cs-137 1.27E-03 245/H113-2 Ni-63 1.39E-02 217/C118 AmBe 9.15E-02 245/A018 Co-60 1.15E-03 245/H113-2

April 2023 License No. SNM-362 6 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Current Storage Current Storage Nuclide Activity Location Nuclide Activity Location (Ci) (Ci)

Cs-137 8.39E-04 245/H113-4 Ni-63 2.77E-02 217/C104 RaBe 9.84E-01 245/B143 Cf-252 4.88E-06 245/H113-2 Co-60 1.20E-02 245/B015 Am-241 3.93E-05 245/C019 Co-60 1.35E-01 245/B021 Cd-109 8.58E-08 245/C019 Co-60 6.18E-05 245/H113-2 Cd-109 8.52E-08 245/C019 Cs-137 9.03E+01 245/B021 Co-60 8.90E-06 245/H113-3 Cs-137 9.62E+00 245/B015 Mn-54 4.56E-09 245/H113-3 Ra-226 3.72E-02 245/B132 Mn-54 4.19E-09 245/H113-3 Ra-226 1.99E-02 245/B132 Eu-152 5.40E-07 245/H215 Ra-226 1.51E-02 245/B132 Cs-137 3.15E+02 245/B014 Ra-226 4.93E-04 245/H113-2 Cf-252 7.38E-06 245/B143 Ra-226 1.00E-03 245/H113-2 Ni-63 9.19E-03 217/C118 Ra-226 1.87E-03 245/H113-2 Cf-252 2.93E-07 245/H113-2 Ra-226 4.72E-03 245/H113-2 Cf-252 2.81E-07 245/H113-2 Ra-226 9.57E-03 245/H113-2 Cf-252 2.81E-07 245/H113-2 Ra-226 1.38E-02 245/H113-2 Cf-252 2.78E-07 245/H113-2 Ra-226 2.28E-02 245/H113-2 Cf-252 2.65E-07 245/H113-2 Ra-226 4.61E-02 245/H113-2 Am-241 4.90E-03 245/H223 Ra-226 9.18E-02 245/H113-2 Pu-239 4.00E-09 245/H220 Ra-226 2.23E-01 245/H113-2 Pu-238 7.83E-09 245/H220 AmBe 5.88E+00 245/B143 Ni-63 9.16E-03 220/A32 RaBe 9.23E-01 245/B143 Am-241 2.06E-08 245/H113-4 RaDBe 7.20E-04 245/H113-2 Fe-55 3.32E-09 245/H220 Cs-137 4.69E+02 245/B036 Am-241 8.47E-09 245/H113-4 RaDBe 5.87E-03 245/H113-2 Cl-36 1.03E-08 245/H113-4 Po-210 7.01E-03 226/A310 Cf-252 4.43E-06 245/H113-2 I-125 2.68E-07 245/H115-1 Kr-85 8.74E-04 221/B355 Po-210 8.04E-05 218/F005 Kr-85 4.37E-03 221/B355 Cs-137 9.74E-04 245/H113-4 Kr-85 4.37E-03 221/B355 Co-60 3.30E+04 245/H018 Ni-63 1.37E-02 227/B111 Na-22 6.20E-06 220/A218 Am-241 1.57E-04 221/B355 Co-60 8.71E-05 245/C019 Ba-133 1.56E-05 245/H113-2 Cf-252 1.87E-04 245/H113-2 Ba-133 1.56E-04 245/H113-2 Am-241 1.78E-03 245/C019 Ba-133 1.56E-05 245/H113-2 Am-241 2.06E-03 245/C019 Co-60 4.61E-04 245/H113-2 Cs-137 1.93E-04 245/C019 Co-60 1.30E-04 245/H113-2 Po-210 2.59E-05 223/A262 Co-60 6.65E-04 245/H113-2 Th-228 1.12E-04 245/C019 Co-57 2.39E-10 245/H113-2 Am-241 9.29E-08 245/H113-4 Co-57 2.39E-10 245/H113-2 Pu-239 1.13E-01 245/H113-2 Co-57 2.39E-10 245/H113-2 Eu-152 4.22E-07 245/H113-4 Fe-55 1.82E-03 245/H113-4 Cs-137 4.64E-07 245/H113-4 Cf-252 2.60E-04 245/B143 HEU (U-235) 6.49E-06 245/H113-2 Cf-252 2.92E-07 245/H113-2 HEU (U-235) 6.49E-06 245/H113-2 Cf-252 2.88E-04 245/B143 HEU (U-235) 6.49E-06 245/H113-2 Ni-63 9.10E-03 217/C104

April 2023 License No. SNM-362 7 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Current Storage Current Storage Nuclide Activity Location Nuclide Activity Location (Ci) (Ci)

HEU (U-235) 6.49E-06 245/H113-2 Kr-85 3.96E-03 227/B311 HEU (U-235) 6.49E-06 245/H113-2 Kr-85 3.86E-03 227/B311 HEU (U-235) 6.49E-06 245/H113-2 Ni-63 9.04E-03 220/A32 HEU (U-235) 6.49E-06 245/H113-2 Ni-63 9.04E-03 220/A32 HEU (U-235) 6.49E-06 245/H113-2 Sr-90 6.68E-09 245/H220 HEU (U-235) 6.49E-06 245/H113-2 Cs-137 7.06E-06 245/H113-4 HEU (U-235) 6.49E-06 245/H113-2 Ni-63 1.35E-02 217/D122 Tc-99 1.66E-07 245/H113-4 Na-22 1.65E-06 245/H225 H-3 2.42E-01 423/X100 Kr-85 3.58E-03 226/A326 Pu-239 1.13E-01 245/H113-2 Cf-252 9.54E-08 245/B23 Pu-239 1.13E-01 245/H113-2 Cs-137 6.23E-04 245/H113-2 Pu-239 1.13E-01 245/H113-2 Ni-63 2.68E-02 217/D119 Pu-239 1.13E-01 245/H113-2 Ni-63 8.83E-03 318/D100 Pu-239 1.13E-01 245/H113-2 Co-57 3.45E-12 245/C019 Pu-239 1.13E-01 245/H113-2 Kr-85 6.71E-04 224/A262 Pu-239 1.13E-01 245/H113-2 Np-237 6.35E-05 245/C019 Pu-239 1.13E-01 245/H113-2 Cs-137 5.70E-05 245/C019 Pu-239 1.13E-01 245/H113-2 Cs-137 1.21E-05 245/C019 Po-210 7.90E-07 227/A358 Co-60 2.53E-06 245/C019 Cs-137 2.62E-05 245/H215 Co-60 7.09E-07 245/C019 Am-241 4.03E-08 245/H113-4 Ba-133 4.71E-05 245/C019 Ba-133 1.38E-05 245/H215 Ba-133 2.85E-06 245/C019 Cs-137 1.29E-07 245/B127 Am-241 4.57E-05 245/C019 Eu-155 5.02E-07 221/A58 Ba-133 4.44E-06 245/C019 H-3 8.33E+00 245/H113-3 Am-241 4.49E-04 245/C019 H-3 8.33E+00 245/H113-3 Ba-133 7.48E-06 245/C019 H-3 8.33E+00 245/H113-3 Co-60 2.22E+03 245/B140 Co-60 2.03E-04 245/C019 Cf-252 2.20E-08 245/B143 Co-60 8.85E-05 245/C019 Cf-252 4.14E-08 245/B143 Co-60 4.37E-05 245/C019 Cf-252 1.64E-08 245/B143 Co-60 4.61E-05 245/C019 Cf-252 1.64E-08 245/B143 Eu-152 3.77E-07 245/H113-4 Pm-147 7.00E-11 245/H113-4 Cs-137 4.40E-07 245/H113-4 Pb-210 6.05E-09 245/H113-4 Am-241 1.99E-04 245/C019 Tc-99 9.76E-09 245/H113-4 Am-241 4.96E-04 245/C019 Sr-90 6.71E-09 245/H113-4 Co-60 1.68E-05 245/C019 Cl-36 4.41E-10 245/H113-4 Co-60 4.80E-05 245/C019 C-14 1.15E-04 245/H113-4 Cs-137 4.06E-05 245/C019 H-3 3.51E-02 220/A32 Cs-137 8.34E-05 245/C019 Ni-63 8.77E-03 217/C104 H-3 1.56E+00 245/A018 Ni-63 1.32E-02 220/A32 Cf-252 7.41E-06 245/H113-2 Cs-137 7.32E-09 245/H220 Cs-137 6.94E-05 245/C019 Sr-90 2.00E-02 245/H113 Co-60 1.10E-05 245/C019 Sr-90 4.00E-02 245/H113 Ba-133 1.81E-05 245/C019 Sr-90 1.00E-02 245/H113 Co-57 4.89E-08 245/C019 Sr-90 3.00E-02 245/H113

April 2023 License No. SNM-362 8 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Current Storage Current Storage Nuclide Activity Location Nuclide Activity Location (Ci) (Ci)

Eu-152 3.05E-03 245/H113-2 Bi-207 6.37E-07 245/B023 Th-232 1.41E-05 245/C019 Ni-63 1.26E-02 227/A126 U-232 1.17E-05 245/C019 Kr-85 3.22E-04 224/A262 U-232 1.70E-05 245/C019 Kr-85 2.05E-04 224/A262 Cs-137 1.02E-05 245/C019 Sr-90 8.02E-08 245/H220 Ba-133 6.89E-06 245/C019 Pu-239 2.35E-09 245/H220 Ra-226 8.08E-06 245/C019 Pu-239 2.66E-09 245/H220 Ra-226 8.08E-06 245/C019 Pu-239 2.66E-09 245/H220 Ra-226 8.08E-06 245/C019 Am-241 4.83E-03 245/H115 Ba-133 1.26E-05 245/H215 Pu-239 7.16E-08 245/H113-4

These NIST sources above 1 microcurie (Ci) are assumed to go to a processor for encapsulation and disposal at the Waste Control Specialists Facility in Andrews, TX. (See Section 6. 3.1)

NOTE: Building 235 Facilities and Sources are not included in this report because they are covered in the TR-5 licens e DCE.

Any sources onsite belonging to other licensees at decommissioning are assumed to be returned to them. The sources less than 1 microcurie will be included with other waste and shipped to a waste processor for processing and/or disposal.

4.3 Unsealed Sources

The health physics database was used to estimate the amount of radioactive material in the form on unsealed sources on-site. The total activity of those sources is approximately 946 millicuries (mCi) but can fluctuate at any given time based on continued operations. This material can be mixed with other low-level waste for disposal. Only sources belonging to NIST are included in this estimate; it is assumed all other sources will be returned to the custom er.

4.4 Labor Estimates

All labor estimates are expressed in workdays. Workdays are actual days on the job. Project schedules were based on five -day workweeks excluding weekends, holidays, etc., consisting of eight hours per day.

Labor estimates for p lanning and preparation include time for document preparation, decommissioning plan submittal to regulatory agencies, work plan development, equipment procurement, staff training, and mobilization. Pre-planning labor estimates assume straightforward internal and external document, plan, and procedure reviews and approvals. The duration of field activities for decontaminating and dismantling the facilities were estimated based on the task sequence and project schedule.

Crew sizes and number of workers were limited to those that could be efficiently utilized in the field. The size of the work force will vary. At its peak, it is assumed to consist of one Project

April 2023 License No. SNM-362 9 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Manager directing the activities of two crews. Each crew will consist of one Supervisor, two Health Physics Technicians, four Skilled Craftsmen, and four Unskilled Laborers. Additionally, one Shipper and one A dministrative A ssistant will report directly to the Project Manager.

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

Similarly, estimates for the level of effort required for the final radiation survey were based on previous experience with facilities of comparable complexity. As noted above, the assumed endpoint is license termination and unrestricted release of the facility; consequently, long-term stabilization and monitoring is not required,and no costs are incurred for this element.

Annual labor rates were estimated for the P roject Manager, a P roject Supervisor, a H ealth Physicist, a S hipper, H ealth P hysics T echnicians, Radiation W orkers,and administrative support.

Labor rates include base salary and fringe benefits (e.g., vacation, health insurance, etc.). A rate of 75% was applied for overhead costs. The base annual labor rate plus the overhead expenses was divided by the number of workdays per year (taken as 260) to determine a daily cost for each category of employee.

Living expenses were taken from allowable government per diem rates - $299 per day (average) for Montgomery County, Maryland. Project management, supervision, and technical staff are paid the daily living allowance since they are assumed to be from outside the local area. Radiation workers (laborers) and administrative support staff were assumed to be local hires and are not paid a living allowance. The daily living expenses were multiplied by seven days per week then divided by five workdays per week to corr ectly incorporate living expenses into the daily wage rate.

5.0 RELEASE CRITERIA

The ultimate release criteria is specified in 10 CFR 20.1402: A site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a TEDE to an average member of the critical group that does not exceed 25 mrem (0.25 mSv) per year, including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA).

Determination of the levels which are ALARA must take into account consideration of any detriments, such as deaths from transportation accidents, expected to potentially result from decontamination and waste disposal.

For the NIST facilities in Gaithersburg, it is assumed the buildings will be reused for some other, as yet unknown purpose.The occupant will have unrestricted access. Pathways applicable to such an occupant include external dose, inhalation, soil ingestion, and drinking water from radioactivity that migrates to groundwater.

Tools, materials, and removable equipment will be surveyed for unconditional release as applicable using the guidance contained in Regulatory Guide 1.86 for the radionuclides of concern.

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

Areas adjacent to one another having similar radiological characteristics will be grouped together as applicable into survey units. Contamination release limits will be derived from a number of April 2023 License No. SNM-362 10 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

sources. For planning purposes, the radionuclide knownto be present or shown in the database as having been used that is associated with the lowest release limit will be used according to the following guidance:

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

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

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

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

In this DCE, the values shown in Table 4 are limiting, assuming no more than 10% of the total activity is removable.

Table 4. Limiting Radionuclides Radionuclide(s) Default Screening Value Basis (dpm/100 cm2)

Beta-gamma Emitters Except H-3 and C-14 7,100 Co-60 Transuranics 23 Am-241 Uranium 88 U-238 H-3 1.2E+07 10% of Screening Value C-14 3.7E+06 Screening Value

For activated building components, the major dose pathway is external exposure from gamma emitting radionuclides. DSVs for contaminated surface soil listed in NUREG 1757, Appendix B are used. See Table 5.

Table 5. Surface Soils Default Screening Values ( DSVs)

Radionuclide DSV (pCi/g)

Co-60 3.8 Eu-152 8.7

6.0 PROGRESSION OF NIST FACILITIES DCE IMPACT.

In total the DCE Cost has increased $2,495,153 since the 2009 Philotechnics DCE. A number of rooms and systems have been added and/or removed over the past 14 years and the following sections attempt to provide some context for the changes to the f inal DCE Value.

The breakdown of historical DCE Impact on this DCE and its evolution to this 2023 DCE is important for tracking changes and understanding the impact to the final DCE value. In total 323 rooms were evaluated for this DCE. The Previous DCE Contained 155 Rooms, adding 168 new rooms to be evaluated for impact. Of those 168new rooms, 108( provided in Table 6) were found April 2023 License No. SNM-362 11 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

to have an impact on the DCE for various reasons noted in section 6.1. T he remaining 60 found in (Table 7) have no impact on the DCE.

After evaluation of the 2009 DCE, 80 rooms (Table 8) from the 2009 DCE were reclassified to not impacted for various reasons noted in section 6.2. The remaining 75 impacted rooms can be found in (Table 9). After all evaluations were completed, the ReNuke Services team, in collaboration with the NIST RSD concluded that 183 rooms are still radiologically impacted for this DCE ( sum of Table 6and Table 9).

6.1 DCE Additions (since 2009)

- The 2023 DCE included rooms for various reasons required by MARSSIM. Over the evolution of the NIST site for the past 14 years, (108) rooms have been impacted, requiring them to be added to this DCE.

- Several rooms were added due to the new H Wing addition of building 245.

- Several rooms were identified as impacted by NIST RSD, which were missed in the previous DCE.

6.2 DCE Subtractions (withdrawn since 2009)

The 2009 DCE included rooms for various reasons required by MARSSIM. Over the evolution of the NIST site over the past 14 years, (80) rooms have been positively impacted to allow removal from this DCE.

- Several rooms from the 2009 DCE were included due to their proximity to an impacted room.

By default, rooms connected to impacted rooms are required to be evaluated per MARSSIM for their potential impact due to migration of contaminants.

- Approximately (40) Rooms from the 2009 DCE were extensively surveyed, decontaminated and/or decommissioned all together by NIST. (Table 5)

- Several of the rooms in the 2009 DCE were unnecessarily included and after further evaluation and concurrence with NIST RSD, Removal was appropriate.

April 2023 License No. SNM-362 12 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Table 6. Newly Added Rooms to DCE Building Rooms 217 C105; D105; D115 (aka D117); F101; F106; F109; F111; F112; F118; F122 220 A26; A32; A264; A218; A05; A251; A321; A324; A340; B118; B122; B329; 221 A12; B331/B333; B355; B367; B43; B49; C11 223 A306; A234; B125; B133; B139; B167; B321 226 B159; B325; 227 A334; B151; A230; B225; B343-1; B345; B353; 245 A004; A006;; A013; A014; A018; B002; B003; B127; B20; B21; B26; B53; C003; C005; C007; C009; C011; C013; C015; C019; G104; G105; H007; H007-1; H015; H018; H104; H113; H113-1; H113-2; H113-3; H113-4; H115; H115-1; H119; H119-2; H119-3; H120; H204; H208;H210; H214;H215; H217; H218-1; H218-2; H220; H221; H223; H225; H227; H229; H233; H237-1; H237-3; H237-5; H237-6; H247-1; H247-2; "Pent.H-wing; H031-1;H108-1; H108-2;H219

Table 7. New Rooms Investigated and found to have no Impact to DCE Building Rooms 101 E114; B15; B08; B40; 205 X113; X104; X115; X117; X125 208 L01; G01 217 C104; C103(C101 inside) 218 F005; D012; D010 221 B331; B323; B255; B157; B110; A54; A41; A39; A158 223 B341; B251; B131; A358; A262; A126 224 A346; A167 226 B367; B337; A310; B357 227 A118; B357; A330; A358; B339; B217; B137; B119 245 H237-4; H247; H237-2; H237; A10W; B043; B109; B111; B113; B115; B24C317; H114

April 2023 License No. SNM-362 13 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Table 8. Rooms no longer impacting the DCE as accounted for in 2009 Building Rooms 202 X233; X124 217 D120; D119; C118; D104 218 C002 221 A47; B149; A146; A142/A144/A146; 222 Various 223 B221 224 B225; B363; A363 226 A326; B225 227 B153; B123; B311; B111 245 B013; B030; B033; B02; B03; B06; B08; B110; B11; B119; B123; B147; B149; B150; C103; C104; C105; C106; C107; C108; C109; C11; C112; C115; C116; C13; C133; C135; A141; A145; B001; B011; B15; B151; B153; B158 Hallway; B24; B30; B40; B41; B42; B43; B52 (Hallway); Restroom; C06 ; C10; C137; C138; C15; C17; C201; C203; C211; C25; C400 301 185A/C 303 X112 423 X100; Modular 245 - A01; A02; A04; A09; A011; A017; A019 & A020 are part of the Surf Facility Accelerator DCE.

Table 9. Rooms from 2009 DCE continuing to impact the DCE Building Rooms 202 X158; X154 217 C115; D113; D101; D108; C121 220 A122; A266; A226 221 B21; A58 223 B313; B150/B151; A132; A150; A232 224 A264/A262; B154; 227 A126; B147; B326; B141; B143; B243; B333; A316 245 A005; A010; A012; A10E; B009; B014; B015*(formerly B11); B017; B019; B021; B023; B024 bsmt; B024 sub-bsmt; B029; B034; B035; B036; B041; B044; B045;; B125; B131; B132; B133; B140; B141; B142; B143; B145; B146; B152; B155; B15 6; B157; B200; B23; B25; B37; B44; B46; B47; B48; B49; B50; B51; F101

6.3 Impacted Laboratory Facilities

All impacted rooms have been evaluated utilizing Walkdown sheets to document, among other things, room dimensions, systems/components, classification, percent expected to be waste and labor hour estimations. These Summations can be found in A ppendix A for the Laboratory Facilities and Appendix B for the Accelerator Facilities. Those totals ultimately feed into the final DCE.

April 2023 License No. SNM-362 14 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

The additional/revised rooms resulted in an increase of approximately $1,427,667 to the laboratory section of the DCE since 2009 (based on Appendix A tab 3.18 comparison). Most of this being contributed to the addition of H Wing, additional waste volumes and labor rate increases. This number may continue to increase as Laboratories experience further use and potential contamination spread.

6.3.1 Physical Sources

The Sources referenced in section 4 are assumed to go to a processor for encapsulation and disposal at the Waste Control Specialists Facility in Andrews, TX. The sources will be shipped as two Type B shipments at an estimated cost of $640,000 ($320,000 each.). This number was previously accounted for as $500,000.00 under miscellaneous in the 2009 DCE but has been included in the Waste Disposal Cost section (Appendix A tab 3.14) of the Laboratory Facilities and incre ased by approximately $90,000.00.

6.3.2 Process Systems

Under the SNM license, no major process piping, centrifuge, hot cells, reactors, or other highly contaminated systems were encountered.

B Wing and H Wing ventilation and drainage systems are accounted for in total under their respective HEPA bank room locations on the HSA Table. (H Wing penthouse accounts for all vertical and horizontal wastewater and ventilation systems for H wing, including HEPA banks and c ollection tanks.) B Wing information can be found under Room B -200. The addition of H Wing v entilation provided a significant impact to the DCE cost as it will generate approximately 5,000ft 3 of radioactive waste to process and ship.

6.3.3 Additional Laboratories

The total rooms increased by 33 since the 2009 DCE. These rooms didnt have a significant impact on the DCE as the total square footage was very small when compared to the laboratories that were removed since the 2009 DCE.

In total the volume of waste expected to be generated in D&D was reduced in the laboratories DCE by 1,131 ft 3.

The total labor increased in this DCE by $479,044 (based on Appendix A tab 3.13 comparison).

6.3.4 Waste Disposal.

With the increased cost of equipment, materials, waste processing and disposal, the cost of equipment and waste processing has increased by approximately $422,481 since the 2009 DCE This is based on Appendix A tab 3.14 comparisonand excludes the $500,000 sealed source cost added to tab 3.14 (previously accounted for in miscellaneous tab in 2009 DCE).

April 2023 License No. SNM-362 15 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

6.3.5 Equipment/Supply, Laboratory, and Miscellaneous.

The total of Equipment/Supply, Laboratory and Miscellaneous costs increased by a total of $282,007 since the 2009 DCE. This is based on Appendix A tabs 3.15, 3.16, and 3.17 comparison (excluding the $500,000 sealed source cost moved to tab 3.14 in this DCE).

6.4 Impacted Accelerator Facilities

Similar to the Laboratory Facilities, the accelerator Facilities receive the same thorough evaluation documented on a walkdown sheet and can be found in Appendix B.

While the accelerator facilities themselves have had very little change, the final value in this DCE for the accelerator facilities increased by approximately $1,067,503 since 2009 (based on Appendix B tab 3.18 comparison).

6.4.1 Waste Packaging, Volume and Disposal Distance Changes

The 2009 DCE concluded significantly less to package and ship the waste from the Accelerator areas. Waste Container costs have risen significantly since the 2009 DCE. It appears the disposal location from the 2009 DCE was either onsite, or not accounted for as this is where approximately $240,145increase is found in our DCE.

6.4.2 Labor, Materials, Equipment and Sampling Cost Increase.

A larger number of samples are required during decommissioning of activated facilities to ensure successful adherence to the limitations of the FSS. Additionally adjacent areas will become impacted by the physical decommissioning of the activated walls/components and are also included as their own impacted room with their own walkdown sheet. With the increased cost of labor, equipment/material, waste processing and disposal, the cost to decommission has increased since the 2009 DCE.

7.0 DECOMMISSIONING PROCESS AND COST ESTIMATE DETAILS

The work crew consists of:

• Project Manager (1)

• Project Supervisors (2)

• Shipper (1)

• Health Physics Technicians (4)

• Skilled Laborers (2)

• Unskilled Laborers (2)

• Administrative Assistant (1)

The time required to complete the project is approximate ly 190 days on-site: 130 days for the laboratories and 60 for the accelerators. It is assumed that reciprocity fees will be incurred over 2 years for both aspects of the work. Therefore, reciprocity fees of $ 2,700( each) were assumed.

April 2023 License No. SNM-362 16 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Following is a description of the assumptions made and data entered into individual worksheets to calculate the potential cost of decommissioning. Two sets of spreadsheets were developed for this cost estimate. One set of spreadsheets pertains to laboratory areas and the other to the accelerator areas. The spreadsheets pertaining to the laboratories are provided in Appendix A and the spreadsheets for the accelerator areas are provided in Appendix B.

7.1 Tab 3.5, Detailed Descriptions of Facilities and Equipment

For clarity, this worksheet was split up into multiple parts, each labeled by building number.

Accelerator facilities and associated equipment, housed in Building 245, are attached.

In addition to the accelerators, Building 245 also houses most of the active radiological laboratories.

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

Each individual laboratory that was inventoried for this DCE is listed in Tab 3.5. The inventory lists, as a minimum, room dimensions, amount of furnishings and equipment used and stored in the room, the radionuclide(s) currently or previously used, and the expected MARSSIM class based on current use and survey data.

Initial assignment of MARSSIM class for final status surveys is presented in Table 10.

Table 10. Forecasted MARSSIM Class Determination Guidelines for Future Demolition MARSSIM Room Configuration/ Historical Use/Findings CLASS Operational Intent CLASS 1

• Current use of unsealed material

• Some remediation may be expected

• Current or previous use of

• Some radwaste may be expected -fraction neutron sources inversely proportional to release limit

• Areas adjacent to accelerators

• Accelerator facilities will have a significant

• Areas with uncertain history amount of radwaste

• Some rooms are not listed in the database as ever having radioactive materials -so if it was unknownwhat wa s used, the worst was assumed CLASS 2

• Accelerator support areas

• Verification that materials are not activated separated by shielding or contaminated

• Previous use of unsealed

• Removable contamination surveys transuranic (TRU), U, Ra, or Th previously performed cannot detect alpha sources and clearance surveys emitters below DCGL were done (many have been

• No remediation is expected gutted and remodeled)

• No radwaste (except sources) is expected

CLASS 3

• Current use of sealed beta,

• No history of leaking sources gamma,or alpha sources

• Removable contamination surveys

• Previous use of unsealed beta-previouslyperformed should detect most gamma sources, but clearance beta-gamma emitters surveys were done

• No remediation is expected

• No radwaste (except sources) is expected

April 2023 License No. SNM-362 17 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

MARSSIM Room Configuration/ Historical Use/Findings CLASS Operational Intent

• Restrooms and hallways upstream of personnel contamination monitors

7.2 Tab 3.6, Planning and Preparation

This tab includes such tasks as filing for reciprocity to conduct the decommissioning, preparation of work plans including the Decommissioning Plan, site-specific training for workers, and mobilization to the site. The Project Manager develops work plans and submits reciprocity applications. The Laborers and A dministrative Assistant are assumed to be local hires and no time is required for mobilization; the other workers need a full day to mobilize to the site. The Project Manager also must secure a contract for a crane and crew.

This tab also includes facility characterization. Characterization is performed to determine the radionuclides present in each area and the extent of contamination. Health Physics Technicians will enter each area where radioactive materials have been used, collect samples, scan surfaces, segregate potentially radioactive material from non-radioactive, and identify any mixed waste.

In most cases, the health physics database maintained by NIST identifies current and historical use of radionuclides in each room. The time estimated to characterize the room is based on that information. For instance, if a room contained transuranics, uranium, radium, beta-gamma emitters, and I-129, the room will be scanned three times. A beta-gamma probe (floor monitor for large floor areas and BP19 or equivalent for other surfaces ) will be used to measure contamination from most beta-gamma emitters. An alpha -sensitive probe will be used to measure contamination from alpha emitters. A very slow scan rate of approximately an inch or so per second is required.

Finally, a probe sensitive to gamma and very low energy beta emitters (such as the GP-13 or equivalent) will be used to measure contamination from I-129, Co-57, and similar difficult-to-detect radionuclides. Smears will be collected and counted for gross alpha and gross beta and analyzed on a liquid scintillation counter. Samples will be sent to an independent laboratory for radionuclide identification. These assumptions will also apply to Tabs 3.7 and 3.9.

7.3 Tab 3.7, Decontamination or Dismantling of Radioactive Facility Components

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

The order in which various buildings will be decommissioned is unknown; however, in Building245, laboratory areas will be decontaminated and decommissioned before accelerator facilities for a number of reasons: accelerators contain short-lived byproduct material and delaying work allows for some decay; most accelerator spaces are below laboratory spaces and it makes sense to start at upper floors and work down; laboratories will be fully decontaminated and

April 2023 License No. SNM-362 18 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

remediated while some accelerator spaces will be locked shut and subject to long-term surveillance.

7.4 Tab 3.8, Restoration of Contaminated Areas

Based on existing survey data, surface scans performed during the site visit, and interviews with knowledgeable individuals, very few laboratory areas will require any remediation.

Accelerator facilities (described separately) will require extensive remediation of floor, walls, equipment, and structural materials. The Time of Flight Facility is above grade and remediation efforts will result in partial demolition of the building. Other activated accelerator spaces are below grade, and many are below the water table. Many of the most highly activated areas are load-bearing or exterior walls. Complete remediation is therefore impossible without demolishing all of Building 245 - a costly endeavor. For reasons of cost reduction and worker safety, those areas will be remediated to the extent practicable and then re -evaluated. It is assumed the sub-basements containing those accelerators will be secured and long-term monitoring instituted, until activation products decay to levels acceptable for unconditional release.

7.5 Tab 3.9, Final Radiation Survey

The final radiation survey is performed by H ealth Physics Technicians, with guidance from the Project Manager and project S upervisors and administrative support. In cases where no decontamination or remediation was required, the characterization survey may be used as the final status survey (FSS) for a particular area.

7.6 Tab 3.10, Site Stabilization and Long-Term S urveillance

Because the goal is unconditional release of the laboratory facilities, there are no long-term surveillance requirements associated with them.

The long-term surveillance for the accelerator facilities is based on four quarterly surveys per year for 20 years.

7.7 Tab 3.11, Total Days by Labor Category

This is the sum of person-days listed in Tabs 3.6 through 3.10.

7.8 Tab 3.12, Worker Unit Cost Schedule

Worker mean nationwide salaries are taken from the Bureau of Labor Statistics and are adjusted to account for the cost of fringe benefits. A 75% multiplier is also added to account for profit to the contractor performing the decommissioning work. Workers who are not local hires are paid the average government per diem rate of $299daily for the Gaithersburg area.

April 2023 License No. SNM-362 19 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

7.9 Tab 3.13, Total Labor Costs by Major Decommissioning Task

This tab shows the cost of each major task from Tabs 3.6 through 3.10, multiplied by the daily labor cost for each worker shown in Tab 3.12.

7.10 Tab 3.14, Packaging, Shipping, and Disposal of Radioactive Wastes

This tab reflects the most costly component of the facility decommissioning. It is assumed waste is shipped to a licensed waste processor in Oak Ridge, Tennessee, a distance of approximately 525 miles.

7.11 Tab 3.15, Equipment Supply Costs (excluding containers)

This tab shows the approximate costs of personnel protective clothing and respirators, rental of specialty equipment including health physics survey instruments, and consumables required to complete the decommissioning.

It is assumed a crane and crew will be needed for removal of accelerators and large equipment.

Other equipment includes health physics survey instrumentation, concrete cutters, jack hammers, containment structures, vacuum cleaners, negative ventilation systems, nibblers, and shears.

7.12 Tab 3.16, Laboratory Costs

This tab shows the total of all samples to be collected and sent out for analysis as shown in the various subsections of Tab 3.5. It is assumed all samples will be analyzed for gamma emitters, Sr -

90, H-3, C-14, and alpha emitters such as uranium, plutonium,and americium isotopes.

Samples collected from accelerator facilities will be analyzed for gamma emitters.

7.13 Tab 3.17, Miscellaneous Costs

This tab shows other costs not specifically captured elsewhere. It is assumed the decommissioning contractor will perform the work under reciprocity agreement with the NRC at a cost of $2,700.

Liability insurance and state/local taxes are included at the rate of 6% and 10%, respectively, of the on-site labor costs.

8.0 PERIODIC UPDATES TO DECOMMISSIONING COST ESTIMATE

This cost estimate was prepared using the tables and instructions provided in NUREG 1757. Tables were converted to Excel spreadsheets and modified as necessary to enhance their applicability to the NIST site and to facilitate updating costs in the future.

As areas are decommissioned from radiological use or new areas are added, that information may be changed in the spreadsheet.

April 2023 License No. SNM-362 20 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Labor and per diem rates are likely to change in the future. That information may be updated in Tab 3.12 to reflect future labor costs.

Transportation costs including mileage, fuel surcharges, overweight/oversize charges, costs of shipping containers, disposal, site access, and license costs may be updated by inserting applicable values into Tab 3.14.

April 2023 License No. SNM-362 21 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Appendix A Facility Laboratory Cost Estimating Worksheets

April 2023 License No. SNM-362 Appendix A-1 ReNuke Services Inc. Decontamination and Decommissioning Cost Estimate (DCE)

NIST-TR 003 Rev. 0

Appendix B Accelerator Component and Area Cost Estimating Worksheet s

April 2023 License No. SNM-362 Appendix B-1 NIST-TR-23-003 NIST DCE Report Final Audit Report 2023-04-25

Created: 2023-04-25

By: Ryan Larochelle (ryan@renuke.com)

Status: Signed

Transaction ID: CBJCHBCAABAARjFOsWlOvTRgDtARTrlmuWNOn0v4B05x

"NIST-TR-23-003 NIST DCE Report" History

Document created by Ryan Larochelle (ryan@renuke.com) 2023-04 6:53:23 PM GMT

Document emailed to paul.a.jones@perma-fix.com for signature 2023-04 6:54:17 PM GMT

Email viewed by paul.a.jones@perma-fix.com 2023-04 7:30:20 PM GMT

Signer paul.a.jones@perma-fix.com entered name at signing as Paul Jones 2023-04 7:30:58 PM GMT

Document e-signed by Paul Jones (paul.a.jones@perma-fix.com)

Signature Date: 2023-04 7:31:00 PM GMT - Time Source: server

Document emailed to Jeff Knight (jknight@perma-fix.com) for signature 2023-04 7:31:02 PM GMT

Email viewed by Jeff Knight (jknight@perma-fix.com) 2023-04 7:34:22 PM GMT

Document e-signed by Jeff Knight (jknight@perma-fix.com)

Signature Date: 2023-04 7:36:15 PM GMT - Time Source: server

Document emailed to Ryan Larochelle (ryan@renuke.com) for signature 2023-04 7:36:16 PM GMT

Email viewed by Ryan Larochelle (ryan@renuke.com) 2023-04 7:38:33 PM GMT

Document e-signed by Ryan Larochelle (ryan@renuke.com)

Signature Date: 2023-04 7:38:41 PM GMT - Time Source: server Document emailed to Ian Howard (ian@renuke.com) for signature 2023-04 7:38:42 PM GMT

Email viewed by Ian Howard (ian@renuke.com) 2023-04 7:39:05 PM GMT

Document e-signed by Ian Howard (ian@renuke.com)

Signature Date: 2023-04 7:39:28 PM GMT - Time Source: server

Agreement completed.

2023-04 7:39:28 PM GMT