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 1Unified Decommissioning Funding PlanForThe Pennsylvania State University Radiation Facilities AtUniversity Park, Hershey Medical Center,And Related CampusesDecember 18, 2013Prepared byJeffrey LeaveyRadiation Safety Officer, University ParkSteve KingRadiation Safety Officer, Hershey Medical Center12/18/2013 Executive SummaryPage I of 6 MIntroduction and Executive SummaryThis decommissioning funding plan (DFP) was prepared using NUREG-1757 Volume 3 Rev 1 (2012) asa guidance document.

The section designations correspond to the numbering system used in AppendixA.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 MedicalCenter, and the Breazeale reactor.

The Harrisburg campus, while an authorized place of use under the UP PA statelicense, has only one laboratory that has only ever utilized P-32 once in the month of November 2013. TheAltoona campus has only one laboratory using nanocurie amounts of A1-26 and they have been inactive for thepast few years.There are five licenses that are held by Penn State University:

License Number Issuing Agency Brief Description and Campus Location DFP AppendixPA-0100 PA DEP Broad scope byproduct materials, UP & others APA-0127 PA DEP Broad scope byproduct materials, PSH\MC campus BPA-0127A PA DEP Self-shielded irradiator

license, PSHMC campus CSNM-95 NRC Special Nuclear Materials, UP campus DR-2 NRC Research and Test Reactor license, UP campus EBecause 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 updateto10 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 theUniversity Park Environmental Health and Safety offices and at the Health Physics offices at theHershey Medical Center.12/18/2013 Executive SummaryPage 2 of 6 The decommissioning cost estimates for each license, individually and combined, are as follows:Penn State University Unified Decommissioning Cost EstimateLicense 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 $455,623SNM-95 Special Nuclear Materials D $356,776R-2 Reactor E $16,031,304 Penn State University TOTAL $23,986,584 Basic Assumptions Common to All DFPsSeveral assumptions must be made to estimate the cost of decommissioning the facilities under eachlicense.

The assumptions common to all licenses are listed below while assumption specific to a licenseare 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 CFR20.1402.

This release limit requires that "residual radioactivity that is distinguishable frombackground radiation results in a TEDE to an average member of the critical group that does not12/18/2013 Executive SummaryPage 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 ofshifts in the focus of research utilizing radioactive material over time, it is much more probablethat only one license would be terminated at any one time. Normally Penn State staff would beavailable for decommissioning work in these instances;

however, this DFP assumes anindependent 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, theDFP 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 forradioactive material work are surveyed and inspected by Radiation Safety staff. Location ownersare 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 ofmaintaining 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, asappropriate, soon after discovery.

Penn State can support this assumption by review of manyyears 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 reducethe actual costs of decommissioning.

6. No remodeling costs are included.

Decommissioning costs do not include removal or disposal of non-radioactive structures ormaterials beyond that necessary to terminate the radioactive material license.

Costs are notincluded 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 normalscope of tasks currently performed on a regular basis in accordance with established writtenprocedures.

If these tasks are performed by Penn State employees or by an outside group, thetasks are expected to be commensurate with normal activities.

12/18/2013 Executive SummaryPage 4 of 6

9. Vendors will ship Type B materials.

Large activity sources that require Type B shipping containers will be shipped by outsidevendors in accordance with the disposal methods currently used. No costs are included forwriting and documenting a quality assurance plan. The outside vendor(s),

specifically licensed toperform 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 periodof 24 months ..." are decommissioned in accordance with 10 CFR 30.36.(d).(3).

Generally, it isinfrequent that a building that had radioactive materials labs is decommissioned because labs donot terminate their use often. When a building is decommissioned its hoods, ducts, and sinks arechecked 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 ofindividual 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, butdecommissioning can only be accomplished if a low-level radioactive waste disposal facility isavailable.

12. DOE will accept the return of their materials.

Certain sources and materials must be returned to the Department of Energy for disposal.

If theDOE refuses to receive this material then long-term storage costs may be significant; these costsare 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 andwaiting disposal at the start of decommissioning.

Added to this amount will be thedecommissioning waste so that the total amount of rad waste will be slightly larger than justfrom decommissioning only.Reasons for the Differences in Cost Estimates With This DFPThe 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, wastehandling, and record keeping activities.

2. Prior UP and PSHMC DFPs assumed that only a small fraction of labs and/or facilities wouldneed decontamination based on Penn State's policy of"no contamination".

The current UP andPSHMC DFPs assumes that all labs and facilities will require decontamination efforts and12/18/2013 Executive SummaryPPage 5 of 6 generate the associated wastes.3. New and conservative costs for irradiator disposal at UP were taken from 2013 estimates ofirradiator disposal at PSHMC.4. In prior DFPs labor rates were based on Penn State staff salaries covering labor costs. With thechange to a third party contactor, higher labor rates based on current market conditions wereused 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 DFPAppendix 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 continueto use that cost for this DFP.12/18/2013 Executive SummaryPage 6 of 6 I-- MAPPENDIX E -- University Park R-2 NRC Reactor LicenseSection A.3.4 Facility Description License Numbers and TypesThe 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 researchreactor 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 DetailsLte Isotope Form Allowed Quantity* I -I* UDescription of How Licensed Materials Are UsedThe Penn State Breazeale Nuclear Reactor (PSBNR) is a I MW water cooled natural convection reactorusing TRIGA fuel that has been in operation since 1955. It is the center piece of the Radiation Scienceand 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 atest 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 workingconditions are maintained.

Normal operating procedures require that radioisotope laboratories minimizecontamination.

Typically, surveys show no removable contamination above background (approximately

< 50 dpm/100cm

2) on surfaces and equipment using liquid scintillation counting (LSC) and Geigermeters. Penn State maintains a "no contamination" policy and any finding above background ispromptly 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 poolstructure, miscellaneous activated support components, and radioactive waste consisting of paper,12/18/2013 Appendix EPage 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 allfuel. All fuel disposal costs, other than shipping, are assumed to be covered by the DOE.Description of Facilities Table 2 -PSBR Buildings and RoomsNumber ofCampus Building Use RoomsUP Breazeale Reactor IUP Breazeale Reactor IUP Breazeale Reactor IUP Breazeale Reactor 2UP Breazeale Reactor IUP Breazeale Reactor 2TOTAL Rooms 8Within 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 tostore 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 similarfacilities will form the basis for estimating Penn State's future costs. Cost and labor estimates wereobtained from the Georgia Institute of Technology for the decommissioning of their 5 MW reactor in2001, from the University of Virginia for the decommissioning of their 2 MW reactor in 2002, thedecommissioning plan estimates of the AFRRI TRIGA reactor found in AFRRI Report TR89-2 (similarto the Oregon State University TRIGA reactor),

and the Cornell University Ward Nuclear CenterTRIGA 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, then12/18/2013 Appendix EPage 2 of 20 surveyed and released as non-radioactive waste. Liquid wastes with half-lives greater than 120 days aredisposed via sanitary sewer by Radiation Protection staff to ensure that legal release limits are notexceeded.

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 andcomingled with waste from other laboratories in one waste handling facility.

As stated in the generalassumptions, 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 wasteshipment data, the volumes,

isotopes, and costs are shown here:Table 3 -Waste HistoryNumber of Total TotalYear Containers Isotopes Activity Volume Weight Shipment(mCi) CostH-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-455 Fiber 20.5 fi3Drums 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 $6,403drum 51, Co-58,Mn-54, Zn-65, activated metalsH-3, C-14,Co-60,Cs-137, Fe-55,8 Cardboard U(Nat), Zn- 125 ft32012 Boxes 65, Eu-152, 9.4 (15.6 ft3 per 980 lb(DAW) Eu- 154, Eu- bx( 155, Ra-226, box)U-238, Sr-90I Drum Co-60, Cs- 1.7 mCi 7.4 ft3 143 lb(55 gal) 137, Eu-152,12/18/2013 Appendix EPage 3 of 20 drum Eu- 154,activated metals3 Fiber 12.3 ft3Drums 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 ft32013 Cardboard U(Nat), Zn- 12.2 mCi (15.6 ft3 per 1,140 lbBoxes 65, Co-60, box)(DAW) Cs-1373 Fiber 12.3 ft3Drums 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 $8,500S(10 gal) carcasses) drum) IThe cost per waste type for the past three years is:Table 4 -Waste Cost HistoryYear Waste Type Cost per Cubic Foot Cost per Pound2011 Dry Active Waste $40.22 $5.40Ecology Services, Inc. (DAW)Activated Metals $181.33 $6.60LSC Vials $92.93 $6.502012 Dry Active Waste $35.12 $4.48Ecology Services, Inc. (DAW)Activated Metals $133.47 $7.00LSC Vials $116.10 $7.252013 Dry Active Waste $34.22 $5.61Ecology Services, Inc. (DAW)LSC Vials $81.46 $6.77Animal Carcasses

$306.11 $19.00For easier analysis, the unit costs table above has been rearranged as follows:Table 5 -Cost per Cubic FootYear DAW Metals LSC Animals2011 $40.22 $181.33 $92.932012 $35.12 $133.47 $116.102013 $34.22 $81.46 $306.1112/18/2013 Appendix EPage 4 of 20 Table 6 -Cost per PoundYear DAW Metals LSC Animals2011 $5.40 $6.60 $6.502012 $4.48 $7.00 $7.002013 $5.61 $6.77 $19.00The waste on-hand will be assumed to be the largest amount of all types of waste for the past threeyears. 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 AnimalsPounds 1,140 206 293 58Cost per Pound $5.89 $7.35 $7.35 $19.95Total $6,715 $1,514 $2,154 $1,157Grand Total $11,540Volume of Contaminated Subsurface Materials The PSBR is a pool type reactor using 71,000 gal of ultra-pure water for neutron moderation andcooling.

Throughout the operating history of the facility, pool water leaks have occurred to varyingdegrees and at varying times. Most recently, in early October of 2007 a pool water leak was detectedwith the release of an estimated 12,300 gal (based on integrating the reported variable leak ratescontained in the NRC inspection report, accession number ML073480163, over the 43 days of theevent). At the time of the incident and for 3 months following (into December 2007), well water wassampled at 5 locations near the PSBR facility.

The data showed a maximum well water concentration ofslightly 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 isassumed 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 Level of Contamination:

< 100 dpmn/100 cm2Table 8 -Reactor Components Component I Number of Components Dimensions of Component Reactor Pool Structure 1 17 W x 45 L x 24 D feet12/18/2013 Appendix EPage 5 of 20 Reactor Core Structure 1 3 x 3 x 5 feetReactor Suspension Tower 1 2 x 2 x 24 feetControl Rods 10 0.2 x 0.2 x 5 feetReactor Bridge 1 17 W x 4 D x 8 H feetD20 Tank 1 2.5 Dia x 1.5 HD20 Water 1 55 gal (210 L)Pool Water 1 71000 galCirculating Pumps 2 2 x 6 x 2 feetWater Purification 1 3 x 3 x 10 feetHeat Exchanger 1 3 x 3 x 12 feetModerator/Coolant Piping 1 600 ft2Evaporator Shed 1 10x20x 8 feetUnderground Tanks/Piping 2 1000 galHot Cell 2 10 x 8 x15 feetBulk Equipment:

Waste Containers 3 1.5 x 1.5x2.5 feetHand Items (Misc tools, etc.) 100Section 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 normaloperations continue up until the date the contractor comes on site. The contractor will need to firstfamiliarize 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 ofradioactive materials under the licenses.

These include receipts, stock vial inventory, locations of use orstorage, waste inventory, personnel, and sealed sources.

The records are kept electronically in a databaseand updated as the record is generated (i.e. inventory is updated as stocks are received; lab survey data isupdated soon after the survey is completed, etc.) Radiological surveys are performed on at least aweekly basis and paper records kept for at least three years; therefore, a review of these documents willdemonstrate 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 EPage 6 of 20 Survey reports typically record the radionuclides recently used and may not reflect all historical uses in aparticular 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, orship-out.

E) Scale floor plans of buildings are maintained by Facilities Management but survey maps used by theRPO 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 pastsurveys 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 thescope of work, the radiological conditions of the site, and provide a plan for action. Upon approval bythe 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 ofVirginia, the AFRRI TRIGA (AFRRI Report TR89-2),

and the Cornell reactor facility as these werefacilities similar to the PSBR. Note that not all of these past facilities had data that is directlycomparable to the detailed breakdowns suggested in NUREG-1757; most offered only lump-sum costdata 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 WasteHealth HP Clerical Construction Wast Civil/Mech/QA ProjectActivity Physicist Technician

/ Admin Laborer Supervisor Mgmt Engineer Manager((3) Specialist (1) (2) (1) (1) (1)Preparedocumentation 60 20 30 0 0 60 30 30for regulatory agenciesSubmittal ofdecommissioning 5 0 10 0 0 5 5 5plan12/18/2013 Appendix EPage 7 of 20 Development of 90 20 120 0 90 90 90 120work plansProcurement ofequipment and 10 0 5 0 15 10 10 10suppliesStaff training 5 10 0 15 5 5 5 5Characterization of radiological 40 90 30 15 0 40 0 45conditions OtherOtion 5 10 5 15 5 5 5 5(mobilization)

Total 215 150 200 45 115 215 145 220Person-Days 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, D20 tank, and possibly others. All reactorconfinement structure, equipment, and materials will be surveyed and designated as contaminated oruncontaminated.

Uncontaminated equipment and materials will be released for unrestricted use ordisposed as clean waste. Contaminated equipment will be decontaminated and handled as otheruncontaminated 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 surfaceswill be decontaminated by hydro-lazing the waterproof coating.

Reactor components and activated poolhardware will be removed for disposal as low level radioactive waste. Piping embedded in the concretepool 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 thecontaminated areas. Contaminated material will be removed and packaged.

The structural integrity ofthe 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 bepresent) 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 andthen all D20 will be held for transfer back to the DOE.12/18/2013 Appendix EPage 8 of 20 Water purification

/ demineralizer

-The resin will be collected and disposed of. The tank and relatedpiping will be wiped down.Hot Cells -The two hot cells and manipulators are not in use, currently not contaminated, and do nothold unsealed materials; the cells are currently uged to store sealed discrete sources.

The cells are notincluded in this version of the DFP.Type of Space: Reactor, bay, rooms, and components.

Average Size: Not Applicable Level of Contamination:

< 100 dpm/100 cm2Table 10 -Decontamination or Dismantling of Components Work Person-Days Clerical WasteConstruction Wast Civil/Mech/QA ProjectDecon HP HP Tech / Laborer Supervisor Engineer ManagerComponent Method (1) (2) Admin (3) uei Specialist Ege Mng______l)__________

(I) (I ) (1) (1)Reactor Pool Hydro-laze, 30 120 40 360 120 120 120 120Structure DisposalReactor CoreStructure Disposal 40 180 80 120 40 240 30 40ReactorSuspension Tower Disposal 10 40 40 120 10 60 15 10Control Rods Disposal 10 20 10 10 10 120 15 10Reactor Bridge Wipe 15 20 40 60 20 15 15 20ReatorBrige DownD20 Tank Disposal 10 20 10 15 10 120 15 10Drum,D20 Water hold for 5 15 10 15 5 15 5 5DOEPool Water Disposal 10 15 40 15 10 120 5 10Circulating Pumps Wipe 10 30 40 120 10 40 20 10Cirulain Pups DownWater Purification Wipe 10 15 20 45 10 40 10 10DownHeatExchanger Wipe 10 15 20 30 10 20 10 10Hea Exhaner DownModerator/Coolant Wipe 20 20 20 90 20 20 10 20Piping DownEvaporator Shed Disposal 10 20 5 30 10 15 5 10Underground 10Tanks/Piping Disposal 10 30 5 60 10 20 10Waste Containers Wipe 5 10 5 5 5 10 5 5DownHand Items (Misc Wipe 15 30 60 10 15 40 15 15tools, etc.) Down 5 3 6 1 I 4 1 112/18/2013 Appendix EPage 9 of 20 Potrso-as 220 600 445 1105 315 1015 305 315Assume 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 andunderground tanks that will require removal, an estimated soil volume of 4,200 ft3 (20 x 40 x 5 fi) underthe reactor pool footprint and 600 ft3 (approx.

four times the volume of 2 tanks) will be used for thisDFP. It is also assumed that should soil removal be required, access to the soil will be from inside thepool 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 ManagerTech Admin Supervisor Specialist Engineer (1)A t(2) () (3) (() (1)Removal ofPool 30 60 10 120 30 30 20 30FloorSoil Excavation 15 40 5 120 40 40 40 20Backfill 5 5 5 90 30 5 30 20Excavate Tanks 10 20 5 30 10 30 10 10Soil Excavation 5 10 5 30 10 20 10 10Backfill 5 10 5 30 5 5 10 10TotalP onay 70 145 35 420 125 130 120 100Person-Days Section A.3.9 Final Radiation Survey (Work Days)Table 12 -Final Radiation Survey Work Person-Days HP HP Clerical

/ Construction Waste Mgmt Civil/Mech/QA Project ManagerActivity (P Tech Admin Laborer Supervisor Specialist Engineer (1)A tvt(2) () (3) () ()FinalCharacterization 20 40 10 5 5 20 5 20SurveyFinal Report 15 20 15 5 5 15 5 15TotalP onay 35 60 25 10 10 35 10 35Person-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 EPage 10 of 20 Section A.3.11Total Work Davs Bv Labor Cate2orvSetoI..1Toa okDy By LaorCae ITable 13 -Total Work Days By Labor Person-Days HP eHP Clerical Laborer Construction Waste Mgmt Civil/Mech/QA Project ManagerAciiy() Tech Admin () Supervisor Specialist Engineer()

() (2)) (I) (3) (1) (1) (1))Planningand 215 150 200 45 115 215 145 220PrepDecontamination 220 600 445 1105 315 1015 305 315Restoration of 70 145 35 420 125 130 120 100Contam Areas IFinalRad 35 60 25 10 10 35 10 35SurveySite Stabilization 0 0 0 0 0 0 0 0TotalP onay 540 955 705 1580 565 1395 580 670Person-D ays II IIIIIISection A.3.12 Worker Unit Cost ScheduleSalary and labor rate data for Pennsylvania May 2012 was obtained from:http://www.bls.gov/oes/current/oes pa.htm# 19-0000Life, Physical Social Sci -nuclear technician

= $78,250Construction Supervisor

-construction managers

= $109,540Office admin support -info and records clerks = $39,600Construction laborers

= $35,470Waste Mgmt -nuclear engineer

= $98,280Civil/Mech/QA

-civil engineer

= $78,190Project Mgmt -general and ops managers

= $115,050Salary data for CHPs for 2012 was obtained from:http://www.hps.org/documents/2012 chp salary survey.pdf Median CHP salary for the Northeast

= $116,25012/18/2013 Appendix EPage I!I of 20 Travel andPer-Diem

$175 $175 $175 $175 $175 $175 $175 $175per DayTotal Costper Person- $884 $652 $417 $391 $843 $775 $652 $877Day ** Based on 260 work days per yearSection A.3.13 Total Labor Costs by Major Decommissioning TaskTable 15 -Total Labor CostsClerical

/ Const Waste CiMech/ ProjectHP HP Tech Admin (3)Labo Superv Engineer Manager TotalsActivity (1) (2) (1) (1) Scl (g) (1)Planning and Prep $190,060

$97,800 $83,400 $17,595 $96,945 $166,655

$94,540 $192,940

$939,935Decontamination

$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 $718,220Contamn AreasFinal Rad Survey $30,940 $39,120 $10,425 $3,910 $8,430 $27,125 $6,520 $30,695 $157,165Site Stabilization 0 0 0 0 0 0 0 0 0Total 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 WastesNote: Labor costs for waste processing is included in this section and not in the above analysis.

Packaging Material CostsPacking costs are based only on the items in Table 10 that are for disposal.

The pool water is notincluded here because it may be disposed via the sanitary sewer and there for only labor costs are shownfor this item. To be conservative, soil disposal is included.

The demineralizer uses ion exchange resinand 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 fromdecommissioning.

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 CostsTotalNumber of Type of Container PacWaste Type volume Containers Container Unit Cost Packaging CostsReactor Pool 1,0 B-25 90 ft3Floor Rubble 1,600 18 Metal Box * $1200 $21,600Reactor Core 90 ft31 Custom Box $5000 $500012/18/2013 Appendix EPage 12 of 20 ReactorSuspension 20 ft3 I Custom Box $1000 $1000Tower (Cut up)Control Rods 10 ft3 I Custom Box $2000 $2000D20 Tank 10 ft3 1 Custom Box $500 $500D20 Water 55 gal 2 55 gal Drum $45 $90Pool Soil 4,200 ft3 47 B-25 90 ft3 $1200Metal Box * $56,400Demineralizer 37 ft3 5 55 gal Drum $45 $225ResinEvap Shed Custom Box $5000 $5000(Demolished)

Tanks (Cut up) 20 ft3 1 Custom Box $1000 $10000ft3 7B-25 90 ft$2Tank Soil 600 7 Metal Box *$1200 $8,400Existing 30 gal 12 Fiber Box $0 $0WastesExisting 30 gal 3 Drum $0 $0WastesExisting 10 gal 3 Drum $0 $0WastesTotal $101,215*See for example:

http://www.lingo-netalfab.com/containers.htrnl Shipping CostsOnce the facility has been decommissioned, there is labor cost associated with the collection of thewaste containers, documenting the shipment, and packing the truck. These costs are addressed below. Tocalculate 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 shippedis:Table 17 -Shipping Volume of Wastes ALL LabsContainer Unit Number of Containers Total VolumeWaste Type Volume (Decomm + On-hand)

( t3)Reactor Pool Floor 90 ft3 18 1620RubbleReactor Core 90 ft3 1 90Reactor Suspension 20 ft3 1 20TowerControl Rods 10 ft3 1 10D20 Tank 10 ft3 1 10Pool Soil 90 ft3 47 4230Demineralizer Resin 7.4 ft3(55 gal) 5 3712/18/2013 Appendix EPage 13 of 20 Evap Shed 325 ft3 1 325(Demolished)

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

packing, handling containers, and packing the truck are:Table 18 -Shinning Labor Work Person-Days HP PTh Clerical

/Const Waste Civ/Mech/

Clrcl/ Laborer Cont gmt QA ProjectAdmin Superv Manager Totals(1) (2) (1) (3) (1) Specialist Engieer ()Pool Rubble 10 20 5 30 10 20 10 10 115Core 15 30 10 45 15 30 10 10 165Tower 5 10 5 15 5 10 5 10 65Control Rods 10 20 5 15 10 15 5 5 85D20 Tank 5 10 5 15 5 10 5 5 60Pool Soil 20 40 10 60 20 20 20 10 200Evap Shed 10 10 5 30 10 10 10 10 95Tanks 10 10 5 30 10 10 5 10 90Tank Soil 10 20 5 30 10 10 5 10 100Totale otal 95 170 55 270 95 135 75 80 975Person-Days Table 19 -Shipping Labor CostClerical

/ Const Mmaste Q ProjectActivity HP HP Tech Admin Laborer Superv Mgmt QA Manager Totals() (2) (( Specialist Engineer (1)Activity(1 (112)())

IPool Rubble $8840 $13040 $2085 $11730 $8430 $15500 $6520 $8770 $74,915Core $13260 $19,560 10 $18765 $12645 $23250 $6520 $8770 $102,780Tower $4420 $6520 $2085 $6255 $4215 $7750 $3260 $8770 $39,065Control Rods $8840 $13040 $2085 $6255 $8430 $11625 $3260 $4385 $57,920D20 Tank $4420 $6520 $2085 $6255 $4215 $7750 $3260 $4385 $38,890Pool Soil $17,680 $26080 $4170 $25020 $16860 $15500 $13040 $8770 $127,120Evap Shed $8840 $6520 $2085 $11730 $8430 $7750 $6520 $8770 $60,645Tanks $8840 $6520 $2085 $11730 $8430 $7750 $3260 $8770 $57,385Tank Soil $8840 $13040 $2085 $11730 $8430 $7750 $3260 $8770 $63,905Total Cost $83,980 $110,840

$18,775 $109,470

$80,085 $104,625

$48,900 $70,160 $622,62512/18/2013 Appendix EPage 14 of 20 Shipping costs were provided by Ecology Services, Inc. Note that normal rad waste would ship toEnergy Solutions in Oak Ridge, TN (705 miles) and to EnviroCare in Utah (1800 miles) for a total of2500 miles.Table 20 -Total Shipping CostsWaste Number of Unit Cost Surcharges Overweight Distance Labor TotalWaste Numberofd UnmitCost Surcharges Charges Shipped Cost ShippingType Truckloads

($/mile/load)

(S/mile)

($/mile)

(miles) M CostsAll 3 $3.60 $0.50 $0 2500 $30,750Truckrenta 3 $2500 $7,500R ental _ _Labor $622625 $622,625Total $660,875Waste Disposal CostsAll wastes are assumed to be low level rad waste and not require any special handling or disposalmethods.

Historically, the cost per pound is more consistent year to year so this DFP will estimatedisposal cost by weight rather than volume. The following densities are assumed for each waste type:Concrete

= 150 lb / ft3Reactor core, tower, and D20 tank, underground tanks -stainless steel = 490 lb / ft3Control rods = 200 lb totalSoil = 100 lb /ft3Ion exchange resin = 3000 lbShed material

-aluminum

= 171 lb/ft3For the reactor core, tower and D20 tank, these are not solid stainless steel items so the weight to bedisposed has been adjusted for the air space.Table 21 -Waste Disposal CostsWaste Type Total Weight (lb) Unit Cost Surcharges Total Disposal($/Ib) ($/Ib) CostReactor 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 $7,350ReactorSension 4,000 $7.35 $0 $29,400Suspension TowerControl Rods 200 $7.35 $0 $1,470D20 Tank 50 $7.35 $0 $370Soil 420,000 $5.89 $0 $2,473,800 Demineralizer 3,000 $5.89 $0 $17,670Resin__ _ _ _ _ _ _ _ _ _________

__________

_______ __Evap Shed 55,575 $5.89 $0 $327,336Tanks 9,800 $7.35 $0 $72,03012/18/2013 Appendix EPage 15 of 20 Tank Soil 60,000 $5.89 $0 $353,400Existing Wastes -$11,540All (Table 7)Total $5,058,366 Section A.3.15 Eauipment and Suoolv CostsThe only supplies anticipated will be gloves, smears, vials, scintillation fluid. An allowance of $5000will 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 CostsEquip / Supplies Quantity Unit Cost TotalSurvey Supplies

$5000Rigging Equip 1 $3000 $3000Backhoe 4 weeks $2000/week

$8000Total $16,000Section A.3.16 Laboratory CostsAny analyses will be performed by independent third party laboratory.

Table 23 -Laboratory CostsEquip / Supplies Quantity Unit Cost TotalSample Analysis

-soil 50 $300 $15000radionuclide Sample Analysis

-well 20 $300 $6000water radionuclide Total $21,000Section A.3.17 Miscellaneous CostsPresent methods of waste disposal are through a waste broker and no special licenses or site permits arenecessary.

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 statussurvey reports, confirmatory survey efforts, department lab, or contractor fees and oversight of licensetermination activities.

An estimate of these costs is included in the following table.12/18/2013 Appendix EPage 16 of 20 Table 24 -Miscellaneous CostsCost Item TotalLicense fees, insurance, taxes, other $0NRC oversight

$50000Total $50,000Section A.3.18 Total Decommissioning CostsThe total decommissioning costs are shown in Table 25. This estimate does not take credit for anysalvage 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 actualdecommissioning costs, they are a more reliable estimate of the costs to decommission the PSBR. Thehighest estimate will be used for this DFP after adjusting for 5% cost increases per year from the time ofthe 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 EPage 17 of 20 Table 25 -Total Decommissioning CostsTask/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 EPage 18 of 20 Comparison to Other Reactor Facilities The costs for decommissioning of the Georgia Institute of Technology 5 MW reactor were provided byBill Miller, project manager in 2001.Table 26 -Georgia Institute of Technology 5 MW reactorDecommissioning CostsBasic Tasks CostConsultant Support & Characterization

$242,100Decommissioning Contract

$5,948,282 Executive Engineer

$728,682ALARA Allowance

$39,171Special Costs* $161,718Resident Inspector

$21,511Total $7,141,464 Assumed Cost Increase per Year 5%N = Elapsed Years from 2001 to Present 12Adjusted Cost to Present Dollars = (2001 Est)*(1.05)N

$12,825,043 25% Contingency

$3,206,260 Present Day Total Cost $16,031,304

ýHealth Physicist

Overtime, video record, relocate rad storage area.4Estimates 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 CostOutside consultant site characterization and plan preparation.

$250,000External contract for decommissioning the facility (initial

$4,500,000

$3.5M, current estimate of $4.5M.)* Internal costs (This includes about 10 -15 person yearsfor overseeing UV's program and complying with reactorlicense 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 10Adjusted 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 EPage 19 of 20 M* As described in a personal communication from Paul Benneche, the internal costs toUV were not well documented.

However he estimated 10 -12 person-years for UV tooversee the decommissioning.

AFRRI Report TR89-2 was published in 1990 for the decommissioning cost estimates of a TRIGAreactor.

Costs from Table 5, page 8 of the report in 1990 dollars.Table 28 -AFRRI TRIGA ReactorBasic Tasks CostEnergy use $5,600Labor costs (all) $1,929,300 Waste disposal costs $589,179Contingency/other

$631,000Site demolition and restoration

$376,800Total $3,531,879 Assumed Cost Increase per Year 5%N = Elapsed Years from 1990 to Present 23Adjusted 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.

Thecontractor performed demolition, waste disposal, and radiation safety functions for a lump-sum amountof $2,700,000.

Cornell estimated that had the contractor performed all duties, the cost would have beendouble at $5,400,000.

It should be noted that the reactor was shut down in 1996 and fuel was removedand shipped to DOE in early 2000. The reactor pool tully protruded into the high bay and wascompletely demolished.

An additional approximately 2 feet of soil directly under the reactor was alsoremoved.

The project started in March 2006 and lasted for 8 months.Table 29 -Cornell University ReactorBasic Tasks CostContractor 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 7Adjusted Cost to Present Dollars = (2006 Est)*(1.05)N $7,598,342 25% Contingency

$1,899,585 Present Day Total Cost $9,497,928 12/18/2013 Appendix EPage 20 of 20