ML20083H153

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Rev 1,to Allied-General Nuclear Svcs Barnwell Nuclear Fuel Plant Decommissioning Plan
ML20083H153
Person / Time
Site: Barnwell File:Allied-General Nuclear Services icon.png
Issue date: 10/31/1983
From:
ALLIED GENERAL NUCLEAR SERVICES
To:
Shared Package
ML20083H142 List:
References
NUDOCS 8401090083
Download: ML20083H153 (46)


Text

  • Octobar 14, 1983 Revision 1 ATTACH 3ENT 1 ALLIED-GENERAL NUCLEAR SERVICES i BARNWELL NUCLEAR FUEL PLANT l DECOMMISSIONING PLAN l

October 1983 0401090083 831213 PDR ADOCK 05000332 H PDR '

I

F GLOSSARY AEC - Atouic Energy Commission AGNS - Allied-General Nuclear Services AWR - AGNS Work Request BNFP - Barnwell Nuclear Fuel Plant CFR - Code of Federal Regulati)ns CNSI - Chem-Nuclear S ys tems, Inc.

DOE - Department of Energy EAA - Federal Aeronautics Administration FRSS - Fuel Receiving and Storaga Station HCLA - Hot and Cold Laboratory Area HP ' - Health Physics HWP - Hazardous Work Permit LTRC- - Lower Three Runs Creek LWR - Light Water Reactor MTU - Metric Tons of Uranium NRC - Nuclear Regulatory Cor: mission OSC - Operational Safety Committee RWP - Radiation Work Permit R&D - Research and Development SCDHEC - South Carolina Department of Health and Environmental Control SEC - Safety and Environmental Control SRP - Savannch River Plant TBP - Tributyl Phosphate TRU - Transuranic UF 6 - Uranium Hexafluoride WTEG - Waste Tank Equipment Gallery ii

. , _ _ . - . - _ . ~ . , - - . - . . ~ - . - . _ . - . _ , . - - - .

. TABLE OF CONTENTS PAGE l

l l

GLOSSARY

1.0 INTRODUCTION

................................................ 1 l.1 Purpose ................................................ I 1.2 Ge n e r al B ac kgr o und . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l_ l.3 Re a s on fo r S hut d o wn . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1

2.0 BNF P DE SC RIPTION AND HIS TORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.1 S ite T.oca t ion and De s c rip t io n . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.2 Separations Facility ................................... 3 2.3 Ur anium He xa f luoride F ac il i ty . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.4 Hot and C old Lab ora to ry Ar ea . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.5 other .................................................. 5 3.0 DECOMMISSIONING OBJECTIVES .................................. 9 4.0 REGULATORY REQUIREMENTS ..................................... 10 5.0 MANAGEMENT PLAN ............................................. 11 5.1 Manage me n t o rga niz a t io n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.2 Qua lity Ae aurance and S afe ty . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.3 consultant ............................................. 11 6.0 DECOMMISSIONING PLnN AND ANTICIF 4TED RESULTS ................ 14 6.1 Separations Facility ................................... 14 6.1.1 Process Systems ................................. 14 6.1.2 Proces s ~ Building C le anup . . . . . . . . . . . . . . . . . . . . . . . . 15 6.2 Uranium Hexa f luoride Fac ility . . . . . . . . . . . . . . . . . . . . . . . . . . 13 6.2.1 General ......................................... 15 6.2.2 Carbon Steel Piping and Equipment ............... 15 6.3 Hot and C old Lab o ra to ry Area . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 6.3.1 General ......................................... 15 6.3.2 Portable Equipment and Supplies ................. 16 6.3.3 Hoods .and Glove Boxes ........................... 16 6 . 3 . 4 . W a s t e S ys t e m . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 6.4 Other .................................................. 17 6.4.1 Waste Tanks ..................................... 17 6.4.2 Support Buildings ............................... 18 iii

,. =_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -

TABLE OF CONTENTS (CONTINUED)

PAGE 7.0 DIS POSITION OF SURPLUS EQU IPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 7.1 Disposition of Equipment ............................... 19 7.2 Radiological Controls .................................. 19 8.0 WASTE DISPOSAL ............................................. 21 8.1 Radio ac t ive No n-Tr a ns ur anic . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 8.2 Rad io ac t ive-Tr ans ur anic . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 8.3 Non-Radioactive ....................................... 21 9.0 ENVIRONMENTAL LMPACT OF DECOMMIS SIONING . . . . . . . . . . . . . . . . . . . . 22 10.0 FINAL STATUS AND CONTINUED SURVEILLANCE .................... 23 11.0 DOCUMENTATION .............................................. 25 TABLES Table No. Title Table 7-1 HP Release Code Classification . . . . . ................ 20 FIGURES Figure No. Title Figurc 2-1 BN F P S i t e L o c a t io n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Figure 2-2 Aerial Photograph BNFP Site and Surrounding Areas ... 7 Figure 2-3 Plot Plan of the Barnwell Plant ..................... 8 Figure 5-1 AGNS Management Staff ............................... 12 Figure 5-2 Decommissioning Project Organization . . . . . . . . . . . . . . . . 13 iv

_._____z_n_________._ _;

1.0 INTRODl'CTION 1.1 Purpose This Plan has been prepared to describe fully the decommissioning of the Barnwell Nuclear Fuel Plant (BNFP), including non-radiological con-siderations and non-licensed facilities, in a single, comprehensive document. Therefore, the proced'tres and status described herein are not necessarily intended to reflect license requirements. Proposed specific license conditions will be submitted as part of the BNFP license amend-ment application.

1.2 General Background The BNFP was designed and cons tructed, as a privately owned facility, to process light-water reactor fuel equivalent to 1500 metric tons of uranium per year. A Construction Permit was applied for on November 6, 1968 and issued (as CPCSF-4) by the Atomic Energy Commission on Decembe r 18, 1970. Construction began in early 1971 and presently existing facilities were essentially completed by mid-1976.

These facilities provide for fuel receiving and storage , separation of the uranium, plutonium and fission products in the spent fuel, conver-sion of uranyl nitrate solution to uranium hexafluoride (UF6 ), storage of plutonium nitrate and liquid wastes and for laboratory analyses and rerearch. As these facilities were completed, cold testing for operability was conducted using natural uranium as surrogate fuel. M no time has spent nuclear reactor fuel been present at the BNFP. During this period applications were made for other requisite Federal licenses and permits.

1.3 Reason for Shutdown On December 23, 1977, responding to an abrupt reversal of long-s tanding governmental policy, the Nuclear Regulatory Commission terminated all licensing proceedings related to reprocessing and recyc le of recovered products, leaving undicturbed, however, the BNFP Construction Permit.

Promptly thereafter, in early 1978, recognizing the BNFP as a national asse t , the Congress authorized and provided funding fo r research and development programs at the BNFP in support of national policy. This R&D work, which continued through July 1983, involved use of all on-site f acilities other than the Uranium Hexafluoride Conversion Facility which was deactivated and placed in standby status.

In December 1982, the Congress passed a resolution which specified that "no Federal funding is provided for any activities at the Barnwell Plant beyond July 31, 1983." Proceeding on that basia, activities le ading to an orderly shutdown of the BNFP by year-end 1983 were initiated in May.

There is continuing industry / utility interest in the pos sibility of making a proposal to the Department of Energy for future operation of

the BNFP. If such proposal is made, it may be possible to modify the ongoing shutdown program. However, in the cbsence of such proposal, activities leading to shutdown in December 1983 continue. These activities include implementation of this Decommissioning Plan.

2.0 BNFP DESCRIPTION AND HISTORY 2.1 Site Location and Description The BNFP is located about 7 miles west of the City of Barnwell on a site of approximately 1706 acres of land of which approximately 200 acres have been cleared. This site is situated in a predominantly rural area in Barnwell County, South Carolina. The plant base line reference is positioned at the' approximate Mercator coordinates of la t i t u de 33*15 '0" N and longitude 81*29'20" W (South Carolina S tate Lambert coordinates Y:516,100 and X:1,850,300).

The BNFP site is bounded on the west and south by the DOE Savannah River Plant (SRP) reservation, on the east by the Chem-Nucle ar Sys tems, Inc.

(CNSI) site, and on the north by the Barnaell County Industrial Park.

The location of the BNFP site with respect to South Carolina and Georgia is shown in Figure 2-1. The site perimeter relative to surface streams, abutting properties , industrial plants, and othe r items of specific interest within a five-mile radius is shown in Figure 2-2.

The BNFP site is largely forest land, with a small number of abandoned farm fields undergoing secondary succession, and several Carolina Bays.

Forestation consists of loblolly pine plantings, mixed pine forests, and mixed pine-hardwood (scrub oak) forests.

There are no natural streams on the BNFP site. .

The plant site is wholly-owned private property. A right-of-way for Osborn Road, which is the principal access road to t h~e site, has been granted to the State of South Carolina. An easement fo r the power transmission lines that supply the BNFP has been granted to South Carolina Electric and Gas Company. The rai'. road spur se rv ing the Fuel Receiving and Storage Station (FRSS) within the site boundary is wholly AGNS-owned.

A plot plan'of the BNFP plant area showing significant features is pre-sented as Figure 2-3. A chain-link exclusion fence has been ins t alled around the plant area.

2.2 Separations Facility The Separations Facility was designed to process 1,500 me tric tons of uranium (MTU) per year at a daily rate of 5 MTU/ day. The plant was designed for processing fuel elements that prior to irradiation had a fissile material content of up to 5% U-235 or the equivalent fo r plutonium fuels.

The process sys tems in the BNFP for the recovery of special nuclear material are an adt.ptation of the Purex solvent extract ion proces s , for which the technology and risks are well-defined.

l

_ j

The Separations Facility includes five (5) contact maintenance cells, two (2) remote maintenance cells, two (2) plutonium nitrace storage cells and associated equipment, e.g., pumps, ins t rume nt a t io n , and piping. Only liquid process equipment in the Separations Facility has been exposed to solutions containing uranium (natural only). No plutonium has been used in any process area. Process support equipment ,

such as the shear and cranes, has not had direct contact with uranium.

The plutonium nitrate storage cells and auxiliary systems ha"e not been in contact with uranium. Closed-loop cooling water and steam generating systems are clean; however, their status will be verified. The status of the Plant's ventilation systems will also receive cons ide r a r.io n depending on areas it se rv ic ed , some of which have been exposed to natural uranium. Generally, residual in-cell natural uranium contamina-tion levels were less than 1000 dpm/100 cm2 a and 2000 dpm/100 cm2 gy smearable prior to the start of decommissioning. Process piping and vessels that have contained solutions of natural uranium may have higher levels. Such levels in normal access areas, (e.g., operating s ta t io ns , i piping and ins trument galleries , stairwells and hallways), in general are less than 50 and 500 dpm/100 cm 2 a and By strearable , respectively.

2.3 Uranium Hexafluoride Facility The UF6 facility contains equipment to convert uranyl nitrate to uranium hexafluoride. This equipment is housed in an eight-story metal fr ame building. Some of the process-related equipment, such as piping, calciners, screw conveyors, bag houses, and vessels, nas been in direct contact with uranium, in most cases in the fo rm of uranium oxide powde rs . Auxiliary systems and areas, such as compres sors , refrigera-tion, fluorine prod action and UF6 cylinder loading / unloading , have not been in direct contact with uranium. Residual uranium levels in normal access areas are comparable to those that exist in the S ep a ra t io ns Plant.

2.4 Hot and Cold Laboratory Area The Hot and Cold Laboratory Area contains a temporary lunchroom, a change and locker room, Health Physics support offices, and laboratories.

The Analytical Chemistry Laboratories consist of individual laboratories equipped to provide specific ty pe s of analyses or services. The laboratories include all facilities required for analyzing samples for purposes of process control, accountability and safeguards, product and raw material specifications, and process ins trumentation calibration.

The Analytical Chemistry Laboratories have been used for DOE-sponsored research and development work, support of plant cold testing, and ,

analytical procedures development. Radioactive materials have been used in all of the lab o r a to r ies . Plutonium has been used in six labora-tories; thus, the hoods and glove boxes in these six laboratories contain residual TRU.

h. _ _ -

The Engineering and Technical Laboratories consist of an Engineering Laboratory, Alpha Laboratory, Radiochemical Laboratory, and Cold Chemical Laboratory.

The Engineering L'aboratory consists of pilot plant scale equipment, e.g. , stainless steel tanks up to 500 gallons capacity (15-20 vessels),

pumps, heat exchangers, ins trument s , three glass pulse columns, pulsers, piping, and valves. Only uranium and thorium have been used in this laboratory.

The Alpha Laboratory contains three very large glove boxes and one standard fumchood. One box (18'L x 10'H x 2.4'D) coniains solvent extraction pulse columns and ancillary equipment, such as glass vessels, pumps, stainless steel tubing, and valves. A second box (approximately

25'M x 10'L x 5'D) is used for waste solution handling. This box contains a vacuum pump, stainless steel tank, glass mixing vessel, and several 26-liter polyethylene bottles for storage of waste . The third glove box is used for analyt ic al tests. All three glove boxes will contsin residual plutonium.

The Radiochemical and Cold Chemical Laboratories are standard chemical laboratories containing fume hoods, normal bench tops, and sinks, and are equipped with standard chemical labware. These laboratories have been used for work with natural and/or depleted uranium and by product tracer level radionuclides. No plutonium has been used in the Radio-chemical and Cold Chemical Laboratories.

2.5 other The Fuel Receiving and Storage Station (FRSS) contains a cask testing and decontamination pit, two (2) cask unloading pools, a fuel storage pool, and associated pool water cooling and treatment equipment and handling cranes. The FRSS has not been exposed to radioactive materials.

The Waste Tank Equipment Gallery (WTEG) houses the pumps, piping, and equipment for maintahing and saopling the three (3) underground liquid waste storage tanks. Some transfer and sampling lines have contained uranium solutions , but the ge ne ral area is c le an . Two of the three underground storage tanks have also contained uranium-bearing solutions.

Support facilit ies , such as the utility area, administration buildings, snops, and warehouses have never been exposed to radioactive materials.

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_. . . . . _ _ . . _ _ _ . _ . . _ _ . _ _ . ~ _ _ . . _ .

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(. 3.0 DECOMMISSIONING OBJECTIVES The objective of tha BNFP Decommissioning Plan is to place the BNFP f acilities and the site in such a condition that a minimal level of radiological controls and security will be required following shutdown.

The Plan is consistent with preserving the option of reprocessing at the BNFP in the near term future. However, should a decision be made later that the reprocessing option no longer needs to be preserved, then the plan provides that-the future level of ef fort necessary to place the facilities in an " unrestricted use" status also should be minimal. To accomplish the Plan's objectives, source, special nuclear, and by product materials will be removed from the site. Low levels of residual natural uranium will remain on the interior surfaces of process piping and vessels. In addition, some residual plutonium contamination will remain on the interior surfaces of glove boxes. The TRU glove boxes will be isolated from ventilation systems and securely sealed.

The ' exterior surfaces of equipment and structures will be cleaned to the "unres tricted use" levels set forth in NRC Regulatory Guide 1.86.

Selected equipment outside of process cells will be salvaged and sold.

All waste will be disposed of in accordance with existing reg ula t io ns .

AGNS.will submit to the SCDHEC an ap plic a t io n to amend its existing s tate radioactive material license to a " posses sion only" licens e . The f acilities will be closed and all acces s points secured. Continued surveillance will be provided as described in Section 10.0 of this plan.

_9_ i

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4.0 REGULATORY REQUIREMENTS Allied-General Nuclear Services (AGNS) has been licensed by the State of Sauth Carolina to possess and use radioactive materials. The State regulations governing the use of radioactive materials are published in

" Rules and Regulatio :s for Radiation Control, Regulation No. EC-1." The shutdown and decommissioning of the BNFP will be conducted under these regulations and in conformance with existing AGNS procedures which are incorporated by ref erence in the State license. Although the State regulations do not specifically- address de c ommi s s io n in g , Section RHA 2.19 states that the "Departmant may terminate a specific lic ent.e upon request submitted by the licensee to the Department in writing.".It is intended that this decommissioning plan and the supporting docu-mentation which will be generated during the course of decommissioning will support an application to amend AGNS' current State license to be a

" possession only" licensee.

A second set of applicable regulatory requirements is associated with the AGNS Construction Permit granted under 10 CFR Part 50. 10 CFR 50, paragraph 50.82 s tates that "a licensee must submit decommissioning plans to the NRC." However as.with State Regulations, no specific guidance is providel. The NRC recently revised 10 CFR Parts 30, 40, anu 70 for the purpose of establishing procedures for te'rmination of licenses. Although these revisions address the ques tion of acceptable levels of residual radioactive materials, no specific limits were 3stablished. Regulatory Guide 1.86, " Termination. of Ope rating License for Nuclear Reactors." dated June 1974, included by reference in numerous NRC-issued licenses as guidelines for release of facilities ^ for unrestricted use, will be so used during the decommissioning act ivi t ies .

All other applicable State and Federal regulations governing packaging ,

trans port at ion , and disposal of radioactive and hazardous materials ,

shutdown of sanitary waste treatment facilities, inert industrial was te landfills, etc. , also will be followed.

a.

.s

5.0 MANAGEMENT PLAN 5.1 hanagement organization The AGNS present management organization is depicted in Figure 5-1.

Dr. J. A. Buckham, President, has appointed J. H. Ellis, Director, Ope rations , to be Chairman of the BNFP Shutdown Steering Committee. The Committee has the responsibility for detailed planning, scheduling , and conduct of the plant shutdown and decommissioning program. Other committee mambers are:

J. L. Aughtman - Manager, Procurement and Material Control J. H. Mestepey - Manager, Plant Engineering and Maintenance J.- J. Jernigan - Controller M. Hawkins - Manager, Safety and Environmental Control The functional decommissioning project organization is shown in Fig-ure 5-2.

5.2 Quality Assurance and Safety Quality assurance considerations will be in conformance with the BNFP Quality Assurance Program as set forth in AGNS Policy and Procedure Q-11. The program will be utilized to monitor and provide do cume n t ed evidence of activities during the period of - decommissioning.

The AGNS Operational Safety, Committee (OSC) will remain functional dur- '

ing the . decommissioning period. The OSC provides a management oversight function to assure that activities conducted at the BNFP are carried out in a manner consis tent with the safety policies of AGNS and in con-formance with all applicable regulations.

5.3 Consultant AGNS has contracted with Rockwell International of Canoga Park, Cali- ,

fornia as a consultant to provide an independent review of the BNFP decommissioning program. This accion was taken to provide added impartial and objective assurance that the de commis s ion ing . pr ogr am is properly planned, documented and performed. Rockwell has conducted an initial review, resulting in a number of recommendations all of which have been incorporated in this decommissioning plan. Rockwell will'also perform an independent radioloaical survey to verify the final radio-logical status of the facilities . This consultant is to prepare reports addressing the adequacy of the decommissioning plan and procedures, as well' as perform pericdic reviews during the course of decommissioning.

A final report summarizing the results of the decommissioning program will be prepared. This final report will be availab le for review by appropriate regulatory agencies as will other supporting documentation.

ASNS FAANAGEMENT STAFF J A 8"*k"***

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February 1983 eina w e i I I

  • **d se.mM Aen. + 'd'""'**8'"* +

C. W. Smith Consu!! ant Director Direcler I I I l

,-e e- e Ie,se,- e Commually Retaileas e.eui.im, e Poths Asee Adminishalles l eed fuhancel l- -

1 J. C. Smith

  • G. T. 5tsildes* II. J. Bambas*

Vice Preskjent Vice Presklent Vice-Pie *klent V6ce President-Imployanni cany notahaas hecaemme Q ,, teAw asiaisons s keasing udmW Camel

- - Campensahun red Pubhc Asialiens Centact Adnenishalten Vacael W. B. Someet emmus Admhda.auen

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Pessacis IschacalSuppas E10 Compliame hans C8ma**v avame Assmose

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NuciaPsecess Olfica tervices _

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    • Now reports to the Director of Operations.

+As part of the shutdown plan, these employees have been terminated and the positions are nou vacant.

ACNS MANAGEMENT STAFF FIGliRE 5-1

4 1

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l Program Manager

  • l John H. EllIs 4

i Alternate Monte Hawkins AGNS Operational

~~~~--------------------

Safety Committee George T. St.'ibling, j Chairman Quality Assurance Shutdown and Control _ .....................

Steering M. L. Rogell- Comunittee 4,

Hanager l l l -

1 I I Separations Facility UF. Facility Safety & Envirornnental i Lab Deconwissioning Waste & Nuclear Material

- Deconsnissioning Deconsnissioning .Centrol George A. Huff,' Processing Disposal ~

" Ken E..Plusener, James 11. tiestepey,* Monte Hawkins.* Manager . Ken E. Plumener, 8 sunerintandent Superintendent Manager Analytical Services Superintendent. Separations l

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Equipment Identification Bu'dget & Cost Equipment Removal Records Documentation l

Jerrel J. 'Jernigan,

  • James H. Mestepey, Georgia F. Fields, Jc Ais n,* Controller Manager Manager H ant Eng. & Maint. Office Services i

ProcuremenUIf5aterial q Control t

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  • Steering Committee Member j .

1.

DECOMMISSIONING PROJECT ORGANIZATION 4

FIGURE 5-2 i

t 6.0 DECOMMISSIONING PLAN AND ANTICIPATED RESULTS Existing AGNS procedures will be followed during decommissioning opera-tions. A Hazardous Work Permit, Radiation Work Permit, AGNS Work Request and/or Work Instruction will be issued by AGNS to cover items of work in order to provide written instructions, to assure compliance with existing procedures and regulations , and- to document that the work was done.

Disposal of non-TRU Radwaste , TRU waste, non-rad waste, and non-rad hazardous waste will be governed by existing AGNS procedures.

6.1 Separations Facility 6.1.1 Process Systems Proces s solutions will be removed from process vessels and piping.

Unused TBP and diluent will be removed from their respective feed tanks.

Solvent with uranium contamination will be cle aned with sodium car-bonate. Process solutions will then te packaged for of f-site disposal or sale. Approximately 14.5 MTU of DOE-owned natural uranium, in the form of uranyl nitrate solution, will be shipped ^ to an of f-site ve nd or for conversion to UF6 Prior to return to DOE.

In order to remove residual quantities of uranium and reduce residual internal levels in the Separations process equipment and piping , nitric acid and water flushes will be performed. Internal smear survcys will be taken from selected vessels ~ and' piping sections prior to perf orming an initial acid flush. Solution samples will be taken before and after.

" flushing" so that the ef fectiveness of this flushing can be determined.

Additional (repeat) internal smear surveys will also be taken. Where indicated, vessels will also be flushed with sodium carbonate solutions to remove organic residues.

Data collected from this initial flush will be used to de termine if an additional acid flush is required on all or part of the proces s. Waste generated from these acid flushes will be collected in a waste tank.

- Following these acid flushes, a water flush will be performed and pro-cess vessels and pipir.g will be filled to overflow. A final dilute acid flush will then be performed to enhance clean-up and to assure passi-vation of the' internal surfaces of the piping and ve ssels. All flush solutions will be collected and prepared for of f-site disposal.

Records will be maintained to document the history of clean-up of major vessels and process systems (internal residual levels , ty pe and number of flushes, etc.).

  • Shipment was completed on September 26, 1983.

1

It is expected that the above cleanup and flushing program will result in residual uranium levels on the interior surfaces of precess piping and vessels of less than 1000 dpm/100 cm 2 sme arab le natural uranium alpha. The res ilts of the flush solution samples and smear surveys of the interior surfaces of process systems will be analyzed to verify this expected result.

6.1.2 Process Building Cleanup i

All areas of the process building (contact cells, remote cells, gal-1eries, stations, and areas) will be cleaned to levels as low as practicable. Direct radiation levels in the buildings will not exceed background. Final radiological surveys will be performed.

To the extent prac t icable , all wood, paper, flammable liquids, and other combustibles will be removed from the process building.

Cell ventilation lines will be surveyed by Health Physics (HP), and closed off. Ventilation and of f gas filtere will be lef t in place.

Af ter clean-up is complete , all water will be shut off and all lines drained. All electrical service will be de-energized and the buildings secured.

6.2 Uranium Hexafluoride Facility 6.2.1 General The same general procedures will be followed for cleanup of the UF6 Pro-cess system and building as are described for the Separations Facility.

6.2.2 Carbon Steel Piping and Equipment Some systems in the UF 6 Facility have been in contact with natural uranium powder. Because they are cons tructed of carbon steel, these systems cannot be flushed with nitric ; acid. These systems will be identified, opened, and vacuum cleaned. They will then be phys ic a1L ly removed from the facility. Piping will be discarded as non-TRU was te.

Where practicable, equipment such as conveyors , blowers , valves, etc.,

will be trans fe rred to Allied Corporation's Metropolis, Illinois Facility. These items will require HP approval prior to disposal or shipment.

6.3 Hot and Cold Laboratory Area 6.3.1 General The laboratory area of the BNFP consists of analytical chemistry laboratories, an engineering laboratory and an alpha laboratory. The analytical chemistry laboratories are equipped with hoods, glove boxes,

~

J work tables, and the necessary analytical chemistry equipment to perform sample analyses for process control, accountability and safeguards, product and raw. material analyses. The engineering and alpha labora-tories contain pilot plant scaled equipment and have been used for process development work.

The general plan for decommissioning the laboratory areas is to remove all radioactive sources, contaminated equipment and any other radio-active materials. Fixed work tables , hoods, and glove boxes will be left in place. Floors, ceiling, counter tops, and if pos s ib le , the interior of hoods will be cleaned to AGNS Zone II limits wh ich are 50 dpm a /100 cm2 and 500 dpm sy/100 cm2, sme ar ab le . The in t e rio r surface' of the glove boxes which. have not contained Pu will also be cleaned to Zone II linits.

The laboratory area also containe administrative of fices for laboratory personnel, a temporary lunchroom, and Health Physics support offices.

All of these areas will be cleaned to Zone II limits. It is expected that as a result of this decommissioning effort, the laboratory area, except for the interior surf aces of TRU glove boxes and hoods, will not have res idual levels greater than Zone II levels on any acces sible surfrees.

6.3.2 Portable Equipment and Supplies Portable equipment will be cleaned and placed in storage cutside of the laboratory area for future sale or disposal. If the equipment cannot be readily cleaned, it will be discarded as waste. Compa tib le laboratory chemicals will be discarded to the Separations Plant Waste Treatment Systems. Other chemicals will be packaged for disposal at an approved chemical disposal site.

All cabinets and drawers will be emptied and the contents removed from the laboratory for sale or subsequent disposal. The ' interio r surfaces of cabinets 'and drawers will be cleaned to Zone II limits. All portable equipment will be removed from hoods and glove boxes.

6.3.3 Hoods and Glove Boxes All accessible exterior surfaces of the hoods will be cleaned to Zone II limits. The interior surfaces of hoods will be cleaned to a level that is considered to be as low as practicable.

All drain lines from hoods, non-TRU glove boxes, and sinks will be flushed with nitric acid and water. The flush solutions will be treated in the Separations Facility Waste S ys tems. Flush solutions from TRU glove boxes will be collected and treated as TRU waste.

Af ter cleaning, the glove boxes and hoods, wh ich had contained TRU material, will be isolated from the ventilation system and other utilities. The gloves .will be lef t in place in the glove boxes and a gasketed cover plate will be placed over the glove port. Since there

will be residual plutonium remaining in some of the glove boxes, a periodic surveillance program, as described in Section 10, will be performed to assure that the integrity of the boxes is maintained.

There are three large non-standard glove boxes in the alpha laboratory which have been exposed to plutonium. As much equipment as practicable will be removed from these boxes via existing bag-out ports. These boxes will be cleaned to a level that is considered to be as low as practicable, sealed and isolated as described ab ov e . As with the analytical laboratories, periodic surveillance will be performed.

6.3.4 Waste System Af ter clean-up of the laboratories is completed, all drain lines sad tanks in the laboratory waste system wili be flushed with nitric acid and water. It is expected that the interior surfaces of thepipes and vessels in this system will contain less than 1,000 dpm/100 cm natural uranium alpha. No plutonium-bearing solution has ever contacted the laboratory waste system.

All wasta disposal operations required as a result of laboratory decom-missioning will be performed in accordance with existing AGNS procedures and applicable state and Federal regulations.

6.4 Other 6.4.1 Waste Tanks There are two High-Level and one Intermediate-Level stainless steel waste tanks. Each tank has a nominal capacity of 300,000 gallons and is located inside a concrete vault which is lined with stainless steel.

One High-Lav _? tank and the Intermediate-Level Was te Tank were used to collect wastes generated during the DOE-sponsored demons tration runs of the Separations Facility. These solutions have been removed and solidified. Howeve r., a waxy film containing a small amount of uraaium adhered to some of the cocling coils in the High-Level Waste Tank. The Intermediate-Level Waste Tank has been cleaned, and it will be surveyed by HP. The second High-Level tank has not been used.

The Intermediate-Level Was?.e Tank will be used to collect the nitric acid flush solutions used in cle aning the Separations Facility. The used High-Level Waste Tank will ' collect the water flushes wh ich follow the acid flush.

The water flush solution will provide suf ficient volume to submerge the coils and -sodium hydroxide solution will be added to dissolve the vaxy film on them. This solution will then be used to neutralize the acid in the intermediate-level tank and the combined solutions will be concen-trated and prepared for disposal at an authorized burial site.

- - _ = ____ - _

AIHed-General Nuclear Services Pod CICce Bos 847 Barnwell. South Carolina 29812 J. A. Budham -

Pro,: dent (803) 259 1711 December 9,1983 PRES /83/166 The Honorable Donc1d Paul Hodel Secretary of Energy 1000 Independence Avenue, S.W.

Washington, D.C. 20585

Dear Mr. Secretary:

My letter of April 15, 1983 promised to keep you informed of progress in the orderly shutdown of the Barnwell Nuclear Fuel Plant. Subsequently, in letters dated May 24 and June 17, 1983, I advised hat we were proceedir.g with both the cleanout of equipment and .the issuaace of notices of termination to employees. This . letter is to summarise for you the current status of such-shutdown activities, which will be virtually complete by December 31, 1983.

All work under RbD contracts with the Department of Energy has been completed and described in twenty-nine (29) reports which we provided to the Depart-ment's Savannah River Operations Office. (As that Of fice is svare, cvr costs for the FY 1983 R&D work exceeded the contract funding by apprcximately

$700,000.) Duricg the six year course of the DOE /AGNS research programs,

$5.6 million of ge rernment-owned equipmut was purchased for use or testing at the BNFP. This equipment is being returned to DOE's possession in conformance with the Department's regulations and instructions.

Following completion of the DOE-sponsored research, we initiated an extensive and thorough cleanout of the plant, transferring to others all usable nuc le ar materials which had been associated with the R&D programs. Waste materials were sent to approved waste disposal sites. The cost of this decommissioning activity will be approximately $3.3 million.

On April 15, 1983, the BNFP employee census stood at 293. Today, it is 127, and it will be reduced to 14 by December 31, 1983. The census reduction is being accompanied by outplacement and severance programs consistent with practice at AGNS ' owner companies . The cost of severance and outplacement is estimated at $2.7 million.

The AGNS pension plan is being terminated with funds wh ich er e mo re than adequate to cover required distributions to plan participants. We have submitted the required documentation to the Internal Revenue Service and to the Pensior. Benefit Guaranty Corporation.

.-4 s -.~

The Honorable Donald Paul Hodel Page 2 December 9,1983 In a separate program, selected items of plant equipment have been removed and sold. Those items have been restricted to: (1) those which would be expected to deteriorate or become obsolete within a few years, such as laboratory and portable instrumentation, and (2) readily replaceable, high-value equipment and materials such as emergency diesel generators , silver zeolite, and alu-minum canisters. For the time bei.3, in-cell process equ.pment i is being left in place and necessary quality control and other vital records are being preserved.

I believe you share our regret that these actions have become necessary. We most certainly share your views, as reported last month at the AIF's annual meeting in San Francisco, that disposal of spent fuel is an " atrocious, unacceptable vaste" and that "sometima, somewhere, we've got to come to grips with the reprocessing issue." Reprocessing is clearly a better way to manage the disposal of high-level waste than is the burial of spent fuel. However, our decommissioning activities do not provide for long-term preservation; hence, un11ss prompt actions are undertaken, the Barnwell Plant will not long I

he preserved as the most timely and cost-ef fective place in which the nation can realize the energy conservation and waste disposal benefits of reprocessing.

As I have done in the past, I am providing copies of this letter to members of i the South Carolina Congressional delegation and to Governor Riley.

S ince rely, b M J. A. Buckham -

JAB /jr i

cc: .Mr. R. L. Morgan, Mgr. SR e

~

? - - - - - , _. - s .

The two tanks will then be flushed and final surveys will be taken. The unused High-Level Waste Tank will also be inspected and surveyed. All utilities will then be shut of f, and the vaults will be closed.

6.4.2 Support Buildings There are a number of support buildings such as warehouses , machine, vehicle maintenance, and instrument-electrical shops at the BNFP. All of these support facilities are clean. Port able equipment, flammable liquids, and to the extent pract icable , combustible material will be removed for disposal or possible sale. Power will be shut down, and the buildings will be locked.

It is possible that the administration buildings will be used for records storage and will be occupied by records pe rs onnel for the immediate future. In addition, portable equipment will probably be stored in the warehouse.

18 -

7.0 DISPOSITION OF SURPLUS EQUIPMENT A system has been-established for. controlling the distribution of sur-plus materials. - All items of equipment or lots of similar-items will be

-assigned a unique identification number. All pertinent . data will be keyed to _ this number and maintained in a computerized data management

.= ys t em. The data collected will . include , among other things, a descrip -

tion of the item, its value, loca tion , to whom it was' donated or sold, and Health Physics survey and release data.

7.1 Disposition of Equipment Portable equipment -(i.e. , readily disconnected by unplugging or unbolt-

.ing) is located 'in the Separations, Laboratory, and UF6 fscilities as well as administrative and support areas. This equipment include s such things as office furniture, laboratory ins truments, welding machines ,

medical and safety equipment, and small tools. This equipme nt will be cleaned , tagged, surveyed by Health Physics, and moved to a designated holding araa. Movement of this . equipment will facilitate subsequent cleanup of the building.

Some of this equipment, such as safety and medical equipment, may be donated to area hospitals, schools, fire departments, and rescue squads; limited quantities of office furniture and other selected items will be

-sold to employees. Other selected equipment also will be sold. All equipment that' is released from the site will be cleared by the Safety and Environmental Control Department (SEC)' in compli'ance 'with 'exis ting'

~

AGNS procedures.

7.2 Radiological Controls The SEC Department will determine whether an item can be relensed from the site on en " unconditional use" basis or whether it must be treated as a " restricted use" item. " Restricted use" items will be released only to organizations or persons authori' zed to receive radio ac t ive materials,- such as other licensees or the Department of Energy.

Table 7-1 describes the criteria to be used to determine the Health Physics- Release _ Code' classification for the release of material from the BNFP.

TABLE 7-1 HP RELEASE CODE CLASSIFICATION Type of Resid- ~ HP Release Limits (D) ual Material Code Classification Definition Alpha (c) Beta / Gamma unconditional 2 2 Smearable (a) A use of items $100dpc/100cm 1100dpm/100cm restricted B use of items >100dpm/100cm 2 >100dpm/100cm 2 unconditional 2

Fixed I use of items 1100dpm/100cm 10.1mR/hr restricted 2 use of items >100dpm/100cm 2 >0.1 mR/hr (a) No covering or coating materials shall be applied to items for the purpose. of reducing removable residual levels.

(b) Except as noted (see Note No c), the limits shown shall pertain only to natural uranium.

(c) . For items removed from plutonium handling areas in the HCLA, the uncond itional use limit for smearable alpha shall be 110dpm/100cm2, A code letter and number designating fixed and sme arab le classifications shall be assigned -to each item.

The restrictions associated with Health Physics Release Codes shall be applied independently and the most res tr ic t i ve limits shall determine the subject item's disposition. For example, items claesified with a " Health Physics Release Code of

' Al'" are defined as unconditional use items. Items classified as "A 2, " "B 1, " o r "B2" are defined as being restricted use items. Only authorized part ies , e.g.,

radioactive material licensees , shall .be eligible to take possession of restricted use items. -

l 1

8.0 WASTE DISPO _ SAL A number of types of waste will result from the shutdown and de c ommi s-sioning of the BNFP. All waste disposal operations will be in com-pliance with applicable State and Federal regulations.

8.1 Radioactive Non-Transuranic The waste which will be generated in this category will include such things as non-salvageable uranium-bearing equipment , including some pipes and vessels from the 'JF6 Facility; " job control" was te res ult ing from decommissioning activities; non-salvageable laboratory glassware which may have been in contact with uranium; and solidified aqueous waste resulting from process equipment cle an-up. The principal radio-active material in these wastes is natural uranium. The waste will be packaged for disposal in accordance with existing regulations . It will then be transported to a licensed commercial site for disposal.

8.2 Radioactive-Transuranic During the performance- of rese arch and developme nt programs for the Depactment of Energy, it was necessary to use limited quantities of plutonium. Because the plutonium was used in support of Department of Energy programs, it has been determined that all transuranic was tes resulting from decommissioning activities can be accepted by the Department of Energy's Savannah River Operations Of fice fo r interim storage. In addition, plutonium and other transuranic waste labor a to ry standards, sources, and stock material will be trans ferred to the Department of Energy.

8.3 Non-Radioactive Non-radioactive wastes will include such items as paper, wood, scrap metal, plas tics , and ge ne ral trash resulting from c le anu p. AGNS is currently licensed by the state to ope ra te an inert industrial waste landfill on the BNFP site. Materials such as those de scribed will be placed in that land fill . The landfill will be stabilized and shut down in accordance with state regulations. After the landfill is shut down, AGNS will obtain the services of ' a commercial was te contr ac tor to accommodate the small volume of waste that will remain.

AGNS has on hand a number of chemicals used in support of laboratory operations and as stock for process solutionc. These nonradioactive chemicals will be donated, sold, or disposed of as chemical was te at a licensed dispossi site. Any other chemicals or hazardous nonradioactive materials will also be disposed of only at an authorized disposal site.

9.0 ENVIRONMENTAL IMPACT OF DECOMMISSIONING The shutdown and decommissioning of the BNFP will not have a significant environmental impact beyond the socio-economic impact on employees and the community associated with. loss of employment.

All flammable liquids, chemicals, rad io ac t ive , and other hazardous materials will be removed from the site for sale or for disposal at an authorized facility. Any environmental impact associated with such disposal will have been' evaluated and cons ide red during lic e n s ing activities for the disposal facilities.

The radiation exposure of personnel during decommissioning will be negligible since the principal radioactive material which must be removed from the site, natural uranium, will be handled in pipes, tanks, and similar essentially closed systems. Where it is necessary to work with plutonium, protective measures will be taken in accordance with existing AGNS procedures which have been proven ef fective. No exposures to the general public will result from decommissioning.

The outfall from Beacon pond will be closed off and liquid discharge into the pond and thence Lower Three Runs Creek (LTRC) wilI be termi-nated. Since the pond's discharge cons titutes only a'small fraction of the total flow of LTRC, cessation of discharge will have minimal, if any, impact.

An Environmental Consultant retained by AGNS has recently inspected the site to determine if erosion would be a problem should the site be abandoned. His. cenclusion was that the surface fe a ture s of the site have stabilized and that erosion will not be a problem.

m

10.0 FINAL STATUS AND CONTINUSD SURVEILLA' ICE Upon ecmpletion of the decommissioning program, the BNF P s i:. e and facilities will be in a condition such that only minimal pe riodic surveillance will be required.

Except for previously discussed residual amounts, all radioactive material will have been removed from the site. All normal acces s areas will have been cleaned to Zone II limits and entrance may be made wearing street clothing only. Some natural uranium will be present on the internal surf aces of process pipes and ve s s e l s . However, it is anticipated that levels of residual material will be less than the limits set forth in Regulatory Guide 1.86 for " Unrestricted" use. While glove boxes which previously contained plutonium will still have resid-ual quantities of plutonium on their interior surfaces, the external ourfaces will be less than Zone II limits. Hoods, laboratory work benches, floors , ceilings, and walls in the laboratory area will also be less than Zone II limits.

The doors to laboratorien and cells will be securely locked. Ven-tilation dampers to cells and laboratories will be closed. Glove boxes which have contained plutonium will be isolated from the ve nt ila tion system. All combustibles , flammable liquids, portable equipment, and furniture will be removed from the laboratories and process buildings.

Electrical power and other utilities will be shut down. All entrance points to the process buildings will be securely locked.

Support buildings such as utility areas, training center and warehouses will be emptied of the ir contents. Entrances will then be locked.

However, it is possible that some equipment may be stored in existing warehouses on site.

Two of tnree large waste tanks at the BNF- have been contained with natural uranium. These tanks will be cle aned to a level that is considered to be as low as practicable. It is expected that the residual level in these tanks will be less than the levels specified in Regulatory Guide 1.86, for "Unres tr icted" use .

Although the amount of radioactive material remaining on site will be extremely small and will be present only as low-level surface residues, a periodic surveiltance program will be implemented. Security inspec-tion.of the process areas will be pe rf o rmed quarterly. The security inspector will look for ubvious damage to buildings or evidence of attempts to enter the facility. Site boundary fences will be inspected for evidence of entry and the site will be observed for erosion damage.

While the meteorological tower remains in place , the FAA warning ligh t s will be checked daily for operation.

Semi-annual radiological surveys and safety and fire protection inspec-tions will be performed. This will consist of walk-through ins pect ions

- ?3 -

of. the facility Lto detect fire or safety problems. Smear surveys will be conducted in the -Separations Facility, the laboratory areas, and the UF6 Facility. In the laboratory areas, smears will be taken around glove ports to assure that any ' residual material remains confined.

Glove ports will beLvisually inspected to insure that the integrity of the bex is maintained.

As a part of preparing for operation of the BNFP, an extensive radio-logical environmental survey was performed by a consulting team now headed by Dr. ' John M. Palms of Emcry Univers ity in Atlanta, Georgia.

Although AGNS' contractual relationship with these consultants has been terminated, a new contract will be written to provide for a - final environmental ' survey of the BNFP. However, because only minimal levels of radicactive r;aterials will remain - at the BNFP, it is not considered necessary to perform periodic environmental curveys such as soil, air, and water sampling.

AGNS will contract' with a- qualified organization to perf orm the sur-veillance functions. An individual within one of the parent companies will be assigned responsibilities for assuring that the surveillance program is properly conducted.

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11.0 DOCUMENTATION All activities associated with the decommissioning of the BNFP will be performed under existing AGNS procedures. These procedures will be supplemented with written work ins tructions as necessary. Copies of procedures , work instructions, radiological survey data, and property disposition records will be retained as supporting documentation.

~~

_ .O BARNWELL NUCLEAR FUEL PLANT POST - DECOMMISSIONING SURVEILLANCE PROGRAM Allied-General Nuclear Services is contracting with Chem-Nuclear Sys-tems, Inc. of Barnuell, South ~ Carolina, to perform the surveillance program described in the BNFP Decommissioning Plan (Attachment 1 to this License Application).

Chem-Nuclear is intimately familiar with the regulatory, radiological and industrial safety, and security aspects of nuclear ope ra tions in Barnwell, across the country, end around the world. This experience, the Company's reputation for quality, and the familiarity and proximity to the Allied-General Nuclear Services (AGNS) Barnwell Nuclear Fuel Plant make Chem-Nuclear superbly suited to operate the AGNS Surveillance Program.

The CNSI Surveillance Program of the AGNS Facility will consist of two phases:

A. Radiological surveillance B. Quarterly security inspection AGNS will provide to Chem-Nuclear the name and telephone number of a designated AGNS representacive who will be notified immediately of any radiological, safety, or security problems- de tect ed on the AGNS property.

Descriptions of each phase of the surveillance program follow.

A CNSI procedure will be prepared to implement ~ the-AGNS surve illance program. This procedure will be supplied to the AGNS representative and to the SCDHEC.

A. Radiological Surveillance Chem-Nuclear will perform a semi-annual radiological survey of the Separations and UF6 Facilities. The first of these surveys will be performed as soon as possible af ter the AGNS decontamination project is comple.ted, and prior to December 9,1983, to pe rmit AGNS pe rs onnel to escort CNSI personnel through the facility on the initial survey and so that AGNS can assist in establishing a baseline set of survey readings.

These surveys will be performed in accordance with existing CNSI radiological survey procedures.

The radiological survey will consist of:

1. A general safety and fire protection inspection of all areas entered
2. Smear surveys of the entrance areas, ground floor, hallways, and stairwells of the' Separations and UF6 Facilities and of the ballways of the HCLA.. Sample locations will be demarcated for standardiza-tion of ' samples. The smears will be counted for alpha and be ta-gamma activity.

- 3. Smear surveys and portable alpha and beta gamma ins trument surveys ,

of the HCLA Analytical Chemistry Lab, the Engineering Lab, and the Alpha Lab. - Special attention will be given to the smear surveys of the external surfaces of gloveboxes, gloveports, and hoods for evidence of removable contamination.

4. At the UF6 Facility, additional smear surveys and portable alpha and beta gamma instrument surveys ' will be perf ormed at the ' following equipment / locations : spray dryer, laboratory, base of main stack, decontamination tank, decontamination room, calciner, 8th floor bag house , ' and oxide vacuum sys tem.

The AGNS representative 'will'be notified of any contamination found in 2

excess of 50 dpm/100 cm2 alpha or 500 dpm/100 cm beta gamma or of any significant variation in radiological conditions from those found in the baseline survey.

' In addition, semi-annual reports de tailing the above surveys will be submitted to AGNS within- 30 days of the end of the report pe riod . If requested by AGNS, a copy of the report will also be submitted to the South Carolina Department of Health and Environmental Control.

Chem-Nuclear will designate Mr. James E. Purvis, CNSI Dire'e t o r of Licensing and Safety, as the " Contract Radiological S afe ty Of fic er fo r the BNFP." He will be responsible for working with the South Carolina Department of Health and Environmental Control in matters -related to the BNFP Radioactive Material License. Mr. Purvis' resume is attached.

The Radiation Procection Officer's training and experience (itema 8-and

~ 9 on the South Carolina Application for Radioactive Material License);

I Individual-' Users (item 9); Radiation Detection Ins truments (item 10);

Methods, Frequency and Standarde Used in Calibrating Ins truments Listed Above (item 11); Film Badges, Dosimeters, and Bio-Assay Procedures Used (item 12); Facilities and Equipment (item 13); Radiation Protection Program (item 14); and Waste Disposal (item 15) can be found on Chem-Nuclear Systems, Inc. , Radioactive Material Licenses Numbers 097, 287-01,~287-02,-and 287-03. These licenses are on file with the South Carolina Department of Health and Environmental Control, and all CNSI operations performed for AGNS uill follow the procedures listed on these

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B. SecurAq Inspection In addition, Chem-Nuclear will perform a quarterly security ins pe ct ion which will consist of:

1. ' Checking the outside doors and gates of all buildings for signs of attempted entry.
2. Entering the warehouses and administrative buildings and ch ecking for signs of entry or removal of equipment.
3. Inspecting the BNFF boundary for damages . All incidents will be reported to AGNS and damages to fences or gates will be repaired.

4 Checking posted signs for legibility and replacing them as necessary.

5. Checking for possible safety or fire protection problems throughout the ins pect ion.

CNSI will control accesr. to the BNFP via Osborne - Road. This will be accomplished using an electronically operated gate that can be con-trolled from the CNSI security building. Chem-Nuclear will receive one day's prior notice of any persons wishing to enter the AGNS Facility.

Upon arrival, all persons will be required to report- to the CNSI ,

security. station with proper identification. Individuals will also be required to check out at the security - station upon leaving the AGNS Facility.

A quarterly summary report detailing the quarterly inspections will be submitted to-AGNS. In ad di t io n , CNSI will pe rf o rm a preliminary investigation of any. abnormal findings and will recommend corrective action to the AGNS representative.

u gg JAMES E. PLRVIS 1433 Canttrbury Court Aiken, S. C. ~ 29801 803-648-6449 (Ecme) 803-259-1781 (Business)

March, 1981 - Director, Licensing and Safety present Chem-Nuclear Systerrs, Inc. '

P.O. Box 726 Barnwell, South Carolina 29812 i

Deputy Director, Regulatory Affairs '

Chem-Nuclear Systems, Inc.

P.O. Box 726 Barnall, South Carolina 29812 Manager, Regulatory Affairs Chem-Nuclear Systems, Inc.

P.O. Box 726 Barnwell, South Carolina 29812 Provide and maintain a workable regulatory system for site operations. Ensure coupliance in regulations. Provide CNSI Radiation Safety Officer functions. Provide A1 ARA guidance in operacions and equipment design. Maintenance of the Site Criteria and planning. Provide licensing functions for new sites and new operations, as necessary. Maintain accurate waste ir.rentory records in volute, location and activity, with periodic reports to regulatory agencies. Provide liaison, as necessary, between the site surveyor, site operations, site construction contractor and site engineerirg in site construction.

. Coordinate and perform special projects, requested by regulatory agencies and other CNSI departments, to i= prove and/or clarify site pcrformance and operations. Investigate all radiological incidents, license and health physics procedure violations and ensure proper reporting. Make notifications to custcmers and regulatory agencies of any discrepancies in shipments and make recocmendations for correction or disposition. Meet and work with regulatory agencies on all matters that affect Co:pany operations. Director of Emergency Safety Review Board functions.

Direct the preparation and inplementation of the co=pany-wide industrial safety program.

. Janes E. Purvis resume' Paga 2-June 1, 1983 October, 1979 - Supervisor, Health Physics March, 1981 Chem-Nuclear Systems, Inc.

P.O. Box 725 Barnwell, South Carolina 29812 Provided health physics supervision for operations of CNSI's Ica-Level Radioactive Waste Burial Facility. Responsibilities required a thorough knowledge of burial license requirements, NRC and DOI' regulations for packaging, transport and Site Crited a. Completely revised the site's Health Physics program and included an effective Health Physics Technician Training Program. Was instrumental in establishing and preparing the compcny's AIMA and Health Physics policies. Provided license preparation and liaison with regulatory agencies.

January, 1974 - Supervisor, Operational Safety October, 1979 Allied General Nuclear Services Barnwell, South Carolina 29812 Assisted in establishing the complete Health Physics Monitoring Program (Policy and Procedures) for a nuclear fuel reprocest:rg plant. Supervised the cractical application of all baalth physics and industrial safety functions required for preparation and start-up. Established and implesanted an elaborate and complete Health Physics Technician Training Program.

April, 1971 - Broker / Salesman January, 1974 Real Estate Sales and Investments Levy Realty Ccmpany las Vegas, Nevada September,1969 - Working Forenan, Eadiation Mcnitoring and Industrial Hygiene April, 1971 Reynolds Electrical and Engineering Company Mercury, Nevada Test Site Underground nuclear weapons testing (tunnels and drill holes).

. Responsibilities consisted of pre-shot planning, preparation l

and provisioning of equipment and materials required for re '

entry and recovery. Post shot responsibilities included l radiation protection for entry and re=cval of test equipment experiments from highly contaminated and radioactive areas.

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Palp 3 June 1, 1983 April, 1966 - Supervisor, Deconr eim tion Septed er, 1969 General Monitoring and Industrial Safety Pan American World Airways, Incorporated Nuclear Rocket Development Station Jackass Flats, Nevada .

Supervised the group responsible for all radiation monitoring for Nuclear Reactor Operations for the ROVER Program. These operations included all phases of hot cell and recote handlig operations, establiahing methods and procedures for denne=4-ation of all areas used for testing and disassembly.

August, 1963 - Senior Et@vering Technician August, 1965 Westinghouse Astrenuclear Laboratory Jackass Flats, Nevada Worked with group respcnsible for planning tests to be performed on the nuclear reactor for the NERVA Program, (Nuclear Engine Reactor for Vehicle Application), Project ROVER.

. March, 1961 - Licensed Reactor Operator March, 1963 Caroliras-Virginia Nuclear Power Associates Pressure Tube Reactor Parr, South Carolina _

Operation of nuclecr reactor, preparation of test procedures, start-up cad operating instructions and ere.rgency procedures.

Pre-operational test, checkout, start-up aad operation of all systems and cargenents associated with tFa reactor.

June, 1960 - Licensed Reactor Operator March, 1961 General Electric Test Reactor Vallecitos, California f Operating of a 30-M E test reactor.

EDUCATION Graduated frcm Eastran High School, Eastran, Georgia. Attended Diablo Valley College, Concord, California. Have had continuous intensive training in nuclear reactor tec'Tology, plant systems and health physics during the past c:eenty-three (23) years. This i training censisted of both classrocm and practical applicatien and was mandatory for obtaining nuclear power reactor operator license and health physics qualifications. Have had specialized training Lin Mine Rescue, Industrial Hygiene and Industrial Safety. Have participated in several training courses in effective supervision and management.

J. A. Buckham ,

Dr. James A. Buckham is President of Allied-General Nuclear ' Services.

He obr.ained his Ph.D. in Chemical Engineering from the University of Washington in 1953, preceded by an M.S. degree in 1948 and a B.S. degree in 1945 from the same institution.

Dr. Buckham has overall responsiblility for activities of AGNS and the Barnwell Nuclear Fuel Plant.

. Dr. Buckham'has been a leading ' figure in the development of nuclear reactor technology, the reprocessing of irradiated nuclear fuels, and the management of nuclear wastes. He is probably best known for his R&D work on the application of fluidized bed technology to the solidifica-tion of high-level radioactive waste and for the development and opera-tion of several new dissolution processes for irradiated reactor fuel elements.

He is the author or coauthor of over 25 technical publications related to nuclear technology, nuclear fuel reprocessing, and radioactive waste management and is active in the American Institute of Chemical Engi-

~

nee rs , the American Nuclear Society, American Chemical Society, and the Atomic Industrial Forum. In 1974, Dr. Buckham was awarded the Robert E. Wilson Award by the AIChE in re cogn it ion of his outstanding accomplishments. In 1976, he was elected a Fellow of AIChE, and in 1979 he was elected to a three year term as Director. He is a member of the honorary societies Tau Beta Pi, Sigma Xi, Phi Lambda Epsilon, and Zeta Hu Tau.

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e PACE 2 OF 10 BNFP SOURCE INVENTORY (CONTINUED)

Source De sc r i p t ion Serial No. Activity Assay Date Final Disposit ion Remarks Solid Salt C-2342 to 16 sources 1/17/83 Transferred to DOE C-2357 166.4 mci tot al/CoS7 0-2342 Included I/17/33 Transferred to DOE C-2343 Above Sealed Source C-1903 10 mci /CoS7 12/11/80 CNSI waste Scaled Snurce C-1904 10 mci /CoS7 12/11/80 CNSI waste Encapsulated C-1905 10 mci /CoS7 12/11/80 CNSI waste Encapsulated C-1906 10 mci /C157 12/11/80 CNSI waste Sealed Source C-1907 to mci /CoS7 12/11/80 CNSI waste Scaled Source C-1908 10 mci /CoS7 12/11/80 CNSI waste ,[

Encapsulated C-lo09 10 mci /CoS7 12/11/80 CNSI waste Sealed Encsu. C-1910 10 mci /CoS7 12/11/80 CNSI waste Sealed 7-14 I mci /Pu238 4/19/77 Transferred to DOE Encapsulated MCR Pu & BE-374 4.1 Ci/Pu238 Be 12/29/76 Transferred to DOE Sealed A-4530-5 300 Ci/Co60 9/72 CNSI Waste Pe nd ing Scaled in a 949-E #153 36 mci /Pu239 7/15/76 Tr ans f e r red t o DOE plastic vial Metal Pellet Sealed Encap. R-141, R-2966 7.01 pCi/U2 35 10/16/75 Transferred to DOE (3.26 g total)

Solid Scaled 94-238-2 (total) 40 Ci/Pu23eBe 10/2/75 Transferred to DOE Source 94-238-3 Solid Scaled CE-104 1 mci /Cel44 3/16/76 CNSI waste Solid Sealed 1000577 40 toi/Cs137 10/7/74 CNSI waste

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-BNFP SOURCE INVENTORY (CONTINUED)

Source Description Serial No. Ac t ivit y Assay Date Final Disposition Remarks Sealed Rod 909 113 mci /CsI37 '5/21/74 CNSI waste Source Sealed Rod 814 10.2 aci/ Col 37 .4/14/74 CNS! waste Source Calibrated 2638-1 10 mci / Cal 37 11/12/75 CNSI waste Source Sealed Solid Sealed Cat. No. (10 ea.) 2 mci ca. CNS! waste Source CHCQ 1126 20 mci total /Cel44 Solid Sealed Cat. No. 150 mci /Rul06 t/12/76 CNS! waste RKCQ 1127

~ Solid Sealed Cat. No. 4.2 mci / Cal 31 1/12/76 CNSI waste CDCQ 1128 Solid Sealed Cat. No. 42 mci /csI37 1/12/76 CNSI waste CDCQ l129 Solid Sealed 0905 19.8 Ci/Co60 CNSI waste Solid Scaled CCCQ 1130 '420 mci /Cel37 t/27/76 CNSI waste Sealed (79) 3037 2.7 mci /Pm R7 1979 One source to DOE with rifle.

Encapsulated 3289 One source vill be returned to DOE with revolver.

Liquid 83-1/ .037 mci /UZ35,Uz38 2/7/83 Golidified to CNSI waste Liquid 82-7 .1.33 mci /HNO3,U233 7/23/82- Solidified to CNSI waste U234,U235,U236,3238 -

Liquid 82-6 109 gEi/Zr 95 Nb95 4/28/82 Solidifia* to CNS! waste Liquid 82-5 l 14i/C057 4/30/82 Solidified to CNS! waste Liquid 82-4 I mci /Rul03 4/13/82 Solidified to CNSI waste Liquid - In 82-3 ' 22 g/U238,U235 Solidified to'CNSI waste Liquid 82-2 (SRM 996) .106 acl/Pu244 1/4/82 Transferred to DOE Liquid 82-1 127 gCi/Zr95, Nb95 12/22/81 Decayed

  • 6:

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PAGE 4 OF 10 BNFP SOURCE INVENTORY (CONTINUED) '

Source Desc ript ion Serial No. Activity , Assay Date Final Disposition Remarks Liquid Sale March 1981 1.32 g/U235 3/2/81 - Solidified to CNSI waste 5 January 1982 45.5 g/U238

. Liquid SRM-995 .005 g/U233 8/25/20- Solidified to U.S.E.-Washington -

. Liquid 8791HJ1 -2 mci /Cel44 8/19/80 Solidified to CNSI waste Liquid 10M28-J8 2 mci /Sr85 8/19/80 Solidified to CNSI waste Liquid 6801 -2 mci /Colo 8/19/80 Solidified to CNSI waste Liquid 58,68,7B,8B Al g total Ul.1 gU235 Solidified tot CNSI waste Liquid 59/60/34 29 pCi/Cel44 11/26/79 Solidified to CNSI waste Liquid So-30-12 Depleted - 59 34i/Cel44 6/11/80 Solidified to CNSI waste So-30-13 Depleted So-30-14 Liquid F-10124-1 20 mci /CobD 6/8/80 Solidified to. CNSI waste F-10124-0 Liquid RO/2 5/121 5 micro curies / 2/1/80 Solidified to CNSI waste mixed gamma Liquid 4233B .2 mci / Cal 37 8/29/79 Solidified to CNSI waste Liquid 4926-C' .38 pCi/H3 Solidified to CNSI waste Liquid SRM 4234-8 62 pCi/Sr30,.Y3D Solidified to CNSI waste

. 4234-16 Liquid RS/217/5 50 34i/Rd106 11/20/75 Solidified to CNSI waste Liquid SRM-4232-33 23 pCi/Aglio 6/4/74 Solidified to CNS1 waste Liquid SRM-4949 .193 pCi/Il29 9/29/73 Solidified to CNSI waste Liquid 63010 6 mci /Cel "* 11/13/75 _ Solidified to CNSI waste

I PACE 5 0F 10 '

BNFP SOURCE INVERTORY (CONTINUED)

Source-

. Description Serial No. Activity' ' Assay Date Final Disposition Remarks.

Liquid 82-2 .106 Hillicuries/ l/4/82 Transferred to inventory section Pu244 i Plated 44026 5 pCi/Se75 8/13/77 CNSI waste Plated 61008-63 5 mci /Cos7 10/4/78 CNSI waste Plated 62034-Sr-1 5 vC1/Se 75 10/4/78 CNSI waste Plated 7779-C2 5 mC1/ col 7 8/15/77 CNSI waste 878073-136 Plated SRM-4906-74 .36 gCi/Pu238 4/25/69 SRP waste Liquid - 6801 N4(2) 2 mci / Cal 37 8/19/80 Returned to CNSI Liquid item #Z27975 60 poi /kulD6 10/31/78 Solidified to SRP waste

. Code RKZ64

, Solution #59/48/12 Liquid 59/60/12 63 pci/Cel44 11/26/79 Solidified to' CNSI waste Liquid 50299/61008 5 mci /CoS7 5/19/78 Solidified to CNSI waste 4

Liquid 620ll 1 mci / Cal 34 9/l/74 Decayed Liquid 63027 25 mci /Sr90 7/23/76 Decayed Liquid (NEN) 989]A 2 mci /Coso 9/25/74 Decayed

, Liquid (NEN) 9891 119 pCi/Bal33 9/25/74 Decayed a Liquid (NEN) 1743 1 mci / Cal 37 9/25/74 Decayed-4 Plated 61008-63 5 mCL/CoS7 4/8/77 Solidified to CNSI waste Plated 62034-SR-1 5 mci /Se75 4/11/77 Solidified to CNSI waste

( Solid SRM944 Batch #15 .5 grams /Pu239 Not accepted. Returned to New w Brunswick Lab.

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BNFP SNH AND SOURCE NATERI AL INVENTORY

. Material Trans ac t ion Quantity Final Disposition Remarks Natural U Receipt 136,610.20 --

Receipt 100.01 --

Receipt 4.56 --

Receipt 2.64 --

136,717.41 Kg/U

, . Trans fe r 109.28 SRP

! Transfer 116,507.00 DOE-Paducah as UO3 I,

Transfer 0.14 NBS-NBL Transfer 14,222.ll Ke r r-McGee As Un solution Transfer .75.70 DOE-Hanford Wa t e Transfer 4.717.79 CNSI Waste Transfer 171.00 CNSI Waste - Not shipped yet Transfer 574.00 Allied-Hetropolis l 136,377.02 Kg/U Residual in Plant 5.0 Kg/U Est.

Inventory Di f ference(I) 335.39 Kg/U Composite Measurement Error (2) ~;+ 680 Kg/U (-0.5%)

1 (1) The invent ory dif ference is the arithmet ic dif ference between the measured receipt s and t ransfers, adjusted for the quantit y remaining in plant.

(2) The composite measurement error is an estimate of the uncertainty of the measurements made upon receipt and prior to t ransfer of SNM

, or source materials at the BNFP. This estimate is based on the results of calibrations, standards programs, and experience and is i expressed as a mass quantity and as a percent of throughput. Inventory diffarences within the range of uncert aint y are not stat ist ically significant.

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PACE 8 OF 10 ,

BNFP SNH AND SOURCE HATERI AL INVENTORY (CONTINUED) i I

Haterial Transaction Quantity- Final Disposition Remarks

' Plutonium Receipt 157.70 --

, Receipt 0.26' --

Receipt 31.00 --

Re aipt 25.30 --

Receipt 3.00 --

217.26 g/Pu

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Transfer 44.73 DOE-SRP i

Transfer 2.00 . NBS-N BL Transfer 132.12 DOE-SRP Waste +102 Transfer 30.82 DOE-H ANFORD ., Waste;+10%

209.67 g/Pu f nesidual in Plant 0.80 g/Pu:

Inventory Dif ference 6.79 g/Pu Composite Heasurement

, i. Error ~+16 g/Pu (based on +10% uncertainty on waste measurements)

I 4 U-233 Receipt 0.058 t --

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Receipt 1.270 --

i keceipt 0.025 --

233 1.353 g/u Transfer 0.860 DOE-S RP Transfer 0.470 DOE-SRP Waste +10%

Transfer 0.060 DOE-H ANFORD Waste;+10%

) 1.390 g/U 233 Residual in Plant Inventory Difference (0.037) g/U 233 Composite Measurement +0.06 g/U 233 (Based on +10% on waste, II on balance)

, Error 4

_ _ _ _ . . . _ _ __ . . ~..

PACE 9 0F 10

\

BNFP SNM AND SOURCE MATERI AL INVENTORY (CONTINUED)

Haterial Transaction- Quant it y Final Disposit ion Remarks Enriched U Receipt 3.66 --

Rece ip t 0.27 --

l Receipt 6.00 --

Receip t 22.64 --

Receipt 3.27 --

Rece ipt 4.20 --

235 40.04 g/U Transfer 13.38 DOE-S RP Standards Transfer 1.58 DO E-S R P Waste Transfer 3.60 CNSI Waste Transfer' 21.78 Internal Blended with 40.34 g/U 235 Nat. U. Inventory Residual in Plant Inventory Dif ference 0.3 g/U235 Composite Measurement

,, Error , + 0.4 g/U235 (,1.0%)

Thorium Receipt 59.00 Kg/Th i

Transfer 0.90 DOE-SRP Transfer 31.96 CNSI Waste Transfer 26.14 CNSI Waste not shipped 59.00 Kg/Th Residual in Plant Kg/Th Inventory Di f ference Kg/Th Composite Measurement Error. + 3.0 Kg/Th (+ 5%)

. - ~ . . - , . _ . - . _ .

PAGE 10 OF 10 BNFP SNM AND SOURCE NATERIAL INVENTORY (CONTINUED)

Mat erial Transaction Quant it y Final Disposit ion Remarks Depleted U Receipt 394.33 Kg/U --

r Transfer 8.07 DOE-SRP Transfer 2.43 Internal Blended with Enriched U Transfer 389.30 CNSI Waste - to be Shipped ,

399.80 Kg/U i

Residual in Plant Kg/U Inventory Difference (5.47) Kg/U Composite Measurement Error +20 Kg/U (5%)

it Ne pt unium Receipt 20.00 g/Np Transfer 10.80 DOE-SRP >

Transfer 6.20 DOE-S RP Waste Transfer 1.00 DOE-HANFORD Waste Transfer 3.00 CNSI Waste 21.00 g/Np Reafdual in Plant g/Np inventory Difference (1.00) g/Np Composite Measurement Error +2.00 g/Np (based on +10% on waste measurements)

. I e