Available: Technology, Safety and Costs of Decommissioning A Reference Small Mixed Oxide Fuel Fabrication Plant

BEST AVAILABLE COPY
NUREG/CR-0129
Vol. 1
TECHNOLOGY, SAFETY AND COSTS OF

DECOMMISSIONING A REFERENCE SMAll
MIXED OXIDE fUEL FABRICATION PLANT
Volume 1
Main Report
C.E. Jenkins, t:.S. Murphy

K.J. Schneidar
Pac;fic f'tlorthwest labora'i:ory

Operated by
Battelle Memorial Institute
Prepared for
U.S. Nuclear Regulatory Commissior.
NUREG/CR-0129
Vol. 1
TECHNOLOGY, SAFETY AND COSTS OF

DECOMMISSIONING A REFERENCE Sf\11ALL
MIXED OXIDE FUEL FABRICATION PLANT
Volume 1
Main Report
C.E. Jenkins, E.S. Mur,hy

K.J. Schneider
Manuscript Submitted: January 1979

Date Published: February 1979
Pacific Northwest Laboratory

Richland, WA 99352
Operated by
Battelle Memorial Institute
Division f"f Engineering Standards

Office of Standards Development
U.S. Nuclear Regulatory Commission
Under NRC FIN No. 82136
STUDY CONTRIBUTORS
Studx Coordinator
C. E. Jenkins C. E. Jenkins
Oecomnissioning Experience
G. H. Winsor E. S. Murphy
C. E. Jenkins
M. H. Arndda)
Decon~issioning Alternatives
and Study Approach Safety Assessments
K. J. Schneider C. E. Jenkins
C. E. Jenkins G. H. Holter
B!:gu1atory Considerations ~omparison with Other Studies
H. L Lippek C. E. Jenkins
R. J. Brauns
P. l. Hendrickson
K. J. Schneider Design Considerations
K. J. Schneider
Financial Alternatives C. E. Jenkins
P. L. Hendrickson
fa~ility Description G. H. Winsor

E. S. Hurph{
M. H. Arndt a) Editor
G. i-1. Holter
0. R. Payson
Disposition Criteria Methodolo9Y
R. B. McPherson
E. C. Watson
J. P. Corley
(a) Associated with Columbia Engineers, Inc.
iii
FOREWORD
BY
NUCL(AR REGULATORY COMMISSION STAFF
The NRC staff is in the process of reappraisir1g its regulatory position

relative to the decomnissioning of nuclear facilities.(l) As a part of this
activity NRC has initiated two series of studies through technical assistance
contracts. These contracts are being undertaken to develop information to
support the preparation of new standards covering decommissioning.
The first series of studies will cover the technology, safety and costs
of decofi1Tlissioning reference light water reactor nuclear facilities. Both
reactors and fuel cycle facilities are included. Facilities of current
design on typical sites are selected for the studies. Separate reports w·ill
be prepared as the studies of the various facilities are completed.
The f"irst report in this series was published in FY 1977 and covered a
fuel reprocessing plant. ( 2 ) The second report was published in FY 1978 and
covered a pressurized water reactor. ( 3} The following report is the third
of the series and deals with a small mixed oxide fuel ~abrication plant.
Additional topics wi 1 ! be reported on the tentatwe schedule as follows:
FY 1979 • Boiling Water Reactor
• Low Level Waste Burial Ground
• Uranium Fabrication Plant
FY 1980 • Uranium Mil1
• By-product Utilization Facilities
I {1) Plan for Reevaluation of NRC Polic,¥ on Decommissioning of Nuclear

Facilities. NUREG-0436, Office of Standards Development, U.S. Nuclear
Regulatory Cormtission, March 1978.
(2} lechnology, Safety and Costs of Decommissioning a Reference Nuclear
Fue1 Reprocessing Plant. NUREG-0278, Pacific Northwest laboratory
for U.S. Nuclear Regulatory C01r,mis.sion, October 1977.
(3) Technology, Safety and Costs of Decommissioning a Reference Pressurized
Water Reactor Power Station. NUREG/CR-0130, Pacific Northwest Laboratory
for U.S. Nuclear RegulatOi"Y. Commission, June 1978.
I
v
The second series of studies covers the facilitation of the decon1111ission ...
ing of light water reactor nuclear facilities. Both reactors and fuel cycle
facilities are included. The major purpose is to identify modifications or
design changes to facilities~ equipment and procedures which will improve
safety and/or reduce costs.
Three reports are planned in the second series. The first consists of
an annotated bibliography on the decommissioning of nuclear facilities. ( 4 )
The other two facilitation reports are tentatively scheduled as follows:
FY 1979 • light Water Reactors
FY 1980 • Fuel Cycle Facilities
The information provided in this report on the small mixed oxide fuel
fabrication plant, including any comments, will be included in the record
for consideration by the Commission in establishing criteria and new standards
for decommissioning. Persons wishing to comment on this report should mail
their comments to:
Chief
Fuel Process Systems Standards Branch
Division of Engin~ering Standards
Washington, DC 20555
-----·--
(4) Decomm·issioning of Nuclear Fa::ilities - ~n Annotated Bibl !oarapht_.
NUREG/CR-0131 ~ Pa·cific Northwest laboratory for U.S. Nuclear
Regulatory Commission~ Septem':ler 1978.
vi
ABSTRACT
Safety and cost information are developed for the conceptual decommis-
sioning of a small mixed oxide fuel fabrication plant {MOX) with character-
istics similar to the Cimmar·on Plutonium Facility. The process building, the
contaminated sewage lagoon, and the conceptual liquid waste evaparation and
uranium nitrate 1oad-in facilities are postulated to be decommissioned in this
study. The plant is conceptually decommissioned to three decommissioning
states or modes: Immediate Oismantle~ent, Safe Storage with Deferred Dismantle-
ment, and Entombment. These modes range from complete removal of radioactivity
above de minimus levels, with subsequent release of the site for unrestricted
use, to minim<:tl decommissioning requiring significant continued maintenance
and 3urveil1ance.
The decommi:;sioning methods c:ssurned for use in each decommissioning mode
are based on state-of-the-art techno 1ogy. Assuming favorab 1e work perfor·mance,
the elapsed time following plant ~;hutdown required to perform the decommis-
sioning work in each mode is estimated to be 1.6 years for Immediate Dismantle-
ment, 1.0 years to olace the plant in Safe Storage and 1.5 years to accomplish
Defe1rred OismantlemEmt) and about 0.65 years to entomb the facility. Planning
and prepal~ation for· decommissioning prior to plant shutdown is estimated to
t·equire about 2 years for Immediate Oismantlerm~nt and about 1.5 years for
either Entombment or Preparations for Safe Storage. Planning and preparation
for Defet-red Dismantlement is estimated to rE.yuire about 2 years prior to
beginning the actual work.
Decomnlissioning costs, 'in te"ms of 1978 donars, are estimated to be
$7.7 mill-ion for Immediate Dismantlement and $2.8 m·illion for· Entombment.
Placin9 the facility into Custodi:li Safe Storage is estimated to cost $3.5
million, and the annual costs of Interim Care are estimated to be about
$0.6 million. Deferred Dismantlenent is estimated to cost about $7.3 million.
All of these estimates include a 25% contingency. The combination of Custodial
s,~f,e Storage for 10 or 30 years f) 11 owed by Defet"red Oi sm.:u1t l ement is estimated
to cost $16.2 million and $28.2 million, respectively, in nondiscounted 1978

do11ar·s.
Safety analyses irtdicate that radiological and nonradiological safety
impacts from decommissioning activHies should be smalL The 50-year radiation
dose commitment to the members of the !IUb 1 i c from airborne re 1eases from
normal decommiss·ioning activities were estimated to be less than 0.5 man-rem.
Radiation doses to the public from accidents were also found to be ·iow for
all phases of decommissioning. Intrusion into the entombed facility by
archaeologists or scavangers is examined and potential radiation dose to the
intruder is estimated to Je severe. uccupational radiation doses from normal
initial deco11111issioning operations (excluding transport operations) ,are estimated
•
to be 70 man-rem for Immediate Dismantlement, 23 man--rem for placin9: the
facility in Custodial Safe Storage, 7.1 man-rem annually during the]Interim
Care period, 70 man-rem for Deferred Dismantlement, and 9.4 man-rernjfor Entomb-
' '
ment. Deferred Dismantlement ircreases slightly the public and occ.Jpational
radiation doses. The number of f:Italities ancl serious lost-tim~ injuries n)t
related to radiation arf~ found to be sma11 for all of the decommis~.ioning
modes considered.
Comparison of the cost estimates shows that Entombment is the least

expensive~ followed by Immediate Dismantlement, and by Custodial Safe Storage
with Deferr.ed Dismantlement. The costs of Interim Care make Custodial Safe
Storage quite expensive. Entombm1~nt has the disadvantage of requiring th~~
property to be dedicated in perpe~:uity as a nuclear waste dispma·l site.
Methods for assurin~ that the 1 icensee has adequate funds -~or decommi s-
sioning are considered. Methods ·investigated (all based on exp~cted decom-
missioning costs) range f"om a single payment 1,o~hen plant operations beqin
to accumulative payments during the ncrmal plant operating period, to a sing·le
payment when normal plant operations cease and decommissioning begins.
viii
VOLUME 1
TABLE OF CONTENTS
STUDY CONTRIBUTORS. "iii
FOREWORD . v
ABSTRACT vii
1.0 INTRODUCTION . ., -1
REFERENCES . 1-5
2.0 SUMMARY. 2-l
2.1 REVIEW OF DECOMMISSIONING EXPERIENCE 2-2

2.2 STATUS OF REGULATORY GUIDANCE. 2-3
2.3 APPROACHES TO FINANCING DECOMMISSIONING . 2-4
2.4 METHODOLOGY FOR DETERMINING .~CCEPTABLE CONTAMINATION
LEVELS FOR A SMALL MOX FUEL FABRICATION FACILITY 2-4
2.5 IMPORTANT FACILITY CHARACTERISTICS 2-6
2.6 ESTIMATED RADIONUCLIDE INVENTORIES 2-6
2.7 DECOMMISSIONING METHODS. 2-8
2.7.1 Dismantlement Procedures . 2-9

2.7.2 Custodial Safe St,rage Procedures . 2-9
2.7.3 Entombment Procedures 2-10

2.8 COSTS. 2-ll
2.9 SAFETY . • I . 2-13
2 . 10 WASTES 2-1 5
2.11 OVERALL COMPf\RISON OF DECOMMISSIONING ALTERNATIVES. 2-1 5
3.0 REVIEW OF DECOMMISSIONING EXPERIENCE . 3-1
ix
3.1 HISTORY AND STATUS . 3-2
3.1.1 The Plutonium Fabrication Facility (PFF) at Argonne
National Laboratory (ANL). 3-3
3.1.2 [lecorrmissioning of the Special Metallurgical (SM)

Building at Mound laboratory. 3-5
3.2 LESSONS LEARNED FROM DECOMMISSIONING EXPERIENCE. 3-8

REFERENCES . 3-10
4.0 DECOMMISSIONING ALTERNATIVES AND STUDY APPROACH 4-1

4.1 DECOMMISSIONING ALTERNATIVES . 4-1
4.1.1 Definition of and Rationale for Safe Storage with
Deferred Dismantlement 4-5
4.1.2 Definition or and Rationale for Entombment. 4-8
4.1.3 Definition of and Rationale for Dismantlement 4··9

4.1.4 Viable Combinations of Decommissioning Modes 4-10
4.2 TECHNICAL APPROACH . 4-12
4.3 KEY STUDY BASES . 4-15
REFERENCES . 4-19
5.0 REGULATORY AND SAFEGUARDS CONSIDERATIONS. 5-1
5.1 EXISTING REGULATIONS~ STANDARDS, AND GUIDES 5-1
5.1.1 Federal Jurisdiction . 5-2
5.1.1.1 NRC Regulations. 5-8
5.1.1.2 License Termination . 5-·l 0
5.1.2 State and Local Jurisdiction. 5-12
5.1.3 Safeguards Considerations. 5-14
5.1.4 Regulation of Effluents . 5-20

5.2 REGULATORY CONSIDERATIONS DURING DECOMMISSIONING PHASES . 5-22
5.2.1 Regulatory Considerations During Decommissioning
Planning . 5-22
5.2.3 Regulatory Considerations During Interim Care 5-25
5.2.4 Operator's Checklist for Federal Regulations 5-26
5.3 CONCLUSIONS. 5-28
REFERENCES . 5-29
6.0 ALTERNATIVE APPROACHES TO FINANCING DECOMMISSIONING 6-1
6.1 NEED FOR ASSURANCE OF DECOMMISSIONING FUNDS . 6-1

6.2 APPROACHES TO PROVIDING FUNDS FOR DECOMMISSIONING AND
LONG-TERM CARE. 6-3
6.2.1 Creation of a Sinking Fund to Accumulate Sufficient
Decommissioning Funds During the Facility's Operating
Life. 6-4
6.2.2 Prepayment of Anticipated Decommissioning Costs 6-7
6.2.3 Payment of Decommissioning Costs when Incurred. 6-8
6.3 DECOMMISSIONING FUNDING IN THE EVENT OF PREMATURE FACILITY
CLOSURE . 6-10
6.3.1 Initial Cash P<,iyment . 6-11
6.3.2 Higher Initial Sinking Fund Charges . 6-12

6.3.3 Surety Bonds . 6-12
6.4 PROVISIONS FOR ACCIDENT AND CONTINGENCY COSTS . 6-12
6.5 WHO SHOULD CONDUCT DECOMMISSIONING ACTIVITIES . 6-14
6.6 POWER OF STATE GOVERNMENT TO IMPOSE FINANCIAL OBLIGATIONS
ON FACILITY OPERATORs 6-15
6.7 SUMMARY . 6-16
REFERENCES . 6-17
7.0 CHARACTERISTICS OF THE REFERENCE MIXED OXIDE PLANT . J-1
7.1 SITE DESCRIPTION . 7-1
7.2 PROCESS OESCRIPTION . 7-5
7.2.1 Coprecipitation Head-End . 7-5
xi
7.2.2 Dry Process Head-End . 7-8
7.2.3 Pellet F()r·mation and Fuel Rod Assembly 7-9
7.2.4 Scrap Recovery . 7-9
7.2.5 Waste and Effluent Processing . 7-11
7.3 PLANT DESCRIPTION. . 7-11
7.3. 1 Facility Description • 7-15

7.3.2 Ventilation System Description . 7-16
7.4 RESIDUAL RADIOACTIVITY ESTIMATES. 7-19

7.5 CHEMICAL INVENTORIES. 7-21
REFERENCES . 7-22
8.0 METHODOLOGY FOR DETERMINING ACCEPTABLE CONTM4INATION LEVELS
FOR PUBLIC USE OF THE DECOMMISSIGNED REFERENCE MIXED OXIDE
FUEL FABRICATION FACILITY AND SITE. 8-l
8.1.1 Definition of Use Catagories. ..,-3
8.1.2 Disposition Criteria . 8-5

8.2 CALCULATION OF THE ACCEPTABLE CONTAMINATION LEVELS AT THE
DECOMMISSIONED REFERENCE MOX PLANT . 8-9
8.?.1 Acceptable Residual Contamination Levels in the
Reference MOX Facility. 8-9
8.2.2 Acceptable Radioactivity levels on the Reference
MOX Site . 8-12
8.2.3 Acceptable Contamination Levels on MOX Facility
Equipment . 8-17
8.3 EXISTING GUIDANCE ON RESIDUAL CONTAMINATION . 8-17
8.4 MEASUREMENT CAPABILITY . 8-17
REFERENCES • 8-24
9.0 DECOMMISSIONING ACTIVITIES 9-1
9.1 DECOMMISSIONING BY IMMEDIATE DISMANTLEMENT 9-l
xii
9.1.1 Program Plan 9-l
9.1.1.1 Planning and Preparation. 9
9. 1. 1.2 Final Processin9 Inventory Cleanout 9-5

9.1.1.3 Decontamination. 9-5
9.1.1.4 Disassembly and Transport 9-7

9. 1.1.5 Demolition and Site Restoration 9-12
9.1 .2 Quality Assurance Program. 9-13

9.1.3 Work Schedule Estimates 9-15
9.1.4 Essential Systems a11d Services 9-15
9.1.5 Security 9-17
9.2 DECOMMISSIONING BY CUSTODIAL SAFE STORAGE. 9-17

9.2.1 Program Plan . 9-18
9.2.1.1 Planning and Preparation. 9-20
9.2.1.2 Final Processing Inventory Cleanout 9-22
9.2.1.3 Facility Decontamination. 9-23
9.2.1.4 Equipment Deactivation and Isolation of
Contaminated Areas. 9-26
9.2. 1.5 Disposal of Radioactive Materials. 9-27
9.2.1.6 Interim Care A~tivities . 9-28
9.2.1.7 Quality Assurance 9-29
9.2.3 Essential Systems and Service~ 9-29
9.3 INTERIM CARE FOR CUSTODIAL SAFE STORAGE 9-31
9.3.1 Surveillance and Maintenance Activities . 9-3?
9.3.2 Environmental Surveillance Program. 9-33
9.3.3 Security 9-33
xiii
9.3.4 Quality Assurance . 9-34
9.3.5 Essential Systems and Services . ~.

9-34
9.4 DECOMMISSIONING BY DEFERRED DISMANTLEMENT. 9-35
9. 5 DECOMMISSIONING BY ENTOMBME;n. 9-·37
9.5.1.1 Planning and Preparation. 9-39
~.5.1.2 Final Processing Inventory Cleanout 9-39
9.5.1.3 Facility Decontamination. 9-40
9.5.1.4 Equipment Deactivation and Isolation of
Contaminated Areas to be Entombed. 9-41
9.5.1.5 Disposal of Radioactive Materials. 9-43
9.5.1.6 Quality Assurance . 9-43
9.5.3 Essential Systems and Services . 9-44
9.5.4 Environmental Surveillance Program. 9-46
REFERENCES • 9-47
10.0 DECOMMISSIONING COSTS. 10-1
10.1 COST ESTIMATES FOR H4MEDIATE DISMANTLEMENT . 10-1
10.1.1 Manpower Requirements and Costs for Immediate
Dismantlement . 10-3
10.1.1.1 M3npower Requirements 10-3
10.1.1.2 Manpower Costs. 10-9
r-
10.1.2 Material and Equipment Requirements and Cost:. for

lm11ediate Dismantlement . 10-12
xiv
10.1.3 Waste Management Requirements and Costs for
Immediate Dismantlement . 10-13
lO.l.::S.l Waste Management Requirements. 10-13
10.1.3.2 Waste Management Costs . 10-16
10.1.4 Miscellaneous Owner Expenses for Immediate
Dismantlement • 10-17
10.1.5 Specialty Contractor Costs for Immediate
Dismantlement . 10-18
10.1.6 Building Demolit1on and Site Restoration 10-20
10.2 ESTIMATED COSTS OF PREPARATIONS FOR SAFE STORAGE . 10-20
10.2.1 Manpower Requirements and Costs of Preparations for
Safe Storage. 10-22
10.2.1.1 Manpower Requirements 10-22
10.2.2 Estimated Material and Equipment Requirements and
Costs of ?reparations for Safe Storage . 10-25
10.2.3 Estimated Management Requirements and Costs of
Preparations for Safe Storage . 10-25
10.2.3.1 Waste Management Requirements. 10-27
10.2.3.2 Estimated Waste Management Costs. 10-28
10.2.4 Miscellaneous Owner Expenses for Preparations for
Safe Storage. 10-28
10.2.5 Speciality Contractor Costs for Preparations for
Safe Storage. 10-29
10.3 COST ESTIMATES FOR INTERIM CARE. 10-30
10.3.1 Manpower Requirements and Costs for Interim Care. 10-30
10.3.2 Material and Equipment Requirements and Costs for
Interim Care. 1~-32
10.3.3 Miscellaneous Owner Expenses During Interim Care. 10-33

10.4 ESTIMATED COST OF DEFERRED DISMANTLEMENT. 10-33
XV
10.4. 1 Manpower Requirements and Costs for De""'erTed
Dismantlement 10-35
10.4.2 Material and Equipment Requirements and Costs

for Deferred Dismantlement . 10-37
10.4.3 Wast~ Management Requirements and Costs for
Deferred Dismantlement 10-37
10.5 COST ESTIMATES FOR ENTOMBMENT 10-41
10.5.1 ~ianpm-1er Requirements and Costs for Entombment 10-43
10.5.1 .1 Manpower Requirements 10-43

10.5.2 Material and Equipment Requirements and Costs for
Entombment 10-48
10.5.3 Waste Management Requirements and Costs for Entomb-
ment 10-49
10.5.3.1 Waste Management Requirements. 10-49
10.5.3.2 Waste Management Costs . 10-50
10.5.4 Miscellaneous Owner Expenses for Entombment 10-52
10.5.5 Specialty C3ntractor Costs for Entombment . 10-53
10.5.5.1 Foundation and Floor Grouting Contractor 10-54
10.5.5.2 Foundation Consultant 10-54
10.5.5.3 Crane Rental 10-54
10.5.6 Building Demolition, Earth Protective Cover for
Entombment and Site Restoration 10-55
10.6 COST COMPARISONS. 10-55
REFERENCES 10-58
11.0 PUBLIC AND OCCUPATIONAL SAFETY OF DECOMMISSIONING A REFERENCE
SMALL MOX FUEL FABRICATION FACILITY . 11-1
xvi
11.2 PUBLIC SAFETY EVALUATION OF DECOMMISSIONING THE REFERENCE
SMALL MOX FUEL FABRICATION FACILITY 11-7
11.2.1 Radiological Safety Evaluation of Routine

Decommissioning Operations . 11-7
11.2.2 Radiological Safety Eva·luation of Postulated

Decommissioning Accidents 11-11
11.2.3 Nonradiological Safety Evaluation. 11-14

11.3 OCCUPATIONAL SAFETY EVALUATION OF DECOMMISSIONING THE
REFERENCE MOX PLANT. 11-14
11.3.1 Radiological SaTety Evaluation of Routine
Decommissioning Activities . 11-15
11.3.2 Safety Evaluation of Construction or Industrial
Accidents. 11-21
11.4 TRANSPORTATION SAFETY EVALUATION FOR DECOMMISSIONING
THE REFERENCE SMALL MOX FACILITY 11-21
11.4.1 Radiological Safety Evaluation of Routine

Transportation Activities 11-23
11.4.2 Radiological Safety Evaluation of Postulated
Transportation Accidents. ll-25
11.4.3 Nonradiological Transportation Safety Evalu-
ation . ll-27
REFERENCES 11-29
12.0 DISCUSSION OF RESULTS. 12-1
12. 1 REFERENCE 1 : 1975 ANL STUDY. 12-2

12.2 REFERENCE 2: 1974 ANL-8124 STUDY . 12-3
12.3 REFERENCE 3: 1974 ARH-ST-106 STUDY 12-4
12.4 REFERENCE 4: 1976 MLM-2381 STUDY . 12-4
12.5 REFERENCE 5: 1977 ARH-ST-141 STUDY 12-5
12.6 REFERENCE 6: 1978 DP-1473 STUDY 12-6
12.7 DISCUSSION OF STUDY RESULTS . 12-7
REFERENCES 12-11
xvi i
13.0 DESIGN CONSIDERATIONS FOR THE FACILITATION OF OECOM~HSSIONING 13-1
14.0 GLOSSARY • 14-1
14.1 ABBREVIATIONS, SYMBOLS AND SI UNITS 14-1
14.2 GLOSSARY DEFINITIONS • 14-3
REFERENCES • 14-19
xviii
TABLE OF CONTENTS - VOLUME 2
APPENDIX A - REFERENCE SMALL MOX FUEL FABRICATION FACILITY

DESCRIPTION. . . . . . • . . . . . A-1
APPENDIX B - SITE DESCRIPTION DETAILS . . . B-1
APPENDIX C - RESIDUAL RADIONUCLIDE INVENTORY ESTIMATES. . C-1
APPENDIX D - PAYMENTS NEEDED TO FINANCE DECOMMISSIONING . D-1
APPENDIX E- RADIATION DOSE METHODOLOGY . . . . . . E-1
APPENDIX F - GENERAL DECOMMISSIONING CONSIDERATIONS. . . F-1
APPENDIX G - DECOMMISSIONING ACTIVITY DETAILS. G-1
APPENDIX H - COST ASSESSMENT DETAILS. H-1
APPENDIX I - SAFETY ASSESSMENT DETAILS I-1
xix
VOUJt-1E l
LIST OF FIGURES
4.1-1 Generalized Decommissioninq Path\'mys and A1ternatives fC'r

-t4any Fuel Cycle Facilities. 4-11
4. l"~-1 Approach for Decommi S'> ion 'lr1g Study 4-13
7.2-1 Sirrplified Process Flo~ Qiagram for Reference Mixed Oxide Fuel
Fatr'ication Plant. 7-7
7.3-1 Iscme:tric: of Refere:r.ce !"1ixed Oxide Plant 7-13
7.3-2 Sinp1ified Flow Diagr·am for MOX Plant Ventilation System. 7--18
8.1-1 Lo~ic Diagram for the Relationship of Disposition Criteria

to Referer.ce and Sp•ecific Decomm·issioning Studies 8·-5
8.1-2 De·:ails of the Di~·;>osition Criteda l¥1ethodo 1 ogy Based on

Annua 1 Dose. 8··8
9.1-1 Seluence of Major Dismantlement Activities 9-2

9.1-(~ Sequence and Schedule of the Planrling and Preparation Phase
of Immediate Dismantlement. 9-3
9.1-3 DE:contaminatior. anc. Oismant1ement Sequence for Major
A1·eas in the fq'J)( Fabdcation Plant . 9-9
9.2-1 Sequence and Schedule of the Planning and Preparation

Phase of Custodial Safe Storlge . 9-20
9.2-2 ~iequence and Sched~le of Activities for Custodial Safe Storage
tor· Major· Ar-eas in the MOX Fuel Fc:tbrication Plant 9-30
q_s-1 Sequence and Schedule of the Planning and Preparation Phase
of Entombment . 9-39
9.5-2 Work Schedule Estimate for Entombing the Reference MOX Facility 9-44
10.1--, Postu-lated O·rgo.nization Chart fov· Immediate Oism.:1ntlf:~ment 10-5
10.2-1 Postulated Organization Chart for Preparations for Safe

Storage • 10-23
10.2-1 Postulatecl Organization Chart for Interim Care 10-3'
10.5-1 Postulated Or~janization Char·t for Entombment. 10-4~
XX
VOLUME 1
LIST OF TABLES
2.4-1 Example of Maximum Acceptable Residual Contamination

Levels for the Reference Radionuclide Mixture in the
Reference MOX Facility and on the Gener-ic Site . 2-5
2.5-1 Characteristics of the Reference Small MOX Fuel Fabri-
cation Plant and Their Effects on Decommissioning . 2-7
2.8-1 Summary of Estimated Costs for Decommissioning the
Reference Small MOX Fuel Fabrication Plant
2.8-2 Decommissioning Cost Distribution 2-12
2.9-1 Summary of Safety Analysis - Decommissioning of Reference
Small MOX Fuel Fabrication Plant. 2-14
2.10-1 Radioactive Wastes from Decommissioning 2-16
2.11-1 Comparison of Study Results 2-16
3.1-1 The Status of Plutonium Fuel Fabrication Facilities 3-2
4.1-1 D·igest of Contemporary Decommissioning Mode Definitions and
Deconmissioning f'lode Characteristics Ll-3
5.1-1 Principal Feder·al Agencies and Statutory Authority that
May Affect Decommissioning. 5-3
5.2-1 Abbreviated Checklist of Principal Federal Regulatory Require-
ments that r1ay l-\pply to the Decommissioning of o. Small f40X
Facility. 5-27
7.1-1 Estimated Maximum Quantities of Radioactive Materials Deposited
on the Generic MOX Site Over a 10-Year Operating Lifetime 7-4
7.2-1 Overall Processing Characteristics of the Reference Mixed Oxide
Fuel Fabrication Plan 7-6
7.3-1 Fu~ctional Uses of Process Rooms in Reference Plant 7-17
7.4-1 Est:1mated Radioactivity Levels in Reference MOX Plant .ll.fter
F"ini.il Inventory Cleanout and After Decommissioning Decontami-
nation Operations. 7-20
X Xi
B. Example Acceptable Contamination Levels Within the Refer-
ence MOX Facility at Plant Shutdown (Unrestr·icted Use) B-lO
8.2-2 Maximum Acceptable Residual Contamination Levels Within

the Reference MOX Facility at Plant Shutdown (Unrestricted
Use) . . . . . . . . . . . . . . . . . . 8- ll
8.2-3 Residual Contamination Levels on the Generic MOX Site

(Class W Material) 8-14
8.2-4 Residual Contamination Levels on the Generic MOX Site

(ClassY Material) 8-14
8.2-5 Maximum Acceptable Residual Contamination Levels on the

Generic MOX Site at Plant Shutdown and Selected Times
After Shutdown (The Site was Plowed and all Exposure
Pathways are Included) . 8-15
8.2-6 Summary of the Disposition Criteria fat· the Reference

MOX Facility and Generic Site. 8-16
8.3-l ANSI N328 Surface Contamination Limits. 8-18
8.3-2 Acceptable Surface Contamin~tion Levels from Appendix A
of Reference 3
8.4-1 Detection Capabilities for Direct Surveys with Portable
I:.struments. 8-20
8.4-2 Detection Capabilities for Environmental Sample Analysis. 8-22

8.4-3 Comparison of Measurement Methods fm~ Radiation Sur'/I.:!YS
to PermH Unrestricted Use. 8-23
9.1-l Systems and Services Required During Immediate Dismantlement 9-16
9.2-1 Specialty Contractors Utilized During Decommissioning by
Custodial Safe Storage . 9-31
9.3-l Systems and Services Requil~ed During the Interim Care
Period of Custodial Safe Storage. 9-35
9.5-1 Specialty Contractors Utilized During Entombment 9-44
9.5-2 Systems and Services Required During Entombment. 9-45
·!o.l-1 Summary of Estimated Immediate Dismantlement Costs. 10-2
10.1-2 Summary of Manpower Utilization and Staff Cost~ for Planning

and Preparation Phase of Immediate Dismantlement 10-10
10.1-3 Summary of Manpower Utilization and Stoff for the Dismantle-

ment Phase • 10-11
xxii
10.1-4 Estimated Material and Equipment Requirements and Costs
for Immediate Dismantlement 10-12
10.1-5 Waste Disposal Requirements for Immediate D·ismantlement. 10-15

10.1-6 Estimated Costs for Packaging, Transportation and Disposal
of kaji1active Material from Immediate Dismantlement. 10-16
10.1-7 Estimated Miscellaneous Owner Expenses for Immediate
Dismantlement. 10-17
10.1-8 Subcontractor Cost to Decommission the Sanitary Lagoon 10-19
10.1-9 Costs of Building Demolition and Site Restoration. 10-20
10.2-1 Summary of Estimated Costs of Preparations for Safe Storage 10-21
10.2-2 Summary of Manpower Utilization and Staff Costs for Planning
and Preparation Phase of Preparations for Safe Storage 10-24
10.2-3 Summary of Manpower Utilization and Staff Costs for
Decommissioning Phase of Preparations for Safe Storage 10-25
10.2-4 Estimated Costs of Equipment and Supplies for Preparations
for Safe Storage. 10-26
10.2-5 Waste Dispoal Requirements of Preparations for Safe Storage 10-27
of Radioactive Material from Preparations for Safe Storage. 10-28
10.2-7 Estimated Miscellaneous Owner Expenses During Preparations
for Safe Storage. 10-29
10.3-1 Estimated Annual Costs of Interim Care 10-31
10.3-2 Estimated Annual Staff Requirements for Interim Care. 10-33
10.4-l Summary of Estimated Deferred Dismantlement Costs. 10-34
10.4-2 Su~nary of Manpower Utilization and Staff Costs for ~~anning
and Preparation Phase of Deferred Dismantlement 10-36
10.4-3 Summary of Manpower Utilization and Staff Costs for Decommis-
sioning Phase of DefetTed Dismantlement . 10-36
10.4-4 Estimated Material and Equipment Requirements and Costs for
Deferred Dismantlement. 10-38
10.4-5 Estimated Waste Disposal Requirements for Deferred Dismantle-
ment. 10-39
xxiii
of Radioactive Material from Deferred Dismantlement 10-40
10.5-1 Summary of Estimated Entombment Costs. 10-41
10.5-2 Summary of Manpower Utilization and Staff Costs for Planning
and Preparation Phase of Entombment 10-46
10.5-3 Summary of Manpower Utilization and Staff Costs for the
Entombment Phase. 1'J-4 7
10.5-4 Material and Equipment Requirements and Costs for Entombment 10-48
10.5-5 Waste Disposal Requirements for Entombment . 10-51
of Radioactive Material from Entombment . 10-52
10.5-7 Estimated Miscellaneous Owner Expenses for Entombment 10-53
10.5-8 Foundation and Floor Grouting Contractor. 10-54
10.5-9 Cost of Building Demolition, Earth Protective Cover for
Entombment and Site Restoration. 10-56
10.6-l Cost Comparison for Decommissioning Options. 10-57
11.1-1 Anticipated Airborne Radioactive Releases During
Routine Decommissioning Activities. 11-5
11.1-2 Postulated Accidental Airborne Radioactive Releases
During Decommissioning. 11-6
11.2-1 Summary of Radiation Doses to the Maximum-Exposed Individual
From Airborne Radionuc1ides Released Durinq Normal Decommis-
s i ani ng Activities . 11-9
11.2-2 Summary of Radiation Doses to the Population from Airborne Radio-

nuclides Released During Normal Decommissioning Activities 11-10
11.2-3 Summary of Radiation Doses to the Maximum-Exposed Individual
from Accidental Airborne Radionuclide Releases During Decom-
missioning Activities . 11-12
11.3-l Summary of the Estimated External Occupational Radiation

Exposure for Inplant Activities During Immediate Dismantlement
of the Reference Small MOX Facility 11-16
11.3-2 Summary of the Estimated External Occupational Radiation
Exposure During Preparations for Safe Storage . 11-17
xxix
11.3-3 Summary of the Estimated Externa~ Occupational Radiation
Exposure for Inplant Activities of Entombment of the
Reference Small MOX Facility. 11-18
11.3-4 Estimated Average Quarterly Occupational Radiation Dose
from Decommissioning Activities. 11-19
11.3-5 Summary of the Estimated External Occupational Radiation
Exposure During Interim Care Following Preparations for
Safe Storage . 11-19
11.3-6 Summary Qf the Estimated Collective Occupational Radiation
Doses for Onsite Decommissioning Activities of the Reference
Small MOX Fuel Fabrication Faciltiy 11-20
11.3-7 Estimated Occupational Lost-Time Injuries and Fatalities
from Decommissioning Activities 11-22
11.3-8 Estimated Occupational Lost-Time Injuries and Fatalities
from Interim Care Activities Following Preparations for
Safe Storage 11-22
11.4-1 Estimated Collective Radiation Dose from Truck Transport
of Radioactive Wastes . 11-24
11.4-2 Transportation Accident Severity Categories. 11-26
11.4-3 Estimated Frequencies and Radioactivity Releases for Selected
Transportation Accidents . 11-26
11.4-4 Estimated Injuries and Fatalities from Decommissioning
Transportation Accidents . 11-28
12.7-1 Actual or Estimated Costs for Immediate Dismantlement
of TRU-Contamin~teo iacilities . 12-8
12.7-2 Comparison of Average Worker Radiation Dose for Immediate
Dismantlement of TRU-Contaminated Facilities 12-9
XXV
1.0 INTRODUCliON
This report presents the results of a study sponsored by the U.S. Nuclear
Regulatory Cmnmission (NRC) to conceptually decommission a small facility for
fabrication of mixed oxide fuels for nuclear reactors. It is the third study
comp 1eted as a part of the avera 11 NRC progr·am covering the decomm·i ss i ord ng
of LWRs and LWR fuel cycle facilities. (l, 2 )
The primary purpose of this study is to provide information on the tech-
nology, safety, and costs of decommissioning a small mixed oxide fuel fabrica-
tion plant. This information is intended to contribute background data
and provide bases for future regulations regarding decommissioning of such
facilities. Decommissioning techniques are reviewed and conceptually applied
to a reference facility. Potential new guidelines and criteria are developed
and utilized where appropriate.
Decommissioning of a nuclear facility can be defined as the measures
taken at the end of the faci1ity S operating lifetime to assure the continued
1
protection of the public from the residua·l radioactivity and other potential
safety concerns associated with the retit·ed facility. A spectrum of possible
decommissioning options are possible for such a facility and, for this study,
three specific options are examined. They are: Immediate Dismantlement,
Safe Storage with Deferred Dismantlement, and Entombment.
HS used in this study, these decommissioning options are defined as
follows:
• Immediate Oismantlement(a) - Radioactive materials are removed and the

facility is decontaminated and disassembled immediately following final
shutdown. Upon r.ompletion, the property is released for unrestricted
use.
• Safe Storage with Deferred Dismantlement - Radioactive materials and
contaminated areas are secured and structures and equipment are main-
tained as necessary to Jssure the protection of the public from the
(a) This mode is defined in References 1 through 3.
1-1
residual radioactivity. During the period of safe storage, the facility
remains limited to nuclear uses. Dismantlement is deferred for reasons
specified by the facility owner. Upon completion of dismantlement, the
property is released for unrestricted use. Eventual dismantlement and
unrestricted use supports the objective of minimizing the number of sites
with long-term dedication to radioactivity containment.
Safe storage can range from Custodial Safe Storage (layaway(a), ventilation
systems operating}, to Passive Safe Storage (mothballed(b), no active
systems operating), to Hardened Safe Storage (protective storage or
temporary entombment(c)}.
• Entombment - Radioactive materials, equipment and contaminated areas are
encased in concrete. The resulting concrete monolith is ma1n~~ined as
necessary to restrict the release of residual radioactivi t:y to acceptable
limits. The majority of the site and the uncontaminated structures are
released for unrestricted use. The concrete monolith and immediate
grounds are dedicated to long-term radioactive containment.
An existing facility, the C·imarron Plutonium Facility near Crescent,
Oklahoma, owned by the Kerr-McGee Corporation, was selected for this con-
ceptual analysis. The Cimmarron facility operated for five years in fabri-
cating mixed oxide fuels primarily for the Fast Flux Test Facility {FFTF).
It has been shut down since 1975 and is currently in standby status, with
operations limited to certain specific decontamination efforts. It is
believed to be representative of existing small commercial f~el fabrication
plants in the United States. Conceptually added to the facility for inclusion
in this study are a process head-end for rece.iving powdered plutonium dioxide
and uranium dicxide, a load-in station for uranyl nitrate solution, and an
evaporation system for concentrating liquid wastes. The evaporation pond,
used briefly at Cimmarron for liquid plutonium wastes, is not included in the
study because similiar consideratio:1s are encompassed in the portion of the
study denl~r.g with the contaminated sewage lagoons.
(a) This nomenclature is used in Reference l.
(b) This nomenclature is used in Reference 3.
{c) This nomenclature is used in Reference 4.
l-2
[
I
I
I
For each of the decommissioning modes studied, a work plan is developed
for the conceptual decommissioning of the reference small MOX plant. These
I plans describe decommissioning methods, technology, and schedulirg, from the
I planning phase through disposal of material and completion of decommission-

ing. From these plans, estimates are developed of manpower, major equipment
and material needs, material disposal requirements, and the resultant costs.
II The primary guidelines for the development of these plans are:
!
! • to assure adequate public and occupational safety while utilizing
cost-effective decommissioning practices.
c to use only current, proven decontamination and decommissioning
techniques.
To accomplish each of the decommissioned states, e number of variations in
the work plans and techniques described in this study are possible. However,
the methods postulated in this study appear to be representative of activities
expected to be used for decommissioning a small MOX plant, and are believed
to reflect an appropriate balance of safety and cost.
The safety aspects of performing the decommissioning activities, as they
·affect both the genera·l public and decommissioning workers, are assessed.
Safety C~.nd ':ost issues are also evaluated for the inter·im care period of
Custojial Safe Storage, wherein continuing surveillance and maintenance at
the site will be required to assure the continued protection of the public
from the radioactive materials remaining in the facility.
Safeguards and accountability for handling fissile materials, quality
assurance needs, anG methods for assuring decommissioning finances are
examined. Relative environmental and societal advantages and disadvantages
are com~ared, where possible, for the decommissioning modes studied. Criteria
are developed for permissible contamination levels for unrestricted facility
and site reuse, based on the potential for radiation exposure to the public.
Many aspects of decommissioning {e.g., plans, methods~ safety and costs)
may be sensitive to variations in facility location~ specific facility shut-
down conditions and residual contamination levels in the plant. The bases
1-3
and assumptions used in this study must be carefully examined before the
results can be applied to a different facility and site.
The results of the study are reported in two volumes. volume 1 (~1ain
Report) summarizes the key information developed and contains a summary and
general background infonnation (i.e., past experience in decommissioning
selected types of facilities, decommissioning mode definitions, study approach,
applicable regulations and safeguard~ considerations, plant and site descrip-
tion, and an overview of the methodology used to develop allowable residual
contamination levels). Decommissioning techniques are described, and cost and
safety analyses for each of the modes are presented. Finally, to complete
Volume;, basic methods for assuring financial capability for decommissioning
are reviewed and a glossary of terms is included. Volume 2 (Appendices)
contains the ~upporting data, methodo~ogy, and analyses, in appendices that
are organized in sections corresponding to those in Volume 1. In both volumes,
references are presented at the end of each major report section.
1-4
REFEr{ENCES
1. K, J. Schneider and c. E. Jenkins, Technology, Safety, and Costs of

Decommissioning a Reference Nuclear Fuel Reprocessing Plant, NUREG-0278,
U.S. Nuclear Regulatory Commission Report by Pacific Northwest Laboratory,
October 1977.
2. R. I. Smith, G. J. Konzek and W. E. Kennedy, Technology, Safety and Costs
of Decommissioning a Reference Pressurized Water Reactor Power Sta~ion,
NUREG/CR-0130, U.S. Nuclear Regulatory Commission Report by Pacific
Northwest Laboratory, June 1978.
3. U.S. Atomic Energy Co~nission Regulatory Guide 1.86, Termination of
Operating Licenses for Nuclear Reactors, June 1974 ...
4. W. J. Manion and T. S. LaGuardia, An Engineering Evaluation of Nucle!Jr
~ecommissioning Alternatives, AIF/NESP-009, Atomic Industrial Forum,
Inc., November 1976.
1-5
2. 0 SUMt4ARY
This section summarizes the results of a study to conceptually decom-

mission a reference small mixed oxide (MOX) fuel fabrication plant. The
primary purpose of the study is to identify the available technology and to
evaluate the safety, costs, and other factors related to decommissioning such
a facility. The study is intended to provide background information related
to decommissioning for use in the development of regulations, designs, and
operational characteristics of small MOX fuel fabrication plants.
The Cimmarron Plutonium Facility located near Crescent, Oklahoma, is
selected as the reference plant and is characterized for the conceptual
decommissioning activities. The plant is considered to have characteristics
similar to many of the existing small MOX fuel fabrication plants. For
this study, the facility is assumed to be located on a hypothetical generic
riverside site with characteristics typical of mid-western or mid-southeastern
areas. Decommissioning plans, procedures, and schedules are developed for
all plant areas planned to contain radioactive materials and for the insepar-
able adjacent areas witn no radioactivity. Portions of the reference facility
where uranium oxide would be received and liquid wastes would be evaporated
are conceptualized as modifications to the facility to provide a basis for
an analysis of such characteristics. Three decommissioning alternatives
are considered in detail: Dismantlement, Custodial Safe Storage with Deferred
Dismantlement, and Entombment. Costs ar.d safety impacts are estimated for
each of these alternatives, and comparisons of overall costs and potential
risks are made. Methodology developed in previous decommissioning studies
is modified and applied to determine example acceptable contamination levels
for selected facility and site uses.
Some of the key bases for the study are:
• The three decommissioning modes(a) selected for detailed analysis

are Immediate Dismantlement, Custodial Safe Storage with Deferred
Dismantlement, and Entombment. These modes cover the spectrum of viable
decommissioning options for a small MOX fuel fabrication plant.
(a) See Section 4 for descriptions of these modes.
2-1
• Decommissioning plans are se"lected on thf: basis of providing 900d public
and occupational safety in a cost-f.!ffective ma!'lner.
• Decorrrnissioning operat·ions are evaluated assuming efficient per1'ormar,ce
of the work.
• Current decommissioning technology and techniques are used.
• Expected contamination levels within the facility/site ~t the time of
plant shutdown are based on known typical housekeeping practices during
plant operation. This residual radioactive flldterial is assumed to r:ave
accumulated at the rate of 1/10 per year for the assumed 10-year plant
1 ife.
• Decommissioning wastes containing greater than 10 nCi of transuranic

radionuclides per gram of waste are assumed to be sent to deep geologic
disposal. Wastes containing les~ than 10 nCi/g of transuranic radio-
activity are sent to licensed shallow land burial grounds.
• The reference plant is the only nuclear facility on the site.
• A radiation dose of 1 mrem/year to the maximum-exposed individual is
used as the basis for the example determination of the levels of radio-
activity that can remain on the site and the facility when the property
is released for unrestricted use.
The results obtained in this study are specific to the above key bases and
to the other bases and assumptions used in this study. Use of other condi-
tions, bases, and assumptions (e.g., contamination levels) may change the
results significantly.
2.1 REVIEW OF DECOMMISSIONING EXPERIENCE

A review of the documented cases of decommissioning of related nuclear
facilities shows that the facilities decommissioned were generally small o.nd
had operated for relatively short periods of time. The problems encountered
tended to be common to all decommissioning undertakings. The review a·lso
shows that l} considerable experience exists in government and private
2-2
I
I
organizations regarding methods and equipment for accomplishing decommissioning,
i•nd 2) there are no major technical ir>lpediments to the successful decommis-
sioning of small MOX fuel fabrication plants.
2.2 STATUS OF REGULATORY GUIDANCE

Regulatory and federal guidelines are reviewed relative to their general
application to deconmissioning, and specifically to the decommissioning of a
small MOX fuel fabrication plant. The review shows that in many cases the
regulations do not speak specifically to decomntissioning but can be inter-
pretated as being applicable.
Areas where more specific guidance could be helpful are:
• Financial qualifications and responsibilities for decommissioning need
to be clarified to better define the commitments of the facility owner
for achieving the final decommissioned status of the property. Specific
definitions need to be established as to what are acceptable methods for
assuring funds at the time of decommissioning.
• Clearer definitions are needed for determining which contaminated
waste materials can be buried in conventional landfills or shallow-
land burial grounds and which must be sent to deep geologic disposal.
• Some centralization, or at least a central indexing of all regulations
pertaining to decommissioning in the Code of Federal Regulations, would
be very helpful.
• Existing guidance on what levels of residual radioactivity are acceptable
on materials, structures. and sites for unrestricted use tends to be
somewhat fragmentary and does not have a common identifiable basis.
Methodology is developed in this study that could form that basis, pre-
dicated on a decision by regulatory agencies as to what consitutes an
acceptable annual radiation dose to thL maximum-exposed individual
from unrestricted use of decommissioned property.
2-3
• Existing guidance on safeguarding of fissile materials does not speak
directly to specific safeguards needs as decommissioning progresses
and after plutonium is removed to various residual levels within the
plant.
2.3 APPROACHES TO FINANCING DECOMMISSIONING

Three general approaches to financing future decommissioning costs are
identified. They are: 1) payment of costs when they are incurred during
decommissioning, 2} creation of a sinking fund by annual payments during the
operating lifetime of the facility, and 3) an initial payment into a trust
fund at the startup of the facility. A set of five criteria is identified
that may be helpful in evaluating the desirability of each of the three
approaches for providing financial assurance. In approximate order of
importance, as judged by the authors, these criteria are: 1) the extent to
I
which decommissioning is financially assured, 2) the present value cost of

each approach, 3) the extent to which the beneficiaries of the operation of
the facility pay for its decommissioning costs, 4) the extent to which the
approach facilitates the consideration of decommissioning costs when making
selections between alternative power generation systems, and 5) the ease with
which the approach can be administered.
2.4 METHODOLOGY FOR DETERMINING ACCEPTABLE CONTAMINATION LEVELS FOR A SMALL

MOX FUEL FABRICATION FACILITY
Methodology presented in Section 8 is used to develop numerical values
for acceptable residual radioactive contamination levels for decommissioned
small MOX facilities and sites. The methodology is based on maximum annual
doses to any member of the public from all probable radiation exposure path-
ways resulting from unrestricted use of the reference facility or site.
Numerical dose limits for unrestricted use of decommissioned facilities
and sites by members of the public are currently being invest·igated by the
Nuclear Regulatory Commission and the Environmental Protection Agency. For
this study~ it is assumed that the limit will apply to an annual dose and
will probably be about 1 mrem per year. Example calculations presented in
2-4
Section 8 for a maximum annual dose of 1 mrem are summarized in Table 2.4-1.
These numbers are based on a specific radionuclide mixture expected to be
present in the reference small MOX facility and in the site soil, resulting
from normal pruduction operations and associated atmospheric releases. For
the site, acceptable residual contamination levels are determined for various
times between plant shutdown and final decommissioning.
TABLE 2.4-l. Example of Maximum Acceptable Residual Contamination

Levels for the Reference Radionuclide Mixture in the
Reference f~OX Faci 1ity dnd on the Generic Site
Surface Contamination
Time After Plant Critical (~Ci/m2) Corresponding to
Shutdown(a)(Yrs) Organ an Annual Oose(bJ of 1 mrem
Class WMaterial(c)
MOX Facility o(d) Bone 0.00071
MOX Site 0 Bone 0.031
5 Bone 0.29
10 Bone 0.39
30 Bone 0.19
Class Y Material(e)
MOX Faci 1ity o(d) Bone 0.0019
MOX Site 0 Lung 0.015
5 Lung 0.27
10 Bone 0.62
30 Bone 0.28
(a} Time between final shutdown of the plant and final decommissioning.
(b) The maximum annual dose to any organ of reference from all probable
exposure pathways.
(c) Class Wmaterials are translocated from the lungs over intermediate
times, in the order of a few days to a few months.
(d) For times after plant shutdown, the acceptable residual contamination
levels only decrease by approximately 10% of the levels calculated
at shutdown.
(e) Class Y materials are slowly translocated from the lungs over times
in the order of 6 months to several years.
I 2-5
1
I
The principal contributors to the calculated an11ual dose are found to be
238Pu, 239Pu, 240Pu, 241Pu, and 241Am.
I
As dose limits for decommissioned facilities and sites are promulgated
by federal agencies, corresponding acceptable residual contamination levels I
,.
can be derived using the methodology developed in Section 8 of this study for
conditions specific to a particular facility. ihe example acceptable contam-
ination levels derived in this study are specific to the facility and site
conditions assumed to exist at the reference MOX plant.
2. 5 IMPORTANT FACILITY CHARACTERISTICS

ihe plant is assumed to be operated for 10 year~ at a production rate
of 2 metric tons of heavy metal per year (MTHM/y"r). The feed to the plant
can be either the oxide powders or the nitrate solutions of plutonium and
uranium. The plant process is assumed to incorporate either coprecipitation
using ammonia or mechanical blending. The plant processes include solvent
extraction, ion exchange, oxalate precipitation for recovery of dirty scrap,
and a conceptual two-stage liquid waste evaporation system followed by
concreting for treatment of liquid wastes. The plant uses small, criticality-
. safe vessels located in numerous glove boxes distributed thrc•Jghout nine
rooms. Operation of most steps is on a batch basis.
Some of the more important design features of the reference plant that
affect the major decommissioning considera~ions, along with the general effects
of these features (i.e., favorable and unfavorable) on decommissioning, are
given in Table 2.5-1. The unfavorable features merit consideration for
modifications during the design of future facilities.
2.6 ESTIMATED RADIONUCLIDE INVENTORIES

are made of the amount of residual radioactivity within the
E~timates
plant (after final operational flushing and chemical decontamination) and on

the plant site from 10 years of normal operation. Numerous activities could
occur during the operational phase of the facility that could significantly
affect radionuclide inventories. The estimates used in this study are pre-
sented in Table 7.4-1 and are based on engineering judgment that considers
2-6
TABLE 2.5-1. Characteristics of the Reference Small MOX Fuel Fa~rication Plant and Their
Effects on Decommissioning
Characteristics ravoral:lle · Unfavora~·--·-·-·---··

Effects on Decomml.·ssioni"g -·----- ---
-----·-
Main process functions are divided into Separation allows isolation of Several process functions are combined
separate rooms and located mostly inside areas for decommissioning. within some glove boxes, causing inter-
glove boxes. ferences in decommissioning the various
process functions.
Wet process areas contain major amounts of High corrosion re~istance of !n some area~ piping is difficult to
small pipes. pi~ing aids in chemical decon- decontaminate and remove.
taminition.
Activities require contact operations. Dose Contact activities simplify Hazardous radionuclides are essentially
rates are iow enough to permit decommissi0~ decommissioning techniques and all plut0nium and its decay daughters,
in~ activities by direct contact. reduce the need for special which require careful confinement. Also,
equipment/techniques. direct dccess causes some occupational
exposure.
Most glove boxes are made primarily of stain- Stainless steel is conductive Decontamination of Plexiglass is diffi-
N
less steel and Plexiglass in separable form. to decontamination: Disas- cult resulting in large TRU waste
semble of glove boxes is mod- volumes.
'
.......,
erately easy.
Facility has highly efficient ventilation System maintains low effluents
and filtration system. during decommissioning opera-
tions.
Facility has system for the evaporation of Can process and solidify most
liquid wastes and incorporation of the waste liquid decommissioning wastes
residues into concrete. within the plant.
Facility has no system for compaction of Portable system must be brought in from
solid wastes, (e.g., incineration). offsite.
Inventory of fissile materials is expected Significant safeguards requirements are
to be relatively large at plant shutdown. required during much of decommissioning
Also, recovered plutonium from decommis-
sioning must be shipped offsite.
Many process building areas are constructed Concrete is difficult to decontaminate.
of reinforced concrete. Reinforced concrete is difficult to
remove.
the characteristics of the reference facility. After opera tiona 1 inventory
cleanout, the total plutonium inventory in the building is estimated to be
23 kg. Chemical decontamination activities during decommissioning reduces
this inventory to ll kg.
2.7 DECOMMISSIONING METHODS

A plan and a set of procedures are developed for each of the three modes
studied for decommissioning the reference small MOX fuel fabrication plant.
Decommissioning is assumed to start after termination of production opera-
tions. Termination includes a nrocess inventm~y cleanout and plutonium audit
of the type done periodically betv,;een operating campaigns and for material
segregation and accountability.
The first decommissioning phase for each mode is termed planni:lg and
11
preparation." This phase takes place during the last two years of normal
plant operation. During this phase, the decommissioning staff is assembled;
a decommissioning plan and procedures are prepared; safety and safeguards
analysis reports and an environmental impact evaluation are prepared; an
application for a modified license is prepared and approval is received; a
quality assurance program is established; health and safety requirements are
developed; bulk quantities of unneeded process chemicals, radioactive materials,
and nonessential equipment are removed; and modification of effluent control
systems is initieted.
In general, decommissioning is assumed to be done on the basis of live
days per week with two shifts of workers. Chemical decontamination activities
are performed on a three-shift-per-day basis in the two decommissioning modes
requiring decontamination (Dismantlement and Preparations for Safe Storage}.
For Dismantlement, extensive chemical and physical decontamination activities
precede the disassembly of equipment. For Preparations for Safe Storage, the
chemical decontamination activities are similar to Dismantlement, but the
physical decontamination is far less extensive in preparation for deactivation
of the nonessential plant operating systems. For Entombment, decontamination
activities are held to u minimum. Contaminated equipment and materials
from outlying areas are disassembled ar,d moved into the entombment zone.
2-8
The contaminated process rooms and their associated equipment are
then encased in place in concrete.
2.7.1 Dismantlement Procedure~
After about 2 years of planning and preparation, Dismantlement activities

are generally divided ·:nto two or three additional phases:
o chemical decontamination·
• physical decontamination of equipment and structure~
• demolition of structures and restoration of the site (optional).
Some of these phases can proceed simultaneou~ly for different parts of the
facility. Approximately 1.6 years ,~re needec to complete all phases of
Dismantlement and release of the site for un1estricted use.
Chemical decontamination involves flushing of internal surfaces of
process piping and equipment, followed by spraying the external surfaces of
process equipment and piping and the internal surfaces of glove boxes with
chemical solutions.
Physical decontamination involves disassembly of equipment and enclosures
and removal of the resulting materials. Physical decontamination also involves
removal of contaminated parts of structural and site materials. These con-
taminated materials are packaged and transported offsite as waste, eithe\' as
is or after chemical decontamination to remove bulk quantities of radionuclides.
Upon completion of this phase, the facility can be released for unrestricted
use.
In the optional demolition and restoration phase, all above-grade portions
of structures undergoing decommissioning are demolished using conventional
methods such as explosives and impact balls. The site is then graded and
planted with vegetation to near pre-facility conditions. The facility
site is then released for unrestricted use.
2.7.2 Custodial Safe St~rage Procedures
After about ~.5 ye~~~ of planning and preparation, Safe Storage activities
are divided into three phases:
2-9
• chemical decontamination
• Preparations for Safe Storage
• Interim Care activities. I
Many of the decommissioning activities associated with Preparations for !I
Safe Storage can proceed simultaneously. It is estimated that these activities
require approximately 1 year to place the plant and site in Custodial Safe
Storage. Approximately 1.6 additional years are needed to dismantle the I
facility at the conclusion of the period of Safe Storage.
Decontamination efforts are similar to those performed for Immediate
Dismantlement, but are performed to a lesser extent for Custodial Safe Storage.
Also involved are deactivation and isolation of contaminated areas, sealing
of contamination by adding durable seals or covering with paint, refurbishment
of the plant ventilatior. system, and installation of improved alarm and
protection systems for fire:. intrusion, or malfunctioning equipment.
Interim Care activities during Custodial Safe Storage include operation
of the facility ventilation system, routine inspection, corrective and pre-
ventive maintenance on the ventilation and other safety systems~ environmental
surveillance, and prevention of unauthorized intrusion by man.
Safe Storage must be terminated eventually by Deferred Oismant'lement.
For this actio,. . , activities are generally similar to those for liilmediate
Dismantlement, with allowances for the prior decontamination efforts and
retraining of new decommission·ing staff.
2.7.3 Entombment Procedures
After about 1.5 years of planning anci preparation. Entombment activities
are generally divided into three additional phases:
• structural preparations for Entombment
• concrete placement
• burial of entombed structure. I
About 35 weeks are required to complete Entombment of the faciiity. An addi-
t·lona l 4 weeks are required to bury the concrete monolith in an earthen mound. \
I
2-10
i
Pt~eparingthe structure for entombment involves sp1·ay painting equipment
and process areas to prevent the spread of contamination, pressure grouting
building foundations and floors to withstand the additional weight of entomb-
ing concrete, transferring contaminated equipment and materials from outlying
areas into the area to be entombed, providing new afid plugging old accessways
into the entcmoment urea, and drilling pour holes.
Concrete placement involves encasing rooms and associated equipment in
concrete and covering the entire entombed facility with a tough Wirand
concrete cap.
When operations cease at the site, the entire entombed structure is buried
in an earthen mound to protect the concrete from the effects of weathering.
The earthen mound is gently sloped and planted with native grasses to stabilize
the soil. The site is dedicated as a permanent radionuclide repository. Use
of the site is restricted.
2.8 COSTS
Table 2.8-1 summarizes the estimated costs in 1978 dollars for the three
decommissioning modes analyzed in this study. All cost estimates include
TABLE 2.8-1. Summary of Estimated Costs for Dec0rr~'Tiissioning the Reference

Small MOX Fuel Fabrication Plant ($ Millions)
C•stod ia l Safe
Storage with Deferred
hrmediate Dismantlement After
Item Dismantlement ------
Entombment --
10 ---·----
Years 30 Years
''
Initial Decommissioningla, 7.7 2.4 3.5 3.5
Surveillance <0. ~ S.4 17.4
Deferred Dismantlement(a) 7.3 7.3
Burial of En~ombed Structure 0. 4
Total Costs 7.7 2.8 16.2 28.2
Present Value Costs(b,c) 7.5 2.6 12.6 15.8
Building Demolition and
Site Restoration
{Optional) 0. 1 0.1 0.1
(a) Costs are based on 10 shifts/\-leek (double shifts) for most of the
decommissioning. Decommissioning on a 24-hour/day oasis would further
reduce costs and time requirements.
lb} Present value costs are based on 6% inflation rate and 10% discount rate.
{c) See Section D.4 of Volume 2.
2-11
25% for contingencies. The decommissioning costs are estimated to be
$7.7 million for Immediate Dismantlement and $2.8 million for Entombment.
Placing the facility into Custodial Safe Storage is estimated to cost
$3.5 million, and the annual costs of Interim Care are estimated to be about
$0.6 million. Deferred Dismantlement is estimated to cost about $7.3 million.
The combination of Custodial Safe Storage for 10 or 30 years followed by
Deferred Dismantlement is estimated to cost $16.2 million or $28.2 million,
respectively, in nondiscounted 1978 dollars. The costs of demolition of the
decontaminated buildings and restoration of the site, estimated at
$0.1 million, are not included in the above estimates. The cost of burial of
the entombed structure, estimated at $0.4 million, is included. A present
value analysis of decommissioning costs indicates an economic disincentive
to defer dismantlement for the example ca:e, primarily because of the high
cost of Interim Care. The Entombment decommissioning mode has a short-term
economic advantage over the other two modes investigated. The disadvantages
of having the site dedicated in perpetuity to the containment of radionuclides
and the eventual loss of human institutional controls may over·shadow this
economic advantage.
The breakdown of costs by major cost element is given in Table 2.8-2.
Labor costs are 66 to 75% of the total costs. Thus, there is considerable
TABLE 2.8-2. Decommissioning Cost Distribution
Cost in Millions nf 1978 Dollars(a)

Custodial Safe
Immediate _Qismantl~ent After
Item Q_ismantlement En~mbmen~ !_9___y_~_ars{_b.!_ lQ__Y_!!arsj_~!
Labor 5.1 1.6 11.5 2.12
Materials 1.1 0.5 1.6 1.8
waste Management. 0 7 0.1 0.9 0.9
Subcontracts 0.2 0.1 0.2 0.2
Utilities, Taxes and Others 0.6 0.1 2.0 4.1
Total 7.7 2.4 16.2 28.2
Burial of Entombed Structure 0.4
Building Demolition and
Site Restoration :optional) 0.1 0.1 0.1
(a) Includes 25t contingency

(b) Includes the costs of Interim Cbre for the years before dismantlement.
2-12
incentive to develop plans or techniques that could reduce labor costss such
as working around the clock for the total decommissioning project to reduce
support labor costs as well as license and miscellaneous costs. The deferral
of dismantlement requires additional costs to refurbish auxiliary facilities,
to reinstitute a trained decommissioning organization, and to provide a new
safety analysis and an additional license application. Also, Interim Care
costs become more significant with increasing storage time. Other costs of
Deferred Dismantlement are lower than for Immediate Dismantlement.
Cost of management of the wa!>tes from dismantlement amounts to about 9%
of the total costs. Of the waste management costs, transportation accounts
for about 20% and disposal costs account for about 68%. Thus there is ~
modest economic incentive to reduce the volume of material to be placed in a
disposal facility.
2.9 SAFETY
Generally conse..-vative est·imates are made of the potential safety impacts
on the public and on workers from decommis~. ioning the reference smal ~ MOX fuel
fabrication plant. Events are analyzed relative to potential consequences
and approximate frequency of occt1rrence. Radiation exposures from normal
operations and potential accidents are investigated for immediate and deferred
decommissioning activities, interim care of partly decommissioned facilities,
and transportation of radioactive materi.als. The results are sunllllar-ized in
Table 2. 9-1.
The 50-year radiation dose commitment to the populace located within
80 km (50 miles) of the facility from airborne releases resulting from normal
decommissioning activities is conservatively estimated to be about 2 man-rem
to the bone for Dismantlement and for Custodial Safe Storage. This radiation
dose is a small fraction of the dose received by the affected population
from naturally occurring radiation. Radiatio~ doses to members of the public
during the Interim Care period of Custodial Safe Storage are essentially
negligible. All of the postulated raa:~~ion doses are low, primarily because
of greatly reduced radionuclide inventories during most of the decommissioning
operations and the utilization of efficient process and ventilation filtration
systems.
2-13
TABLE 2.9-1. Summary of Safety Analysis - Decommissioning
of Reference Small MOX Fuel Fabrication Plant
Custodial Safe
Storage with Oefer{e~
Type of Source of l!l1Tiediate Dismantlement After a
Safety Concern Safety Concern Units
------ Dismantlement Entombment 10 Years -30- -Years
--
Public Saf~(b)
Radiation Exposure Deco!l1Tiissioning
Operations man-rem(c) 2.2 0. 1 2.3 2.3
Transportation man-rem 1.5 0.15 1.9 1.9
Interim Care man-rem(c) 0.05 0.10
Totals 3.7 0.25 4.3 4.3
Occueational Safetl
Serious Lost-Time Oeco!l1Tiissioning
Injuries Operations no./rr.ode l.O 0.22 1.3 1.3
Transportation no./mode 0.57 0.0073 0.59 0.59
Interim Care no./mode 0.63 2.1
Totals 1.6 0.23 2.5 4.0
Fatalities .Decommissioning
Operations no./mode 0.007 0.0015 0.0083 0.021
Transportation no./mode 0.034 0.0004 o:o35 0.035
Interim Care no./mode 0.0059 0.019
Totals 0.041 0.0019 0.049 0.075
Radiation Exposure Oecolllllissioning
Operations man-rem 70 9.4 93 93
Transportation man-rem 6.4 0.63 8.1 8.1
Interim Care man-rem 64 206
Totals 76 10 165 307
(a) Time after reference facility final shutdown. includes one year of Preparations for Safe
Storage.
{b) Radiation doses from postulated a.ccidents are not included. They are given in Section 11
of this report.
(CJ Fifty-year radiation dose commitment to critical organ.
Occupational radiation doses from initial decommissioning activities are

estimated to be 23 man-rem for Preparation: for Safe Storage~ 9.4 man-rem for
Entombment, and 70 man-rem for- Immediate or Deferred Dismantlement. Deferral
of dismantlement does not reduce occupational doses.
Potential radiation doses to members of the public from accidents are
generally found to be quite low. A potential accident that is expected with
a high frequency (greater than 10-2 per year) is the loss of auxiliary HEPA
2-14
filters during chen1ical decontamination of the plant. This accident is esti-
mated to give a 50-year dose commitment of 0.025 rem to the bone of the
maximum-exposed member of the public.
Man intrusion is postulated to occur in the entombed facilHy after
knowledge of the facility's purpose is lost. For this intrusion, the extremely
conservative assumptions are made that the intruder works for an extended
period of time in the area of maximum plutonium concentration in an extremely
dusty environment. Under these extt~eme conditions, with no respiratory pr~
tection, the intruder is postulated to receive a resultant radiation dose
exceeding 10 5 rem to the bone dOd lung. Among other accidents postulated, a
severe earthquake during dismantlement of the facility results in a 50-year
radiation dose commitment of less than 2.2 x 10-6 rem to the bone of the
maximum-exposed individual residing near the site; the anticipated fre:quency
of this accident is low (less than 10- 5 per year).
2.10 WASTES
Management of wastes (i.e., contaminated equipment and materials and
solidified chemical decontamination solutions) resulting from decommissioning
is an important aspect of decommissioning. Table 2.10-1 gives a summary of
wastes from the three disposition modes studied. The cost of radioactive
waste management is highly dependent upon the ultimate disposition of the
waste, (i.e., deep geologic disposal or shallow land burial). There is a
significant cost incentive to minimize the amount of metallic radioactive
waste that must go to geologic disposal. In this study, the volume of this
waste is reduced by electropolishing those materials that can be successfully
treated, thus permitting them to be either placed in shallow land burial or
released for unrestricted use.
I 2.11 OVERALL COMPARISON OF DECOMMISSIONING ALTERNATIVES

Decommissioning of a small MOX fuel fabrication plant is technically
feasible with present-day technology. Further development of some techniques,
such as chemical decontamination and waste volume reduction, could lead to
reductions in costs.
2-15
TABLE 2.10-1. Radioactive Wastes from Decommissioning
Wastes as Packaged
Preparations for
Dismantlement Safe Storage Entombment
Disposition Volume Contained Volume Contained Volume Contained
of Waste m3 kg of Pu m3 kg of Pu m3 kg of Pu
Deep Geologic
Disposal 160 11 52 <2 21 <I
Shallow Land
Burial 270 <0.01 -5
Total 430 11 52 <2 26 <1
The land area committed to the storage of radionuclides on the site

following Immediate or Deferred Dismantlement is 0; during Custodial Safe
Storage, 4.7 km2 are committed (or the original total site area), while for
t he Entombment mode~ 2.2 x 10-3 km 2 are ded1cate
. d for permanent storage of
radionuclides.
The parameters that affect the selection of a decommissioning alternative
are shown in Table 2.11-1. The primary parameters are the potential radiation
doses» the economic costs, and the societal aspects of providing surveil~dnce
for long periods of time.
TABLE 2.11-1. Comparison of Study Results
Decommissioning Alternative
Custodial Safe
Dismantlew.ent After
Inmed i ate
_ __cU:.:.:n:..:..it~----- __ _EntombmJ!.!l..t_ Dismantlement 10 Years 30 Years
Decommissioning Cost
(millions of 1978 dollars) 7.7 16.2 28.2
?resent Value Cost
(millions of dollars) 2.6 7.5 12.6 15.8
Occupational Radiation Dose
(man-rem) 10 76 165 304
Staff Required (man-years) 38 131 295(b) 555(b)
Waste Volume (m3 ) 26 430 472(c) 472{c)
Site Status Restricted( d) Unrestricted Unrestricted Unrestricted
(a) Potential maintenance and surveillance costs neglected.

(b) Includes 55 man-years for Preparations for Safe Storage.
(c) Includes 52 m3 of waste from Preparations for Safe Storage and 420 m3 of waste
from Deferred Dismantlement.
(d) Approximately 0.0022 km2 of land permanently dedicated to storage of radionuclides.
2-16
I
The total costs (in constant dollars), the worker radiation dose, and
the man-years of staff labor are lower for Entombment than for Immediate Dis-
mantlement or for any combination of Custodial Safe Storage with Deferred
Dismantlement. Immediate Dismantlement costs are considerably lower than the
costs of Custodial Safe Storage with Deferred Dismantlement. The total
radiation exposures {received mostly by the decommissioning workers} does not
decrease with time for deferral of dismantlement. Results of the study indi-
cate that there is an initial economic and radiation dose incentive to entomb
the facility. With these attractive advantages, there is a major long-term
disadvantage associated with Entombment (i.e., the protection of the public
from long-lived hazardous materials for extremely long time periods). This
is a major societal concern that is associated with the disposal of any
long-lived hazardous material in close proximity to man's environment. There
are other concerns that may also serve to decrease the incentive to entomb.
These are such societal or institutional concerns as the proliferation of
sites ded~cated for containment of radioactivity, long-term surveillance and
ntaintenance requirements, financial responsibility, and institutional control.
All of these concerns are directiy associated with protection of the public
from potentially hazardous materials.
The differences between other ~actors consider~d, such as aesthetic
effects, ecological effects, and other environmental concerns, appear to be
very small between Dismantlement and Safe Storage.
The results of these comparisons are valid for the specific bases, condi-
tions and assumptions used in this study. The conditions in effect at a
specific facility at the time it is decommissioned, including sociological
aspects, may alter the results of the study and dictate the choice of decom-
missioning mode. Therefore, the results and conclusions in this report should
be used in the context of the reference site and facility studied and the
key bases and assumptions used.
2-17
3.0 REVIEW OF DECOMMISSIONING EXPERIENCE
This section contains a review of 'Information from past decommissionings

of plutonium processing facilities. In the United States, the term "decom-
missioning" means to take out of service, with decontamination and/or removal
of radioactive material from the facility and the site, fixation of residual
radionuclides, and/or other procedures to assure the health and safety of the
pub 1ic. Current governmenta 1 phi 1osophies encourage a decom:1n s~ i oning approach
that results in the termination of the facility's nuclear license, and the
release of the property for unrestricted use within a reasonable period of
time. Thus, the Safe Storage (layaway, mothballing, or temporary entombment)
approaches that have been used for many nuclear facilities in the past are not
the end point but require an eventual dismantlement to complete the total
decommissioning process.
Information specific to MOX fuel fabrication facilities is 1imi ted because
only a few of the small number of commercial plants constructed have been
decommissioned. Information in the open literature regarding these decommis-
sionings is fragmentary and poorly documented. For these reasons, information
on the decommissioning of other types of plutonium processing facilities is
included in this section, since their decommissioning problems are similar in
nature to those anticipated for MOX plants. These facilities include several
government-owned plutonium fabrication plants where the buildings were decon-
taminated, usable source and special nuclear materials were recovered, and
unusable containment enclosures and processing equipment were discarded as
radioactive waste to low-level waste burial grounds.(l- 4) Most of the govern-
ment-owned buildings so processed are still standing and contain radioactive
contamination in concentrations greater than those permissible for unrestricted
use. Some buildings are sealed off and unused, while others have fixed contami-
nation and are now housing new but related activities. Thus, the decommission-
ing of most plutonium handling facilities to date has not resulted in a con-
ditien that releases the facility and site for unrestricted use.
3-1
3.1 HISTORY AND STATUS
Table 3.1-1 is a brief outline of information concerning plutonium
facii ities in the United States with fuel fabrication capabilities. A dis-
cussion of experience at two decommissioned facilities fol1 ows. ExperiE:nce
at additional facilities was deemed to provide only minimal i nforma t ·ion for
this study.
TABLE 3.1-1. The Status of Plutonium Fuel Fabrication Facilities

""drr.(" 1;1
'.}t;e"F"-4't 101 ~ ~H 1l1 t f ;',.-t<'.f•Jt1 'ft••H '. ~ ., r.fi<, t '!(, iJt•t r}r;r, 1 '-'> 1 on 11'\'-f In·•-·~ ·
''.<;;nt_"<J(tOr ;'t-.1!"~ ' .. ~" 1 J ', ;~{_r!'"'l''',\ll;fl 'F•irJ''1"1',',lrJr' "{~ttwlqvf' 1•,-r-•_r•r.t ;_!',P
ll't)(._'!l!l~l~ ~nt~rr (.in~.''1d t:'..,..-k, .\~)I'" 1' •• ; ',J ~ :.of•l ':..

to.H n .• n.d: l {[Jot J t<1l1 f{).nn1-J :r:t~.'""n-~•1on.1! P,1 f<J~·l r.a,r:.
· ,-! '' t' -l 'r ro;;
Ar-<;o'"'"'-t' "idt '0:':· !ir•.;n''·fl~·. '.&(•l

,t l tdtXJf'"·t~nrr_, !~Xli; jllp
:-·1 -·· ["1..,1..,(' ,, j 1 ,,~, ~ \ • "-11 ~ ... -1 \t•r t 1 ')nf'd ~ 1 r;>ll' •1ew Bn;llSwlc¥
J Jtr 11 .1~
t elf. 1 1 : t ~
• •.., 1 ,..-.1 wt.,;
,, 'f ~~·
'\ "~ ~,1\ ~ 1t"· -~ ,
';I
brJJf''; d f tf•r ~abor~tory

;·.,_, !~<'I 1.1 '" ~· 1 r • !l, 1 i'q<,J1Pf!l('r•t ( N8l) nf'•
'f·.lrl·:; ....~(~)() "(' (j ')Utlf;H"., l';].jr,J
S<!~K·X• ~ 'f''h t!h~'l"''j, l:j: :.l< ()c t \ ; ' .l ~ .••• l\ Rl•',f'drr!·, M.,.,
\ ifli',hO:H '(·.:, -.. 1 ,..q ~n ~ j, ;oj i 1c O• fl'Pvt•loprrlf>nt
i ell:'chtJ..;r·~. '-c.~.lf•H f ~~f·l <,"

Pem1\ylwl;lf>l·;t Mdt!'1'. -~: ., ;· ... ; w~("1 Q~;.,
h;Ju~l (o 1 ·j f•u (>< r~p
:~\)~[ i
fP:,~tt~'i\'f." ~D(H'1c!i1 (o ~ '"'·''.t)ll~,

In')tqyte Cm1c:
{Wl.~'>!H)"' [~qHh "":ntl;;.o--, f.,f>1

t''f't'UH], if:;l (()f::l"\t"t t lt IJI, i .; i .,~,c.1 P,t,!l
[J.xO~ ~utledrr .:tO<hL.,fH!, { . 'l01'l Pu f -~~· 1 '>, -~tJr..tC\~l!ll

(<JmPdl"lj ~ tnc. t.lid'.:tt1"rqtun 'ljw(l'f:•ti-.- P" fup; P~.r~. ~~ft>
' :.lt:'1" n~r.·. rJ!lC Pu r~p S t r1r a if'
Gen.e-q l At~ H.: }<:~n D··eQo.

C~<!~J Cai~forn1~
Pdwl :1H;, Decont,.~~inrJte-d t icense tenni ~

!ie-.1 ¥ork ""d ( Qu 1pment ndted- · ·;nr-r•~
Disas~ernbl~d strictefi u;.e
GenE'f\~l [,<"_tnc Ple.tsdntoo. f Wf' 1\,

'-"' Cal Ho• n1d 'WJ.H.
~ f'"'tf'r
~~"1~~" Pu f.uel R'-0.
Cold ru )( rnrr
J.err McGee { H1d' ron. p,_,. f r,Jf>l -~ ''1''':1t,,

lluc le1r fonL Ok.1.a"o."\3 Pu f.u-f>l P!.D Decontami nat icn
and Equipment
flemova l Oper.'l
t ~on;;. Underw.~y
libnS.t'ltO !till ,sn1 sbu•-q ~ Spp;:;_-,,al PrJ-23B Par,s i 'ole

Research (orp. O•lH)
111) ',tH"b?r Stripptod equip~ Empty -
Meta:ilu:r_,.- flltJTlUltion <idfe ~~P..,<. went , w~; ter Locked
(.a·· :-1 . d lc-,r.q. StoriJqe- 144 '~an VE>arr, bla:.l-N1, foam Not used.
filled boxes.
Getty-S~elly 'l'!ucl-e-ar F'ue'i Pu fuels~ Prpp11-rat Hms

Decontamination
Oil C""""'"'" S~rvkes.
'!nc
Co1d Pu Scrap for S<~fe
Storaoe
Operations
Nearing Com-
:West i r.gnou~e
-----~~-.:.~~~----"--
Andersen. Andtorson Pu fuels~ Future-
£1e<:trlc Cr~··p_ Soutl':r fuel Plant +-:u Fue'l -R&tJ
(arol iM LD ld Pu Strap
Cheswick. Fueh Pu f;;eh. Operating

Pennsylvania laboratory Pu fuels p;[i
3-2
this study.
TABLE 3.1-1. The Status of Plutonium Fuel Fabrication Facilities

N4m" of
Ope rot inq ~· 1 te Fanl1ty Prev~nt Y~dr\. lfJ Cost To Oe(onJl'lissiOnlnq A,.-e4 1 '~
(.onJrac tor_ location Nd'flf." Cajldblll tj C..tdlY'".. ne_c~~!ll_'»O:._lOfl Dec.OI"'!lll ~~') lo_n _Tet hn~l~~ Prr:~~e!J_t _U!e
Rockwell lnter- Canoga Pork, At)lnl~ ~~ Pu rue I~, l)pprot 1oq

ndt itJfld I (DOE) Cal1forn1d Intt·rna•.•ona I Pu Fu!'l RMl,
Col <I Pu I',}( f'dl)
Argonne NdtlOn· Arqonne, fuel Pu ru"h. (Jpr:r(lt 10flii l

a I Lat>orat.ory (DOl) I ll1• u is T~:-chn,)lOq'/ Pu FuPI R&D.
(!'nter lolrl Pu )UdP
Plyton1um Pu ruf!)t, 1 Hdlf Wd': f/.6 Sett ioned '!love New Brur.swick
I abrltd!. !On Pu l'uel P&O, Dl\11'ldflt lPd' boxes after Laboratory
Far_ iII ty Cold Pu ~( rd(J Balanc" HltdC t equipment ( NBl) now
(flldg. 0·1'.'1) removed. ou.upies bldg.
Babcock Lynchburg, Babcock Pu ruPl~ OpPrd t, "'I Resear(h and

&Olilcox Co. Virqinia Wilcox Oeve 1opment
Leec hburrJ, Nucleu Pu Fuel<:., Operat1nq

Pennsyhtan1a Mdterial~ Pu Fuel R&O,
fquifr. lo. Cold Pu Scrap
(NU~i.l)
Battelle Memorial Columbus, Columhu~ Pu Fuel F~&O

Institute Ohio li;bordtOrleS
Combustion Engin- Windsor, (.n•ohusllnn Pu Fuel',

eering, Inc. Connecticut Div1 \1on P,, Fut>l R&ll
Exxon Nu(.lear Richland, Exxon Pu fuels, Custo<lia I

Company, Inc. Olashington NucieM Pu ruel R&D, Safe
Fuels PIM,~ Cold Pu Scrap Storaqe
General lltomic San Diego, Pu Fuel R&IJ

Company ca 1ifornia
Pawl in<J, Pu Fuel R&D Decontuminated License termi ·

New York and Equipment nated- · unre-
Disassembled stricted use
General u~ctric Pleasanton, Va 11 ec itos Pu Fuels, Operating

~ny Ca 1ifor·nid Nuclear Pu Fuel R&D,
Center Cold Pu Scrap
··-· -----~ ------------------------------------------------
ICI!rr McGee Cirlldr·ron, Pu Fuels
llvcle4r Corp. Decontamination
Ok lal!oma Pu Fuel R&D and Equipment
Remova 1 Oper~.
tions Underway
._,nsanto Miamisburg, Specie] Pu-238 Passive 4 115 '·1orker
Research Corp. Stripped equip- Empty -
Otrio Metallurqi- Fabrication Safe ment, water
cal Building,
Re"'' Locked
Storage 144 Man Years blasted, foam Not used.
fllled boxes.
-- --- --· ---------- --·- ----------------------------- ------~-----------------------
Getty-Skelly Erwin, Nuclear Fuel Pu Fuels, Preparations
Decontamination
Oil Companies Tennessee Services, Cold Pu Scrap for Safe Operations
Inc. Storage Nearing Com-
---------------- ,.___________ -.. ---- -~ ....... ---- --~--··-·------- ------·--·- -- ----------------- ----·-·· ----·- ----- ··------ -------- -- .. --------------------- pletion
Westingnouse Anderson, Anderson Pu Fuels, Future
Electric Clir'p. South Fuel Plant Pu Fuel R&D
Carol ina Cold Pu Scrap
- - ------ -----~-- ---------- -- ----------~- ---- - --------- ·--- --- ------ ---- ----··- ------ -- ----------------------------------
Cheswick, Fuels Pu Fuels, Operating
Pennsylvania laboratory Pu Fuels R&D
----··------·-·-------·-·------·-----··-·----·--···----- ------------------·------------------
3-2
3.1.1 The Plutonium Fabrication Facility {PFF) at Argon!]_I?__ Nat_:L<:>n~J_
Laboratory (AriL)
The PFF was used extensively during its 15-year life span for developing
methods of alloying, casting, machining, cladding, and assembling fuel
elements containing plutonium. The facility contained a variety of equip-
ment, from small-scale laboratory instruments to full-scale rolling mills,
mach,ne tools, hydraulic presses, and a variety of furnaces. All of this
equipment was enclosed within a modular system of specially designed glove
boxes, inter-connected through a 30-meter-long central conveyor system.
It was decided to dismantle one-half of this facility within a seven-
month time frame to make room for the-construction of facilities for the
New Brunswick Laboratory (NBL} when their Pu and U standards activities
were transferred from New Jersey.
Several methods of contamination control during the dismantling of the
glove box system were considered:
l) Decontaminate or fix the radioactivity within the glove boxes to permit
disassembly of the syste~ with minimal protection required from loose
contamination.
2) Construct a temporary enclosure, probably of plastic film, around each
glove box line with appropriate personnel and equipment transfer
facilities.
3) Develop new methods of disassembly that would permit the glove box
system to be taken apart without chemical decontamination.
Several chemical cleaning methods to reduce radioactivity levels were
tested but were determined to be unsuitable for this facility. The intricate
configurations of the equipment prevented access to a 11 of the surfaces;
therefore, the first approach was abandoned.
The design of temporary enclosures for contamination control during
glove box dissection was studied, but it was determined that this appr·oach
would require a 1najor design and construction effort, because each glove box
line would require its own specially designed enclosures.
3-3
The last approach involved separation of the glove boxes into sections.
The modular construction of the glove box framework was the key to the
selection of this method as the one to be attempted. Work procedures were
.
developed and modified from testing, and a safety evaluation was performed of
the proposed dismantlement plan.
The first step in the dismantlement plan was to remove all loose equip-
ment anj materials within the glove boxes through the existing conveyor
system. (The accountable fissile materials had been removed at the time
programmatic work was ended.) Next, all accessible surfaces in the interior
of the boxes were hand wiped using a mild detergent solution and cloths.
During this activity, all ventilation and utility systems were functioning.
After completion of this activity for each glove box line, the following
general sequences were followed:
1) The utility systems were isolated from their sources; however, the
ventilatiqn system remained in operation.
l) The electrical conduit and fluid piping systems were disconnected
from the boxes and r~movec.
3) All auxil ;dry equipment pieces (vacuum systems, pumps, motors, controls,
etc.) were disconnected and removed.
~> The ventilation ductwork for each glove box was isolated from the main
system and the glove box line. {A clean high-efficiency (HEPA) filter
was installt:::d on each section to permit the section to 11 breathe 11 during
transport, wi tho•:t 1. ss of radioactive confinement.)
5) Finally, each predetermined section of the glove boxes was separated
at the flanged joint ana removed from the line.
A subframe re-enforcement was added to strengthen some boxes that
contained heavier equipment (the hydraulic press weighed 11,340 kg
(25,000 lb)). The section was lift~d by hydraulic jacks or a forklift
truck, and standard casters were bol ,·ed to the structural members on the
subframe. The packaged glove box was then rolled to the loading dock where
it was placed on a flatbed trailer, anchored, and shipped elsewhere
3-4
for reuse or for disposal as wa3te. All of the unused boxes and equip-
mPnt are still retained onsite, waiting final disposition decisions.
The dismantlement of the equipment in part of the PFF is an example

of the cost and time ~ffectiveness of the continued utilization of plu-
tonium facilities for related work. It took about six years to build and
check out the PFF. Ic was dismantled (one-half of the area) in seven
months. The containment of plutonium was effective and the building was
not contaminated. NBL brought in their own plutonium glove boxes to set
up in the cleared space, and are now expanding into the other half of the
PFF.
3.1 .2 Decommissioning of the SQecial Meta11urigical (SM) BuildinB_at
Mound Laboratory
The decommissioning of the SM Building at Mound Laboratory was initiated
in August 1968 and was concluded in September 1972. The SM Buiiding was a
facility in which plutonium-238 was processed for' use in the fabrication of
isotopic heat sources. This building contained 178 linear meters of glove
boxes used to:
• Process 238 Pu into a final product form for encapsulation as
heat so~rces
• Encapsulate 238 Pu fuel forms in the fabrication of isotopic
heat sources
• Recover 238 Pu residues generated from production of fuels, from
research and development activities, and from analytical support
activities
• Perform analytical activities that were required to support the
238 Pu production and recovery processes.
Special techniques, procedures, and equipment were developed to safely

decontaminate the facility.
The Phase I portion of the SM Building had a steel superstructure with
exterior walls consisting of two aluminum panels with a fiberboard insulating
core. The total floor area was 1230 m2 . The interior walls were also double
3-5
aluminum panels with fiberboard core, and the ceiling was a suspended type
with drop-in insulation panels. The roof consisted of metal decking attached
to the superstructure. The metal decking was covered with a conventional
gravel asphalt roof. The floors were reinforced concrete with vinyl-asbestos
tile. All piping and duct services were overhead in a 1.2 m crawl space
between the ceiling and the roof. These services included ventilation ducts,
steam and condensate return lines, water, compressed air, process gases, nitric
acid supply lines, solution transfer systems, building vacuum system piping,
and liquid waste transfer systems. The building also had two high-efficiency
filter banks.
The Phase II portion of the building was a 492 m2 addition at one end
of the Phase I Building. The addition was construc~ed with a steel super-
structure and an exterior of concrete block. All interior walls and ceiling
were plaster on concrete block or metal lath. The roof, floors, piping and
ventilation Gucts were similar in b~th portions of tne building.
The decontamination treatment required for individual glove boxes was
determined by gamma sc~nning the 238 Pu. From the gamma scanning information,
it was detennined as to whether additiondl glov~ box cleaning was required,
or if the glove box was ready to be removed, packaged and shi~ped for subse-
quent burial. Equipment was cleaned inside glove boxes using a high-pressure
water {35 atm. or 50G psia) spray processed through a recirculdting system
with a centrifuge to remove entrained solids. The solids were removed,
packaged, and transferred to the recovery system for recovery of 238 Pu. Glove
boxes that did not appear to be watertight were manually cleaned with scrapers,
brushes, and rags.
The glove boxes that contained processing equipment that extended through
a series of bpxes (in-line equipment) and the associated piping presented
special contamination control problems. With all of the equipment still in
place, the boxes were filled with polyurethane foam. A loose-fitting vinyl
bag was affixed to each point of separation of the service to be dismantled.
The size of the vinyl bag was sufficient to permit unbolting or cutting of the
service line inside the bag. When the necessary sectionings were made in the
service line, that section was turned inside the vinyl bag, thereby twisting
3-6
a small section of the bag tightly at each end. This area was taped and
cut in the taped, twisted area and the section was then removed.
Special procedures were used to protect personnel against exposure to
radioactive material, to ensure the effective control of contamination, and
to prevent the release of radioactive materials to the environment. Orienta-
tions, instructions, and training were given to all personnel involved in
the dismantlement operations. Special training was given to everyone who
operated the 680 atm (10,000 psi) water blaster unit, since it was capable
of severing a 20 em (8 in.) concrete block. Protective clothing and respira-
tory equipment {almost exclusively, the supplied-air bubble suit} were worn
by the decommissioning workers. Entry and exit from the radiation-contamina-
tion control areas were made through a series of three control zone enclosures.
Outer protective clothing was removed in zone 1, initial personnel monitor-
ing was performed in zone 2, and the remaining clothing was removed in zone 3.
Follow-up personnel monitoring was performed in the clean area. Plastic tents
and enclosures were used to house equipment to aid in personnel protection
when opening contaminated systems and equipment. Equipment was spray painted
to fix contamination and minimize subseq~ent release of contamination during
removal. Outside doors not in use and building joints were sealed with room
temperature vulcanizing (RTV) rubb~r to preclude the release of contaminated
water.
A total of 36 people worked four years to aeactivate this facility.
There were no s.gnificant internal depositions of Pu. Individual whole body
exposures to ionizing radiation averaged 0.8 rem/yr, with a range of 0.0 to
3.83 rem/yr.
A total of 1065 g Pu were recovered and shipped of;site for further
processing. A total of 520 g were buried in an estimated 9800 m3 of waste
containers. About 0.25 g of Pu remained inside the building (floor smears
of 2,000 d/m/100 cm2) and 0.64 g remained underground in sewers, drains, etc.
After this expenditure of effort and exposure, the SM Building remains
standing, unused, and with entry restricted.
3-7
3.2 LESSONS LEARNED FROM DECOMMISSIONING EXPERIENCE
Something about the practicality and acceptability of the various decom-
missioning approaches has been learned from the deactivation and· modernization
of plutonium fabrication and handling facilities. A wide variety of necessary
technology exists and has been successfully applied to a wide variety of nuclear
installations. Because of the uniqueness of each facility, no two facilities
had identical problems or conditions. However, the basic approach to any mode
of decommissioning remains virtually unchanged, i.e., the gathering of staff
manpower, a period of planning and preparation, followed by chemical decon-
tamination and mechanical removal operations. The fundamental course of
events varies primarily with building design and with the inherent refine-
ments potentially available or needed for a given facility. Areas that can
always use technology improvements are re~ote handling equipment, disassembly
techniques, decontamination techniques, and waste volume reduction.
From the standpoint of decontamination, all walls should be seamless and
have a smooth durable surface to aid in flushing and cleaning. Sandwich walls,
such as those used in the Special Materials Building, present difficulties in
their decontamination. Compartmentization of process areas allows for more
effective control of the movement of radioactivity. Sealed-off access areas
behind processing pipes or glove boxes would provide an effective means of
controlling radioactive contamination, while also providing a suitable work
area for personnel. Building and glove box fluid services) located either
beneath the floor level or in some area away from work areas, tend to minimize
the hazardous effects of pipe leaks. Location of building service systems, such
as vacuum systems, corrosive vapor removal systems, and glove box exhaust
systems in isolated areas, would allow maintenance work to be performed with
little interruption of ongoing processing operations. These are only a few
of the more obvious improvements in design that could enhance decommissioning.
A more comprehensive listing of design considerations favorable to decommis-
sioning of the reference MOX facility is given in Section 13.
3-8
Much of the decontamination experience gained by Kerr-McGee at their
Cimmarron MOX -facility is reflected throughout this report. New techniques,
as well as improvements in current decommissioning techniques, can be expected
to occur. The use of remote plasma arc cutting techniques and explosive
techniques employed during reactor dismantlement are prime examples of developing
technologies. These techniques and others will be further developed, and
these improvements, in turn, will directly impact future decommi ss ·ioni ng
considerations.
3-9
REFERENCES
1. J. M. Garner and W. P. Davis, "A Sunmary of Mound Laboratory's Experience

in 0&0 of Radioactive Facilities {1949-1973)," in Proceedings of the
First Conference on Decontamination and Decommissioning (D&D) of ERDA
Facilities, USERDA, CONF-750827, pp. 223-23; Idaho Falls, ID,
August 1975.
2. A. Martin, et a.l., A Preliminar·y Study of the Decommissioning of Nuclear
Reactor Installations, ANS Report No. 155, July 1977. Associated Nuclear
Services, 123 High Stree, Epsom, Surrey, KT19 8EB.
3. B. J. Koprowski, et. al., "Dismantling A Plutonium Fabrication Facility,~~
Proceedings of 23rd Conference on Remote Systems Technology, American
Nuclear Society, 1975.
4. W. R. Harris, B. R. Kokenge and G. C. Marsh, Termination of the Special
Metallurgical (SM) Building at Mound Laboratory--A Final Report,
MLM-2381, Mound Laboratory, Miamisburg, OH, Oecember 1976.
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3-10
4.0 DECOMMISSIONING ALTERNATIVES AND STUDY APPROACH
Once a mixed oxide fuel fabrication plant reaches the end of its useful
operating life, it must be decommissioned, i.e., placed in a condition such
that future risk to public safety from the facility and its site is within
acceptable bounds. A number of alternatives {modes) are possible to satisfy
this general requirement for decommissioning. These modes range from minimal
initial cleanup requiring continued surveillance and physical security followed
by later more-complete cleanup, to immediate complete cleanup and removal of
contaminated materials, resulting in unrestricted public use of and access to
the facility and site.
This section discusses the decommissioning alternatives evaluated for
a mixed oxide fuel fabrication plant and further discusses why these alterna-
tives are selected for con3ideration in this study. The approach for the
evaluation is also discussed. In any generic analysis, certain assumptions
must be made in the absence of specific data to permit more general applica-
~ tion of the results. The more important overall assumptions or key bases ..
11
for the study and the rationale for their selection are identified in this
I section.
4.1 DECOMMISSIONING ALTERNATIVES

Three basic decommissioning modes are considered: Safe Storage (with
three subclasses and Deferred Dismantlement), Entombment, and Immediate
I Dismantlement. The general characteristics of these three modes are summarized
I
! in Table 4.1-1. Each of these terms as applied to a reference mixed oxide
~
fuel fabrication plant is defined and discussed in the following subsections~
iJ One of the primary bases of this study is to assess the span of potential
l
decommissioning alternatives, with a minimum of duplication between alterna-
j
, tives. Because Custodial Safe Storage represents the minimum initial de.commis-
sioning activ-ity, this mode (followed by Deferred Dismantlement), is selected
I
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as one mode to be studied for the reference facility. Passive Safe Storage
encompasses many of the activities involved in Custodial Safe Storage and
Immediate Dismantlement and therefore is not specifically included in this
study.
I
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4-1
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TABLE 4.1-1. Digest of Contemporary Decommissioning Mode Definitions and Decommissioning
Mode Characteristics
Sulllllclry g_f!)eccrrrnissioning Mode Characteristics

Mode and Definition -----Tacil itYStafUS-~--:-=- --Plint/Site use
Di smantl e~~~ent: After final(n~clear facility shutdown, the immediate Plant Equipment - removed Plant - Unrestricted
or deferred aJ removal from the site of all radio- Continuing Care Staff - none Site - Unrestricted
materials (including nuclear fuel), radio- Security - none
active fluids and waste, and all other material~ Environmental Monitoring - none
having residual radioactivity leveis greater than Radioactivity - removed
those permitted for unrestricted use of the property. Surveillance - none
The nuclear facility owner may then have unrestricted Structures - removal optional
use of the site with no requirement for a license.
The remainder of the facility may be dismantled and
vestiges removed and disposed of if the facility
owner so desires.
Safe Storage: Those activities required to place and maintain a
nuclear facility in such a condition that future risk
from the facility to public safett is within accept-
able bounds and that the facility can be safely
stored for as long a time as desired.
Several subcategories of safe storage are possible. (b)
These are:
• Hardened Safe Storage [temporary entombment(c)] - Plant Equipment - none operating Plant - Conditional
the comprehensive cleanup and decontamination is Continuing Care Staff - none on site Non-nuclear
coupled with the construction of barriers around Security - hardened barriers, fencing Site - Conditional
areas containing significant quantities of radio- and posting Non-nuclear
activity. These barriers are of sufficient Environmental Monitoring - infrequent
strength to make accidental intrusion impossible Radioactivity - sealed in hardened
and deliberate intrusion extremely difficult. struct" ·e
Surveillance requirements are limited to detection Surveil! :uce - ir.frequent
of attack upon the barriers and maintenance of the Structures - partial removal optional
int~grity of the structures.
• Passive Safe Storage [mothball (d)] - a more com- Plant Equipment - none operating Plant - Nuclear Only
prehensive cleanup and decontamination effort is Continuing Care Staff - optional (on- Site - Conditional
performed initially, sufficient to permit deacti- site) - routine inspections· Non-Nuclear
vation of the active protective (ventilation) Security - remote alarms
systems during the continuing care period. The Environmental Monitorinq - routine
structures are strongly secured and electronic periodic ·
surveillance is provided to detect accidental or Radioactivity - immobilized/sometimes
deliberate intrusion. Maintenance of the integ- sealed
rity of th~ structures is required. Surveillance - periodic
Structures - intact
• Custodial Safe Storage [layaway(e)] - a m1n1mum Plant Equipment - some operdting Plant - Nuclear Only
cleanup and decontaminition effort is made Continuing Care Staff - some required Site - Nuclear Only
initially. followed by a period of continuing Security - continuous
care with the active protection systems (princi- Environmental Monitorinq - contin· · tS
lly the ventilation svsteml keot in service Radioactivi
<,,,, ·.· ·.•. .•.••,'; •~;,,·,. ;..,•.•'' x.·····< <'·.··:·\' ),'_ ''~. ';' ·,,•;·1'; • ·. •· •:• . ,
~nMJugnotn; 1:ne SWrage per1.00. ~UII 1:~~ O~Slte sur~~111anci ~ ~on~iriUOUS
surve1:1ance by security forces is required to Structures - intact
prevent accidental or deliberate intrusion into
the facility and the subsequent exposure to radi-
ation or the dispersal of radioactivity beyond the
confines of the f&cility.
Entombment: The comprehensive cleanup and decontamination of Plant Equipment - none operating Plant - Cunditional
the site is coupled with the confinement of the Continuing Ca~e Staff - none on site Non-nuclear
contaminated components and materials within Security - hardened barriers )ite - Conditional
a monolithic concrete structure. En vi ronmenta 1 ~lon i tori ng - infrequent; Non-nuclear
eventually none
Radioactivity - sealed in hardened
Ideally, the structure should provide integrity structure
for a time period of sufficient length for the Surveillance - infrequent; eventually
contained radioactivity to decay to unrestricted none
release levels. An appropriate and continuing Structures - partidl removal optional
surveillance program would be desirable under a
possession-only license during the lifetime of
human institutions. Unless dismantled, the
monolithic structure will eventually become a
permanent onsite repository without human con-
trols. The structure will eventually disinte-
grate and release its contents into the environ-
ment.
(a) Deferred Dismantlement, as used here, is a generic term that includes whatever actions are required at some
time to accomplish termination of the facility's nuclear license and the release of the property for unrestricted
use. These actions can range from radiation surveys that show that the residual radioactivity has decayed to
releasable levels, to disassembly and removal of radioactive material.
(b) All categories of Safe Storage are open-ended and some positive action is required at th~ conclusion of the
period of continuing care to release the property for unrestricted use and terminate the license for radioactive
materials. Depending upon the nature of the nuclear facility and its operating history. the ne:essary action
can range from a radiation survey that shows the property to be releasaLle, to dismantlement and removal of the
l'esidua1 radioactive materials.
(c) W. J. Manion and T. s. LaGuardia, An Engineering Evaluation of Nuclear Power Reactor Decommissioning Alternatives.
Summary Report, AIF/NESP-009SR, p. 12, November 1976.
(d) U.S. Atomic Energy Commission Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors,
June 1974.
(e) K. J. Schneider and C. E. Jenkins, Technology, Safetl and Cost of Decommissioning a Refer~nce Nuclear
Fuel Reprocessing Plant, Report of U.S. Nuclear Regu atory Commission by Pacific Northwest Laboratory,
NUREG-0278, p. 3-3, p. 3-4, October 1977.
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4.1. 1 Definition of and Rationale for Safe Storage
with Deferred Dismantlement
Safe Storage is defined as those activities required to place and maintain
a nuclear facility in a condition that places risk to the public within accept-
able bounds and safely stores the facility for as long as de·:;ired.
Several subcategories of Safe Storage are possible. These are:
• Hardened Safe Storage !temporary entombment(a,b)J - A comprehensive
cleanup and decontamination is coupled with the construction of barriers
around areas containing significant quantities of radioactivity. These
barriers are of sufficient strength to make accidental intrusion impos-
sible and deliberate intrusion extremely difficult. Surveillance
requirements are limited to detection of intrusion through the barriers
and maintenance of the integrity of the structures. The primary restric-
tion to facility and site use is that of prohibiting activities such as
excavating, drilling, or any other means nf breaking the barriers that
isolate the radioactivity.
• Passive Safe Storage !mothball, (a) protective storage(b)j - A cleanup
and decontamination effort is performed initially, sufficient to permit
deactivation of the active protective (ventilation and utility) systems
during the period of interim care. The structures are strongly secured
and electronic surveillance :s provided to detect accidental or deliberate
intrusion. Maintenance of the integrity of the structures is required.
Plant use is limited to nuclear only. Site use may be non-nuclear, with
certain restrictions.
• Custodial Safe Storage hayaway(b}j - A minimum cleanup and decontamination
effort is made initially, followed by a period of interim care, with
the active protection systems (principally the ventilation, utility
and fire protection systems) kept in service throughout the storage
period. Full-time onsite surveillance by security forces is required to
(a) This nomenclature is used in Regulatory Guide 1.86(l}

(b) This nomenclature is used in NUREG-0278(2)
4-5
. ······---·-··-~=---------------
prevent accidental or deliberate intrusion into the facility and thP
subsequent exposure to tadiation or dispersal of radioactivity beyond
the confines of the facility. Use of the facility and site is generally
limited to nuclear activities.
All categories of Safe Storage are open-ended and some positive action is
required at the conclusion of the period of interim care to release the
property for unrestricted use and terminate the license for radioactive
materials. Depending upon the nature of the nuclear facility and its operating
history, the necessary action can range from a radiation survey that shows the
property to be releasable, to dismantlement and removal of residual radioactive
materials. These latter actions, whatever their scale, are generically
identified as Deferred Dismantlement.
Safe Storage is used as a means to satisfy the requirements for protection
of the public while minimizing the initial commitments of time, money,
occupational radiation exposure, and waste repository space. Modifications to
the facility are limited to those that assure the security of the buildings
against intruders and those required to assure containment of radioactive
or toxic material. It is generally not intended that the facility would
ever be reactivated, although that is a possible option, particularly with
Custodial Safe Storage. For a mixed oxide fuel fabrication plant, decay of
residual radioactivity is very slight and personnel exposure to radiation is
not significantly changed during reasonable periods of Safe Storage (a few tens
of years). Thus, placing an inactive MOX facility in Safe Storage for a
reasonable period of time produces virtually no benefit in terms of reducing
radiation exposure t.o decommissioning personnel.
The reduced initial effort (and cost) of Safe Storage is tempered some-
what by the need for continuing surveillance and physical security to assure
the protection of the public. For all Safe Storage modes, electronic surveil-
lance devices are in service full-time, with off-shift readouts monitored in a
local law enforcement office or a private security agency. These devices,
which monitor for intruders, radiation-level increases, and fire detection,
require periodic checks and maintenance. For Custodial Safe Storage, a small
operating and security staff is required at the retired facility to provide
4-6
for equipment operation, general maintenance. and plant security. This staff
also guards against unauthorized access to any inventory of Special Nuclear
Materials (SNM).
Maintenance of the facility•s outer-confinement barriers and surfaces and
an )n-going program of environmental surveillance are also necessary for all
Safe Storage modes.
The duration of the period of interim for a plant before final decommis-
sioning may vary depending on the needs of the plant owner, based primarily
on economic and safety trade-offs. For example, if the value of the site
property for unrestricted use is large and the cost of interim care is also
large, there would be incentive to dismantle reascnably soon. On the other
hand, ~ potential alternative use of the facility may suggest maintaining the
faci1ity in Safe Storage for an extended time period. Similarly, the decision
on the extent of chemical decontamination within the plant during the prep~a
tions for Safe Storage depends on the cost of interim care and the planned
length of the storage and surveillance period. Regulatory requirements and
public concerns may also influence the duration of the interim care period.
At the end of the Safe Storage period, several things remain to be done
before the facility can be made available for unrestricted use and before
the possession-only license for radioactive materials can be terminated.
The remaining quantities of long-lived radioactivity that exceed unrestricted
release limits must be removed and contaminated equipment must be packaged
and removed to a regulated disposal site. Significant amounts of materials
ar.d equipment contaminated with transuranic elements would be removed and
shipped to a federal repository. Once the remaining radioactive materials
are less than the unrestricted release limits, the nuclear facility license
can be terminated.
Thus, for a mixed oxide fuel fabrication plant, Safe Storage consists of
temporary decommissioning and is followed by a variable period of interim
1 care consist1ng of security, surveillance and maintenance. When termination
of the nuclear facility license is desired, final dismantlement will likely
be required.
4-7
The Custodial Safe Storage mode appears to be most applicable to short
term inactivation (e.g.~ 5 to 10 years) of a mixed oxide fuel fabrication
plant, to a multi-facility site where surveillance, security, maintenance
and operating capabilities exist, or to the situation where the likelihood
exists for later use of the retired facil{ty.
Passive Safe Storage involves shutdown of all plant operational systems,
leaving in service only those passive systP.~S required for safety and surveil-
lance. In addition, more decontamination a~d equipment removal will be required
than for Custodial Safe Storage to assure removal of SNM to low enough levels
to allow remote surveillance. Rigid physical barriers are installed to assure
confinement of remaining radioact:ivity. Reactivation of the facility could
onlv be done at great expense and effort and would likely not be contemplated.
Thus, Passive Safe Storage could potentially be considered for mixed oxide
fuel fabrication plants when future plant use is not planned, or when longer
Safe Storage times {e.g., several tens of years) are contemplated.
4.1.2 Definition of and Rationale for Entombment
Based on the guidance put forth in NRC Regulatory Guide 1.86,(l) Entomb-
ment of a nuclear reactor facility requires the encasement of the radioactive
materials in concrete or other structural materials sufficiently strong and
structurally long-lived to assure retention of the radioactivity until it has
decayed to levels that permit unrestricted use of the site. The amount and
half-life of the res·idual radioactivity in the facility to be entombed deter-
mines the time period that the integrity of the structure must be assured
and whether or not re-entry for additional decomissioning is required.
The Environmental Protection Agency (EPA) is developing generally
applicable environmental .protection criteria for management of all radioactive
wastes that will impact NRC decommissioning standards and guidelines. In a
background report entitled Considerations of Environmental Protection Criteria
for Radioactive Wa~te,(J) EPA proposes a criterion limiting reliance on
institutional controls to a finite period of time. EPA suggests that the use I
of institutional control to protect the public from hazards in retired
nuclear facilities should be limited to a period of 100 years at most and
preferably to less than 50 years. After the allowable institutional care
period is over, the site would have to meet radioactive protection levels
established for release for unrestricted use.
4-8
Extrapolating from the intent of Regulatrry Guide 1.86, a nearly ·identical
draft guide relating to non-reactor facilities,( 4 ) and the EPA-proposed
criteria,(J) it is concluded that any permanentlyn entombed structure must
11
be designed to outlast any contained radiological or chemical hazard to man,

or be designed perhaps to dilute th~~e hazards to innocuous levels as the
structure disintegrates. Unless the structure is to be re-entered later and
decommissioned further, these potential chemical and radiological hazards
should vanish in no more than about 100 y?ars9 in order to fulfill the bases
for Entombment. Taking no credit for the clnution effects of Entombment,
these criteria and guidanc·~ virtually prohibi~ entombing any nuclear facility
containing long-lived radio~uclides or ttxic chemical elements.
While it is reasonable to assume that man can design and construct high-
integrity, long-lived surface structures, it is also reasonable to assume that
any long-term human controls on or responsibility for that facility will
ultimately disappear and that the long-lived radionuclides, chemicals or toxi-C·
:....~
elements contained therein will ultimately be dispersed into the environment~· !.~-'.';,
For the radionuclides of concern in this study {239 Pu, 24,100-yr half-life), '·
the entombed structure would likely disinteg~ate long before the plutonium
has decayed to innocJous levels.
Since the 1nore restrictive decommissioning guidance and criteria from
NRC and EPA are only currently being proposed and the Entombment mode has
been selected in the past for certain nuclear facilities, it is evaluated in
this study to gain perspective as to its relative merits.
4.1.3 Definition of and Rationale for Dismantlement
Immediate Dismantlement provides a way to meet the requirements for term-
ination of a nuclear possession-only license in the near term, thus eliminating
long-term security, maintenance, and surveillance needs and making the site
available for unrestricted use within about three years following facility
shutdown. To accomplish dismantlement requires that all potentially contaminated
systems be disassembled and removed from the facility and transported to a
regulated disposal site.
4-9
In Immediate Dismantlement~ larger initial conJJlitments of money are made
·in exchange for prompt availability of the plant site for other purposes~
reuse of plant components, and elimination of continuing costs for security,
maintenance, and surveillance.
Deferred Dismantlement~ as might occur at the end of an extended period
of interim care, perhaps a few tens of years, continues decommissioning
activities beyond those done during the preceding Safe Storage period. Dis-
mantlement activities will still be controlled by residual long-lived radio-
activity in the plant. The benefits to be gained by Deferred Dismantlement
of a mixed oxide fuel fabrication plant (i.e., the possibility of re-use of
the faci 1i ty and the deferra ·1 of d 'i s~.:;:.~t1t:~~~cl1t costs) wi 11 depend on the
char·acteristics of each facility a:.. the tirne of' final production shutdown.
These benefits must be weighed a9ainst di~advant~~es of deferring dismantle-
ment (i.e.~ costs of interim ~:1re~ value of and need for the reclaimed site,
and the need to familiarize the new decommissioning staff with the facility).
Based on the arguments presented previously, Immediate Dismantlement is a
viable mode for a mixed oxide fuel fabrication plant and represents the
maximum decommissioning activity that can be undertaken at the end of plant
life. Thus, Immediate Dismantlement is analyzed in this study. Also, because
it is currently believed that the final decommissioning action for the types
of plants under consideration must be dismantlement~ Deferred Dismantlement
following Safe Storage is also analyzed.
4.1.4 Viaba~ Combinations of Decommissioning Modes
Figure 4.1-1 illustrates the major decommissioning modes (including the
three variations of Safe Storage) for nuclear fuel cycle facilities and shows
how they might be scheduled for implementation~ depending on timing of and
decisions for facility disposition use. From top to bottom on the diagram,
the decommissioning modes require increasing fixation or removal of radio-
activity. Time increases are shown from left to right on the diagram. Before
plant shutdown, a decision must be made as to which decommissioning mode will
be implemented (at least initially), as shown by the diagona·l lines. The
possibility of starting with minimum decommissioning activitie£ and allowing
for deferral of decisions to do more extensive decommissioning is provided
for in all cases except Immediate Dismantlement.
4-10
·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·,
ESSENTIALLY NO USE FOR NONRADIOACTIVE OPERATIONS j RESTRICTED OR j UNRESTRICTED j
!
CONDITIONAL USE j USE i
1I SURVEILLANCE AND j
INCREASING
DECOMMISSIONING ---- j MONITORING ;
V.'"RK ,--l•l------.lj REQUIRFDI j
DEFERRED ___ ·- _ ,..1
l t--~-II'(N
I
PASSIVE SAFE
STORAGE
-·-·.,_·-·-·-·-·-
•
RADIOACTIVITY I.
I
DECAY
_______ ,..._~:._ _____ _....J

t'
I
I
I
•
RADIOACTIVITY
DECAY
~
I
•
I
j
I 1 1-
j I
I RAD I OACTI VI TY j
HA~%~Efd"1-·~·..;)---.."l!t--·--<~ ---,.. - ~ES!:f- ...,
,
-----·-·
I ·-- ----·~
ENTOMHMENT j,,.,.J
"'" ·-··,- ··-<>--: __ ..!!,£~~--~
1 RADIOACTIVITY j
__ ...
I PERMANENT I I DEFERRED
. 1 Dl:=~,j~:---y- -·- ------·-·--·---

- -..··1 0 i SMANTLEMENT
!I .
0 1
L--·-·-·-·-·i.·-·-·-·-·-·-·-·...1·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-
APPROXIMATE TIME - - - •
0 DECISION POINT
<ij> DECISION POINT INCLUDING POSSIBILITY FOR CONVERTING TO OTHER NUCLEAR USE
D DECOMMISSIONING ACTION
- - - UNLIKELY ROUTE
FIGURE 4.1-1. Generalized Decommissioning Pathways and

Alternatives for Many Fuel Cycle Facilities
Also shown are the general facility/site use categories for the various
combinations of decommissioning modes. These use categories are: l) essen-
tially no non-nuclear use, 2) conditional use, and 3) unrestricted use. For
completeness, decommissioning routes from Safe Storage modes, via radioactivity
decay to unrestricted use levels, are shown w·ith dashed lines, although these
are determined to be nonviable routes •or mixed oxide fuel fabrication plants.
A potentially viable combination of modes not shown in the diagram is
that of dismantlement of part of the facility, together with Safe Storage of
the highly radioactive areas. The principal virtues of this combination are:
the structures outside of the access barriers are decontaminated, dismantled,
4-1'1
and released for unrestricted use or for, demolition, and highly radioactive
sectors and associated components (selected process rooms, glove boxes~
vessels, pumps, piping, etc.) are left intact, thus reducing radiation
exposure to decommissioning personnel. For the Passive Safe Storage mode,
active protection systems would not be required for the contaminated areas.
While the initial (and total) costs would be larger than for total Safe
Storage, reductions tn the interim care costs would be possible, and other
beneficial use could be made of the facility/site areas outside the boundary
of the secured area.
In summary, t~e princinal decommissioning routes for a mixed oxide fuel
fabrication plant/site are:
• Dismantlement immediately after plant shutdown
• Deferred Dismantlement following a period of Safe Storage
• Monolithic Entombment immediately after plant shutdown.
For the case of Deferred Dismantlement, total decommissioning of the
facility to unrestricted use involves two stages of decommissioning, separated
by a period of interim care.
4.2 TECHNICAL APPROACH

The initial effort in this study is to develop a plan to accomplish the
study objectives. The plan is developed by a team of key personnel with
expertise in the primary areas of interest. The areas of expertise include
fuel fabrication plants and their operation, decommissioning techniques,
chemical decontamination, chemical and radiological toxicant regulations,
safety analyses (including pathways of toxic materials in the environment),
operational health physics, and cost and benefit estimating and analyses.
Consultants and/or no~-Battelle experts are utilized to contribute to or
review the study results. The resultant approach is shown in simplified form
in Figure 4.2-1. The study is then carried out by the same staff or by staff
with similar backgrounds.
4-12
Q COSTS, AND
OTHER EFFECTS
ESTIMATE
COSTS AND
OTHER EFFECTS ---
FIGURE 4.2-L Approach for Decommissioning Study
The first step in conducting the analysis is to select and characterize

the reference facility in sufficient depth to perform an engineering and
safety analysis of decommissioning the facility. An existing plant is selected
on the basis of having characteristics typical of existing small mixed oxide
fuel fabrication plants that will be subjected to decommissioning in the reason-
ably near future.
The total facility is placed on a co~ceptual generic site that is also
being used in similar and related studies'of other fuel cycle facilities. A
detailed description of the facility is compiled that includes information
such as plant equipment and material sizes, volumes, surface areas and we·ights.
Pre-decommissioning conditions for the plant and site are defined, including
residual radioactivity levels.
A span of decommissioning modes (i.e., Custodial Safe Storage including
a period of interim care before Deferred Dismantlement, Immediate Dismantle-
ment and Entombment) and site use limitations for decommissioned facilities
(i.e., nuclear use only, conditional non-nuclear use, and unrestricted use)
are selected. Related regulatory guidance is reviewed, summarized, and used
as an aid and basis in the study.
Methodology is developed for defining residual radioactivity levels in
faciiities and sites that would permit unrestricted us~ of decommissioned
facilities, in terms of the allowable radiation dose to the maximum-exposed
member of the public. The variety of potential pathways through which radio-
nuclides could reach man are considered in determining these acceptable levels
4-13
or disposition criteria." This methodology is applied to develop example
11
criteria ir terms of allowable amounts of residual radionuclides, based on the

assumed radionuclide mixtures at the plant/site. These disposition criteria
are then used in the study to define the extent of decontamination necessary
to achieve the planned end-use objectives.
Past decommissioning experience of facilities with characteristics related
to the reference facility is reviewed. From this review, a summary of insights
from these decommissioning experiences are derived and applied where applicable
to this study.
Techniques for decontamination of facilities are reviewed. A work
schedule and time schedule al''E~ 'H:?loped conceptually decommission t';e
reference facility for each of the three nndes. The techniques used are
selected on the basis of engineering judgment. This is done maintaining a
balance of safety and cost.
Safety analyses ar·e performed for the decommissioning modes studied.
These analyses include radiological and chemical exposures to the public and
to workers for normal decommissioning operations and from potential accidents.
Nonradiological industrial accidents to workers are also estimated. The
safety analyses utilize established data and methodology to estimate the
various factors required, such as release mechanisms, dispersion pathways,
and exposure modes of the releases materials.
Direct costs of decommissioning are estimated, including labor, materials,
equipment, packaging, transportation, waste disposal, and surveillance costs
where applicable. Costs are projected into the futur·c to provide a reference
base for estimating future financial requirements. Alternatives for financing
decommissioning are examined and compared using example costs from this study.
Cost ranges are defined to estimate the sensitivity of the total cost to
variatio~s in selected key cost elements.
-
For each decommissioning mode, all of these factors are combined into an
overall comparison of their safety-costs-benefits and advantages and disad-
vantages.
4-14
m·~nsr ·nzr
The study is documented in this report, with Volume 1 containing the
main study information and Volume 2 containing supporting details.
4.3 KEY STUDY BASES

From the outset, a number of important ground rules are established to
guide the emphasis of the study. These bases are derived from the primary
objective of the studys which is to provide an analysis of safety, costs, and
other factors involved in decommissioning a small comMercial mixed oxide fuel
fabrication plant. The study is intended to provide background information
useful to regulators, plant designers and o~terators of such facilities. From
these objectives, the key bases are establi hed for all aspects of the study
to assure that the overall study' objectives (see Section 1) are achieved.
These key bases, listed below, can have major impact on the issues of safety,
cost, and t1me for decommissioning. As stated earlier, many aspects of
decommissioning will change with facility locations, specific facility shutdown
conditions and residual contamination levels in the plant. The bases and
assumptions used in this study must therefore be carefully examined before
the results can be applied to a different facility and site.
1) The study is to yield realistic and up-to-date results. This primary
basis is a requisite to meeting the objectives of the study, and provides
the foundation for most of the other study bases.
2) The objective of decommissioning is to assure the continued protection
of the public from the residual radioactivity and any other potential
safety hazards in the retired facility.
3) The study is to evaluate, in so far as possible, a real and contemporary
facility. This basis is an obvious necessity to meet the study objectives
and the primary basis above. The facility selected as reference for the
study, Kerr-McGee's Cimarron plant, is felt to satisfy this condition.
The existing Cimarron facility is a small, glove box ("hands on") operation
and appears to represent existing facility features. Where there may be
exceptions to this latter point, the issue is dealt with in the study
by adding conceptual features to the existing plant (e.g., the head-en9
4-15
facility for dry blending preformed uranium and plutonium oxides, a load-
in station for uranyl nitrate solution, and an evaporation system for
concentrating liquid wastes).
4) The study is to include a·n analysis of a spectrum of decommissioning
..
modes. This is done by investigating Immediate Dismantlement, Safe
I;_ ·~
Storage followed by Deferred Dismantlement, and Entombment.·.

5) Only facilities planned to contain radioactive material and contiguous
areas are included in the study. Decommissioning of separate nonradio-
active subfacilities is to be accomplished by conventional demolition/
salvage techniques and is outside the scope of this study.
6) The mixed oxide fuel fabrication facility is assumed to be the only
nuclear facility on the site. It is assumed to have operated for 10 years
prior to plant shutdown and the onset of decommissioning operations. During
operation, the plant is assumed to have had a conceptual mixed oxide
production capacity of two metric tons per year of contained heavy metal
(uranium) based on operation of the plant by three full shifts per day,
365 days per year.
'7) Current and proven decommissioning technology and techniques are used
in the study. Where developmental techniques are applied, they are in
an advanced state of development and believed to be ready for application
in this study.
8) A single decommissioning plan is evaluated for each mode analyzed. Where
different techniques or assumptions have significant impact on the study
results, the effects of alternatives are discussed at least qualitatively.
9) De~commissioningtechniques conform to the principle of keeping occupationa1
radiation doses As Low As is Reasonably Achievable (ALARA).
10) Decommissioning plans are selected to provide public/occupational safety
in a cost-effective manner.
11) All personnel assigned to decommissioning operations are assumed to be
experienced radiation workers with previous experience in the operation
of a mixed oxide fuel fabrication plant, reprocessing plant, or other
similar nuclear facilities.
4-16
12) The performance of decommissioning is assumed to be relatively trouble-
free; that is, no scheduling or cost allowances are made for unforseen
events that might impede the conduct of the work. This assumption may
lead to somewhat optimistic results, but is believed to be achievable
with good planning and preparations.
13) It is assumed that pla:tt process areas have been kept relatively clean
during the operating period to allow for easier operational maintenance.
As a result, expected contamination levels are generally modest and should
be reasonably consistent with the quality of operation expected in modern
commercial facilities. Any major contamination episodes are assumed to
have been reasonably welt cleaned-up immediately following the event.
14) A final operational clean-up of the more important inventories of radio-
nuclides is done as part of normal operations, and is not charged to
decommissioning. This clean-up is assumed to be routine and similar
to those done periodically between normal processing campaigns to improve
equipment performance, segregate materials, and to recover materials
unaccounted for. Subsequent decontamination efforts are charged to
decommissioning.
15) The quantity and mixture of radioactive contamination present at plant
shutdown is assumed to represent an accumulation of contamination that
is fairly difficult to clean during operations, thus allowing for decay
of accumulated radionuclides. Specifically, contamination inventories
are assumed to accumulate at the rate of 1/lOth per year of the total
accumulation, for the assumed 10 years of plant operation.
16) The isotopic inventory of input to the plant is typical of that used
in the manufacture of fuel for the Fast Flux Test Facility:
22.7% Puo2: Pu 236 <0.01 wt%

Pu 238 0.04 wt%
Pu 239 86.3 wt%
Pu 240 11.8 wt%
Pu 241 1.7 wt%
Pu 242 0.15 wt%
4-17
u 234 ~0.01 wt%
u 235 0.71 wt%
u 238 99.28 wt%
17) All materials shipped to the plant, and fuel rod and waste shipments from
the plant are assumed to be transported by truck. There are no rail
facilities at the plant.
18) Because of the nature of the facility, all radioactive wastes generated
during decommissioning are considered to coniJin transuraP.ic materials.
These wastes are assumed to be sent to a Federal repository for deep
geologic disposal whenever the alpha radioactivi~ exceeds 10 nCi/g of
waste.
19) External radiation exposures to the public and to decommissioning
workers from normal decommissioning activities are based on assumptions
believed to be realistic. Internal radiation exposures (i.e., those
from internally deposited radioactive material) from normal decommission-
ing activities and from potential accidents are based on assumptions
believed to be conservative.
4-18
I
REFERENCES
1. U.S. Atomic Energy Commission Regulatory Guide 1.86, Termination of

Operating Licenses for Nuclear Reactors, June 1974.
2. K. J. Schneider and C. E. Jenkins, Technology, Safety and Costs of
Decommissioning a Reference Nuclear Fuel Reprocessing Pjant, NUREG-0278,
U.S. Nuclear Regulatory Commission report by Pacific Northwest Laboratory,
October 1977.
3. Considerations of Environmental Protection Criteria for Radioactive Waste,
EPA Docket No. PR-30, 40, 50, 70 (43 FR 10370), August 1978.
4. U.S. Nuclear Regulatory Commission Draft Guide, Guidelines for De"Jntamin-
ation of Facilities and Equipm~nt Prim- to Release for Unrestricted Use
or Termination of Licenses for By-Produc~, Source, or Special Nuclear
Material, November 1976.
4-19
5.0 REGULATORY AND SAFEGUARDS CONSIDERATIONS
In the development of a viable plan for decommissioning a nuclear facil-

ity such as a mixed oxide fuel fabrication plant, consideration must be
given to the regulations that exist to assure public and occupational safety
during such operations. Additionally, because of the anticipated presence
of special nuclear material {SNM) in shutdown MOX plants, consideration mllst
be given to the necessity and methods for safeguarding the material. The
following sections discuss these issues in general and as they apply to
the reference MOX plant. Also, areas are identified where guidance is
incomplete or where application of existing guidance to decommissioning is
unclear.
5.1 EXISTING REGULATIONS, STANDARDS, AND GUIDES

Decommissioning activities in the past have not been a principal focus
of government regulatory activity. Consequently, although an extensive
framework of governmenta 1 requirements apply to decommi ss i oni ng of nuc 1f~ar
facilities, many of the requirements that affect decommissioning do so only
indirectly. Extensive government requirements regarding nuclear facility
construction and operation, the possession of certain nuclear materials, and
limitations of occupational radiation doses are examples of requirements that
apply to decommissioning but that were originally directed towards some other
primary purpose.
Users of information from this section should recognize that regulations
and guidelines in this area are dynamic. National policy relating to the
LWR nuclear fuel cycles is changing. The information found in Section 5.1
reflects the status of the regulations and federal guidelines as of June
1978 and can only be' ,ed as a departure point for future application.
The regulatory framework of requirements is planned to become more
explicit with regard to decommissioning.{l) With increasing public and
regulatory attention being paid to decommissioning issues, an evolution of
requirements can be expected that will have as a principal purpose the
establishment of a comprehensive and systematic body of requirements govern-
ing the decommissioning of nuclear facilities.
5-l
Currently less than a dozen small MOX facilities have been constructed
in the United States. Some of these are licensed as research and develop-
ment facilities. The reference plant for this study is licensed as a com-
mercial and industrial facility. ( 2 ) The current U.S. policy of deferring
commercial recycle of plutonium for electric power production(a) supports
the need to study the decommissioning of these facilities.
5.1.1 Federal Jurisdiction
From its beginnings after World War II, the U.S. nuclear industry has
been subject to extensive government ,a 1on. The Atomic Energy Act of
1 9 4 6 ( 3 ) e s t a b1 i s t. tl P Pd. ': r 't 1on, nut the federal government
r·eta i ned the m'mt::rslli r als and related facilities;
private activity was restrict J con I operations for the govern-
ment. The Atomic Energy Act of 1954( 4 ) changed this policy to facilitate
participation by private industry in the development of atomic energy under
an extensive statutory program of federal licensing and regulation.
The Atomic Energy Act of 1954 requires a license for the possession~
transfer, or use of source material, special nuclear material, and by-product
material. Separate licenses are required for construction or operation of
facilities that produce nr utilize special nuclear materials. Licenses are
issued exclusively by the Nuclear Regulatory Commission (NRC). The issuance
of licenses is statutorily conditioned upon adequate provision for the pro-
tection of the public's health and safety. Extensive regulatory and rule-
making authority is provided in the Act to carry out these requirements.
Several federal agencies have jurisdiction that can affect the decom-
missioning of nuclear facilities. The principal agencies with such juris-
diction are the Nuclear Regulatory Commission, the Environmental Protec-
tion Agency, the Department of Transportation, and the t>. t.r.1ent of Energy.
This subsection briefly identifies these agencies and summar 1 z~; their
regu·iatory judsdictions, as identified in Table 5.1-1.
(a) Remarks by the President on nuclear power policy in a question-and-ans\Jer

session that took place at the White House on April 7, 1977.
5-2
TABLE 5.1-1. Principal Federal Agencie5 and Statutory Authority
That May Affect Decommissioning
Agency Statutory Authority
Nuclear Regulatory Atomic Energy Act of 1954.
Commission Energy Reorgan~ization Act of 1974.
Environmental Protection Reorganization Plan No. 3 of 1970.

Agency Clean Air Act Amendments of 1977.
Safe Drinking Water Act.
Department of Hazardc s Hat~rials Transportation

Transportation Act.
Department of Energy Energy Reorganization Act of 1974.

Department of Energy Organization Act.
Pursuant to the Energy Reorganization Act of 1974, the Atomic Energy

Commission was abolished(S) and NRC inherited its reg•.tlatory authority under
the Atomic Energy Act of 1954. The Department of Energy (DOE) assumed the
disbanded AEC's research and development functions and its promotion of new
technology activities. Among other tnings, NRC is responsible for assurance
of safety to life and property from the civilian use of nuclear material. NRC
authority extends to all persons who possess, use, or transfer by-product,
source, or special nuclear materials.
The Environmental Protection Agency (EPA) is the Federal Government's
chief environmental regulator. EPA assumed the duties of the Federal Radia-
tion Council under the President's Reorsanization Plan Number 3 of 1970. ( 6)
The EPA Administrator is to advise the President on radiation matters that
directly or indirectly affect health; also the Administrator is to provide
guidance to all federal agencies in the formulation of radiation standards
and in the establishment and execution of programs of cooperation with the
states. (l) The EPA Administrator also is responsible for establishing
generally applicable environmental standards for the protection of the
5-3
environment from radioactive material outside the boundaries of property sub-
ject to the control of NRC licensees. Under this authority EPA has proposed
guidance on dose limits for persons exposed to transuranium elements in the
general environment.(B) EPA has authority to regulate radioactive emissions
into the air under the Clean Air Act Amendments of 1977, as discussed in
Section 5.1.4.( 9}
Finally, EPA has authority to regulate doses from radioactive discharges
under the Safe Drinking Water Act. (lO) From this, the EPA has established maximum
contaminant levels in public dri.1king water systems. To date, regulations
have not been issued by EPA that establish standards for radioactive
contaminant levels in drinking water.
The principal fedP•al agencies concerned with the transportation of
radioactive materials are the Department of Transportation (DOT) under the
Hazardous Materials Transportation Act of 1974(ll) and NRC under the Atomic
Energy Act of 1954. Federal safety .·egulations concerning nuclear materials
transportation< 12 ) seek: 1} containment of the radioactive material to avoid
contaminating air, land, or water resources; 2) shielding to control external
radiation exposure to the environment from individual packages; 3) limita-
tions on the quantitv of nuclear material within a given package to prevent
radiation hazards, overheating, and nuclear criticality; and 4) restrictions
on placement and storage of radioactive materials for protection of people.
A .. Memorandum of Understanding .. between the NRC and DOT was signed in
1966 and revised in 1973.< 13 ) This memorandum calls for cooperation between
DOT and NRC and delineates the responsibilities of each agency. DOT is
responsible for promulgating and enforcing safety stand~rds governing pack-
aging and shipping containers, and for the labeling, classification, and
marking of a 11 packages. DOT also implements safety standards fat• the
mechanical condition of carrier equipment and qualificati·ons of carrier per-
sonnel. NRC develops performance standards for package designs and
reviews package designs for Type B, fissile and large quantity packages.
DOT requires NRC approval for shipper and carrier use of these packages. (l 4 )
5-4
The Federal Aviation Administration (FAA), the Interstate Commerce Cornmission(ICC),
and the U.S. Coast Guard also exercise some regulatory authority o•;er the
shipment of radioactive materials.
The transportation or packaging for transport of radioactive material
is subject to issuance of the appropriate licenses. Applicarts for a license
to package or to transport radioactive material must show by a combination of
analysis and experiments that the proposed package or transport vet.Jicle
satisfies all the requirements set forth in the Code of Federal Regulations.
The application must describe proposed controls or precautions to be used in
the loading, unloading, handling and transpo:rt of radioactiv-e material, and
the procedures to be followed in the event of an accident or delay in ship-
ment. Inspection and acc01anta~ility procedures must also be described.
The following Federal Regulations are applicable to the transport of
radioactive ma,terials:
• Title 49 Code of Federal Regulations Parts 170-199 (49 CFR 170-199) -
Department of Transportation regulations governing the transport of
hazardous materials.
• 10 CFR 71 - Nuclear Regulatory Commission regulations governing the
packaging and shipment of radioactive materials.
• 14 CFR 103 - Federal Aviation: Administration regulations for shipment
of radioactive materials by air.
• 47 CFR 146 and 149 - U.S. Coast Guard regulations governing the
shipment of radioactive materials by water.
• 10 CFR 73 - Nuclear Regulatory Commission regulations for the pro-
t tection of special nuclear material in transit.
J The DOT and NRC regulations are the most imj.._rtant for shipments made during
the decommissioning of nuclear facilities.
Occupational safety is also of major importance during decommissioning.
Radiation protection to workers is regulated by 10 CFR Part 20. Section
20.101 defines the external exposure limits. The. operating philosophy of
ALARA ~s Low As is Reasonably Achievable) apply to these exposure limits.
5-5
NRC describes this operating philosophy in Regu'latory Guide 8.8, "Infm~
mation Relevant to Maintaining Occupational Radiation Exposure as Low as
Practicable (Nuclear Reactors)," and Regulatory Guide 8.10, 0perating Phil-
11
osophy for Maintaining Occupational Radiation Exposure as Low as is Reason-

ably Achievable ... Although not specifically cited for application to
decommissioning activities, the guides are intended to apply.
Additional infomation can be found on how to comply with the ALARA
concept in the NRC Standard Review Plan, Section 12.1, .. Assuring that Occu-
pational Radiation Exposures are As Low As is Reasonably Achievable. Some
11
of the more relevant regulations and guidance for control of occupational

exposure are given below:
• 10 CFR Part 19, Notices, Instructions and Reports to Workers;
Inspections
• 10 CFR Part 20, Standards for Protection Against Radiation
• Regulatory Guide 1.8, Personnel Selection and Training
• Regulatory Guide 1.16, Reporting of Operating Information
• Regulatory Guide 1.39, Housekeeping Requirements for Water Cooled
Nuclear Power Plants
• Regulatory Guide 8.2, Guide for Administrative Practices in
Radiation Monitoring
• Regulatory Guide 8.3, Film Badge Performance Criteria
• Regulatory Guide 8~6, Standard Test Procedures for G-M Counters
• Regulatory Guide 8. 7, Direct Reading and Ind·irect Reading Pocket
Dosimeters
• Regulatory Guide 8.8, Information Relevant to Maintaining Occupational
Radiation Exposures as Low As Practicable (Nuclear Reactors)
• Regulatory GJJide 8.9, Acceptable Concepts, Models, Equations and
Assumptions for a Bioassay Program
• Regulatory Guide 8.15, Acceptable Programs for R~spiratory Protection
5-6
• Regulatory Guide 8.XX, Control of Radioactive Surface Contamination
pf Material, Equipment and Facilities to be Released for Uncont~olled
Use (in preparation)
• ANSI Nl8.9-1972, Administrative Controls for Nuclear Power Plants,
America~ National Standards Institute (1972)
• ANSI Z88.201969, Procedures for Respiratory Protection,

American National Standards Institute (1969)
• USBM-23, Respiratory Protective Services for Use in Atmospheres
Containing Radioactive Materials, U.S. Bureau of Mines (1973)
One of the goals of decommissioning a nuclear facility is to make the
land available for other uses if desired. In order to release the facility
and/or site for unrestricted use, the residual radioactive contamination must
be at a level acceptable for public protection. Several attempts have been
made to define the permissible levels of residual radioactivity. In this
report, a methodology for determining the criterion is based on dose and
an example is applied to the reference r·.1QX plant. Other major guidance is
found in Regulatory Guide 1.86(l 5) and 40 CFR 190{l 6) and the proposed ANSI
Standard N328, Control of Radioactive Surface Contamination on r·1aterials,
~ipment and Facilities to be Released for Uncontrolled Use. {a) Another
guidance(l?) that NRC uses for terminations of by-product, source and special
nuclear material licenses (similar to Regulatory Guide 1.86) contains a table
of .. Acceptable Surface Contamination Levels" identical to that in Regulatory
Guide 1.86.
Additional guidance can be inferred from information developed for
plutonium in soils.(la,lg) EPA is also in the process of finalizing their
guidance for the environmental limits of transuranium element contamina-
tion in soils for unrestricted use after accidents.(B)
The Department of Energy {DOE) may also play an i.mportant role in nuclear
decommissioning. DOE owns and operates nuclear facilities as well as trans-
portation equipment. It will operate the federal high-level nuclear waste
(a) The NRC supports the provisions of this standard.
5-7
waste repositories (which wi11 be licensed by NRC). In addition, some have
proposed that DOE also operate low-level radioactive waste burial grounds.(ZO)
Accordingly, DOE may make an important contribution to NRc•s estab1ishment
of standards and specifications for high-level radioactive waste~, tr~ns
uranic and other radioactive wastes, and decorrm·issioned facilities and equip-
ment that require internal disposal in government waste repositories.
Other federal agencies may also have an effect on decommissioning
activities under particular circumstances. For example, the Department of
Justice, under the antitrust laws, may seek to enhance competition in various
phases of the civilian nuclear industry. In addition, under Section 105 of
the Atomic Energy Act of l954,( 2l) the Attorney General is authorized to comment
upon the antitrust a~pects of certain license applications.
Thus, NRC, EPA, DOT, and DOE are likely to be the federa~ clgencies with
the principal responsibilities affecting decommissioning. To the extent that
regulations of more than one agency apply, a nuclear facility operator needs
to comply with all such regulations.
5.1.1.1 NRC Regulations
AlLhough many NRC regulations affect certain decammissioning activities,
there is currently no regulatory focus on decorrmissioning. t1oreover, there
is little in current decommissioning regulations that directly applies to
MOX plants. It is anticipated that in the future, regulations much like those
that exist in 10 CFR Part 50, will be established in Section 10 CFR 70 for
~10X-type facilities. The few direct references to decommissioning activities
include 10 CFR 50.33(f) -- relating to financial qualifications for facility
shutdown; 10 CFR 50.82 -- ou~lining information and procedures for license
termination; 10 CFR 51.5(b) -- relating to environmental impact statement
requirements in licensing proceedings involving decorrmissioning; Regulatory
Guide 1,86 --relating to decommissior.ing of ~uclear reactors(lS); and guide-
lines for decommissioning other nuclear facilities.(ll)
10 CFR 50.33(f) requires that the applicant for an operating license
provide information to show:
5-8
Th?t the applicant possesses or has reasonable assurance of
obtaining the funds necessary to cover the estirn~ted costs of
operation for the period of the license or for five years,
whichever is greater, plus the estimated costs of permanently
shutting the facility down and maintaining it in a safe
condition.
As can be seen, this regulation is not specific or detailed but leaves open
for development on a case-by-case basis the information and activity neces-
sary to provide a "reasonable assurance" of the applicant's financial
qua 1i fica ti ons.
Appendix C to 10 CFR 50 does little to elaborate un the information
re'lUired under 10 CFR 50.33(f) for deconmissioning financing. While construe··
tion financing information requirements arc comparatively detailed, financial
information requirements for oper·ating and shutdown are basically repeated
from 10 CFR 50.33(f).
In addition, NRC Regulatory Guide 3.39, Standard Format and Content of
License Application for Plutonium Processing in Fuel Fabrication Plants,
also briefly discusses decommissioning. Unlike NRC regulations or orders,
compliance with regulatory guides is not required. Approaches different from
those set forth in the guides are acceptable if regulatory requirements are
satisfied. Section 10.6 of Regulatory Guide 3.39 indica'i:es that license
applications should describe provisions for plant decommissioning. The guide
further suggests that procedures for decontamination arrangements with out-
side organizations and arrangements for funding of decommissioning activities
be discussed. The guide provides no specifics on the decommissioning infor-
mation and data that are being requested. Regulatory Guide 3.39 was issued
in January 1976, subsequent to the licensing of most existing small MOX fuel
fabrication plants. Accordingly, most current MOX facility construction or
operating licenses do not have decommissioning financing plans.
NRC is now considering the need for additional assurance that adequate
funds are available for decommissioning when required. Several possibilities
exist for assuring the achievement of this objective. The general alternatives
are discussed in Section 6.
5-9
5.1.1.2 License Termination
A formal application must be made to NRC to terminate operation of a
MOX plant. NRC requirements for terminating a license for-nuclear reactors
and fuel reprocessing plants are contained in 10 CFR 50.82. They require
an application that specifies certain information on planned decomrnissioning
procedures. The regulation authorizes termination procedures, specifies
additional conditions, provides for notice to interested persons, and states
that if such procedures and conditions are followed, then a termination of
license will be granted. Terw.ination of license for a MOX plant will likely
follow a similar format. In lieu of formal regulatory guidance in 10 CFK 70,
the NRC has curiently adopted the decommissioning guidelines ptovided in
Reference 17. The clear implication of the 10 CFR 50.82 regulation is that
dismantling and disposal are the exclusive objectives of the decommissioning
process. However, regulatory guides discussed in detail below also provide
for other decommissioning modes that may not return a site to unrestricted use.
10 CFR 50.82 is broad in scope as to the extent of information that
can be requested by NRC and as to NRC's power to specify conditions for
acceptab·l e decommi ss ioni ng. However, NRC exercise c;>f authority under
this section in the past has been limited. NRC has approached the imple-
mentation of decommissioning policy on a case-by-case basis by inserting
license conditions into applications, amending existing licenses, and by
issuing informal policy statements. Such a case-by-case or informal approach
is useful dt!ring the it;terim period while more detailed regulations are being
developed. This is also a u~eful mechanism for 1btaining public reactions,
testing new ideas, and making decisions that are tailored to specific situa-
tions as required.
Potential ambiguities arise when 10 CFR 50.82 regulatory requirements
with respect to license termination are compared to Regulatory Guide 1.86(l 6 )
and the informal guidance in Reference 17.
Although Regulatory Guide 1.86 is only applicable to reactors, the
nearly identical guidance(l 7) applies to MOX facilities. However, the
application of the regulatory guides by an operator raises some questions.
5-10
First, as pointed out above, 10 CFR 50.82 is inter.ded to provide reasonable
assurance that the dismantling of the nuclear facility and the disposal of
the compon~nts will be performed. However, this apparent policy goal seems
to be considerably revised in References 15 and 17, in that they appear to
permit, in some cases, as an acceptable decommissioning alternative, the
safe storage {layaway, mothballing, temporary entombment) of facilities as
well as dismantlement and conversion to a new nuclear or non-nuclear system.
Apparently, the safe storage decommissioning alternatives and conversion to
other uses are to be interpreted as compatible with the dismantling and
disposal policies of the regulations. The concern of a small MOX facility
operator is that regulatory guides are advisory (although in practice they
are sometimes used as regulations) whereas NRC regulations are mandatory
requirements. When decommissioning regulations are formulated in 10 CFR 70
for MOX facilities, it is not clear if they will require dismantlement or
may permit some form of safe storage.
A licensee will request amendment of hi~ operating license to allow
him to possess radioactive and/or special nuclear materials but not operate
the facility in a production mode. Because of the nature of some of the
decommissioning activities anticipated at the site, NRC may elect to issue
a possession-only license with administrative controls and facility require-
ments appropriate for the decommissioning option selected. Although this
appears consistent with Regulatory Guide 1.86 and Reference 17, it is possible
that a modified operating license will be issued rather than a possession-only
license. The rationale behind this logic is that although the plant operating
functions have changed significantly during decommissioning, many unit opera~
tions may be similar (i.e., chemica 1 decontamination, waste treatment and
solidification). There will be active operations conducted in the plant
involving radioactive materials and utilizing existing systems and components
that can result in release of effluents to the environment. Additionally,
unplanned releases of nuclear material are possible from accidents during
decommissioning. 10 CFR 50.59, Authorization of Changes, Tests and
Experiments, and Section 50.90, ARPlication for Amendment of License or
Construction Permit, provides the rules by which a licensee of a nuclear
5-11
··---"'""'"'"··'··~"-----------·-----------------
reactor or of a fuel reprocessing plant may amend his license. This amended
state of facility license results from NRC approval to amend requirements in
the technical specifications that are applicable to normal facility operations.
It is likely that similar rules will be developed specifically for Part 70
facilities. It appears that the necessary requirements to assure public safety
during decommissioning can be covered whether or not the license is a modified-
operation or a possession-only license.
Another potential question arises from the fact that there is an impli-
cation that the long-term care outlined in the Regulatory Guides could extend
for a period that considerably exceeds the normal licensing period for nuclear
facilities (typically 1 to 5 years between licensing renewals for 10 CFR 70
facilities}. There is no indication in the regulations what the tenm of a
possession-only license might be. This raises questions as to whether renewal
of a possession-only license would be permitted and what the standards for
such renewal would be.
5. 1.2 State and Local Jurisdiction
A nuclear facility operator is also subject to state statutes, regula-
tions, orders and court decisions. Where there are conflicts between the
state and local requirements, generally the state requirement will prevail.
Similarly, where there is a conflict between a valid federal requirement
and a state requirement, the federal requirement is controlling. Where
there is no conflict or where Congress has elected not to fully occupy a
given legislative area, a person must generally comply with all applicable
federal, state, and ·1ocal requirements in the conduct of his affairs.
Section 274k of the Atomic Energy Act of 1954 provides that 11 nothing
in this section shall be construed to affect the authority of any state or
local agency to regulate activities for purposes other than protection
against radiation hazards ... (22 ) Thus, state requirements relating to such
matters as land use, zoning, building construction standards, fire protec-
tion, parking requirements, drainage regulations, elevator standards, traffic
regulations, and similar requirements are generally not preempted under the
Atomic Energy Act even though they can have an important impact upon the •
location, construction and operation of licensed ~uclear facilities.
5-12
The 1977 Clean Air Act Amendments make clear that states are no longer
precluded from establishing and enforcing standards regulating radioactive
emissions into the air. Thus, any state or locality may potentially estab1ish
standards more str~ingent than federal standards -- or, where a federal standard
has not been established, may establish any standards it deems appropriate. (lO)
This is discussed in more detail in Section 5.1.4.
State governments also exercise some control over shipments of radio-
active materials. State hignway departments regulate gross vehicle weights,
vehicular dimensions and other parameters for radioactive shipments just as
they do for other kinds of shipments. Currently, about half of the states
have adopted the U.S. DOT Hazardous ~1ateria1s Regulations to cover intrastate
shipments. Several States have adopted or proposed additional regulations
concerning radioactive materials. (l3, 23 ) These include:
• Special routing of radioactive shipments
• Advance notification for shipments of large quantities of material5
o State inspections of some types of radioactive shipments
• Prohibition of certain ty?es of shipments within the states
• Prior approval for radioactive shipments
• Requirements of exclusive vehicle use for radioactive shipments
• Use of pilot vehicles
• Speed restrictions for radioactive shipments
• Specific hours of movement
o Accompaniment of all shipments by radiation monitoring personnel.
The variation of regulations between adjacent states can often require
special considerations for interstate shipments.
There is a potential conflict between some of the proposed state laws
and the provisions of the Hazardous Materials Transportation Act of 1974 (Public
Law 93-633 signed in 1975). (ll) This law prohibits the states from adopting
laws or regulations more stringent than federal regulations unless the state
regulations improve transportation safety. Even in this case, such rules
can be adopted only if they do not ur~reasonably burden commerce.
5-13
A more detailed review of the regulations pertaining to the transport
of radioactive material can be found in ERDA-76-43 Volume 5, Append'iX E,
1
Alternatives for Managing Waste from Reactors and Post-Fission Operations

)n the LWR fuel Cycle, May 1976.
5.1.3 Safeguards Considerations

Prior to initiating decommissioning of a nuclear facility such as a
MOX fuel fabrication plant, consideration must be given by the licensee to
the necessity of safeguarding the quantities of residual special nuclear
material (SNM) anticipated to be found in the facility following normal
operational clean-out flushes. Regulations for operating facilities licensed
to use or possess SNM in quantities exceeding specified threshold amounts
require special internal material controls for accounting and reporting pro-
cedures for the SNM, both in process and in storage. In addition, physical
protection systems are required for protecting the SNM and vital facilities.
Considerations relating to safeguarding of SNM during the decommission-
ing of a MOX plant, as well as the applicable regulations for physical pro-
tection and accountability, are discussed in this section. Applicable
regulations and guidelines in addition to 10 CFR 70 and 10 CFR 73 are as
follows:
• 10 CFR 70.22(g) requires inclusion ~f a physical security plan in license
application and amendment
• Regulatory Guide 5.52, Standard Format and Content for the Physical
Protection Section of a License Application
• NRC Standard Review Plan, NUREG 75/087, 13.6, Industrial Security
• Regulatory Guide 1.17, Revision l, Protection of Nuclear Power Plant
Against Industrial Sabotage
• Regulatory Guide 5.7, Control of Personnel Access to Protected Areas,
Vital Areas and Material Access Areas
• Regulatory Guide 5.10, Selection and Use of Pressure Sensitive Seals
on Container for Onsite Storage of Special Nuclear Material
5-14
• Regulatory Guide 5.12, General Use of Locks in the Protection and
Control of Facilities and Special Nuclear Materials
• Regulatory Guide 5.14, Visual Surveillance of Individuals in Material
Access Areas
• Regulatory Guide 5.15, Security Seals for the Protection and Control
of Speci a1 Nuc 1ear ~1a teri a1
• Regulatory Guide 5.20, Training, Equipping, and Qualifying of Guards
and Watchmen
• Regulatory Guide 5.27, SNM Doorway Monitors
• Regulatory Guide 5.43, Plant Security Force Duties
• R~gulatory Guide 5.44, Perimeter Intrusion Alarm System
• Regulatory Guide 5.45, Standard Format and Content for the Speci~l
Nuclear Material Controls and Accounting Section of a Special Nuclear·
Material License Application
• Regulatory Guide 5.47, Control and Accountability of Plutonium in Waste
Materia 1
• Regulatory Guide 5.57, Shipping and Receiving Control of Special
Nuclear Materials
• ANSI, Standard Nl5.26-1976, Physical Protection of Special Nuclear
Material Within a Facility
• ANSL Standard Nl8.17-l973, Industrial Security for Nuclear Power
Plants
• 10 CFR 70 and 73, Physical Protection of Plants and Materials,
Performance Or~onted Safequards Requirement (Proposed, Federal Register,
Volume 42, No. 128, p. 34310, June 5, 1977), and Upgrading Guard
Qualification Training and Equipment Requirements (Proposed, Federal
Register, Volume 42, No. 128, p. 34321, June 5, 1977).
• 10 CFR 73, Physical Protection of Plants and Material.~,
Guard Force Response to an Alarm, An amendment to Section 73.50 of
10 CFR 73, Federal Register, Volume 42, No. 246, December 22, '1977.
5-15
• 10 CFR 50, 70 and 73~ licensed Nuclear Materials and facilities,
licensee Safeguards Contingency Plans, Amendments to Sections 50.34,
50.54, 70.22, 70.32, 73.30, 73.40, 73.50, 73.55, and Appendix C of
10 CFR 73, Federal Register, Vol. 43, No. 57, March 23, 1978.
The problem of safeguarding SNM in a facility during decommissioning is
unlike that in an operating facility. r ring decommissioning, the SNM will
be contained in chemical flushing solutions, on the surfaces of process
cell walls and equipment, in sumps, and distributed in waste and rubble.
In general, it will be in inaccessible places. The easily removed SNM would
be recovered during the final operational clean-up and the chemical decontam-
ination activity during decommissioning. Current regulations do not distin-
guish between SNr~ in a relatively concentrated and more accessible form
expected in an operating facility, and similar amounts of SNM in the highly
dispersed and dilute form expected in decommissioning activities. Since SNM
in the latter form is likely to be difficult to remove and to concentrate
in significant quantities, it is probably not an attractive target for theft
or sabotage. For this reason, the requi~ements for safeguarding SNM during
decommissioning should reflect this significant difference.
The requirements governing the safeguarding of SNM and nuc 1ecr faci l i t·i es
are contained in Title 10 CFR Part 70, Special Nuclear Material, and Part 73,
Physical Protection of Plants and Materials. Although decommissioning opera·-
tions are not mentioned specifically in these regulations, the provisions of
Parts 70 and 73 apply to such operations if and when the licensee comes into
the possession of significant quantities of SNM during decommissioning.
The operator of the ~10X plant will have established a final cumulative
snecial nuclear Material Unaccounted For {MUF} value as a result of a clo~e
out of tht .ast accounting period. In the event that the production opera-
tor cannot reduce the MUF of SNM to a value that is insignificant with respect
to the uncertainties in measurement, it can be anticipated that the organi-
zation conducting the decommissionin~ will have to implement procedures to
recover and account for any operational MUF carried over to decommissioning
operations. It is also anticipated that the MOX plant operating licensee
will still be required by NRC to maintain responsibility for the facility
5-16
and the SNM during decommissioning even if another contractor is performing
the work. As indicated in Section 5.1.1, a revision to the operating license
defining these requirements is expected to be required, probably as part of
the decommissioning plan.
Even if MUF is statistically insign~ficant at the time of facility shut-
down, the process of decommissioning may result in recovery of quantities
of plutonium exceeding th~ thresholds for specific safeguards actions from
contaminated equipment and structures. Therefore, an approved safeguards
plan will be needed to define and govern the protection, control, accounta-
bility, reporting and disposal of SNM found in the facility during decommis-
sioning activities. The specific safeguards requirements will be determined
by the NRC during the licensing process. Because of the anticipated small
quantities of SNM, the way it is distributed, and its general lack of
accessibility, it is anticipated that safeguards programs required for
decommissioning will be significantly less stringent than for production
operations.
As previously stated, during the decommissioning activities in the
facility, it is expected that many of the regulations that apply specifically
to the operation of a MOX plant will not be applicable. Strict interpreta-
tion of these requirements for safeguarding SNM during decommissioning may be
unnecessarily restrictive. These regulations, as well as others, are meant
to apply to buik or concentrated quantities of SNM normally found in operating
faciHties. While ....aintaining a uniform level of public protection, such
r·egulations could be relaxed when applied to decommissioning but compliance
with the intent and principles of these regu·lations should still be maintained.
A summary of the regulations j~dged to be relevant {either in total or in
part) for the control of 5t:M during decommissioning activities is given below.
1. A licensee authorized to possess at one site any SNM not in sealed
source form is required to maintain records (of a form approved by the
NRC) of the quantities of SNM acquired, tr·ansferred, disposed of, and
on inventory. The licensee must also provide physical protection o~
the facilities where the licensed activities are conducted against
sabotage and theft of SNM (see 10 CFR 73.40). If the licensee
5-17
receives or transfer~ one gram or more of SNM to another licensee, he
must, in addition to the above, file an SNM transfer form (Form 741)
with the NRC and the transferer or receiver.
2. A licensee authorized to possess 350 g or more of SNM at one site must
in addition to the above, file a status report (Form 742) with the NRC
twice a year and take a physical inventory of his SNM holdings once a
year.
3. A licensee authorized to possess more than one effective kg of SNM(a) at
one site must maintain, in addition to the above, an approved and docu-
mented set of SN~1 control and accounting procedures satisfying the
requirements of Section 70.51, 70.57 and 70.58 of 10 CFR Part 70. The
SNM must be at all times in the physical custody or control of a desig-
nated custodian, a 11 transfer·s between custodians must be documented,
perio~~c inventories must be taken as specified in Section 70.51, and
the status of the material balance reported to NRC at those specified
times. Detailed records of all SNM transactions and inventories are
also required.
4. Each licensee authorized to possess SNM in a quantity exceeding 700 g of
contained 235u, 520 g of 233 u, 450 g of plutonium, 1500 g of contained
235u if no uranium enriched to more than 4% by weight of 235 u is present,
· 450 g of any combination thereof, or one-half such quantities if massive
moderators or reflectors made of graphite, heavy water or beryllium may
be present, shall maintain a monitoring system for nuclear criticality
meeting the requirements of Section 70.24 of Title 10 of the Code of
Federal Regulations.
5. A. licensee who possesses or uses 235u contained in ura.nium enriched to
2o% or more in the 235u isotope, 233u, or plutonium, or any combination
of these materials which totals 5 kg or more as computed by the formula,
,._
.,_~
(a) "Effective kilograms of SNM" means: l) for plutonium and 233 u, their
II
weight fn·kg; 2) for uranium enriched to 1% and above, its weight in kg
multipli-ed ~~Y th,e square of the enrichment (as the decimal weight frac-
tion); and 3) for 4uranium ·enriched to less than 1%, its weight in kg
multiplied by 10'"' (10 CFR 70.22). ·
d-*1
~~ .. .. ··
5-18
~~~-~-··~;~.~-.~.~.~.-~.~~-~··=-=-=·=·-=-=-~-·~--~-~~-·--~-~-~~-~~=-~-=--=~=-=-~--'~·--~-=-~~~~~-
·
kg= (kg contained 235u) + 2.5 (kg 233u +kg plutonium), must, in addi-
tion to 1, 2, 3 and 4.above, provide substantially enhanced physical
protection of the SNM at the site and during transport to other sites.
In addition, the licensee must provide for upgraded physical protection
of the facilities in which licensed activities are conducted. and of
specified material access areas in the facilities. The specific physical
security requirements for fixed sites are described in Sections 73.50,
73.60 and 73.70 of 10 CFR 73.
SNM control and accounting requirements can be reasonably expected to
apply only to plutonium that has been removed, isolated, recovered or con-
centrated to a degree that the quantities are measurable and ac~ountable.
Transfers or disposals of 1 g or more of plutonium are accountable and must
be documented (see 10 CFR 70.54). However, accountability may not be
required for plutonium widely dispersed in or on materials and equipment
being removed from the facility as contaminated waste.
During the decommissioning of a MOX plant a point will be reached when
convincing evidence has been acquired that the amount of plutonium remaining
in the plant is less than 2000 g (i.e., 5000 formula" grams). At that
11
point, the physical protection requirements of Sections 73.50, 73.60 and

73.70 of 10 CFR 73 will no longer be applicable. This will permit reduc-
tions of the guard force, the frequency of patrols and security tests, cer-
tain material and personnel control and search procedures, and certain
record-keeping requirements specified in 10 CFR 73.70. However, an approved
system of physical protection against industrial sabotage and theft of
special nuclear material would still be a general requirement (see 10 CFR
73.40(a). The elPments of that syste~ must be described in a physical
security plan that has received NRC approval. One can expect such a physical
security system to include procedures for: 1) limiting access to the site
to authorized persons only; 2) storing materials and equipment containing
more than a small, specified amount of plutonium in controlled access areas;
and 3) continuous monitoring of the site to detect unauthorized activities.
Regardless of regulatory requirements, prudent licensees will take steps to
prevent trespassing, vandalism, sabotage, and other hazardous activities on
the site, as long as hazards associated with radioactive materials exist.
5-19
The physical security barriers that control access to SNM during
operations are likely to be changing during decommissioning operations.
Safeguarding SNM while the n~rmal protective barriers and methods are being
modified or eliminated could become a concern. Appropriate surveillance
and security measures that are consistent with the changing nature of the
facility, equipment and structures will be needed. Safeguards procedures
should be developed from the existing operational safeguards regulations to
accommodate unique security problems that may be encountered during
decommissioning.
For this study, an allowance for a safeguards plan was made in estimat-
ing the cost of decommissioning. The basic elements of the plan are: 1} main-
taining an operational level SNM accountability and physical protection
program and staff until after the final chemical flushes and treatment and
removal of most of the plutonium from the site; 2) reducing the facility
secur~ty requirements to non-SNM status, with normal industrial security to
control access and prevent unauthorized activities on the site; and 3) re-
taining this status until removal of the radioactive materials is complete
and the site is released for unrestricted use.
5.1.4 Regulation of Effluents
During decommissioning operations, it will be necessary for radioactive
air and water emissions to be kept as low as reasonably achievable. Specific
regulations pertaining to radioactive emissions during decommissioning have
not been issued. In the license termination application, however, an operator
must show that decommissioning will not be inimical to public health and
safety (see 10 CFR 50.82 as an example).
Ti'e radioactive effluents from waste processing operations or other
ac-~ivities during deconmissioning must comply with Environmental Protection
Age~_cy (EPA) regulations as well as 10 CFR Part 20. Currently, no specific

EPA regulations exist for decommissioning. The EPA•s 25 mrem/yr limit of
exposure to any member of the general public from operating facilities of
the nuclear fuel cycle, defined in 40 CFR Part 190, Environmental Radiation
Protection Standards for Nuclear Power Operations, excludes waste managem~nt
5-20"
activitiess but such limits are now being developed. It is anticipated that
a radiation dose limit from waste management operations similar to the
25/mrem/yr fuel cycle limit will be developed by the EPA. This new limit
may well include the impact of decommissioning.
The Clean Air Act Amendments of 1977(lO) includes radioactive emi~sions
within the regulatory framework of the Clean Air Act. Section 122 of the
Clean Air Act Amendments of 1977 creates an important statutory exception to
NRC's primary jurisdiction over radioactive emissions from licensed nuclear
facilities. The 1977 Amendments make it clear that radioactive emissions into
the air (which is presumed to be applicable to effluents from decommissioning)
are subject to the regulatory framework of the Clean Air Act in addition to
remaining under the control of NRC. They require the EPA Administrator to
determine whether or not emissions of radioactive pollutants wi 11 endanger
public health. If the EPA Administrator makes an affirmative determination
with respect to any such substance, he is to categorize the pollutant for an
appropriate control strategy under the Clean Air Act. By February 1980,
Section 122 directs that EPA and NRC are to enter into an interagency agreement
with respect to thos·e sources or facilities that are subject to the juris-
diction of NRC.
The Conference Report on the Clean Air Act Amendments of 1977( 24 ) indicates
that EPA may choose to promulgate identical standards to those previously
established by NRC if it finds such standards meet the requirements of the
Clean Air Act. The 1977 Amendments also permit NRC to disapprove any EPA,
state, or local standard promulgated under the Clean Air Act if the NRC finds
that the application of such a standard to a source or facility within its
jurisdiction would endanger public health or safety. The President may over-
turn such an NRC di-sapproval within 90 days upon appeal by the agency that
promulgated the disapproved standard.
Thus, whether a state emission standard applies to a small MOX facility
depends on several things: whether EPA has determined that radioactive air
emissions will endanger public health, whether a state has validly revised
its air pollution implementation plan to control radioactive pollutants,
whether that implementation plan has been approved by EPA, whether NRC has
5-21
disapproved the state standard, and whether the President has upheld such a
disapproval. Both administrative and judicial appeals may be available at
these steps. Thus, clarification of state authority under the Clean Air
Act may take some time.
5.2 REGULATORY CONSIDERATIONS DURING DECOMMISSIONING PHASES

The pr~ceding discussions on regulatory guidance are presented in this
section in gene•·al terms of applicability to the planning, decommissioning
and certain case phases of decommissioning.
5.2.1 Regulatory Considerations During Decommissioning Planning
Before decommissioning begins, an environmental impact statement or
environment impact appraisal and negative declaration will have to be prepared
describing the probable effects of the proposed decommissioning actions.
These requirements are defined in 10 erR 51, Subpart A. Section 51.5.b(7)
states that license amendments or other orders authorizing decommissioning
of a t~OX p1 may or may not require an impact statement of such planned
actions. If judged that an impact statement is not required, a negative
declaration(a) and an environmental impact appraisal must be prepared in
accordance with Section 51.7 and 51.50(d). Guidance is provided to NRC on
the need for an impact statement by the Council on Environmental Quality
Guidelines, 40 CFR 1500.6.
During the design and planning stage for building a new or modifying an
existing nuclear facility such as a MOX plant, a construction permit must be
obtained from NRC consistent with the requirements of 10 CFR 70.21, 70.22,
70.23 and 70.32, whtch define the content of license applications. As part
of this application, Section 70.2l(f) requires that an environmental report
be prepared. Analysis of the probable safety and envirnnmental effects of
1
I
retiring nuclear facilities are not specifically required at the time of
construction permit and license applications by 10 CFR 70. Decommissioning
(a) A negative declaration is a document prepared by the NRC that states that
the NRC has decided not to prepare an environmental impact statement for
a particular action, and that an environmental impact appraisal setting
forth the basis for that determination is available for public record.
5-22
is specifically addressed in the draft of the Environmental Standard Revh~w
Plans (ESRP), NUREG-0158, Section 5 of Part III. <25 ) Guidance for evaluation
of safety analysis reports for nuclear reactors is given_.in NUREG-75/087. {26 )
Even though most of these guides specifically appiy to nuclear reactors, the
philosophy and methods acceptable to NRC apply generally to other nucl~ar
facilitits and to decommissioning activities.
Currently, no regulation specifically requires a detailed decommission-
ing plan. Regulatory Guide 1.86 and Reference 17 may be loosely interpreted
to imply that one is needed; they state that NRC will impose requirements
depending on the decommissioning option select~d. In the future, such a
plan, namely a Master Decommissioning Plan (MOP), may be require~ and in-
cluded as part of the amended license. The MOP should include the decom-
missioning objectives for the facility/site, safety analysis and procedures,
safeguard plans, emergency plans for unplanned events postulated to occur,
and a time schedule.
As part of this plan, quality assurance (QA) of the decommissioning
should be addressed " ... to prevent or mitigate the consequences of postulated
accidents that could cause undue risk to the health and safety of the public"
(Part 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants
and Fuel Reprocessing Plants 11 ) . The requir~ents in Appendix B pertain to
design, purchasing, fabrication, etc., and do not specifically address de-
commissioning. Guidance is found on acceptable QA plans for a MOX plant in
Regulatory Guide 3.3, Quality Assurance Program Requirements for Fuel
Reprocessing Plants and for Plutonium Processing and Fuel Fabrication
Plants, and for nuclear facilities in NRC's Standards Review Plans 17.1,
"Quality Assurance During Design and Construction," and 17.2, 11 Quality
Assurance During the Operating Phase." The principles and objectives of
such guidance are expected to apply to many activities of decommissioning.
Therefore, applicable portions of Appendix B, Regulatory Guide 3.3, and
SRP 17.1 and 17.2, should Le used to develop a QA plan for inclusion in
the license amendment and the MOP.
5-23
The decommissioning of a t-10X plant will entail the disposal of residual
radioactive materials, and components contaminated with small to major
amounts of transuranic elements. General procedures for the disposition of
these wastes must be clearly defined in the license application. Guidance
on acceptable methods for control of plutonium contaminated materials can
be found in NRC Regulatory G~ide 5.47, Control and Accountability of
Plutonium in Waste Material .
.
Other considerations of ~ignificant concern, mainly to the licensee,
are the amount of the annual 1icens~ fee and the facility insurance premiums
required to satisfy regulations during the periods of decommissioning and
interim care. Neither of these items has been adequately addressed relative
to decommissioning; they are, however, dictated by the type and quantity of
radioactive and/or special nuclear materials, the type of activities being
conducted, and correspondingly the type of license regulating the activities.
Licensing fees are addressed in 10 CFR, Part 170; the schedule of fees for
production.and utilization facilities (Part 50 licen~e) is in Section 170.21
and for holders of material licenses (MOX plants), the schedule of fees is
in Section 170.31. The requirements for financial protection and indemnity
agreements are provided in 10 CFR 140. The levels of protection required
for a MOX plant during decommissioning is not specifically defined.
Once a decommissioning mode has been selected for a MOX plant and the
10 CFR 70 license has been modified, the actual decommissioning activities
can be initiated. The facility will be placed in the planned disposition
mode according to a master decommissioning plan, taking into account the
regulations and guides discussed previously. (a)
(a) Currently, there is a major trend toward placing more emphasis on design-
ing and constructing facilities to more easily accommodate decommissioning.
Design criteria that may be considered applicable in principle to this
purpose for a MOX plant are given in ANSI Standard N300-1975, Desi~n
Criteria for Decommissioning of Nuclear Fuel Reprocessing Plant. It should
be noted, however, that the NRC has not endorsed the provisions in ANSI N300-
l975.) Additionally, 10 CFR Part 50, Appendix F.4 indicates that a design
obje~tive for a Fuel Reprocessing Plant should be to facilitate decontamina-
tior• and rem(lval of significant radioactive wastes at the time of decom-
missioning and this objective is also pertinent to a MOX plant. This
policy is aimed at a concern about proliferation of nuclear sites.
5-24
During the actual decommissioning activities in the MOX plant, radio-
active waste will be accumulated, treated, packaged, stored, and transported
to one or more disposal sites. Regulations defining the requirements to
assure safety of the public and occupational workers from such waste-related
activities are found in 10 CFR Part 70, Licensi.ng~lications, 10 CFR Part 20,
Standards for Protection Against Radiation, and 10 CFR Part 71, Packaging of
Radioactive Materials for Transport and Transportation of Radioactive Material
Under Certain Conditions. Means for compliance with these regulations,
including those for safeguards and security precautions (discussed in
Section 5.1.3}, will be defined in the specifications and plans of the amended
license at the start of decommissioning. These are the same basic requirements
that the licensee would have to address in his application to construct and
operate a MOX plant.
Currently little guidance exists on the final disposition of the wastes
from decommissioning a MOX plant. NRC has proposed adoption of a rule
requiring that all wastes with more than 10 nCi of alpha-emitting transuranic
materials per gram of waste be classified as transuranic waste, and that
this waste cannot be permanently disposed of in shallow land burial grounds. {27 )
Deep yeologic disposal of these wastes is assumed in this study, but final
decisions are pending. A review of the federal regulations pertaining to the
licensing and operation of commercial and DOE-owned waste management facilities
has been completed.( 28 } Also, the NRC is now in the process of developing
comprehensive waste management regulations that will include wastes from
decommissioning. Packaging of the decommissioning wastes will be dictated
by their storage and/or ultimate disposal mode. Requirements for the packaging
of the radioactive material are also defined by transportation regulations.
During decommissioning activities at a MOX plant, normal industrial (non-
radiation related) safety regulations governing occupational work conditions
are provided by Title 29 Code of Federal Regulations, Parts 1900 to end
(Occupational Safety and Health Administration, Department of Labor).
5.2.3 ~e..a::_=:;tory ~rusiderations During Interim Care

This phase primarily deals with surveillance and maintenance of the
facility after it is in a decommissioned mode other than total dismantlement.
5-25
Primary concerns during this period are to assure public safety and safety
of the staff maintaining the facility. The facility may contain amounts of
special nuclear and/or other radioactive material that requires safeguards
or other regulatory control. Applicable regulations governing all of these
points have been previously discussed.
During this period, the license may need to be amended consistent with
the inventory of special nuclear material and the level of potential public
safety concern the facility represents. A possession-only license is likely
in the case of a MOX plant.
When final dismantlement occurs after the period of interim care, ttle
requirements discussed in the decommissioning phase would apply. Following
dismantlement, termination of the license could then occur consistent wiUl
the guidance offered by Regulatory Guide 1.86.
5.2.4 Operator's Checklist for Federal Regulations
The previous sections described and analyzed regulatory requirements
that specifically or indirectly pertain to decommissioning activities. Many
other requirements also apply because the decommissioning activity also
involves other activities that are subject to regulation.
Table 5.2-1 lists the principal federal regulatory requirements that
are most 1ikely to apply to the decommissioning of a small r~ox facility.
Many requirements are-specifically applicable to facilities other than MOX
plants but are listed because they may be applied by analogy.
The focus on decommissioning is increasing, and regulations and guide-
1ines in this area are dynamic. Table 5. 2-1 is Oile interpretation of the
principal applicable regulations and guidelines as of June 1978, and can
only be t~ken as a starting point for any specific application. This is
intended to be a general listing and thus requirements applying to a parti-
cular small MOX facility may vary because of special circumstances. In
addition to the requirements shown in Table 5.2-1, state and local require-
ments should be examined. Federal law may preempt state or local regulation
in many of the areas shown, but state or local requirements may affect the
decOJIIIlissioning of a small t10X facility in areas such as environmental
5-26
protection~ transportation regulations, land-use restl~ictions, building con-
trols and similar requirements. Also, the applicable state Clean Air Act
implementation plan should be consulted.
TABLE 5.2-l. Abbreviated Checklist of Principal Federal Regulatory

Requirements That May Apply to the Decommissioning of
a Small MOX Facility~a)
1. !JecO!'!"j_ssioni_n~_!lU.!_r~nts
10 CFR 50.82(b) . Application for Term"ination of License

Reg. Guide 1.86(b) Termination of Operating licenses for flue lear Reactors
Reg. Guide 3. 3Q . Standard and Content of License Application for
Plutonium Processing iu Fuel Fabrication Plants
10 erR so!b) . . Licensing of Production and Utilization Facilities
10 CFR 50.33(f)(b) Relating to Financial Qualifications for facility
Shutdown
10 CFR 50, Appendix C(b) A Guide for Financial Data and Related Information
Required to Establish Financial Qual ifi~atirns for
Facility Con.truction Permits and Opera tin<! licenses
10 CFR 50, Appendix F(. 1 Policy Relating to the Siting of fuel Reprocessing
Plants and Related Waste Management Facilities
2. Material_~_icense Requiremen~.s
10 CFR 30, :~ """ JO. Regulations for Mater1als licenses Relating to

By-Product, Source, and Special Nuclear Mat~rial
10 CFR 51 . Licensing and Regulatory Policy and Procedu~es for

Environmental Protection
10 CFR 20. Appendix B Offs ite Releases
10 CFR 20.300 Waste Disposal
40 CFR 190.10 Environmental Radiation Protection Requirements
for tlonnal Operations in the Uranium Fuel Cycle (EPA)
40 CFR lSuO. CEQ Guidelines on the Preparation of Environmental
Impact Statements
Guidelines for Decontamination of Facilities and
Equipment to Release for Unrestricted Use or Tennina-
tion of Licenses for By-Product, Source or Special
Nuclear Material (NRC, November 1976)
Proposed Guidance on Dose limits for Persons Exposed
to Transuranium Elements in the General Environment
(EPA 520/4-77-016)
10 CFR 20 . Standards for Protection Against Radiation

5. ~-a.feguards and fl\ys ica 1 Protec;.tl!!!',
10 CFR 70 . Domestic Licensing of Special Nuclear Material
10 CFR 73 • Physical Protection of Plants and Materials
6. Quality Assurance
10 CFR 50, Appendix B(b) Quality Assurance Criteria for Nuclear Power Plants
and Fuel Reprocessing Plants
Reg. Guide 3. 3. Quality Assurance Program Requirements for Fuel
Reprocessing Plants and for Plutonium Processing and
Fuel Fabrication Plants
10 CFR 71 . Packaging of Radioactive Material for Transport and

Transportation o1 Radioactive Material Under Certain
Conditions
49 CFR 170-199. Department of Transportation Hazardous Materials
Regulations
(a) All requirements are the NRC's unless otherwise noted.

(b) It is recognized that these regulations apply specifically to nuclear reactors and fuel reprocessing plants.
It is anticipated that deco11111issloning actions anlogous to these regulations will be required for MOX plants.
5-27
5.3 CONCLUSIONS
Although there are numerous regulations that apply to deco11111issioning,
specific and comprehensive requirements for decomn1issioning a MOX plant ar~
presently lacking. Since some small MOX facilities are apparently ready for
decommissioning in the near future, their decommissioning may provide an
important opportunity to regulatory agencies to gain experience, test concepts,
and determine industry reaction on a case-by-case basis.
It appears desirable that decommissioning requirements be consolidated
and made more comprehensive. This is particularly the case h four major
areas: 1) assurance that funding is available in adequate amounts and in a
timely manner for decommissioning activities; 2) assurance that future
facilities are initia:1y designed to f~cilitate decommissioning; 3) establish-
ment of clear requirements, specific to decommissioning; and 4) development
of mechanisms for cooperation between federal, state and local officials to
assure that broad public input occurs and accommodations are reached in a
timely and efficient manner to avoid regulatory conflicts and an1biguities,
Once the plans for decommissioning of nuclear facilities are in place
(plans that are continuously updated as new information or technologies
become available), and once the four requirements stated above are fulfilled,
then decomJ1lissioning can be handled as a routine step in thB nuc1~ar industry.
Because of the unique nature of decommissioning activities, a safeguards
plan for decommissioning should be prepared. This is currentlY' assured by
existing regulations i~ the license amendment process. The plan must cover
the treatment of quanti ties of S~!M present and identifiable in the facility
and must also describe contingency plans to assure that significant accumulations
of SNM in an accountable and measurable form are detected and properly contained,
protected, measured and accounted for, and disposed of in a manner acceptable
to NRC.
5-28
REFERENCES
l. U.S. Nuclear Regu1atory Commissior., Plan for Reevi'iluation of NRC Poli~

on Decommissioning of Nuclear Facilities, Issued by the Office of
Standards Development, Division of Engineering Sta1dards, USNRC,
NUREG-436, March 1978.
2. 10 CFR 50.21, "Medical Therapy and Research and Development Facilities, ..
and 10 CFR 50.22, Commercial and Industrial Facilities ...
11
3. 42 United States Code (USC) 1801 et seq., Superseded by Atomic Energy

Act of 1954.
4. 42 USC 2011 et seg., Atomic Energy Act of 1954.
5. 42 USC 5801 et seq., Energy Reorganization Act of 1974.
6. 35 Federal Register 15623 (July 9, 1970, Effective December 2, 1970);
23 usc 4321, 1973.
7. 42 USC 2021 (h), Atomic Energy Act of 1954.
8. U.S. Environmental Protection Agency, Propcsed Guidance on Dose Limits
for Persons Exposed to Transuranium Elements in the General _Environmental
Limits of Plutonium Contamination in Soils, EPA 520/4-77-016, September 1977.
9. 42 USC 7401 et seq., Clean Air Act Amendments ot' 1977.
10. 42 USC Amendments, 3CO f-j-'.1, Safe Drinking Water Act of 1977.
11. 49 USC 1801 et seq., Hazardous i\1ctgrial Transportation Act of 1974.
12. U.S. Department of Transportation, A Review of DOT Regulations for
Transportation of Radioactive Materials, August 1976.
13. C. K. Beck, "Intergovernmental Relationships in the Transport of
Radioactive Materials," in Proceedings of the Second Annual Legislative
Workshop, CONF-730588, Oak Ridge, TN, May 1973.
14. \L M. Rogers, Jr., "State and Federal Roles in Regulating the Transpor-
tation of Radioactive Materials," in Proceedings of the 4th Internation-
al Symposium on.Packaging and Transportation of Radioactive Material_.
CONF-740901, Miami Beach, FL, September 1974.
15. U.S. Atomic Energy Commission Regulatory Guide 1.86, Termination of
Operating Licenses for Nuclear Reactors, June 1974.
5-29
16. y~;;.Code of Federal Regulations, Title 40, Part 190, "~nvir?.nmental
Ra nation Protection Standards for Nuclear Power Operat1ons, Super...
intendent of Documents, GPO, Washington, DC 20555, January 1977.
17. U.S. nuclear Regulatory Comnr'ssion, Guidelines for Decontamination of
Facilities and Equipment Pric.r to Release for Unrestricj;ed Use or
Termination of Licenses for By-Product, Source, or Special Nuclear
Material, November 1976.
i8. J. W. Healy, p. Proposed Interim Standard for Plutonium in Soils,
LA-5438-MS, Los Alamos Scientific Laboratory, Los Alamos, NM,
January 1974.
19. A. J. Hazle iind B. L. Crist, Colorado's Plutonium-in-Soil Standard,
Colorado Department of Health, Occupational and Radiological Health
Division, Denver, "'1..' 1975.
20. J. f•1. Deutch, Tr.~k Force Leader, Report of Task Force for Review of
Nuclear Wa~te Management, (Draft) DOE/ER-0004/D, Department of Energy,
Directorat..:: of Enerqy Research, March 1978.
21. 42 USC 2135, ~~ic Energy Act of 1954, Section 105.
22. 42 USC 202·1 (k}, Atomic Energy Act of 1954.
23. W. A. Brabst, "The State of State Regulations," in Proceedings of the
4th International Symposium on Packaging and. Transportation of Radio-
active Material, CONF-740901, ~•iami Beach, FL, September 1974.
24. Conference Report, Clean Air Act Amendments of 1977, H.R. 95-564,
95th Congress, 1st Session, August 3, 1977.
25. Environmental Standard Review Plans for the Environmental Review of
Construction Permit Application for Nuclear Power Plar1ts, (Draft)
NUREG-0158, Parts I, II, III. Office of Nuc'tear Reactor Regulation,
U.S. Nuclear Regulatory Commission, January 1977.
26. Standard Review Plan for the Review of Safet Anal sis Re orts for
Nuclear Power Plants, NUREG-75/087 NTISUB/B/201, Office of Nuclear
Reactor Regulation, U.S. Nuclear Regulatory Commission, September 1975.
27. Proposed Rulemaking on Transuranic Waste Disposal, Publ,;shed in Federal
Register, Volume 39, p. 32922, September 12~ 1974.
28. J. J. Cohen, et al., Oe~rminaticn of.Performance Criteria for High-
Leve·. Solidified Nuclear Waste~ NUREG-0279, Lawrence Laboratory for
USNRC~ July 1977.
5-30
6.0 ALTERNATIVE APPROACHES TO FINANCING DECOMMISSIO~ING
This section discusses alternative approaches to pl :-1iding funds for

long-term care and ultimate decommissioning of a nuclear fuel cycle facility.
The emphasis is on financial issues. Legal-institutional issues, such as
what entity should own the land on which the facility sits, are outside the
scope of the study and are not discussed.
The state in which a MOX fuel fabrication facility is located has two
principal financial concerns. First, the state is concerned that when the
facility ceases operation there will be sufficient funds available to perform a
thorough decommi~sioning, and that sufficient funds will be available for ca~~e
of the property, either before or after decommissioning until the site is
released for unrestricted use. This concern exists for plants that operate
throughout their anticipated life, as well as for plants that are shut down
prematurely. Second, the state is concerned that funds will be available
to provide for unexpected accidents and contingencies, both during the operating
life of the facility and before decommissioning is completed. The primary
focus of this section is on the first concern. The second concern is
briefly discussed as it applies to the financial integrity of the plant
operator and to decontamination and decommissioning operations.
The need for assurance of decommissioning funds is discussed in
Section 6.1; several approaches to funding decommissioning costs are dis-
cussed in Section 6.2; approaches to providing decommissioning funds in the
event of premature closure of a MOX facility are discussed in Section 6.3;
issues associated with protection from accidents and contingency costs
are discussed in Section 6.4; the question of who should actual1y perform
the decommissioning work is discussed in Section 6 . 5; and the ability of
j states to impose financial obligations on nuclear facility owners is briefly
[ reviewed in Section 6.6.
6.1 NEED FOR ASSURANCE OF DECQMMISSIONING FUNDS

One might ask why should a state or the federal government be concerned
about the availability of funds for decommissioning? Why cannot the owner
of the particular facility be respons:ble?
6-1
One answer to these questions is that, in some cases, states may have
ultimate responsibility by agreement. At West Valley, New York, for example,
utlimate responsibility for care and disposal of the radioactive wastes belongs
to the State of New York.(l) Unfortunately, sufficient funds to cover
decolllllissioning were not collected during the facility's unexpectedly short
operating life. In other cases, nuclear facilities, such as most low-level
radioactive waste burial grounds, are located on state-owned land. Thus
many states are very interested in adequate deco111nissioning perfonnance
because they will have responsibility for long-tenn care and monitoring of
the site •. Finally, and most importantly, the state has the obligation to
protect the health and safety of its citizens and therefore must ensure in
some manner that funds are made available for a ~omprehensive decommissioning
program.
Public interest and the regulated monopoly status of utilities provide
a high degree of certainty that the utilities will be financially capable
of undertaking dec011111issioning of a nuclear reactor. Most state utility
commissions currently permit utilities to recover sufficient funds for
decommissioning over the lifetime of a facility by charging current ratepayers
through a negative salvage value depreciation allowance. For non-utilities,
deconmissioning perfonnance is less assured, primarily because they are more
vulnerable to financial incapacity and even bankruptcy. Thus, there is
considerable incentive to impose a means to assure financial capability. If
decolllllissioning funds are paid into a trust fund outside the control of the
operating company, the funds are not likely to be attachable by the company's
creditors. In addition to the financial risk, delaying the commitment of
funds for decommissioning entails the further concern of assuring that the
obligated party wi11 actually perfonn the work and pay the costs. If legal
proceedings are .required to fix responsibility on a case-by-case basis, many
additional years and dollars could be expended before decommissioning is
accomplished.
6-2
6.2 APPROACHES TO PROVIDING FUNDS FOR DECOMMISSIONING AND LONG-TERM CARE
A state's paramount decommissioning concern is t~at sufficient funds are
available to decommission the plant. It is also concerned that funds are
available for long-term maintenance and monitoring of the site as required
before ultimate decommissioning. Three principal alternatives exist for
achieving these objectives:
1) Creation of a sinking fund to accumulate sufficient decommissioning
and interim care funds in a trust account during the facility's
operating life.
2) Payment of the anticipated costs of decommissioning into a trust
account prior to facility startup.
3) Payment of the costs .of decommissioning when incurreds i.e.,
after facility closure.
Option 1 can be used for a new facility and a facility part-way into its cperating
life. Option ? can be used with a new facility prior to its startup, or it can
be imposed later. Options 1 and 2 both require a good decommissioning plan
and decomnrissioning cost estimate early in the life of the plant. Option 3
i~ the only option available for an existing facility for which no trust
account was established and whose operating life is over. Various combinations
of these options are also possible.
In order to discuss and compare the alternatives, it is useful to estab-
lish several evaluation criteria. Five criteria that seem to be pertinent
to evaluating the alternatives are:
1) Is decommissioning financially assured?
2) Are appropriate means provided for paying the costs of decommissioning
when the operating life of the facility is shorter than expected?
3) Do the beneficiaries of the plant operation pay for its decommissioning
costs?
6-3
4) What is the present value cost of the financing alternatives?
5) Can the alternatives be readily administered?
While these criteria clearly have different importance weights, quantitative
determination of these importance weights is not attempted for this analysis.
However, it is the consensus of the authors that criteria 1 is the most
important, while criteria 5 is the least important.
6.2.1 Creation of a Sinking Fund to Accumulate Sufficient Decommissioning
Funds During the Facility's Operating life
This option contemplates the formation of a sinking fund tied to fuel
production to generat~ enough funds during the operating life of the MOX
facility to pay these anticipated costs. Payments would be made into a trust
account permanently outside the control of the facility operator. This
approach is currently used by the states that license and regulate low-level
radioactive waste burial grounds, and is now being used by New Mexico( 2) for
uranium mills.
Payments to the sinking funds would be based on fuel production. The
charge per unit of nuclear fuel produced would be determined by estimating
total decommissioning costs and total anticipated facility Droduction over
its operating life. An amount would b~ paid into th~ fund per unit of pro-
duct so that the payments, plus compound interest earned by investing the
fund during and after the plant operating life, would be sufficient to pay
all anticipated costs and provide a reasonable contingency of perhaps 10 to
15%, in addition to the estim~ted decommissioning costs.
The payment per unit of product into the sinking fund will have to be
adjusted regularly, perhaps every year. One obvious reason for change will
be to provide for cost escalation. Additionally, many other vi!riables will
change with time. For example, the rate of return achieved by the fund
stewards will likely change. The production rate for the facility will not
be completely constant over time. The real (i.e., nonescalated) decommissioning
cost can also be expected to change with time because of technological inno-
vations, added facilities, and new regulatory requirements. It is also likely
. that the expected 1ife of a plant will change. All of these changes can be
6-4
periodically accounted for by adjustments to the sinking fund payment. If
such changes are not severe and are regularly reflected in the payments, the
value of the sinking fund should be close to the needed funds when the
fatility is retired. The procedure for calculating annual sinking fund
payments, plus some illustrative calculations, are shown in Appendix D.
• A variety of entities could be designated to provide stewardship for the
sinking fund. Possibilities include state government, the federal government,
or a private organization such as a bank. An independent 11 0ecommissioning
Assurance Agency .. could also be chartered by each state or by the federal
gol!'~rmilent to retain ar'r,; invest the sinking fund and pernaps oversee activities
and disperse payment~ to those conducting the activities. The pooling of

decommissiuning funds into such a centralized agency could help to ensure
decommissioning performance even if a particular facility operator defaults
in some manner. The agency would act in a fiduciary capacity for the public.
Its governing board might be composed of representatives of the public,
gov·ernment, power-consuming industries, and pow:'·-producing industries. By
including various interest groups, tendencies to overestimate or underestimate
costs and the annual payments needed to fund the costs should be minimized.
Payments and interest received by the stewardship entity should be exempt
from federal income tax, either because the entity is a creation of the federal
or state government (Internal Revenue Code, Section 115), or is an exempt
scientific entity (Section SO"I(C)).
The principal advantage of the annual payment sinking fund approach is
that it should generally assure that decommissioning activities actua ly occur.
With funds set aside to cover the costs, the question of who should pay them
is alleviated and arguments about responsibility are less likely to occur.
A second important advantage of the sinking fund option is that it should
encourage the development of total plant costs when power generating options
are being considered by a utility. Currently, future decommissioning costs
may not be reflected in the electricity prices paid by consumers. If all
fuel cycle facilities were required to create sinking funds to provide for
future decommissioning and waste management expenses, their anticipated costs
6-5
would be evaluated and equitabily reflected in the cost of fuel and in the
utilities' and consumers' power bills. Presumably, utilities would be influ-
enced to incorporate these costs when selecting, for example, between nuclear
and co~l-fired thermal power plants.
Another advantage of the sinking fund approach is that it is equitablQ
to consumers. As lon~ as increases in estimated decommissioning costs are
reflected in adjusted payment schedules, all consumers should pay their
approximately proportional share of costs in dollars of approximately
equivalent buying power.
Several difficulties associated with the sinking fund option should be
recognized. r1e of these relates to the care and investment of the fund
itself. Professional management of the fund would be desireable, as would
controls on the investments made by the fund. For example, the fund might
be limited to investment in bonds and notes issued by agencies of the U.S.
Government, or municipal and private bonds with a sufficiently high rating,
e.g., AA or higher. The fund steward would be faced with the same problem
other investors are: i.e., how can assets be invested to earn a return that
at least matches the rate of cost escalation? If the fund is not able to
match the rate of cost escalation, the payments to the fund (in year of
startup dollars) will have to be increased over time at a rate that exceeds
the rate of escalation. Another difficulty associated with the sinking fund
option is that decommissioning costs must be estimable with reasonable
a~·:uracy in order to provide a basis to calculate an appropriate sinking
fund payment. Although revised estimates can be made and reflected in the
sinking fund payments later in the facility lifetime, the initial estimate
is especially important for a small MOX plant whose operating life is
relatively short.
It must also be recognized that establishment and control of a sinking
.
fund would, by its nature, create some administrative complexities. In addition
to the problems of fund management and control, an additional government or
quasi-government agency could be required to oversee the operation of one or
6-6
more fuel cycle facility sinking funds, thus incurring additional costs for
the administration of the fund.
6.2.2 Prepayment of Anticipated Decommissioning Costs
The general framework of the prepayment alternative is similar to the
sinking fund option. A trust fund woul1 be established. Fund stewards would
invest the monies until required for decommissioning. The difference is
that the present value of anticipated decommissioning and administrative
costs would be paid into the fund before facility startup. Adjustments to
the fund may be required to account for changes in such factors as the trust
fund earnings rate versus the decommissioning cost escalation rate, facility
life, added facilities, changing technology, safety, and regulatory
~ ·equ i rements.
The principal advantage of this approach is that it provides the highest

degree of assurance that decommissioning funds will actually be available when
needed. This is because sufficient money should be available for decommissioning
operations even if the facility ceases operation prematurely. Any funds
remaining in the trust fund after decommissioning is completed could be returned
to the facility owner.
The principal disadvantage of the prepayment option is that it is the
most expensive of the three payment options. Money invested in the prepayment
fund is likely to earn less then if it were being directly utilized by the
company. This is beca~se the discount rate utilized by a MOX facility operator
will likely exceed the interest rate obtainable by the fund stewards. The
Jiscount rate favored by the operator will approximate his minimum rate of return
on alternative investments. This will almost certainly exceed 10% under today's
financial conditions and could be much higher. The fund stew::.r·:l, on the other
hand, may only be able to obtain returns in the 7 to 9% range b: Making
conservative investments in the current bond and note market. By requiring
the operator to prepay the expected decommissioning costs, society loses the
productive value represented by the incremental return the operator could
realize on the funds over what the fund steward could realize.
6-7
To the extent debt funds are used to prepay the present value of
decommissioning costs~ the borrowing capacity of the operator is reduced and
consequently his_ available supply of funds for capital investment is reduced.
However, this approach would increase the amount of funds available for purchase
of conservative government and private security issues.
One can argue that this approach unfairly raises the cost of nuclear
power. Prepayment of decommissioning costs represents an extraordinary expense
not incurred to the same degree in other industries. The prepayment option
may also penalize current power consumers~ becaust future power consumers may
not pay their full share of the decommissioning costs. For instance, if
the facility owner pays the present value of expected decommissioning costs
out of retained earnings from past investments, future consumers will only
pay for adjustments to the fund, such as those dictated by new regulatory
requirements.
The facility owner is likely to fund the prepayment cost from a combina-
tion of retained earnings, equity issues, and lonq-term debt financing, as
though it were a capital expenditure. In this case, future consumers ultimatt:ly
•vill be charged through the pricing mechanism a sufficient amount to retire
the interest and principal of the debt. If the term of debt financing is
less than the facility life during the period when the debt is being retired,
the plant customers may pay as much, or more, to fund decommissioning than
they would pay under the sinking fund option. After the debt is retired, the
customers would pay less.
6.2.3 Payment of Decommissioning Costs When Incurred
This option contemplates delaying payment for decommissioning until the
costs are actually incurred. Essentially this is the approach that has been
used to date for fuel fabrication plants.
The principal concern with this approach is the relatively low assurance
it provides that decommissioning will actually be performed. As long as the
facility operator is willing and financially able to perform the required
work, no major problem should arise. If, however, the operator is financially
incapacitated and/or unwilling to perform the required work, the burden may
fall directly to the state or possibly the federal government, and required
funding would likely have to come from general revenues. Because the life
expectancy of a MDX facility is relatively short, the risk of financial
incapacity is perhaps less than with a longer-life facility. The risk increases
if the Safe Storage option is utilized prior to dismantlement. Another
concern is that the plant beneficiaries may not pay their proportional
share of decomnissioning costs because the full cost of decommissioning may
not be reflected in the fuel cost. Both of these concerns, however, are
l~ss significant for a MOX plant than for a longer-life facility because the
operators of a short-life facility cannot delay the setting aside of funds

for decommissioning.
The principal advantages of this option are that it is least costly, and
it has the least administrative burden.
If this option is selected, it may be desirable to require the operator
to purchase a surety bond or an insurance policy that would assure the
availability of decommissioning funds. This approach is not unprecedented,
in that many states require bonds from co~l mining companies to ensure recla-
mation of strip-mined land.
There are several problems with obtaining a bond or insurance. The
principal difficulty is that surety companies are not likely to be interested
in selling a long-term bond because of the many uncertainties affecting their
obligation. Yet, a long-term bond is needed if a state is to receive decom-
missioning assurance. If the bond is renewable at given intervals, the
bonding company may very well decline renewal if the company becomes financially
weak. Also, the guaranteed amount of the bond would have to be readjusted
periodically to cover revised decolll11issioning cost estimates. If the
bonding company does not agrea ahead of time to automatic escalation of its
guarantee, the usefulness of the bond is again substantially decreased. For
example, over the lD-year operating life of a MDX facility, decommissioning
costs are likely to at least double in nominal dollars.(a).
(a) Nominal dollars are dollars of the year in which payments are made.
6-9
An additional problem is that even 1f a long-term bond can be obtained,
its degree of assurance is only as good as the surety company. Surety com-
panies can become financially incapacitated just as any other company can.
Finally, collecting on a surety bond would be more difficult {possibly
requiring litigation) than utilizing funds previously paid into a decolllnis-
sioning trust fund.
It may be possible for a well-financed company to obtain a bond for the
relatively short life of a small MOX facility if final decommissioning
. is
slated to occur immediately after closure. In order to get the bond, the
applicant may very well have to provide up to 100% collateral.(a) For a
weakly financed company, or under a Custodial Safe Storage approach, where
final decommissioning will not occur until 20 or more years after startup,
a bond would be diftkult if not impossible to obtain, especiat1y if signi-
ficant collater~1 is required. The cost of a bond, if it can bt obtained,
will likely be in the order of 1 to 2% per year of the guaranteed ar110unt. <4>
This is a significant cost burden.
6.3 DECOMMISSIONING FUNDING IN THE EVENT OF PREMATURE FACILITY C~OSURE
With the sinking fund and pay-when-incurred options, the state runs the
risk that sufficient funds will not have been collected to cover decommissioning
costs if the facility closes prematurely. If the facility operator can and
will pay the difference, no problem arises. If he is financially unable to
do so, the state or possibly the federal government could be forced to make
up the missing funds. No special problem exists with the prepayment option
because funds should be available whenever ~losure occurs. This is the
principal advantage of the prepayment approach. With the pay-when-incurred
approach, the risk of incomplete or insufficient decommissioning performance
is somewhat greater in the event of premature closure because the operator
may not have generated sufficient funds to cover the costs.
(a) A task force of the Conference of Radiation Control Directors found

that surety companies are reluctant to issye bonds in excess of $1
million unless secured by 100% collateral.\3)
6-10
.
If the sinking fund option is chosen, a variety of options are available
to assure the availability of funds in the event of premature closure. The
options include one or more of the following:
• An initial extra cash payment to the sinking fund prior to
production.
• Higher per unit sinking fund charges (in real, i.e., constant
dollars) during early years of operation.
• A bond posted by the facility operator.
The first two options can be considered as combinations of the sinking fund
and prepayment options. The bond alternative, while not ;nfeasible, seems
less desirable than the other two because of the difficulty of obtaining
bonds, as discussed in Section 6.2.3. The first and third options could
also be utilized in conjunction with the pay-when-incurred approach.
6.3.1 Initial Cash Payment
This option contemplates that an initial significant cash payment would
be made to the sinking fund prior to startup. This money would become part of
the sinking fund and would presumably be outside the reach of the operator•s
creditors. The size of ~ "? payment could be flexible and might depend ~n the
financial resources of the operator, the probability of premature closure,
the extent of anticipated decommissioning problems, the anticipated operating
life of the facility, and other factors. In general, however, it seems that
an initial payment on the order of at least 10% of total estimated decommis-
sioning costs (in year of startup dollars) would be appropriate.
The principal advantage of this option is the added assurance it provides
that the initial funds, plus sinking fund payments, will be sufficient to cover
decommissioning costs, as well as administrative costs. If the prepayment is
a small portion of total facility cost, there is no significant disadvant~ge
to this option. If the prepayment option is a significant fraction of total
cost, o;.ly operators with a strong financial capability would be able to
apply for a license.
6-11
6.3.2 Higher Initial Sinking Fund Charges
This option contemplates that payments to the sinking fund in constant
dollars would be initially higher than average and then wv~ld decline with
time. The precise sliding scale could be determined by the licensing agency.
One variation in this option would be to attempt to have constant payments
in nominal dollars over the lifetime of the facility. This option also could
be utilized in conjunction with an initial cash payment.
The advantages and disadvantages of this option are comparable to those
for the initial payment option. The main advantage of this option is that
it provides more assurance than the basic sinking fund option that sufficient
deconmissioning funds· wi 11 be avai_lable in the event of premature closure.
It is also reasonably equitable to the operator and to his customers. This
is because total decommissioning costs per unit of production decline as t'.a
total number of production units increase.
6.3.3 Surety Bonds
Surety bonds appear to be the least viable alternat~ve for providing
funds in the event of premature site closure. The chief difficulty is the
problem of obtaining a long-term commitment from a surety company, as discussed
in Section 6.2.3.
If a suitable bond commitment could be obtained, there are two potential
advantages. First, it may be a more equitable alternative for the smaller
company that is unable to make a significant initial cash payment. Second,
it reduces the distortion effect on nuclear power generation costs of a high
initial cash payment.
6.4 PROVISIONS FOR ACCIDENT AND CONTINGENCY COSTS

This section provides a brief discussion of the issues associated with
accident and contingency cost protection for small MOX plants. States and
the federal government are likely to be as interested in this protection
as in decommissioning assurance. They are especially concerned if decom-
missioning funds are available to the operator•s creditors. In this case,
6-12
a large liability claim could financially incapacitate an onerator and render
his decommissioning performance impossible.
Contingency costs here do not refer to ordinary cost overruns incurred
during decommissioning operations. Tnese cost overruns can be allowed for by
building into the sinking fund payments a reasonable contingency factor.
Rather, the concern is with unexpected fac+ors, such as corrective action
needed for unexpected offsite radionuclide migration, or unanticipated
increased decommissioning requirements caused by changing regulations.
During the facility's operating lifetime, liability and property pro-
taction seem to be best covered by insurance purchased by the facility
operator. Purchase of liability insurance for nuclear facilities is not
generally required by states or the NRC. Moreover, only thermal power reactors,
fuel reprocessing plants, and plutonium licensed plants (possession limit
must remain above 5 kg of plutonium} are covered by the Price-Anderson insur-
ance scheme, which operates to limit aggregate liability for a nuclear incident
to $560 million (42 U.S.C. 2210}. Most fuel fabrication operators probably
do carry liability and property insurance. Much of this insurance is carried
through one or more of three pools: the Nuclear Energy Liability Property
Insurance Association, the Mutual Atomic Energy Reinsurance Pool, and the
Mutual Atomic Energy Liabilities Underwriters. rf the states were to require
appropriate amounts of liability and property insurance, concern ov~r the
availability of decommissioning funds could be lessened.
Under the Safe Storage decommissioning option, the plant may sit idle
for years prior to dismantlement. During this interim period and during
the final dismantlement period, it would also be desirable for the state to
require liability and property insurance. After decommissioning, the site
should be available for unrestricted use and further nuclear insurance
should not be needed. The concern is obviously more complex for other
facilities, e.g., low level waste sites, where the possibility of contingencies
may continue for many years.
A final but important issue is who should bear the risk if decommissioning
costs exceed available trust funds. This issue should be covered by licensing
6-13
language or contract agreement used in setting up the fund. In general,
however, it seems justified to assume that the facility operator should bear
the overrun. The primary reason is that he has ultimate responsibility for
decommissioning with or without a trust fund. Moreover, the operator will
presumably want to fully complete decommissioning to mitigate any possible
future liability. If no trust fund is utilized, the facility operator should
have total decommissioning responsibility regardless of cost.
If the operator is· financially ia1capacitated at the time decommissioning
cost overruns are experienced, the burden to cover the excess costs of these
overruns will probably fall to the state. This possibility should encourage
the state to diligently monitor operating practices in order to minimize
decommissioning costs. It should also encourage the state to realistically
estimate trust fund requirements. In extt:·aordinary circumstances, funds
may be available fr'om the federal goverr.ment. For example, the Federal
Disaster Assistance Administrati'"'" of the U.S. Department of Housing and
Urban development is a possible source of funds in t~e ~vent of some type of
disaster. Although this agency normally provides aid i~ response to natural
disasters, it also occasionally provides assistance for fa·.~ures in man-made
structures, such as the :ase of the Teton Dam collapse in I1aho in 1976.
6.5 WHO SHOULD CONDUCT DECOMMISSIONING ACTIVITIES?

When the facility finally ceases operation, the question arises as to who
should actually conduct decommissioning activities. In large part, selection
of an appropriate decorrmissioning agent depends upon the length of time between
shutdown and dismantlement and the financing approach chosen.
A decommissioning contractor could be used, perhaps with varying degrees
of effectiveness, after a plant shut.',down. If dismantlement is to occur
T
shortly after shutdown, th~ plant operator is a likely choice to conduct the
decommissioning work because of his familiarity with the facility. As the
length of time between shutdown and dismantlement increases, the relative
advantage of the op~rator doing the work decreases. Eventually, an out~ide
contractor with decommissioning expertise may be the most suitable choice.
6-14
Selection of a decoDJDissioning organization may depend in part upon the
financing approach chosen. If the pay-when-incurred approach is chosen, it
will be difficult to have anyone other than the operator or a contractor
retained by him perform the work. Tt!e operator will likely want to directly
control the decoDJDissioning work when he is payirtg for it out of current
revenues. If a trust fund is utilized to fund decoDJDissioning, it may
be reasonable for the state to provide that it or the fund steward will
retain a decODJDissioning contractor. This could be done by putting the work
up for bid or by simply selecting a contractor who may or may not be the
.f facility operator. Trust fund monies could be allocated as work progresses,
much as a bank allocates construction funds. The operator will be interested
in the selection process, since he will likely be responsible for costs that
exceed available trust funds, or he may receive a refund if trust fund
monies exceed decommissioning costs. No matter how the selection of a
decommissioning organization is conducted, it appears desirable for the state
and the regulatory agency to at least retain the power to concur in the
process to assure selection of a qualified organization.
6.6 POWER OF STATE GOVERNMENT TO IMPOSE FINANCIAL OBLIGATIONS ON FACILITY

OPERATORS
The power of state governments to impose certain financial obligations
on nuclear fuel cycle facility operators was examined in a study on financial
alternatives for uranium milling operations.(S) The general conclusion was
that a state may impose financial requirements as an exercise of its general
police power to protect the life, health, and safety of the public. With
appropriate legislation it thus appears that any of the financial alternatives
discussed in this chapter, including establishment of trust funds and bonding
requirements, could be implemented. The conclusion applies whether or not
the state is an Agreement State under the Atomic Energy Act. The study also
concluded that a state, as a licensing condition, may require a facility
operator to transfer ownership of the land to the state at the conc·lusion
of the facility's operating life.
6-15
6.7 Slii1ARY
In summary, the options for providing funds for decommissioning activities
that appear to be in the balanced best interest of all parties, are the
sinking fund, the prepayment option, or some combination of the two. These
approaches-provide,good assurance that the work will be perfonned. They
also provide appropriate consideration of costs in power supply planning
and can be made reasonably equitable to nuclear power consumers. The options
present some administrative complexities, but these are not likely to be
severe.
To allow for premature facility closure, there is an incentive to
supplement the sinking fund approac;h with additional protection. Several
mechanisms are available for achieving this protection. First, before start-
up, the state, or possibly the federal government, can require an extra
initial cash payment into the trust account. Second, the state can set
higher real sinking fund charges during early years of operation. If a
long term surety bond can be obtained, it could also be required.
The prepayment option provides the greatest assurance of decommissioning
p'rformance. Prepayment of the present value of all anticipated decommissioning
costs will add a significant amount to the initial capital investment. Much
of the amount can probably be borrowed, however, and then passed on to
consumers through fuel prices. The most serious objection to this approach
is that it is the most expensive option for society and that it taps the debt
market for funds that would otherwise be available for private investment
projects.
The least satisfactory option appears to be the pay-when-incurred option.
The principal concern is the relatively low degree of assurance it provides
of decommissioning performance. It is, however, the least expensive of the
options.
6-16
REFERENCES
1. u.s. General Accounting Office, Issues Related to the Closing of the

Nuclear Fuel Service, Inc.f Reprocessing Plant at West Valley, New
York, EMC-77-26, March 9, 977.
2. New Mexico Statues Annotated, 12-9-5.1, 1977.
3. Task Force Report on Bonding and Perpetual Care of Licensed Nuclear
Activities, Conference of Radiation Control Program Directors, p. 21,
April 19~5.
4. Financial Alternatives for Stabilization, Reclamation, and Long-Term
Monitoring and Maintenance of Uranium Mill Trailing Piles, Science
Applications, Inc., p. 18, Los Angeles, CA, October 1977.
5. Ibid., pp. 84-90.
6-17
7.0 CHARACTERISTICS OF THE REFERENCE MIXED OXIDE PLANT
This section briefly describes the small reference plant for fabrication
of mixed oxide fuel elements (MOX plant), the generic site on which the plant
is assumed to be located, and the physiochemical processes used in the plant.
Estimates are presented of residual radioactivity levels and residual chemi-
cals on the site and in the plant when production operations are terminated.
The Cimarron, Oklahoma plant of Kerr-McGee Company(l, 2) was chosen as
the reference facility for this study because it is believed to be repre-
sentative of contemporary small mixed oxide fuel fabrication plants in the
United States. Existing plants of this type are expected to require decom-
missioning in the near future. The Cimarron plant uses a head-end process
involving coprecipitation of plutonium and uranium solutions to blend uranium
and plutonium. To extend the applicability of the present study to other
MOX plants, a conceptual addition has been made to the existing plant to
provide an additional head-end process based on dry blending of preformed
oxides. The associated facility components for both processes are analyzed
in this study and the methods and costs for decommissioning each head-end
option are discussed separately.
Details of the plant and the plant process descriptions are presented
in Appendix A, site description details are given in Appendix B, and the
bases for residual radioactivity estimates are presented in Appendix C, all
in Volume 2.
7.1 SITE DESCRIPTION

A generic site was developed to aid in assessing the public safety
of conceptually decommissioning the reference plant. The meteorological
parameters and population distributions used for this generic site were
taken from the ALAP Study {J) for the river site in the year 2000. Tfie
~colQgi,~a.l data were taken from environmental information provided for an
operating nuclear reactor. (4) The remainder of the information was obtained
from a variety of sources. The information is felt to be representative of
potential sites for nuclear fuel cycle facilities in the midwestern or
7-1
southeastern United States. This generic s·;te description was developed for
use in a series of studies examining decommissioning of.nuclear fuel cycle
facilities. The detailed supporting information relating to this abbreviated
description is found in Appendix B.
Individual features for specific sites will likely vary from those of
the generic site used in this study. However, it is believed that use of a
generic site rather than a specific site will result in a more meaningful
overall analysis of the potential safety impacts associated with the decom-
missioning of nuclear fuei cycle facilities. Site specific environmental
information will be required for the detailed safety analysis and the Environ-
mental Report submitted with the request for license modification prior to
decommissioning a particular facility.
The generic site occupies 4.7 km 2 (1160 acres) in a rectangular shape
of 2 km (1.24 miles) by 2.35 km (1.46 miles). A river of moderate size
runs through one corner of the site.
The site is located in a rural area that has a relc:.tively low population
density. Higher population densities are located at dhtances 16 to 64 km
(10 to 40 miles) away, and gradually reducing population densities are en-
countered out to 177 km (110 miles). The closest moderatlly large city,
population 40,000, is about 32 km (20 miles) distant. The ~losest large
city, population 1,800,000, is about 48 km (30 miles) away. The total popu-
lation 1n a radius of 80 km (50 miles) is 3.52 million.
The plant facilities are located within a 1.2 hectare (3 acre) fenced
portion of the site. The minimum distance from the point of plant atmospheric
releases to the outer boundary of the generic site is one km. In most of
the surrounding area, about 80% of the land is used for farming.
The relatively clean river flowing through the site has an average
flow rate of 1420 m3/sec. The river is used for irrigation, fishing, boating,
and other aquatic recreational activities, and is a source of drinking water
for larger communities. Large supplies of flowing groundwater exist at
modest depths around the site. This water is widely used for drinking and
irrigation.
7-2
The generic site occupies a relatively flat terrace that has a low
bluff forming one bank of the river. Biologically young soils cover the old ·
basement rocks in the area. This site is in a relatively passive seismic
area and is located at an elevation above the estimated maximum probable
flood level.
The climate at the site is typical for internal continental areas. It
has wide temperature variations and moderate precipitation. Atmospheric
dispersion factors used in this study are derived as an average from the
meteorological data of 16 nuclear reactor sites. The resulting annual
average atmospheric dispersion factor at the closest point on the site
boundary, i.e., 1 km, i.s about 5 x 10-8 sectm3• (l)
Less than 20% of the land around the site is covered with pristine
vegetation. The original vegetation was primarily a climax decidious forest.
A number of migratory birds are present in the area, as well as some annual
birds. A few of these are considered to be rare, endangered, or threatened
by extinction. A number of mammals occupy the general area.
The site is slightly contaminated with radioactive material as a
result of deposition from the release of normal operating effluents over
the 10-year plant operating life. It is assumed that accidental releases
of radioactive material will be cleaned up immediately following the event.
Estimates of the maximum site contamination levels at the time of plant
shutdown and selected times after shutdown are shown in Table 7.1-1. The
site contamination estimates are based on the deposition of predicted normal
operating atmospheric releases of particulates. The normal operating releases
were conservatively assumed to be 10- 9 of the estimated mixed oxide fuel
throughput at the time of fabrication.(S) The plant capacity was assumed
to be two metric tons of heavy metal (MIHM) per year. The assumptions and
calculation'al methods for relating the normal plant effluents to site surface
contamination can be found in Appendix B.
The detail provided in the site description is sufficient to allow the
generic environmental assessments for this study to be made. For similar
analysis of specific facilities and sites, additional depth in the environ-
mental assessment may be necessary to more accurately access the environmental
impact of releases of toxic or radioactive materials.
7-3
TABLE 7•l- 1. Estimated Maximum Quantities of Radioactive
Materials Deposited on the Generif MOX Site
Over a 10-Year Operating Lifetime a)
Deposited Radioactivity (pCi/m2) at Plant
Shutdown and Selected Times After Shutdown
·Radionuclide Shutdown 5 Years 10 Years 30 Years
231Th· 7.OE-6(b) 7.0E-6 7.1E-6 7.2E-6
234Th 1.5E-4 1.5E-4 1.5E-4 1.5£-4
233Pa 2.4E-6 6.5E-6 1.2E-5 4.7E-5
234mPa 1.5E-4 1. 5E-4 1. 5E-4 1. 5E-4
234Pa 1.5E-7 l.SE-7 1. 5E-7 1. 5E-7
234u 3.0E-4 3.1E-4 3.2E-4 3.6E-4
235u 7.0E-6 7.0E-6 7.1E-6 7.2E-6
236u 6.2E-7 1. 1E-6 1.6E-6 3.7E-6
237u 4.5E-3 3.5E-3 2.8E-3 l.lE-3
238u 1.5E-4 1.5E-4 1.5E-4 1.5E-4
237Np 2.4E-6 6.5E-6 1. 2E-5 4.7E-5
238Pu 8.8E-l 8.5E-1 8.1E-l 6.9E-1
239Pu 7.2E+O 7.2E+O 7.2E+O 7.2E+O
240Pu 3.5E+O 3.5E+O 3.5E+O 3.5E+O
241Pu 1.8E+2 1.4E+2 1.1 E+2 4.4E+l
242Pu S.OE·-4 S.OE-4 8.0E-4 8.0E-4
241Am L9Et0 J.lE+O !.1E+P. 6.2E+O
Total 1. 9E+2 1.5E+2 1.3E+2 6.2E+l
{a) Values are calculated based on release factor from Reference 5
and deposition factor from Appendix B.
(b) Notation: Z.Z±V is equivalent to Z.Z x 1o±Y
7-4
7.2 PROCESS DESCRIPTION
Overall processing characteristics assumed for the reference mixed
oxide fuel fabrication plant are presented in Table 7.2-1. A simplified
block flow diagram of the process is shown in Figure 7.2-1. Details of the
process are given in Appendix A.l of Volume 2.
All processes associated with fuel pellet fabrication are performed
inside glove boxes located in three rooms in the process area of the build-
ing (the Wet Processing Room, Room 128, the Dry Blending Room, Room 155,
and the Pellet Processing Room, Room 124). Transfer of product materials
from one process step to the next is sometimes accomplished automatically
and sometimes manually through use of a portable glove box.
Production activities fall into six major categories:
1. Mixing and blending of plutonium nitrate and uranyl nitrate
hexahydrate (UNH), coprecipitation and calcining to a mixed
oxide.
2. An alternative head-end process involving the dry mixing and
blending of uranium and plutonium oxides (U02 and Pu02).
3. Mechanical pressing of mixed oxide into pellets.
4. Fabrication of pellets into fuel pins.
5. Inspection of fuel pins and packaging for shipment offsite.
6. Recovery of plutonium and/or uranium from process materials and
liquids.
7.2.1 Coprecipitation Head-end
For the coprecipitation head-end process, plutonium nitrate solution
arrives at the plant by truck in 10-liter L-10 containers. Plutonium is
carefully weighed and sampled upon receipt and either pumped directly to
weigh tanks or stored in the process building vault room until needed.
Uranyl nitrate hexahydrate (UNH) arrives at the plant in 208-1 (55-gal)
steel drums with polyethylene liners. The temperature of the UNH must be
carefully controlled to maintain UNH as a fluid and to prevent crystals from
forming that would unbalance the process assay. Overhead insulated lines
7-5
,',
t ;"lc •' .. ~.-...... ~ ..:.,.,.;,.-~'<~•·

TABLE 7.2-1. Overall Processing Characteristics of
the Reference Mixed Oxide Fuel
Fabrication Plant
ANNUAL OPERATING CAPACiTY

2.3 MT MOX, 22.76 wt% Pu0 2, 77.24 wt% U02
ANNUAL INPUT
Coprecipitation Mode (Assumes all material processed by this mode)
472.5 kg of contained" plutonium in the form of 250 g/1 Pu as
Pu(N03)4 solution in 3-6 molar nitric acid; packaged in 189
type L-10 containers.
1618 kg of contained natural uranium in the form of 2M
U02(N03)2•6H20 solution; packaged in ten 208-liter (55-gal)
drums.
Dry Oxide Mode (Assumes all materia~ processed by this mode)

540 kg of Pu02; packaged in 12P. type 6M containers.
1820 kg of U02; packaged in seven 208-liter (55-gal) drums.
ANNUAL OUTPUT
12,750 mixed oxide fuel pins per year, containing 144 pellets each
fuel pin, 1 1/4 grams per pellet.
SCRAP RATES
10% of U+Pu throughput recycled as clean scrap;
1 ·to 2% of U+Pu throughput recycled as dirty scrap.
SHIFT STRUCTURE
Around-the-clock oper;~tion for 365 days per year.
Basic operating cyclEr;ls a 7-day cycle with 19 or 20 processing
shifts followed by 1 or ,2 cleanout shifts. Thi.s is done with four
rotating shifts plus one permanent day shift.
Total of 120 people working inside the plant a_rea.
7-6
li 1 P~NO)I4 IN
I-t STORAGE r
Sw
a:s
I L-lOCONTAINER WEIGHING CALCINATION,
MILLING
1-- AND ~ COPRECI PITAliON ~ AND t-
~~ U~!N0)'2·6H2()
IN 1-t STORAGE
BLENDING BLENDING
~-\.ITER DRl.M RECYlLE FROM SLUGGING INSPECTION
FINAL fUEL SHIPMENT
SCRAP RECOVERY ... AND
GRANULATION
r- PELLET
FORMATION
r- PIN
FABRICATION
j-t AND
PACKAGING
TO CUSTOMER
Pu Oz
liE
c;
IN 1-t STORAGE
z .... 6M CONTAINER WEIGHING
~CI
..,o AND
>~
.....,
"'
Cl .. ~
~-!.ITER DRLM
r--t STORAGE
BLENDING
REJECT PELLETS AND POWDER

.....,
I
NONCONTAMI NA TED
PELLETS
r-
AND 1-' DISSOLUTION
4 POWDER
PLUTONil.M
-t EXTRACTION f--.4
CONTAMINATED SOLVENT CYCLE
'-4 PELLETS
AND
r-t Dl SSOLUTI ON ~r' EXTRACTION . i--t> TO COPRECI P11
POWDER URANil.M
4 EXTRACTION I-t
CYCLE
4 ION
EXCHANGE
FIGURE 7.2-1. Simplified Process Flow Diagram for Reference

Mixed Oxide Fuel Fabrication Plant
with electrical heating traces transfer the solution from the dr~ms to the
weigh tanks or to holding tanks in a wall of the process building vault.
For the coprecipitation process, precisely measured quantities of
Pu(N03)4 and uo2(N0 3) 2"6H2o are fed to a weigh tank located 'inside a large
glove box in the wet proc~ssing room. A circulating pump incorporated in
the tank is operated to thoroughly blend the batch. The mixture is then
stored in one of the 107-t wall storage tanks or transferred to a pre-
cipitation column in another glove box.
In the coprecipitation step, the uranium-plutonium feed and ammonia
water are precisely metered into a prec"! p-; tat ion column where the Pu and U
blend is continuously precipitated as plutonium hydroxide and ammonium
diuranate. The precipitate slurry is continuously transferred to aging
columns equipped with temperature control. Additional ammonia is added to
insure completion of precipitation. The slurry is filtered; the solid is
loaded into metal trays, dried, calcined and reduced to (U,Pu)0 2 in a furnace
using nitrogen-8% hydrogen by volume as a reducing atmosphere. The finished
mixed oxide is hammer-milled to a uniformly sized powder, cross-blended into
uniform batches, packaged in safe containers and loaded into a portable glove
box. The glove box is stored in the concrete vault and then moved to the
pelletizing room when the mixed oxide is needed for making pellets.
7.2.2 Dry Process Head-end

For the alternative dry process head-end, plutonium oxide and uranium
oxide pellets (or po~rler) are presumed to be received at the plant with a
quality that permits direct blending for fuel manufacture without the need
for wet processing. The Pu0 2, received in type 6M containers, is first
weighed and then manually transferred to the Puo 2 feed hopper. The uo 2,
received in 208-t drums, is transferred to a similar feed hopper. For
each batch, the two oxides are metered from their respective feed hoppers
into separate batch-weighing hoppers, and then released to the btent1~r. After
blending, the mixed oxide may be hammer-milled, if necessary, to a uniillnn1y
sized powder. The finished mixed oxide is then packaged in safe contai~ers
7-8
and transferred by por.~ble glove box to the concrete vault or to the
pellet processing room.
7.2.3 Pellet Formation and Fuel Rod Assembly
Pellet formation is a two-step process. In the first step, the mixed
oxide powder is fed, one container at a time, into a hydraulically driven
slugging press. This press is used for 11 Slugging 11 the oxide, a preliminary
forming of pellets to increase the oxide density. Pellets from this initial
operation are ground up by a screen granulator and the granulated material
is again calcined and then pressed into fuel pellets. These green pellets
are sintered to ceramic grade pellets, precisely dimensioned in a centerless
grinder, outgassed in a heated vacuum furnace, and transferred to the fuel
rod fabrication room.
finished pellets are incorporated into fuel rods in a glove box opera-
tion in the Fabrication Room. Pellets are inspected, cleaned, and assembled
into rows. The pellet rows are loaded into horizontally oriented cladding
tubes that have the first end cap welded in place. Assembled fuel pins are
evacuated, filled with argon·or helium to slightly negative pressure, and
the final end cap is welded to the cladding tube.
Rod welds are tested at an inert gas leak test station and by x-ray
analysis. The rods are then thoroughly cleaned and tested for bowing on a
high precision granite surface plate. Rods that pass all the required
quality assurance tests are loaded into containers for shipment to the
customer.
7.2.4 Scrap Recovery
There are three product scrap recovery.areas (Rooms 127, 801 and 805).
One area recovers product from clean scrap; the other two.. recover product
from dirty scrap. Processes are available to recover plutonium from the
following m~terials:
1. Non~contaminated (U, Pu)o2 or uo2-Puo2 pellets or powder that
are rejected for physical reasons.
7-9
2. Cnemically contaminated (U, Pu)0 2 reject pellets or powder.
3. Combustible Pu-contaminated solids (paper, doth, etc.).
4. Organic "non-combustible" solids (gloves, plastics, etc.).
5. Highly refractory solids, of assay up to and including pure Puo 2.
6. Contaminated aqueous and organic Pu-bearing solutions.
Unit scrap recovery processes include digestion, leaching, calcination, in-
c·ineration, precipitation, two-cycle solvent extraction for separation and
purification of plutonium and uranium, and ion exchange. Arrangements and
layout are sufficiently flexible to permit several different sequences of
processing.
A substantial fraction of (U, Pu}02 reject pellets, powder, etc., are
rejected on physical characteristics alone and are of adequate chemical
purity for immediate reuse. Such material is processed through a clean
dissolution circuit and is returned to ADU-PU(OH) 4 precipitation without
•
purification processing.
Chemically contaminated reject pellets or powder are dissolved in HN0 3
or HN0 3-HF and purified by the use of two tributyl phosphate (TBP) solvent
extraction cycles and/or a batch anion exchange cycle. The plutonium product
is recycled as Pu(N03)4 solution or converted to Pu0 2 via precipitation as
plutonium oxalate and calcination to Puo2• Purified uranium is removed as
uranyl nitrate solution which is then recycled to the coprecipitation step.
The purification operations generate low-to intermediate-level waste
streams that can be processed for additional product recovery by back-cycling
to the first solvent extraction cycle.
Combustible solids are roasted in an oxidizing atmosphere to remove
organic maJerial. The ash from this roasting contains essentially all the
· p'lutonium and uranium in the original waste, and is processed through dis-
solution. Certain poorly combustible organic materials such as glove box
gloves, plastic bags, etc., are processed through one or more ieaching
operations with warm HN03 or HN0 3-HF and then discarded to offsite burial.
7-10
Processing of clean scrap ceramic materials is accomplished in pro-
cessing modules that carry out the f~llowing distinct functions:
l. High temperature oxidizing roast of high assay (U,Pu) ceramic
materials.
2. Dissolution and precipitation of Pu and U as oxalates.
3. Calcination of plutonium oxalate to plutonium oxide.
4. Conversion of the oxide to plutonium nitrate for blending back
into the coprecipitation head-end process.
Product recovered from processing ceramic materials is returned to the wet
head-end process as the nitrate or to the dry head-end process as the oxide.
7.2.5 Waste and Effluent Processing
All low-level Pu-contaminated aqueous and organic wastes from the plant
are filtered to eliminate large particulate or fibrous material. The filter
media with its collected material is calcined to dry waste and discarded to
burial. The clear filtrate is evaporated to minimize the liquid volume and
1nixed with cement in 208-i (55-gal) drums. The resulting solid is shipped
offsite for disposal in a federal repository. Dry Pu waste material is
similarly processed for burial in 208-i drums.
7.3 PLANT DESCRIPTION

A mixed oxide fuel fabrication plant is a manufacturing facility de-
signed and constructed for the production of (U-Pu)0 2 pellets and incorpora-
tion of these pellets into clad fuel rods. The plant also has facilities
for the recovery of plutonium from unirradiated scrap materials. An
isometric drawing of the reference plant (the Cimarron plant of Kerr-McGee
Corporation) is shown in Figure 7.3-1. Details of the plant description
are given in Appendix A.2 of Volume 2. The plant is assumed to be located
on a fenced-in restricted area of about 12,000 m2 (3 acres). It consists of
about 2400 m2 (26,000 ft 2) cf manufacturing, maintenance, office and labora-
tory floor space located in one building. Auxiliary facilities include a
cooling tower, electrical substation, effluent storage and gas supply.
7-11
SECOND FLOOR
II
...
.,
:i
II FIGURE 7.3-1. Isometric of

Reference Mixed
Oxide Plant
7-13
7.3.1 Facility Description
The exterior walls and roof of the plant building are constructed of
precast, prestressed concrete strengthened with additional reinforcing steel
to withstand a wind load of 190 km/hr (120 mph). A concrete floor was poured
in place after the precast concrete building was erected. The roof construc-
tion over the concrete roof deck is a poured-in-place insulation with built
up roofing and gravel. All exterior and interior joints in the precast
building are caulked to make an airtight structure.
The process area includes a poured-in-place reinforced concrete storage
vault and adjoining basements. The vault is used for storage of plutonium
not currently being processed. It is capable of withstanding wind loads of
480 km/hr (300 mph), and a pressure change of 0.34 atm. (5 lbs/in. 2). Two of
the walls of the vault are constructed to contain storage tanks for plutonium
and uranium liquid solutions. Mild steel sleeves 15.2 em (6 in.) in diameter
and 9.1 m (30ft) long are encased in these two reinforced concrete walls.
Storage tanks are located inside the steel sleeves. Basement areas provide
access to the bottom of the plutonium and uranium solution storage tanks
and house the solvent extraction process, the scrap recovery operation and
the waste solution storage tanks.
The walls, ceiling.and floors throughout the building are coated with
three layers of an organic coating to provide a smooth coated surface that
may be easily cleaned.
Glove boxes for all processing equipment provide additional containment
inside the building. These boxes are built of 1 em (3/8 in.) thick sand-
blasted stainless steel. Windows are made of Plexiglass . Processing is
generally done in process equipment inside these glove boxes.
In order to provide appropriate separation of functions and improve
ventilation control, the building is divided into work areas with each area
subdivided into rooms in accordance with their respective functions. The
work areas include the following:
7-15
• Office area
• Central service core
• Analytical laboratory area
• Process area.
The office area is considered a clean area and is separated from all other
fa.cilities. It contains a reception area, director's office and staff
lunchroom. A central service core contains change rooms, shower facilities,
laundry and health physics laboratories. The analytical laboratory area
includes rooms for general wet chemistry, metallurgical analysis, radiologi-
cal analysis, emission spectroscopy and mass spectroscopy. A maintenance
shop with a glove box for equipment maintenance is located at a central
corridor. The process area is subdivided into wet processinq, dry blending,
pellet fabrication, rod fabrication and inspection, and scrap recovery rooms.
The vault is located in the center of the processing area. Table 7.3-1
lists the individual rooms in the processing area and briefly describes the '__ !'_;
-~~1.·
functions carried out in each room. Detailed descriptions and equipment
lists for process rooms are given in Appendix A.2 of Volume 2.
ai'
There is only one personnel entrance, and that is at the front of the
building. Emergency .. exit only .. doors are provided throughout the plant.
The emergency doors are sealed to prevent inflow or outflow of air and are
equipped to sound an alarm when opened. The shipping and receiving area at
the rear west side of the plant is a material air lock. Two air locks are
provided between the change rooms and the process area. Another air lock
is provided for entry to the laboratory rooms. All air locks are inter-
locked so that only one door to the air lock can be opened at one time.
7.3.2 Ventilation System Description
A simplified flow diagram for the reference small MOX plant ventilation
system is shown in Figure 7.3-2. Air is supplied to the building through an
intake system that provides for dust filtration, heating or chilling as
appropriate to the season, and distribution to the various rooms of the
building. The intake system is located in the Supply Air Fan Room (Room 202)
located on the st:cond floor of the building. The flow of a-ir within the
7-16
TABLE 7.3-1. Functional Uses of Process Rooms
in Reference Plant
Room· General Overall

Number _operations Dimensions (m) ___ Functional U_s~-----------
155 Dry 6.23 X 4.68 Weighing, blending and milling of Pu02
Blending X 4.27 high and U02 powder to form a mixed oxide
powder suitable for fuel pellet fabri-
cation.
128 Wet 14.53 X 7.16 Pu(N03)4 and U02(N03)2·6H20 solutions
Processing X 7.32 high are combined and chemically processed to
precipitate Pu hydroxide and AOU. The
precipitate is calcined, milled and
blended to form a mixed oxide powder
suitable for fuel pellet fabrication.
127 Clean Scrap 16.0 X 5.19 Room contains dissolvers, ion exchange
Recovery X 7.32 high columns and a calciner to process clean
scrap and recover plutonium in a form
suitable for return to production.
126 Storage 13.72 X 5.56 Temporary storage of plutonium and
Vault X 4.27 high uranium solutions, plutonium oxide and
mixed oxide powder.
12~ Pellet 1g.93 X 4.95 Room contains presses, furnaces and
Processing 32 high
X ] • grinders to convert mixed oxide powder
into precisely dimensioned fuel pellets.
123-122 Fuel Fabri- 19.93 X 4.72 Pellets are inspected and assembled in
cation and X 7.32 high cladding tubes. Cladding tube end caps
X-ray are welded and welds are inspected and
x-rayed.
121 Fuel Rod 18.29 X 5.87 Completed fuel rods are washed, in-
Inspection X 7.32 high spected and packaged for shipment off-
site.
801 Dirty Scrap 10.82 X 5.18 Equipment for processing dirty scrap
Recovery X 4.88 high to rernver plutonium and convert it to
a form suitable for return to production.
B02 Waste 16.46 X 7. 16 This room contains liquid waste storage
Treatment X 4.88 high tanks and evaporators.
805 Solvent 5.18 X 3.05 This room houses th? solvent extraction
Extraction X 12.50 high columns for processing liquid waste to
recover plutonium and uranium.
129 General 10.67 X 10.67 Chemical assay of solutions and powders
Chemistry X 4.27 high containing uranium and plutonium.
Laboratory
116 Equipment 10.67 X 5.95 This room contains a glove box for
Maintenance X 4.27 high maintenance and repair of contaminated
equipment.
156 UNH 4.68 X 3.66 Room contains piping for unloading
Receiving X 4.27 high U02(NOJ) 2 ·6H20 for feed to wet process;
also drum storage space.
7-17
a:
:c
::::
!
-
......
I
( X)
ACID ALKALIN£
HANDLING HANDLING
GlOVE BOX GLOVE BOX
~~~~~~ HEPA FILlER @£:] DlfltRENTIAL PRESSURE CONTROLLER

~ ROUGHING FILltR
Q;JaLMR (J.[] ftOWMElER

E3 FIRE SCREEN
~ AIR SAMPLER AND MONITOR
-<J-1f MOTORIZED OW">Q
~ MANUAL DAMP!:<
FIGURE 7.3-2. Simplified Flow Diagram for MOX Plant Ventilation System
building is controlled so that air moves f~om clean areas to areas with
successively higher contamination potential and finally into the glove box
enclosures containing process equipment where the ventilation system becomes
effectively a gaseous radioactive effluent treatment system.
Air 1s supplied to individual rooms through ducts and diffusers located
in the ceilings of the rooms. Room air is exhausted through a roughing
filter followed by a high efficiency particulate air (HEPA) filter installed
in the floor of each room. The air then enters an underground ductwork system
and is filtered by a final HEPA filter system in the Exhaust Air Fan Room
before being exhausted from the plant.
Room air entering a glove box is filtered by roughing and HEPA filters.
Air leaving a glove box is filtered first by roughing and HEPA filters at
the glove box and then by a second HEPA filter located in each room for all the
glove box~s in the room. The air then enters a central ductwork system and
is filtered by a third HEPA filter in the Exhaust Air Fan Room before being
exhausted from the plant.
The Exhaust Air Fan Room (Room 201) is located on the second floor of
the building adjacent to the stack that extends from the building roof (See
Figure 7.3-1).
7.4 RESIDUAL RADIOACTIVITY ESTIMATES

Table 7.4-1 summarizes estimated inventories of plutonium in each pro-
cess room of the reference MOX plant after final inventory cleanout by
operating plant personnel and after decommissioning decontamination opera-
tions. Dose rate levels based on these inventory estimates are also given
in the table. Only plutonium numbers are shown because the plutonium
radiological hazard completely dominates the uranium radiological hazard.
Key assumptions and rationale on which the inventory estimates are based
and detailed inventories for each room are presented in Appendix C. Final
inventory cleanout operations and decommissioning decontamination operations
are described in Appendices F and G.
7-19
TABLE 7 .4-1. Estimated Radioactivity levels in Reference t40X
Plant After Final Inventory Cleunout and After
Decommissioning Decontamination Operations
PROCESS AREA AFTER OPERATIONAL INVENTORY CLEANOUT AFTER CHEMICAL DECONTAMINATION
lloS.! Rate !mrem[hr)!a) Dose Rate {mremlhr)(a)
kg of(d) Gelmll Neutron (d) Ganwna Neutron
Room kg of -· (li'}
Plutonium Room(b) Equlp(c~ Room{b) Equlp{c:) Plutonium [quip(c) Room(b) .E.!I!!!~-
Number Operat!Q!!_ ~
155 Dry 0.34 0.2 1.0 0.03 (1.1 0.18 0.2 1.0 0.02 0.1
Blending
128 Wet 3.1 0.2 1.0 0.3 0.5 1.5 0.2 1.0 0.2 0.3
Processing
802 Wet Proc. & 1.8 0.2 1.0 0.?. 0.2 0.6 0.2 1.0 0.1 0.1
Waste Treat.
128-802 Pip'ng 0.8 1.0 0.03 0.4 1.0 0.02
127 Scrap 2.1 0.2 1.0 0.2 0.2 1.5 0.2 1.0 0.2 0.2
Recovery
BOi Scrap 3. 3 0.2 1.0 0.3 0.3 1.6 0.2 1.0 0.2 0.2
Recovery
SX-127- Piping 2.5 1.0 0.1 1.3 1.0 0.05
801
sx Solvent 5.2 0.2 1.0 0.5 1.0 1.7 0.2 1.0 0.2 0.3
Extraction
124 Pellet 4.0 0.2 1.0 0.4 0.5 2.1 0.2 1.0 0.2 0.3
Processing
123 Fuel 0.11 0.2 1.0 0.01 0.04 0.053 0.2 1.0 <0.01 0.02
Fabric•tlon
126 Storage 0.17 0.05 0.02 0.085 0.05 0.01
Vault
129 laboratory 0.086 0.05 0.05 0.01 0.03 0.043 0.05 0.05 <0.01 0.02
li6 Maintenance 0.034 . 0.05 0.05 <0.01 0.01 ~IL 0.05 0.05 <0.01 <0.01
Rounded Tota 1s 23. 11.
(a) Whole body radiation exposure rates.

(b) Working in room.
;~) Working in glove box.
(d: Values are calculated; the number of significant figures is greater than the expected accuracy.
At shutdown and before final inventory cleanout, the plutonium inventory

in the reference plant is estimated to be between 40 and 50 kg. The plu-
tonium inventory in the process building after final inventory cleanout is
estimated to be approximately 23 kg. These cleanout operations, done periodi-
cally during plant operations between processing campaigns, are defined as
operations that remove process materials, chemicals, trash, visible quantities
of contamination, scrap, scrap solutions and contaminated solutions from the
facility. Empty product, scrap and waste handling tanks are also rinsed to
flush out remaining process solutions. These-operational inventory cleanout
operations are charged to plant operations and not to decommissioning.
7-20
TABLE 7.4·1. Estimated Radioactivity Levels in Reference MOX
Plant After Final Inventory Cleanout and After
Decommissioning Decontamination Operations
PROCESS AREA AFTER OPERATIONAl INVENTORY ClEANOUT AFTER CHEMICAl DECONTAMINATION
Dose Rate (mrem{hr)(a) Dose Rate {mrem{hr)(a)
Room kg of(d} Gallllla Neutron
!!!!!!!!.!! Operation Plutonium Room(b) Eguip(c! Room(b) Egutp(c)
155 Dry 0.34 0.2 1.0 0.03 0.1 0.18 0.2 1.0 0.02 0.1
Blending
128 wet 3. 1 0.2 1.0 0.3 0.5 1.5 0.2 1.0 0.2 0.3
Processing
802 Wet ?roc. & 1.8 0.2 1.0 0.2 0.2 0.6 0.2 1.0 0.1 0.1
Waste Treat.
128-802 Pip'ng 0.8 1.0 0.03 0.1\ 1.0 0.02
127 Scrap 2.1 0.2 1.0 0.2 0.2 1.5 0.2 1.0 0.2 0.2
Recovery
BOi Scrap 3.3 0.2 1.0 0.3 0.3 1.6 0.2 1.0 0.2 0.2
Rect~very
SX-127- Piping 2.5 l.O 0.1 1.3 1.0 0.05

601
SX Solvent 5.2 0.2 1.0 0.5 1.0 1.7 0.2 1.0 0.2 0.3
Extraction
124 Pellet 4.0 0.2 1.0 0.4 0.5 2.1 0.2 1.0 0.2 0.3
Processing
123 Fuel 0.11 0.2 1.0 0.01 0.04 U.05J 0.2 1.0 <0.01 0.02
Fabricdtion
126 Storage 0.17 0.05 0.02 0.085 0.05 0.01
Vault
129 Laboratory 0.086 0.05 0.05 0.01 0.03 0.043 0.05 0.05 <0.01 0.02
1i6 Maintenance 0.034 . 0.05 0.05 <0.01 0.01 0.05 0.05 <0.01 •.0.01
Rounded Totals 23. 11.
(a) Whole body radiation exposure rates.

(b) Working in room.
\~) Working tn glove box.
(d~ Values are calculated; the number of significant figures is greater than the expected accuracy.
At shutdown and before final inventory cleanout, the plutonium invent<J

n the reference plant is estimated to be between 40 and 50 kg. The plu-
onium inventory in the process building after final inventory cleanout is
stimated to be approximately 23 kg. These cleanout operations, done peri<
Decommissioning decontamination operations start with a thorough
flushing and chemical decontamination of all process equipment and piping.
Decontamination procedures include spray cleaning, hot corrosive acid flush-
ing, and dry cleaning and handwiping of dry processing equipment. These
procedures are estimated to reduce the building inventory of plutonium to
approximately 11 kg. Further reductions in the building plutonium inventory
occur as the equipment and glove boxes are disassembled and either packaged
for disposal to a federal repository or further decontaminated using electro-
polishing techniques.
CHEMICAL. INVENTORIES
7.5 ~~~~--~=-·----
Several potentially toxic chemical compounds are used in processing and
scrap recovery operations in the MOX plant. These compounds include nitric
acid, tributyl phosphate, ammonium hydroxide, sodium hydroxide, hydrogen
fluoride and methanol. Most process chemicals not planned to be used for
decommissioning are assumed to be removed from the plant as part of the final
inventory cleanout operations. Inventories of these chemicals will therefore
be limited to residuals in process equipment and piping at the start of de-
commissioning. Except for nitric acid, fluoride salts, and degreasing agents
which are used in chemical decontamination operations, no significant fnven-
tories of other toxic chemicals are anticipated in the plant when decommis-
sioning begins.
7-21
REFERENCES
1. Application fQr Special Nuclear- Mater~ial License, Kerr-McGee Corpora-

tion, Safety Analysis Report for its Cimarron Plutonium Fuel Plant,
March 1969.
2. A~plicants Environmental Repor!, USAEC, Docket No. 70-1193, Supplement
# , Kerr-McGee Corporation, December 1973.
3. u.s. AEC, Final Environmental Statement Concern~ng Proposed Rule-Making
Action: Numerical Guides for Design Objectives and Limiting Condition-
ing for Operation to Meet the Criteria As Low as Practicable .. for
11
Radioactive Material in Light Water-Cooled Nuclear Power Reactor

Effluents, WASH-1258, Directorate of Regulatory Standards, Volume 1 of
3, Figure 68-1, p. 6B-43, and Figure 6C-8, p. 6C-12, July 1973.
4. U.S. AEC, Final Environmental.Statement Related to Operation of
Monticello Nuclear Generating Plant, Docket No. 50-263, p. II-15 through
II-26, November 1972.
5. Final Generic Environmental Statement on the Use of Recycle Plutonium
in Mixed Oxide Fuel for Light Water Reactors, NUREG-0002, USNRC,
Volume 3, p. IV D-27, August 1976.
7-22·
8.0 ~ElHODOLOGY FOR CETERMINING ACCEPTABLE CONTAMINATION LEVELS
FOR PUBLIC USE OF THE DECOMMISSIONED REFERENCE MIXED OXIDE
FUEL FABRICATION FACILITY AND SITE
The ultimate disposition of decommissioned nuclear facilities and their

surrounding sites depends upon the degree and typb of radioactive contamination
remaining. Examination of existing guidelines and regulations has led to the
conclusion that there is a need for a general method to derive acceptable
radioactive contamination levels that can be applied to the public release of
any decommissioned nuclear facility or site.(l) Some guidance currently exists
defining the levels of radioactive surface contamination that are acceptable to
the NRC for the termination of operating Ol' possession:only licenses. ( 2, 3)
Other suggested guidance is directed toward specific types of nuclear facilities,
·or accident situations involving radioactivity~( 4 - 9 )
None of these guidelines are sufficiently flexible to accomodate the
various radionuclide mixtures or site specific features found at each unique
nuclear facility. This fact suggests that the methodology used to calculate
the acceptable lev~~s of residual radionuclide contamination at decommission-
ed nuclear facilities should be based on a more general concept that is
capable of accomodating these unique radionuclide mixtures and site specific
features. One general concept is to compare established annual dose limits
with calculated maximum annual doses to llltmber's of the public to determine
acceptable radioactive contamination levels. The contamination levels derived
from a maximum annual dose concept take into account the radiation exposure of
individuals from all pathways to contamination remaining in a decommissioned
facility or on its site following t'elease for public use.
The purpose of this section is to describe and demonstrate the method-
ology for determining acceptable contamination levels for public use of
the decommissioned reference MOX facility and its site based on the maximum
annual dose to an individual. The following terminology is used in develop-
ing the methodology based on annual dose:
• Disposition Criteria - The acceptable radioactive contamination levels
for public use of deco~m~issioned nuclear facilities and ~ites, based
on a maximum annual dose limit.
8-1
• Organs of Reference - The specific organs of the human body for which
radiation doses are calculated. In this study, the lungs~ bone, liver,
and total body have been selected as the more critical organs of reference.
The total body ·,: the hea:! and trunk of the human body, including active
blood-forming organs, 1 ~ns of eyes, and gonads.
• Exposure Pathways - The potential routes by which radionuclides or radia-
tion may rP.ach people. Exposure pathways of concern in calculating
the dose to personnel in the MOX facility are inhalat·ion of radioactive
particl!lates, submersion in airborne radioactivity, and external exposure
from surface contamination. In the environment, the same pathways are
considered plus the ingestion of food products containing radionuclides.
• Decay Periods - The continually changing mixture of ratlionuc'lide inventories
results in annual doses that are time-dependent. This dependence is
demo-nstrated ir. this study by calculating radiation doses at the time of
the operational shutdown, and at 5, 10, and 30 years after plant shutdown.
• Annual Dose - The radiation dose calculated during any year following
continuous exposure. It is the sum of the doses r~ceived during the
year of interest from all pathways including the dose resulting in that
same year from the intake of radionuclides during previous years. The
highest value found is referred to as the maximum annual dose. For
internal emitters, this methodology differs from the method of calculating
the 50-year dose commitment from one year's intake often used in performing
environmental dose assessments of operating facilities.
• Cluss Wand Y Material - Radionuclides that are slowly removed from the
pulmonary region of the lung by gradual dissolution in extracellular
fluids, or in particulate form by translocation to the 'li tract, blood,
or lympr:dtic system. Class Wrepresents material w1 th maximum clearance
half-time~ in the lungs from a. few days to a few months, and Class Y
is used to describe material with maximum biological half-times ranging
from 6 months to several years.(lO) The translocation class, as described
by the Task Group Lung Model,(lO) depends upon the chemical nature of the
compound inhaled. Plutonium carbides, oxides, hydroxi~es, and lantha~ide
fluorides are specified as Class Y. Plutonium nitrates, carbonates. and
lanthanide halides are specified as Class W.(ll)
8-2
• Class 0 Material - Radionuclides that are dissolved upon contact with
extracellular fluids and translocated to the blood. Class 0 material
is expected to exhibit maximum clearance half-times of less than 1
day.(lO) An example of Class 0 material is uranyl nitrate hexahydrate.
Additional terminology, radiation dose models and parameters, and a
derivation of the equations used to determine the annual doses are contained
in Appendix E and in the Glossary (Section 14).

The basic premise for the disposition criteria methodology described in
this study is that no member of the public will receive an annual dose in
excess of a limit yet to be established by U.S. federal agencies. Discussion
of future use categories and the methodology, based on maximum annual dose,
for determining the acceptable contamination levels are contained in the
following subsections.
8.1.1 Definition of Use Categories
During the planning stages of decommissioning, a variety of future uses
may be considered for the facil-ity and its site. Three general use categories
after decommissioning are considered in this study.
They are:
• Restricted Use - Restricted use permits only nuclear activities to be
conducted at the decommissioned MOX facility and/or site. The residual
radioactive contamination levels for this category are expected to be
similar to the levels found at licensed operating nuclear facilities.
Therefore, the exposure of workers and the pub1i c is contro11 ed t;,y the
restrictions imposed by the nuclear license.
• Conditional Use - Conditional use of the decommissioned MOX plant would
permit use of all or part of the facility or site under some form of
control to ensure public safety. A conditional use category is an
interim category that may permit higher residual radioactive contamination
levels than the unrestricted use category (defined next), assuming that
controls to assure public safety can be adequately enforced. The
8-3
enforcement of the controls or restrictions imposed such as
5
physical barriers or signs and other radiation exposure controls,

may require some form of nuclear licensing or zoning laws.
The interim period for the enforcement of the restrictions would
last until the residual contamination has decayed or until additional
decontamination has reduced the radiation to levels that permit
unrestricted use. The intent of such conditions is to ensure that
annual doses to any member of the public using these facilities or
sites would be below the maximum annual dose limit as may be established
for unrestricted use by U.S. federal agencies. While conditional use
categories do not exist in the regulations, such a category could be
defined for some types of nuclear facilities. The maximum annual dose
limit for this category would be the same as for the unrestricted
use category.
• Unrestricted Use - Unrestricted use of the decommissioned MOX facility
and/or site means that the potential exposure to members of the public from
residual radioactive contamination levels attributable to the facility/site
will not exceed the maximum annual dose that may be established by U.S.
federal regulatory agencies. Decommissioning a site will, in 'general,
result in the unrestricted public use of land areas that the public had
been denied use of during the normal operational life of the MOX plant.
No attempt has been made to define all of the possible specific uses
that may fall into each of these general categories. The ability to enforce
the license restrictions required for the first two use categories for long
periods of time requires ongoing surveillance. Each potential use restric-
tion will require its own specific analysis for acceptable contamination
levels. Furthermore, the restriction can best be assured if the responsi-
bility lies with a government agency. For these reasons, the only category
for wMch examples are derived in this study is for unrestricted use of
the ~ecommissioned reference MOX facility and site. The methodology for
, acceptable residual contamination levels for· the decommissioned reference MOX
facility and site are therefore based on the assumption that no member of the
public will receive an annual dose in excess-of the maximum annual dose
established for the unrestricted use category.
8·4
8.1.2 Disposition Criteria
Determination of the disposition criteria for the reference MOX plant is
a procedure that is necessarily linked with other decommissioning
considerations. The relationship between the objectives of this study, site
specific studies, and the disposition criteria methodology is shown in
Figure 8.1-l. The disposition criteria for the reference MOX plant are
calculated using previously developed methodology.(l,l2)
I r-rifAil5ialiiNrictiil.~z----:
I I I
I : I
I
I I
CIUISIIII ~ WllHIN I
SUY SCCIPl I S111DY SCOPE I
I
I t
I
I
I 'I
I
I
I
I
I
I
I
I
I GIIDIC
L------1-------
SI'(CtnC
ACIICIII'UIIIS fOI liSt

CAll-ItS:
•COMiilSSK*ING
....-s
5Nln.-cost
MYSIS
FIGURE 8.1-1. Logic Diagram for the R~lationship of Disposition Criteria

to Reference and Specific Decommissioning Studies
8-5
There are currently no unique regulations or specific guidance on
acceptable annual dose to individuals living on or near a decorrmissioned site.
Guidances that could be interpreted as annual dose limit recommendations speci-
fically for the cases of interest here include:
1. Recommendations of the International Committee on Radiation Protection
(ICRP), Publication g(l 3) c~
i
!
2. Appendix I of 10 CFR 50, Guides for Design Objectives for Light-Water- 1
Cooled Nuclear Power Reactors (NRC)(l 4) ,I
3. 40 CFR 190.10 Environmental Radiation Protection Standards for Normal
Ooerations in The Uranium Fuel Cycle (EPA).(l5) l
I
4. Pro osed Guidance on Dose Limits for Persons Ex osed to Transuranium
Elements in the General Environment (EPA) 16 lI
5. Surgeon General's Guidelines (DHEW){ll) 1
6. "De Minimus" Concentrations of Radionuclides in Solid Wastes (AIF)(lBf

None of the guidance, which provide limits on the dose rate to the public
from nuclear facilities, was proposed specifically for decommissioned property.
Such guidance as is provided however, does suggest different annual dose
I
1
l
limits, or an equivalent to an annual dose limit ranging from annual doses
to the total body of 1 to 500 mrem per year, and from 3 mrem to 3 rem per
!I
year for individual internal organs.

ij
I
It is not within the scope of this study to recommend annual dose limits ~
i.· .I
for the exposure of the public to radioactive materials. References 13 through •I

r!
18 indicate that the annual radiation dose limit uniquely established for the
control of public exposure from decommissioned nuclear facilities will likely
fall in the range of 1 to 25 mrem.(l) Example acceptable residual contamina-
tion levels are calculated for a normalized annual dose of 1 mrem. Selection
of 1 mrem per year is not intended as an endorsement or recommendation for
limiting public radiation exposure from decommissioned nuclear facilities to
this level. It is assumed that any annual dose limit so established will apply
to the maximum annual dose to any organ of reference, thereby assuring that
the applicable regulatory annual dose limit will not be exceeded. When the
8-6
annual dose limit is set by federal agencies, the contamination levels calculated
and reported in this section can be multiplied by the limit (in mrem/yr) to
obtain the appropriate value.
The methodology for the determination of disposition criteria based on
annual dose is shown in Figure 8.1-2. The three steps shown in this Figure
are completed as follows:
• Compute the Maximum Annual Doses - The maximum annual doses to the
organs of reference from radioactive contamination are calculated using
the radiation dose methodology developed in Appendix E. A derivation
of the annual dose equations and listing of the calculated dose values
are found in subsections E.l.5 and E.2.1. The reference radionuclide
inventories used are discussed in Section 7 and developed in detail
in Appendix B. These inventories are also listed in Appendix E to
show the direct relationship between the calculated doses and estimated
radionuclide inventories.
• Compute the Contamination Levels - The residual contamination levels
expressed in units of microcuries per square meter (pCi/m 2) are calcu-
lated for a maximum annual dose of 1 mrem per year to all organs of
reference.
• Determine the Maximum Acceptable Contamination Level - The maximum

contamination level or disposition criteria (for a unit annual dose limit)
is determined by selecting the largest calculated organ dose. This
organ dose is derived from all exposure pathways. This value is
dependent on the composition of the radionuclide inventory and the
exposure pathways, and it represents the maximum acceptable contamination
level.
8-7
~~-~--------~-------------------,
. STEP 1: COMPUTE THE MAXIMLWI ANNUAL

DOSES FOR THE REFERENCE
RAD I ON UCL I DE INVENTORIES
STEP 2: COMPUTE CONTAMINATION LEVELS

THAT PRODUCE THE ANNUAL DOSE
ASSUMED ANNUAL DOSE VALUEOF 1mrem/yr;
ll MIT RANGE OF 1 TO
REPORT IN UNITS OF ~Ci/m2
25 mrem/yr
STEP 3: DETERMINE THE MAXIMUM !

ACCEPTABLE CONTAMINATION I
LEVEL AT 1 mrem /yr. I
USING THE MOST RESTRICTIVE I
I
COMBINATION OF EXPOSURE I
PATHWAYS AND ORGAN DOSES I
(DISPOSITION CRITERIA) I
I
DETAILS FROM Fl GURE 8.1-1 I
---~------- ......... - - - - - - - - - . - . - - - - - - ____ J
FIGURE 8.1-2. Details of the Disposition Criteria

Methodology Based on Annual Dose
8-8
8.2 CALCULATION OF THE ACCEPTABLE CONTAMINATION LEVELS AT THE
DECOMMISSIONED REFERENCE MOX PLANT
The methodology for developing disposition criteria is best demonstrated
by calculating example criteria for the reference MOX facility and site based
on an annual dose of 1 mrem to the maximum-exposed individual.
8.2.1 Acceptable Residual Contamination Levels in The Reference MOX Facility
Example disposition criteria for the decommissioned reference MOX facil-
ity are calculated following the logic illustrated in Figure 8.1-2, and using
the terminology listed previously and in Appendix E. The surface contamina-
tion inventory of radionuclides in the reference MOX facility is derived in
Appendices B and C. Contamination is assumed to accumulate on exposed surfaces
over the entire 10-yea•· operating life of the plant. Surface contamination
.estimates for the reference MOX facility in this study are based on a variety
of assumptions. In actuality, contamination levels are specific to the facility
design and its operating history. Thus, the levels are best determined by
measurements on a case-by-case basis for each facility. It is reasonabl~,
however, to predict the isotopic composition of this contamination. Therefore,
surface contamination levels in this study are normalized to.l pCi/m2 in
Appendix E at each selected time after pl~nt shutdown. The actual radioactivity
levels and isotopic composition encountered in the facility at shutdown are
important in determining the degree of decontamination required; however,
only the isotopic composition is necessary in determining example disposition
criteria.
The residual radioactive contamination levels present during decommissioning
operations are assumed to be known from surface radiation measurements. The
decommissioning operations, discussed in Section 9 and Appendices F and G, are
designed to remove surface radioactive contamination until the radiation levels
are acceptable for the decommissioned state of the facility and site. These
levels, or disposition criteria, for the facility are derived in this section
based on radioactive surface contamination, with the assumption that all
volumetric wastes generated during decommissioning in satisfying the criteria
are disposed of as radioactive wastes.
8-9
For the maximum annual dose calculations, airborne radionuclide concen-
trations in the MOX facility are calculated using a constant.resuspension
factor of 5 x 10-6 m- 1 , as discussed in Section E.l.l of Appendix E. Results
of actual measurements of airborne radionuclide concentrations in decommis-
sioned facilities could alter the example contamination levels calculated
here.
The maximum annual radiation doses to people who would be working in the
released decommissioned facility (Step 1 in Figure 8.1-2) are calculated using
a 40-hour work week and are listed in Tables E.2-3 and E.2-4 in Appendix E.
These tables contain doses calculated for selected organs of reference from
all exposure pathways considered, and 'for all radionuclides that contribute
more than 1% to the total dose. The corresponding contamination levels (Step 2
in Figure 8.1-2) are next calculated for an annual dose of 1 mrem and converted
from pCi/m2 to pCi/m2• These calculated residual contamination levels,
expressed in units of microcuries per m2 of surface contamination (pCi/m2 ),
for translocation Class Wand Y material are shown in Table 8.2-1 for the
total body and other organs of reference at plant shutdown. The dominant
radionuclide contributors to the dose are 238 Pu, 239 Pu, 240 Pu, 241 Pu, and
241Am.
TABLE 8.2-1. Example Acceptable Contamination Levels

Within the Reference MOX Facility at
Plant Shutdown (Unrestricted Use)
Surface Contamination (pCi/m2)

Orga;1 of Trc.nslocation Correspondin~ lo a t1aximum
Referer.ce Class Annual Dose\a of 1 mrem
Total Body w 1.4E-ib)

y 4.0E-2
Lungs ~I £.3E-2
y 2.3E-3
Bone w 7. lE-4
y 1. 9E-3
liver w 1. lE-3
y 3.0E-3
(a) Ingestion pathways from contamination in the released

decommissioned facility are non-existent. +
(b) Notation: Z.Z±Y is equ·ivalent to Z.Z x lo-Y.
8-10
The disposition criteria bdsed on the largest calculated annual dose to
any organ of reference (Step 3 in Figure 8.1-2) are listed in Table 8.2-2 for
Class Wand Y material. At the time of plant shutdown, the disposition cri-
teria are controlled by the predicted maximum annual dose to the bone. The
resulting disposition criteria range between 7.1E-4 and 4.8E-2 ~Ci/m 2 , depend-
ing upon the translocation class considered. If decommissioning is held off
until sometime after plant shutdown, the disposition criteria would actually
decrease by approximately 10% of the values reported in Table 8.2-2. This
effect is due to the buildup of 241 Am, which overrides any radiological decay
of the plutonium isotopes.
TABLE 8.2-2. Maximum Acceptable Residual Contamination

Levels Within the Reference MOX Facility
at Plant Shutdown (Unrestricted Use)
Material Limiting Disposition Criteria (~Ci/m2 )
Translocation Organ of Corresponding to a Maximum
Class Reference Annual Dose\a) of 1 mrem
w Bone 7.lE-ib)
y Bone 1.9E-3
(a) Ingestion pathways from contamination in the released

(b) decommissioned facility are non-existent. +y
Notation: Z.ZE±Y is equivalent to Z.Z x 10- •
The surface contamination inventory of ra~ionuclides derived for the

reference facility in Appendices B and C is assumed to apply to all areas
within the MOX facility except the uranyl nitrate hexahydrate (UNH) area.
In this area, the isotopic mixture for surface contamination is assumed to
consist of natural uranium in the form of UNH and three daughter products
( 231 rh, 234rh, and 234mPa) as discussed in Appendix C. Uranyl nitrate (Class D
material) is soluble in the lungs, and for uranium mrtxtures enriched to less
than 5% by ~eight with 235u, the chemical toxicity to the kidneys from chronic
exposure to uranium is of greater concern than any present radiological
considerations.< 19 , 20 ) For example, in unrestricted areas, the present
8-11
maximum permissible concentration in air (MPCa) for soluble natural uranium
as a chemical toxicant is 4.7 x l0- 12 ~Ci/ml.< 20 ) The MPCa from radiological
considerations would be 1.2 x 10-ll pCi/ml, or about three times higher than
the limit based on chemical toxicity. Further discussion of the chemical
toxicity of UNH is given in Section 11.
Using the resuspension factor of 5 x 10- 6 m- 1 and the dose factors
described in Appendix E, a surface contamination level based on an annual dose
of 1 mrem can be calculated for a 40-hour work week in areas that contain only
UNH. The acceptable surface contamination level is 4 x 10- 3 pCi/m2 for Class D
natural uranium and its daughter products. The critical organ is the bone.
An acceptable surface contamination level can be calculated for Class W
and Y uranium in a similar manner. Based on an annual dose of 1 mrem to the lung,
the accPntable contamination levels for Class Wand Y natural uranium and its
daughters are 4 x 10- 3 pCi/m2 and 4 x 10- 4 ~Ci/m 2 , respectively.
8.2.2 Acceptable Radioactivity Levels on The Reference MOX Site
Information about the levels and nature of the radionuclide contamina-
tion present on the generic MOX site is derived in Appendix B. Disposi-
tion criteria are calculated from the estimated 10-year accumulated
depositions on the site from routine annual releases from production operations.
Airborne concentrations of radionuclides in the plant environs are
calculated using a time-dependent resuspension factor discussed in Section E.l.l
of Appendix E. The radionuclide inventories, showing the 10-year accumulated
ground depositions and the values at each selected decay period, are listed
in Table 7.1-1 of Section 7.
At plant shutdown, these radionuclides are assumed to be ~ixed to a depth
of one centimeter in the soil with no mechanical mixing or weathering effects.
As part of the decommissioning effort, the site is plowed and the radioactive
surface contamination is assumed to be uniformly mixed to a depth of 15 em.
If the site contamination levels are measured to be below the disposition
criteria at the time of decommissioning, plowing is not required as a decom-
H missioning activity. A dry soil .. surface density .. factor of 224 kg per sqtJare
meter mixed to a depth of 15 em (or soil density of 1.49 g/cc} is used to
8-12
determine the soil radioactivity concentration. This factor is discussed in
Section E.l.2.2 of Appendix E. For calculational convenience, the site dispo-
sition criteria calculated here are based on the surface contamination estimates
after plowing (Table 7.1-1 values divided by 15 to account for mixing due to
plowing).
It should be noted that the contamination levels assumed for the site
are probably higher than might actually be encountered at a MOX plant. This
is primarily because no credit was taken in the calculational procedure for
weathering effects on the radioactive contamination either during the 10-year
MOX plant operating life or during the subsequent decay times. For specific
sites, comprehensive measurements will be necessary at the time of production
shutdown to characterize the quantity and mixture of the deposited radio-
active contamination.
Maximum annual doses calculated (Step l in Figure 8.1-2) for the refer-
ence site radionuclide inventory are listed in Tables E.2-5 through E.2-12,
Appendix E. Again, these tables contain the calculated doses for the environ-
mental exposure pathways considered, the organs of reference, and the radio-
nuclides that contribute 1% or more to the total dose. The corresponding
re.sidual contamination levels are calculated (Step 2 of Figure 8.1-2) for an
annual dose of 1 mrem and are listed in Tables 8.2-3 and 8.2-4 for Class W
andY material, respectively. The dominant radionuclide contributors to the
organ doses are 238 Pu, 239 Pu, 240 Pu, 241 Pu, and 241 Am.
The residual contamination levels shown in Tables 8.2-3 and 8.2-4
demonstrate that the critical organ is the bone for intakes of Class Wmater-
ial at all periods shown after shutdown. For ClassY material, the critical
organ at plant shutdown and 5 years post-shutdown is the lungs; for longer
time periods, the bone becomes the critical organ. This analysis assumes the
site is returned to farming and is plowed.
The change in critical organ is primarily due to the relatively short
half-time of Class Y material in the lung, 500 days, and the long-term
accumulation in the bone via translocation from the lungs and via ingestion.
The resuspension factor decreases with t.ime, red,,tcing the quantity of mater-
ial available for inhalation each year. The net result is the buildup of
8-13
TABLE 8.2-3. Residual Contamination Levels on the
Generic MOX Site (Class WMater·ial)
Time After Plant Surface ContaminDt ton (!lCi/m2)
Shutdown Organ of Correspondin1 to a Maximum
(Years) Reference Annual Dose\_~- 1 mrem
0 Total Body 7 .OE-l(b)

Lunqs 8.1E-2
Bone 3.' . '·'
liver 4.2<:-.::
5 Total Body 5.9E+O
Lungs 1.5E+O
Bone 2.9[-1
liver 4.8E-1
10 Total Body 5.8[+0
lungs 3.8E+O
Bone 3.9E-1
liver a. 7E-1
30 Total Body 2.8[+0
lungs 2.1[+0
Bone 1.9[-1
liver 4.1E-1
(a) Surface contamination is assumed to be mixed uniformly to

a soil depth of 15 em during decommissioni~g.
(b) Notation: Z.Z±Y is equivalent to Z.Z x lo-Y.
TABLE 8.2-4. Residual Contamination Levels on the

Gener·ic MOX Site (Class V Material}
Time After Plant Surface Contamination (!lCi/m2)

Shutdown Organ of Correspondin? yo a Maximum
(Years) Reference Annua 1 Dose a of L!!!r!!!!___
0 Total Body 4.2EJ.b}

lungs l.SE-2
Bone 1.9E-1
liver 2.9E-1
5 Total Body 7.1[+0
lungs 2.7E-1
Bone 6.7E-1
Liver 1.6E+O
10 Total Body 5.8E+O
lungs l.OE+O
Bone 6.2E-1
liver 1.7E+O
30 Total Body 2.8E+O
lungs 7.5E-1
Bone 2.8E-1
Liver 7.4E-t
(a) Surface contamtnation is assumed t~ be mixed uniformly to

a soil de~th of 15 em during decommission1~.
(b) Notation: Z.Z±Y is equivalent to z.z x 10 Y.
8-14
radioactivity in the lungs until ~quilibrium is achiev:::d. At that time the
quantity of material in the lungs decreases in proportion to the resuspension
factor. During this time there is still a buildup of radioactivity in the
bone from ingestion of food products and ~~anslocation from the lungs, with
the result being a change in the organ of reference {critical organ) at
10 years after shutdown.
The disposition criteria in units of ~Ci/m 2 {Step 3 in Figure 8.1-2}
are taken from Tables 8.2-3 and 8.2-4 and presented in Table 8.2-5. For
the generic site, the dominant exposure pathway is inhalation. However,
as the resuspended radionuclide air concentration decreases with time due to
weathering, ingestion of food products, if raised on the site, becomes an
important contri~utor to the radiation exposure. The acceptable contamination
levels tend to increase with time {at least to 10 yr1rs after plant shutdown:
due to a decrease in the resuspension factor.
TABLE 8.2-5. Maximum Acceptable Residual Contamination Levels

on the Generic MOX Site at Plant Shutdown and
Selected Times after Shutdown {The Site was
Plowed and all Exposure Pathways are Included)
Material Time After Plant Surface Contamination (~Ci/m 2 )
Translocation Shutdown Critical Corresponding to a Maximum
Class (Years) Organ Annual Dose of 1 mrem
w 0 Bone 3.1E-2(a)
5 Bone 2.9E-1
10 Bone 3.9E-l
30 Bone 1. 9E~ 1
y 0 Lungs 1. 5E-2
5 Lungs 2.7E-l
10 Bone 6.2E-l
30 Bone 2.8E-1
(a) Notation: Z.Z±Y is equivalent to z.z x 1o±Y.
8-15
At 30 years after plant shutdown, the maximum acce~table residual contami-
nation levels tend to decrease. This is due to the continual buildup and
increased dose contribution from 241 Am, while the total radioactivity is
decreasing (primarily due to the decay of 241 Pu, which contributes less than
1% to the bone dose after 30 years post-shutdown).
The calculated disposition criteria, reported in Tables 8.2-2 and 8.2-5
are summarized in Table 8.2-6. For the facility, the radioactivity present
is characteri1ed by surface contamination measurements. For the site, the
surface contaminatio~ values are presented along with radioactivity per unit
mass mixed to a depth of 15 em after plowing~
TABLE 8.2-6. Summary of the Disposition Criteria for the

Reference MOX Facility and Generic Site
Acceptable Residual Contamination

Levels for an Annual Dcse
of 1 mrem/year
Time After
Plant Shutdown
(Years)
Class WMaterial
MOX Facility(a) 0 Bone 7.lE-ic)
MOX Site(b) 0 Bone 3.1E-2 2.1E+O
5 Bone 2.9E-1 1. 9E+l
10 Bone 3.9£-1 2.6E+l
30 Bone 1.9E-1 1.3E+l
Class Y Material
MOX Facil1tyla) 0 Bone 1.9E-3
MOX Site(b) 0 Lung l.SE-2 l.OE+O
5 Lung 2.7£-1 l.BE+l
10 Bone 6.2E-l 4.2E+l
30 Bone 2.8E-1 1.9E+l
(a) It is assumed that the facility disposition criteria will be used to

.detennine the necessary decqmmissioning procedures. All waste generated
during decommissioning procedures is assumed to be shipped to nuclear
waste disposal site.
(b) It is assumed that plowing the site unifomly mixes the radiation
contamination- to-a depth of lS an. A-dry soil surface density factor
of 224 kg/m2 to. a depth of 15 em is used for this conversion.
(c) Notation: Z.Z±Y is equivalent to z.z x 1o±Y.
8-16
8.2.3 Acceptable Contamination Level~s On MOX Facility Equipment
Disposal of much of the contaminated MOX facility equipment after
decontamination is covered by standards developed by the ANSI Committee N328(g)
and the NRc.< 3> The complexities of decontaminating equipment for public
release are great and are briefly explored in Appendix H. Decommissioning
a specific MOX facility wil\ probably require special procedures to dispose
of equipment and some structural materials on a piece-by-piece basis.
8.3 EXISTING GUIDANCE ON RESIDUAL CONTAMINATION

Existing guidance on acceptable contamination levels for the unre-
stricted release of decommissioned nuclear facilities is found in Appendix A
of Reference 3 and A~SI Standard N328. (g) The leve1s 'reflected in these
standards are listed in Table 8.3-1 and 8.3-2. Other guidance that specifically
deals with plutonium can be found to range from 0.01 ~Ci/m 2 to
270 ~Ci/m2 . (4, 6- 8 , 16 , 21 - 25 } However, the referenced guidance is usually
directed toward specific types of nuclear facilities or equipment, or
accident situations. Simce the methodology and dose bases for the example
disposition criteria calculation used in this study are different from those
used in determining these existing guidelines, the criteria do not compare
directly and require careful analysis. Using the maximum annual dose as
the general basis for determining disposition criteria allows more flexibility
in the consideration of various mixtures of radionuclides realistically expected
at decommissioned nuclear facilities.
8.4 MEASUREMENT CAPABILITY

The surface contamination levels given in Tables 8.2-6, 8.3-l, and 8.3-2
for direct measurements can, for the most part, be detected by commercially
available portable instrumentation, at least in low-background locations.
Table 8.4-1 shows nominal detection levels for several typically used
·instruments. However, minimum detection levels for direct surveys with GM-type
instrumentation are generally limited to the equivalent of the background
reading at the survey location (i.e., a detection level of 100 c/m above
a background level of 100 c/m). Minimum.detection levels for direct surveys
8-17
TABLE 8.3-1. ANSI N328 Surface Contamination Limits
Limit (Activity)
dpm/100 cm2
Nuclide To ta 1 -=-Re_mo_v_a..,..b"""le-
Group 1:
Nuclides for which the nonoccupational MPCa(a) Nondetectable(d) 20
is 2 x l0-13 Ci/m3 or less or for which the
nonoccupational MPCw(b) is 2 x lo-7 Ci/m3 or
less; includes Ac-2~7; Am-241, -242m, -243;
Cf-249, -250, -251. -252; Cm-243, -244, -245,
-246, -247, -248; 1-125, I-129; Np-237; Pa-231;
Pb-210; Pu-238, -239, -240, -242, -244; Ra-226,
-228; Th-228, -23Q.(CJ
Group 2:
( ) (e)
Those nuclides not ip Group 1 for which the Nondetectab1e B,Y 200
nonoccupational. MPCala) is 1 x 10-12 Ci/m3 or 2,000(a)
for which the nonoccupational ~1PCw(b) is
1 x 10-6 Ci/m3 or less; includes Es-254;
Fm-256; 1-126, -131, (-l33; Po-210; Ra-223;
Sr-90; Th-232; U-232. C)
Group 3:
Those nuclides not in Group 1 or Group 2. 5,000 1,000
(a)MPCa: Maximum Permissible Concentration in Air appl.icable to continuous

expo~ure of members of the public as published by or derived from an
authoritative source such as NCRP, ICRP or NRC (10 CFR Part 20 Appendix B
Table 2, Column 1.)
(b) MPCw: Maximum Permissible Concentration in Water applicable to members of
the public. ·
(c) Values presented here are obtained from 10 CFR Part 20. The most lin.iting
of all given MPC values (e.g., soluble vs. insoluble) are to be used. 1n
the event of the occurrence of mixtures of radionuclides, the fraction con-
.tributed by each constituent of its own limit shall be determined and the
sum of the fractions must be less than 1.
(d)The instrument utilized for this measurement shall be calculated to measure
at least 100 pCi of any group, contaminants, uniformly spread over 100
square centimeters.
(e)The instrument utilized for this measurement shall be calibrated to measure
at least 1 nCi of any group 2 beta or gamma contaminants urtiformly spread
over an area equivlent to the sensitive area of the detector.
NOTE: Direct survey for unconditional release should be performed in
areas where the background is 5_100 c/m. When the survey must be performed
in a background exceeding 100 c/m, it may be necessary to use the indirect
survey method to provide the additional sensitivity required.
8-18
TABLE 8.3-2. Acceptable Surface Contamination Levels From Appendix A of Reference 3
Radionuclide(a) Average(b,c,f) Maximum(b,d,f) Removab1e ( b, e,f}

U-nat, 235 ij~ 238u and associated
decay products 5,000 dpm a/100 cm 2 15,000 dpm a/100 cm 2 1,000 dpm a/100 cm 2
. 226 228 230
~23nsuran1cs, 227 Ra, 125 Ra, 129 Th
Th, 231pa, Ac, I, I 100 dpm/100 cm 2 300 dpm/100 cm 2 20 dpm/1 00 cm2
~s-nat 232Th 90sr 223Ra, 224Ra,
2u~ l26I, 1~1 I, d3t 1000 dpm/1 00 cm 2 3000 dpm/100 cm 2 200 dpm/1 00 cm 2
Beta-gamma emitters (nuclides with
decay modes other than alpha emis-
sion or spontaneous fission) except
90sr and others noted above 5000 dpm By/100 cm 2 15,000 dpm By/100 cm 2 1000 dpm By/100 cm 2
fa)Where surface contamination by both alpha and beta-gamma-emitting nuclides exists, the limits
00 established for alpha- and beta-gamma-emitting nuclides should apply independently .
....•
\0 (b}As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive mate-
rial as determined by correcting the counts per minute observed by an appropriate detector for back-
ground, efficiency, and geometric factors associated with the instrumentat·ion.
(c)Measurements of average contaminant should not be averaged over more than 1 square meter. For objects
of less surface area, the average should be derived f0r each such object.
(d)The maximum contamination level applies to an area of not more than 100 cm 2•
(e)Th~ a~unt of removable radioactive material per 100 cm 2 of surface area should be determined by wiping
that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount
of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable
contamination on objects of less surface area is determined, the pertinent levels should be reduced pro-
portionally and the entire surface should be wiped. ·
(f) The average and maximum radiation levels associated with surface contamination resulting from beta-gamma
emitters sould not exceed 0.2 mrad/hr at 1 em and 1.0 mrad/hr at 1 em, respectively, measured through not
more than 7 milligrams per square centimeter of total absorber.
TABLE 8.4-1. Detection Capabilities for Direct
Surveys with Portable Instruments
Nominal
Detection Level
Beta-Gamma Emitters uCi/m?
Count-rate meters with thin- 0. 1-l(a)

window GM probe
Alpha Emitters
Count-rate meter with alpha- 0.02
scintillator probe
Portable duel-channel analyzer
with x-ray scintillator probe
(a) Highly dependent on beta energy and total

· nuclide spectrum.
(b) Plutonium in soil.
with portable alpha meters are 200 d/m per detector area. With laboratory
instrumentation and no time limitations, detection levels equal to or less
than 50 d/m for alpha emitters can be achieved.
The capability of measuring the maximum acceptable residual contamina-
tion levels in Table 8.2-2 is dependent in part on the sensitivity of the
instrumentation utilized and the time available for surveying. The latest
scintillation alpha survey meters have the capability to detect as low as
50 d/m per probe area, if the survey is done meticulously. This detection
level corresponds to a contamination level of 4 x 10- 3 ~Ci/m 2 • The dispo-
sition criteria shown in Table 8.2-2 for Class Wmaterial, with bone as
the organ of reference, is 7.1 x lo- 4 ~Ci/m2 or 16 d/m per 100 cm2• Thus,
measurement of disposition criteria for the reference facility correspond-
ing to an annual dose of 1 mrem would be difficult, if not impossible,
using survey instrumentation available commercially.
8-20
Inside generally contaminated spaces, in the presence of large
contaminated equipment items, or over large generally contaminated surfaces,
it may be necessary to resort to indirect survey methods to measure required
release levels. On hard nonporous surfaces, smears or scrapings may be
taken and removed for analysis to a lower-background location or preferably
to low-level laboratory counting instruments.
The contamination levels and limits shown in the tables of Section 8.2
and 8.3 imply that something is known about the history of the material or
the mixture of radionuclides being measured. Sampling for laboratory
identification and the establishment of relationships between portable
instrument measurements and specific nuclide contamination levels are highly
.
desirable even when the characteristics of the contamination are known. It
is absoltltely essential when such preliminary information is lacking.
Sampling techniques for bulk materials such as soils has nearly as many
variations as practitioners. Practicality limits the fraction of any large
area that can be sampled and analyzed. Some fixed scheme is needed for select-
ing sampling stations and the number, size and spacing of sample aliquots at
each location, not only for appropriate statistical inferences but also for
reproducibility and comparability. For soil, the problem is further com-
pounded by the variability of overlying vegetation and of included rock and
gravel. Regulatory Guide 4.5< 26 ) provides one commonly used scheme that is
generally applicable for soil sampling. Adequate sampling of bulk materials
requires sampling to depths of 30 to 100 em in soil, depending on climate and
history.
There is no commonly accepted procedure for translocation of surface
contamination limits to mass contamination limits or vice versa. :However,
with reasonable assumptions as to soil bulk density and the volume of soil
seen by a portable alpha probe, the value of 0.02 pCi/m2, shown in Table 8.4-1,
translates to approximately 0.01 ~Ci/kg or ~10 4 times the lower limit of
detection (LLD) for laboratory analysis in Table 8.4-2. For ~11 radionuclides
in environmental media, sample radioanalysis can provide the sensitivity
required by any of the proposed limits in Section 8.3 or the surface
contamination levels in Table 8.2-6. The cost will depend on whether chemical
8-21
TABLE 8.4-2. Detection Capabllities for Environmental
Sample Analysis a)
lower limit of Detection (llD}(b)
Water Vegetation Soil Air ·(f)
Anallsis {QCilR.} {QCilkg, Wet} {~Ci[kg, Drl} {QCilm3 }
~3Su(c)
2 ·50 30 6 x 10- 5 pg/m3
238 (c) 6 x 10- 5 pg/m3
u 2 50 30
238
Pu(d) 0.1 5 1 0.05 pCi/m3
239
Pu(d) 0.1 5 1 0.05 pCi/m3
240 (d) 0.05 pCi/m3
Pu 0.1 5 1
241
Pu(~) 100 500 200 200 pCi/m3
241Am(d) '1 10 3 0.02 pCi/m3
(a) This table is intend~d .to be comparable to a similar table in

Regulatory Guide 4.8l~~} reflecting current experience at a
commercial radioanalytical laboratory.
(b) The normal lower limit Qf detection is defined in HASl 300,
Appendix D (Rev. 8/74, (31) at the 95~ confidence level. the
lLD for radionuclides analyzed by ga0111a spectrometry will vary
according to the number of radionuclides encountered in envi-
ronmental samples.
(c) Fluorometric analysis.
(d) Alpha proportional counter after chemical extraction. The lLD
for Pu can be lowered by analyzing larger sample sizes and using
the much more expensive analytical procedure involving electro-
deposition followed by alpha track counting.
(e) Liquid scintillation counter after chemical extraction.
(f) lLD based on 300 m3 sample volume and alpha proportional counter.
separation is required and on the length of counting time needed to measure

a particular radionuclide at a given level above instrumental and sample
background.
·scintillation alpha survey meters are not capable of meeting the
deposition criteria presented in Table 8.2-5 for times soon after shutdown.
Large sc~le aerial surveys would also not be able to meet these criteria.
Sampling of soil, vegetation and ground water would be required to assure
8-22
I
compliance with deposition criteria. These samples would be collected based
on a statistical design( 32 ~ to assure deposition criteria are met. Analytical
procedures involve chemical concentration and separ·ation of the nuclide of
interest. Counting of the concentrated samples is done with gas flow
proportional counters or other systems with similar or superior detection
capabilities.
Table 9.4-3 su0111arizes relative advantages and disadvantages for common
methods for determining surface contamination levels. Further discussion of
instrument capabilities may be found in LBL-1. ( 27 ) Further discussions of
environmental survey techniques may be found in ERDA-77-24( 28 ) and NCRP
Report No. 50( 29 >, as well as the health physics literature.
TABLE 8.4-3. Comparison of Measurement Methods for Radiation

Surveys to Permit Unrestricted Use
__________Oi_r~t _ ui sadvanta.9es
Portable Instruments (a) Relatively fast; Limited sensitivity; usually
Relatively inexpell- not nuc l'i de-specific;
sive; Subject to interferences
Readily availdble; from high background and
llble to del incate surface conditions;
"hot spots". r or ,,1 pha and beta emitters,
useful for exposed surfaces
only.
Aerial Survey htrcmelv fast. ll•.efu 1 in qenera 1 for

qarrw11a emitters only;(h)
I rscns it i ve to sma 11 areas.
Smears, so·4pi ngs Avoidance of hi>Jh Not indicative of total

bac~ground inter- activity present; Hiqhly
ference. va.-iable results; Incomplete
cove.,..age of large surfdces~
Not applicable to loo'e or
confined ~~1aterlals.
- with direct field Re 1at i VP 1y f d S t; Not nuclide-specific

count Relatlv<•ly inexpen·
sive.
- with laboratory fludide ldentifica- Relatively slow and expensive

count in9 tion pos~ible (but
more expensive) ;
Greater sensitivity
than direct field
count.
S~E!_i-~g___a.nd U_bor_atory
Anolys is Nuc l ide-sp<:c if i c; Relatively slow;
Higtoly sensitive. Relatively expensive;
Applicable only whf"n sample
of material can be taken to
laboratory; Provides d.lta for
only small part of totnl '.urface.
(a) See Table 8.4-2 for typical examples and detection lPveh.
(b) With special calib>·ations, aerial >;urveys n;ay be useful for lar~e ar~a for
TRU, but not to release levels specified in Section ll.3.
8-23
REFERENCES
1. K. J. Schneider.and C. E. Jenkins, Technology, Safety and Cost of Decom-

missioning a Reference Nuclear Fuel Reerocessing Plant. Report of u.s.
Nuclear Regulatory Commission by Pacif1c Northwest Laboratory, NUREG-0278,
pp. 6-1, 6-3, D-1, D-4, October 1977.
2. U.S. NRC, Termination of Operating Licenses for Nuclear Reactors. Regu-
latory Guide 1.86, June 1974.
3. U.S. NRC, Plan for Reevaluation of NRC Policy on Decommissioning of
Nuclear Facilities. NUREG-0436, March 1978.
4. U.S. Code of Federal Regulations. Title 49, Part 173, "Shippers -
General Requirements for Shipments and Packaging," Superintendent of
Documents, GPO, Washington, DC, 20555, 1976.
5. U.S. ERDA, "Prevention Control and Abatement of Air and Water Pollution,"
U.S. ERDA Manual. Chapter 0510, April 2, 1975.
6. J. W. Healy, A Proposed Interim Standard for Plutonium in Soils.
LA-5483-MS, Los Alamos Scientific Laboratory, Los Alamos, NM,
January 1974.
7. C. E. Guthrie and J. P. Nichols~ Theoretical Possibilities and Conse-
g~ences of Major Accidents in 2~3u and 239pu Fuel Fabrication and
Radioisotope Processing Plants. ORNL-3441, Oak Ridge National Laboratory
Oak, Ridge~ TN 37380, April 1964.
8. A. J. Ha.zle and B. L. Crist, Colorado's Plutonium In-Soil Standard. Colo-
rado Department of Health, Occupational and Radiological Health Division,
Denver, CO, 1975.
9. ANSI Standard N328, Control of Radioactive Surface Contamination on
Materials, Equipment and Facilities to be Released for Uncontrolle~
Use. In Publication for ANSI National Trail and Use.
10. Task Group on Lung Dynamics for Committee 2 of the International Commission
on Radiological Protection, "Deposition and Retention Models for Internal
Dosimetry of the Human Respiratory Tract," Health Physics. Volume 12,
pp. 173-207, February 1966.
11. Committee 2 of the International Commission on Radiological Protection,
The Metabolism of Compounds of Plutonium and Other Actinides. ICRP
Publication 19, Pergamon Press, Oxford, England, May 1972.
12. R. I. Smith, G. J. Konzek and W. E. Kennedy, Technology, Safety and Costs
of Decommissioning a Reference Pressurized Water Reactor Power Station.
NUREG/CR-0130, U.S. Nuclear Regulatory Commission Report by Pacific
Northwest Laboratory, Section 8. June 1978.
8-24
13. Recolllllendations of the International Commission on Radiological
11
Protection." ICRP Publication 9, Pergamon Press, London,_ England, 1966.

14. Code of Federal Regulations. Title 10, Part 50, Appendix I, Licensing
11
of Production and Utilization Facilities," Superintendent of Documents,

GPO, Washington, DC, 20555, 1976.
15. U.S. Code of Federal Regulations. Title 40, Part 190, "Environmental
Radiation Protection Standards for Nuclear Power Operations," Super-
intendent of Documents, GPO, Washington, DC 20555, January 1977.
16. U.S. Environmental Protection Agency, Proposed Guidance on Dose Limits
For Persons Exposed to Transuranium Elements in The General Environment.
EPA 520/4-77··016, September 1977.
17. Surgeon General, U.S. Public Health Service, Surgeon General's Guide-
lines, "Use of Uranium Mill Tailings for Constructive Purposes."
Hearings Before the Subcommittee on Raw Materials of the Joint Committee
on Atomic Energy October 28 and 29, 1971, pp. 52-54, 1971.
18. W. A. Rodger, S. S. Stanton et. al., "de minimus" Concentrations of
Radionuclides in Solid Wastes. AIF/NESP-016, Atomic Industrial Forum
Report by Nuclear Safety Associates, April 1978.
19. R. E. Alexander, Applications of Bioassay of Uranium. WASH-1251,
Directorate of Regulatory Standards, U.S. AEC, June 1974.
20. U.S. Code of Federal Regulations. Title 10, Part 20, Appendix B,
"Concentrations in Air and Water Above Natural Background," Superintendent
of Documents, GPO, Washington, DC 20555, 1977.
21. W. E. Martin and S.C. Bloom, Plutonium Transport and Dose Estimation
Model. IAEA-SM-199/78, Battelle, Columbus Laboratories, Columbus, OH,
November 1975.
22. J. M. Selby, et al., Considerations in the Assessment of the Conse-
quences of Effluents from Mixed Oxide Fuel Fabrication Plants.
BNWL-1697, Rev. 1, Battelle, Pacific Northwest Laboratories, Richland,
WA, June 1975.
23. J. W. Healy, An Examination of the Pathways from Soil to Man for
Plutonium. LA-6741-MS, Los Alamos Scientific Laboratory, Los Alamos,
NM, April 1977.
24. R. L. Kathren, Towards Interim Acceptable Surface Contamination Levels
for Environmental PuOz. BNWL-SA-1510, Battelle, Pacific Northwest
Laboratories, Richl~rJ, WA, April 1968.
25. H. J. Dunster, "Surface Contamination Measurements as an Index of
Control of Radioactive Materials," Health Physics. Volume 8, p. 354,
August 1962.
8-25
26. Directorate of Regulatory Standards, Measurements of Radionuclides in
the Environment- Sampling and Analysis of Plutonium in Soil. Regulatory
Guide 4.5, U.S. Nuclear Regulatory Commission, Washington, DC, May 1974.
27. Environmental Instrumentation Group, Instrumentation for Environmental
Monitoring. LBL-1, Vol. 3- Radiation, University of California, Lawrence
Berkeley Laboratory, Berkeley, CA, 1972.
28. J. P. Corley, et al., A Guide for Environmental Radiological Surveil-
lance at ERDA Installations. ERDA-77-24, U.S. Energy Research and
Development Administration, Washington, DC, March 1977.
29. National Council on Radiation Protection and Measurements, Environmental
Radiation Measurements. NCRP Report No. 50, NCRP, Washington, DC, 1976.
30. Directorate of Regulatory Standards, Environmental Technical Specifications
for Nuclear Power Plants. Regulatory Guide 4.8, U.S. Nuclear Regulatory
Commission, Washington, DC, December 1975.
31. J. H. Harley~ ed., HASL Procedures Manual. HASL-300, Supplement 2,
Health and Safety Laboratory, HASL 300 REV, pp. D-08-01, 02, 03,
New York, NY, August 1974.
32. R. o. Gilbert et al., Statistical Analasis of 239 - 240 Pu and 241 Am Contam-
ination of Soil Vegetation on NAEG Stu l Sites. The Radioecology of Plu-
tonium and Other Transuranics in Oeser·t Environments, NV0-153, June 1975.
8-26
9.0 DECOMMISSIONING ACTIVITIES
As defined in Section 4 (Table 4.1-1), three approaches to decommissioning

a reference mixed oxide fuel fabrication facility have been selected for
evaluation in this study: Immediate Dismantlement, Custodial Safe Storage
with Deferred Dismantlement, and Entombment. An outline of the major
components of a t~aster Decommissioning Plan (MOP) for each of these approaches
is presented in this section, together with discussions of the major work items
in each plan.
9.1 DECOMMISSIONING BY IMMEDIATE DISMANTLEMENT

In choosing to decommission a MOX facility by Immediate Dismantlement,
the owner trades potentia 1 further usc of the fac 11 i ty for the re ., at i ve 1y
rapid release of the site for unrestricted use. The program plan for accom~
plishing the job and the postulated work schedules and sequences are presented.
Dismantlement details are found in Appendix 6.3 of Volume 2.
9.1.1 Program Plan
The dismantlement of a reference MOX facility can be divided into three
general areas of effort: planning and preparation, decontamination, and disas-
sembly and transport. Building demolition and site restoration are not
requirements of the dismantlement mode but, for completeness, are included
in this study. In any job of this magnitude, many of these areas of effort
are going on simultaneously in different sections of the facility. To
minimize conflicts and accidents, a well-defined sequence and schedule for
decontamination and disassembly of the various portions of the plant must be
created and followed carefully. The major activities considered in this
study of dismantling a MOX facility are illustrated in Figure 9.1-1.
It is estimated that approximately 1.6 years are required to dismantle
the facility (not including 7 weeks for building demolition and site restora-
tion activities). Twenty-four months prior to final plant shutdown are
devoted to planning and preparation. The time and work estimates assume
reasonable success, with a minimum of delays and/or major unanticipated
problems.
9-1
PfNOVE CONTAMINAlt
EQUIPMENT AND
MAltRIALS FROM
DRY PROCESS I!'JG AREAS
DECONTAMINAlt
AND REMOVE EQUIPMENT
FROM LABORATORIES,
MECHANICAL AND FAN
ROOMS
END Of DISMANTLEMENT
............ "·······················
/
/
/ ''' '
/
'
--+ DISMANTLEMENT MODE

---+ VIABLE OPTIONS
FIGURE 9.1-1. Sequence of Major Dismantlement Activities
9-2
9.1.1.~ Planning and Preparation
Essential to the results of this study is the assumption that the faci-
lity owner/operator is also the prime contractor of the dismantlement work;
otherwise, a .nore extensive training program would be necessary to aquaint
workers with details of the facility. Approximately two years prior to
final plant shutdown, work begins in the engineering and operations
departments of the parent organization to perform the ~lanning needed to
convert an operating license to a possession-only ~1cense, to plan decommis-
sioning operations, and to receive a decommissioning license. The proposed
sequence and timing schedule for the planning and preparation phase of
decommissioning the MOX facility is illustrated in Fiq~re 9.1-2.
An important part of the planning involves a review of all regulations
ut• and guides applicable to decommissioning. A detaii~ci compilation and review
tl of such regulations has been presented in Section 5 of this report.
~ Included in the regulations are the requirements for preparation of
~; changes 1n technical specifications, deleting thos,e related to plant opera-
tion; preparation and submittal of a decommissio~.ing plan for NRC review
PREPARE DECOMMISSIONINf' PLAN FOR NRC

PREPARE DATA FOR ENVIRONMmTAL IMPACT
ASSESSAt:NT
NRC REVIEW, DECCNMISSIONING LICENSE ISSlfD l
PREPARE TECHNICAL SPECIFICATION REVISIONS -'
PREPARE DETAILED WORK PLANS AND PROCEDURES

DESIGN, PROCURE AND TEST SPECIAL EQUIPAt:NT
SELECT AND TRAIN STAFF
SELECT SPEC IALTV CONTRACTORS
FINAL INVENTORY CLEANOUT INOT CHARGED TO
DFCOMM ISSIONIN; I
t J J I I I I
24 21 18 u 12 9 6 3 0
NDNTHS BEFORE DECOMMISSIONING BEGINS
FIGURE 9.1-2. Sequence and Schedule of the Planning and Preparation

Phase of Immediate Dismantlement
9-3
and approval; preparation of detailed plans and procedures for physical and
chemical decontamination of intact systems; sectioning and disposal of
contaminated glove box equipment; and detailed sequences for equipment and
systems removal. In addition, design, procurement and testing of special
devices and equipment must be initiated during the two-year period before
final plant shutdown to assure that work can proceed without undue delay
after shutdown.
Creation of a decommissioning organization within the pre~ent organiza-
tion is initiated about two years prior to final plant shutdown5 with the
structure and staffing requirements identified, and co!11Tlitments obtained
from key engineering and operating personnel to fill critical positions.
Orientation and training of personnel identified as members of the decommis-
sioning organ~~dtion is carried on during the final year of plant operation.
A suggesten oryanizational structure and staffing requirements are given in
Section 10.1.1.
Selection of the various specialty contractors required for tt1e dismant~e
ment effort h accomplished during the final yea"' of plant operation. The
types of specialty contractors anticipated to be required for dismantlement
of a MOX facility are listed in Section 10.1.5.
Also included in the planning and preparation effort are such things as
· the.shipment of TRU-contaminated wastes to a federal repository, and the
installation of compaction equipment in the facility. Another preparatory
step is the installation of a set of open top tanks in the former ~uel
Fabrication Room to provide a final stage of electrochemical (electropolishing)
decontamination for piping, sectioned glove boxes, tank walls, tanks, valves,
and similar metallic materials thflt have significant salvage value. This
decontamination facility is described in Appendix F.2.6.
The final preparatory step is a comprehensive survey of radiation
dose rates and contamination levels within the facility, taken after final
, inventor,y cleanout and plant shutdown. This survey provides the baseline
data for decisions on chemical and physical decontamination. It also provides
initial data on radiation dose rates and contamination levels likely to be
encountered during the various dismantlement activities.
9-4
9.1.1.2 Final Processing Inventory Cleanout
Upon termination of routine plant production operations, an extensive
inventory cleanout and plutonium audit is conducted. These cleanout operations
are similar to those conducted periodically to audit plutoniurr. or to prevent
cross-contamination between differing isotopic mixtures or bl,ands of fuel.
Cleanout operations are estimated to remove one-half of the residual plutonium
and uranium plant inventory, based on plant experience. Because these clean-
outs are done typically during plant production, they are also considered a
part of normal plant operations in this study and are not charged to decommis-
sioning. Details of the final inventory cleanout and plutonium audit are
found in Appendix G.l of Volume 2. Decommissioning is assumed to start upon
completion of the final cleanout.
9.1.1.3 Decontamination
Decontamination can involve both chemical and physical attacks to remove
radioactive materials. In this plan, major chemicG·. uecontamination is per-
formed in all wet processing areas, and physical decontamination is the major
technique used in all dry and many wet processing areas. The objectives of the
decontamination effort are two-fold: First, to .reduce the contamination
levels throughout the facility in order to minimize potential worker and
potential public exposure during the remaining decommissioning activities;
and second, to attempt to clean contaminated material to levels that either
permit salvage of valuable material or reduce the quantities cf material that
must be packaged and shipped to a deep geologic disposal site (i.e., to
allow more waste materials to be sent to a less·expensive shallow land burial
ground).
For accounting purposes, physical and chemical decontamination generally
follow existing plant procedures for plutonium cleanout. Selected plant
operating personnel are retained to assist in these decommissioning operations.
Records of previous plant decontamination campaigns are reviewed to identify
potenti.al problem areas and to make maximum beneficial use of past plant
experience.
9-5
Since this decontamination campaign takes place just prior to disassembly,
'
damage to the wet processing systems and equipment from the decontamination
solutions is of secondary concern. Chemical solutions are used that remove
the surfaces of the stainless steel in the tanks and piping, resulting in
decontamination factors (OF) of about two to three, a OF factor greater than
can be achieved by noncorroding acid flushes.
For this study, nitric acid combined with hydrofluoric acid is selected
to chemically decontaminate the wet processing areas. The use of this acid in
chemical decontamination is discussed in Appendix F.l.
In the dry processing area, corrosive acids and chemicals are generally
avoided to prevent damage to mild steel equipment, components, electrical
connections, etc., that would later interfere with their disassembly.
Following decontamination, the systems are disassembled. Equipment,
such as glove boxes that cannot be decontaminated internally to meet shallow
land burial requirements, is cut up and decontaminated by electropolishing,
prior to shipment to a shallow land burial site. As described in
Appendix F.2.6, ductwork, valves~ piping, and glove box plate material are
also decontaminated after disassembly in the electropolishing station. Elec-
tropolishing systems have proven to be capable of rapidly removing stubborn
surface contamination to background levels.
In this study, credit is taken for the potential effectiveness of the
electropolishing system in reducing the quantities of contaminated metallic
materials that must be packaged and shipped to disposal. Electropolished
plutonium-contaminated metals are assumed to be decontaminated sufficiently
to allow their disposal in a shallow land burial site. For several reasons,
no credit is taken for reducing plutonium contamination to unrestricted
release levels.·· First, the systems have not been fully demonstrated in the
type of large-scale usage postulated here. Second, the levels of residual
radioactivity that would be permitted on material that is returned to the
commercial stream are not yet defined by any regulation. Studies sponsored
by' the NRC are in progress to develop the bases for the establishment of
regulations in this area, but the outcome of these studies is not yet known.
Therefore, there is no way to confirm that the electropolishing decontamination
9-6
technique can clean material to unrestricted use levels, since these contami-
nation levels are not yet defined. Third, depending upon the allowable levels
of residual radioactivity (when defined), the costs of adequate surveys and
repeated cleanings of the material to get it releasable for unrestricted
use may be greater than the savings achievable through release of the
material. Therefore, in this study, all of the potentially contaminated
material is assum~d to remain contaminated, even after treatment, and is
packaged and shipped to a shallow land burial site for disposal.
Decontamination of the floors, walls, and other surfaces within the
facility structures is accomplished using the standard techniques d~scribed
in Appendices F.l. and F.2. A similar question exists here as did with the
contaminated metals, i.e., what levels of res;Jual radioactivity are allowable
in structural materials that are to be relea~ed for unrestricted use, and how
are these levels monitored for compliance with the standards? For this study,
it is assumed that available measurement techniques determine when the residual
radioactivity on or in the concrete of the structures is less than the allow-
able levels for unrestricted use. (Levels for unrestricted use are discussed
in Section 8.) Removal of the surfaces of concrete walls and floors is a
relatively time-consuming operation. Therefore, the surface removal method
is assumed to remove most of the.contaminated material in one oper·ation,
with repeated operations needed only in isolated instances.
The removal of the contaminated concrete is accomplished in this study
using mechanical (jackhammers, rock splitters) techniques. The removed
contaminated rubble is packaged as radioactive.waste and shipped to a
deep geologic disposal site.
9.1.1.4 Disassembly and Transport
Disassembly and disposal of contaminated and potentially contaminated
equipment and materials is accomplished by the facility's decommissioning
~taff. The initial disassembly work begins in the Shipping and Fina1
Inspection Rooms (Rool'l 121 and 122), the Fuel Fabrication Room (Room 123),
and the Storage Vault (Room 126), as shown in Figure 9.1-3. The Shipping and
Inspection and Storage Vault r·ooms are used to package and store contaminated
wastes being shipped to shallow land burial and deep geologic disposal sites,
9-7
sa.voo WASTE
EXTRACTI00 TREATMENT
r-
+ WET PROCESS
AND SCRAP
+ CHEMICAL
RECC7JERY AREAS DECOOAMINATIOO
[ PLANNING
AND
PREPARA!ION
. FUEL FABRICATIOO, SHIPPING,
AND INSPECTIOO AREAS,
AND STORAGE VAll.T
121,122,123 AND 126
DMY BLEND lNG
ROO\\ 155
PELLET PROCESSING WET PROCESSING

ROOM 124 ROO\\ 128
FUEl FABRICATIOO, SHIPPING SET UP ELECTROPQ.ISHING

AND INSPECTIOO AREAS, INCINERATI 00 AND WASTE
AND STORAGE VAULT PACKAGING AND SHIPPING
ROO't\S 121,122,123 AND 126 STATIOOS
DISASSEMBLY PELLET PROCESSING

AND TRANSPORT RO!Yt\124
lil4 0 5 10 15
DIRTY SCRAP RECOVERY WASTE

ROOM 801 TREATMENT
ROO\\ BIYl
45 50 55
PHYSICAL
DECONTAMINATION
WET PROCESSING CLEAN SCRAP RECOVERY

Roo.ll28 ROOM 127
25 35 40
TIME, ·weeks
PACKAGING AND SHIPPING

OF CONTAMINATED CONCRETE
AND Pli'ING
MAINTENANCE CHEM
ROO\\ 116 SEWAGE LAGOON
Roo.l
LABORAluoK~ MECHANICAL, AIR SUPPLY AND

ROO't\S 129·143 RIXNS 117, 201 AND 2t2
BUILD lf«l DEMOLITION

AND
SITE RESlORATION
65 70 75 80 85 89
l'IME;weeb
FIGURE 9.1-3 Decontamination and

Dismantlement Sequence
For Major Areas in the
MOX Fabrication Plant
9-9
respectively. The electropolishing station is installed in the Fuel Fabrica-
tion Room to take advantage of the ventilation system and the overhead hoist.
The disassembly work sequences are designed to ensure that essential services,
such as plutonium scrap recovery lines, remain in service as long as needed.
As a given section of the facili·+.y is disassembled, the extension of the
essential service, into those areas is removed.
The exact removal sequences and techniques for equipment in a given room
or system is dictated primarily by accessibility and by anticipated personne1
exposures or loss of contamination control during removal. Items that con-
tribute significantly to the general level 0f exposure in the work area are
either removed first. or are placed temporarily in greenhouses or plastic bags,
while the work goes on. Equipment pieces are unbolted and cut into manageable
sections, using an appropriate cutting device (plasma torch, oxyacetylene torch,
or power saw). Piping is cut into lengths compatible with standard-size waste
disposal boxes and within the capability of the electropolishing station.
Similarly, tanks and glove boxes are cut into plate segments appropriately sized
for electropolishing and disposal, except where in situ electropolishing
techniques are employed. For this study, all initially contaminated materials
are assumed to remain contaminated to greater than unrestricted use levels,
even after final decontamination by electropolishing, and are packaged for
disposal as radioactive waste. All electropolished metals are disposed of
in a shallow land burial ground. Nonmetallic contaminated wastes are sent to
deep geologic disposal.
Packaging of contaminated materials for disposal is accomplished in
accordance with DOT regulations published in 49 CFR,~ Parts 173 through 178,
NRC regulations published in 10 CFR, part 71 and Regulatory Guide 7.1.
Containers could be lined with shieltting material if necessary to reduce
surface dose rates to acceptable levels. It is assumed that none of the
contaminated waste shipments from the MOX facility will require shielding.
Shipping of packaged contaminated materials from the facility to a waste
disposal site (shallow land or deep geologic disposal) is accomplished
using trucking compan~es that specialize in transporting special materials.
9-11
The volume of these materials to be transported and the number of shipments
required are estimated in Section 10.1.3, and the costs are summarized in
Table 1o. 1-6.
9.1.1.5 Demolition and Site Restoration
The NRC's responsibility is to ensure that the public is protected from
excessive exposure to radioactivity from nuclear facilities. Once the site
and the facility have been decontaminated to levels that permit unrestricted
use of the property, the nuclear license is terminated and the NRC's responsi-
bilities at the facility and site end. There are no provisions in any
regulations that imply that the decontaminated structures must be demolished
and the site restored to pre-facility conditions. Therefore, demolition and
site restoration are not part of dismantlement and are not required to
complete decommissioning. For completeness, however, the costs and time
required for demolition and site restoration of the decontaminated structures
are estimated in this study, and the costs are included in data presented in
Section 10.
One of the last steps in the demolition of a facility is a comprehensive
radiation survey to ensure that the radioactivity remaining on any material
in the structure is less than the amount allowable for unrestricted use, as
defined in Section 8. Surveys of the surfaces of the site are also required
to ensure that the accumulation of radioactive releases from the operating
reactor during 10 years of operation on the site surfaces is sufficiently
small to permit unrestricted use of the site. Decontamination of portions
of the site (hot spots) is accomplished by removing and packaging a few
centimeters of soil surface or sections of paving material from those areas.
The remainder of the site is plowed to a depth of 15 em ("'6 in.) . .When the
facility and site can be released for unrestricted use, application is made
to NRC to terminate the possession-only or modified operating license.
Once a building's interior is decontaminated and disassembled to levels
of radioactivity that are releasable, as defined in Section 8, it is turned
over to a demolition contractor for removal of the structure (assuming this
option is chosen). Almost no contaminated mater·ial remains in a structure when
it is released for demolition. However, in some instances, contamin>.'c'.ed
9-12
piping or similar material that is imbedded in the concrete structure and is
identified and sealed during dismantling, could be removed during demolition.
All above-grade structures are removed. Below-grade structures are
demolished to at least one meter below grade level, with the base floors
broken up sufficiently to permit normal drainage of surface waters through
these floors. Large quantities of uncontaminated rubble are used in backfil-
ling the below-grade cavities, thus reducing the quantities of fill material
that must be hauled in to complete the site restoration. Uncontaminated
rubble, in excess of that required to backfill the below-grade cavities, is
transported to a local sanitary landfill for disposal.
The amount of effort expended in site restoration is determined by the
planned future use of the site by the owner. For this study, it is assumed
that the land is restored· to a reasonable facsimile of the conditions that
existed before the facility was constructed. Other choices for land use
such as the buildihg of new facilities on the site or the use of existing
structures, would have significant impact on the nature of the restoration
work.
Work performed in this option is by fixed-price contractors. Sufficient
top soil is supplied to adequately cover the back-filled cavities and to
restore the land contours to approximately the condition that existed before
plant construction. Planting of native vegetation on the restored land
surfaces is accomplished to complete the task·of returning the site to approx-
imately its original condition.
9.1.2 Quality Assurance Program
An extensive quality assurance program (QA) is carried on throughout the
decommissioning effort, to assure that all applicable regulations are met,
to assure that the work is performed according to plan, to assure that the
work does not endanger public safety, and to assure the safety of the
decommissioning staff.
During the two-year period prior to shutdown, it is the QA personnels'
job to:
9-13
• review decommissioning plans for quality assurance involvement
• prepare inspection/test procedures as work plans are developed
• review designs of test equipment for quality input
• order any inspection/test equipment required to perform quality
assurance/quality control function
• receive procured equipment, verify acceptance
• qualify suppliers for fabrication of radioactive shipping containers
• prepare inspection/test procedures to be imposed on subcontractors
• prepare inspection plans for shipment of radioactive materials,
containers, trucks, etc.
• finalize formal Quality Assurance Plan.
QA efforts during the··actual dismantlement period involve:

• performing QA functions for procurements
o auditing all program activities
• monitoring performances of specialists, utility operators, laborers,
craftsmen, and health physics technicia/s for compliance with work
procedures /
• verifying compliance of radioactivephipments with appropriate
I
procedures and regulations
• performing dimensional, visual, nonll.estructive examinations, or other
required inspection services to assure compliance with work plans
• maintaining auditable files on the QA audits
• preparing a final report on overall performance of the dismantlement
program with regard to the QA function.
A more detailed review of the anticipated elements of an appropriate Quality
Assurance Program for the dismantlement effort is given in Appendix F.4.
9-14
9. 1.3 Work Schedule Estimates
The proposed overall schedule and sequence of events for the dismantlement
effort, presented in Figure 9.1-3, is based on detailed schedules developed in
Appendices G.2 and G.3. Initial work begins about two years prior to final
plant shutdown, with 1) preparation of a decommissioning plan for NRC approval,
2) preparation of the revisions to the facility technical specifications
necessary to change from an operating license to a possession-only license,
3) preparation of the data needed to make an assessment of the environmental
impact of the dismantlement work, 4} preparation of detailed work plans and
procedures for accomplishing the dismantlement of the facility, 5) design,
procurement and testing of all special equipment needed for dismantlement, and
6} selection and training of the personnel for the decommissioning staff.
Following cessation of production, a final inventory cleanout and
plutonium audit is conducted to tenninate operations and to obtain NRC
approval to proceed with decommissioning of the facility. Any recovered
plutonium and uranium products are shipped to offsite locations.
Initial decommissioning efforts center around the physical and
chemical decontamination of the contaminated areas within the facility.
Dismantlement begins with the Fuel Fabrication Room (Room 123), where all
but the equipment needed fO\' installation and operation of the electropolishing
station is removed, and generally progresses from the dry processing zones
into the wet processing areas, as shown in Figure 9.1-3. Physical decontami-
nation and disassembly can progress in parallel, as indicated in the figure.
Removal of the MOX buildinq, backfilling, grading, plowing and land-
scaping of the site completes dismantlement. As can be seen in Figure 9.1-3,
about 1.6 years of effort is required after plant shutdown to complet~ the
dismantlement effort.
9.1.4 Essential Systems and Services
-.
'
Certain of the facility systems and services must remain in place until
all radioactive and/or contaminated material have been removed from the site,
t~ assure that no significant quantities of radioactive or hazardous materials
are released to the environ~. Also, certain of these systems are needed to
9-15
facilitate the cleanup and disassembly efforts. As areas within the facility
are readied for demolition, the extensions of these services into those
areas are deactivated and removed, while maintaining continuity of the services
to the remaining work areas. The required support systems, together with the
justification for retaining each system, are listed in Table 9.1-l.
TABLE 9.1-l. Systems and Services Required During

Immediate Dismantlement
Svstens or Coag!onents Justification
Electrical polll!r, including emergency Requir!!d for HVAC, lighting and radiation moni-
diese I backup sys tell! toring
HVAC Systems Required for ventilation and ct>ntamination
confinement
Environmental Survelllance and Safe· Required to identify and quantify any releases
guards Program of radioactivity to the environs from dislllntle-
ment acttvitles,and to identify and safeguard
any Significant q~antltles of plutoniutll dis-
oovered during diSI!IIntlement
water Supply (service and dllllllstic Required for decontamination, cleanup,
systems) fire protection, anel 1eneral potable water usage
Fire Protection System (direction and Req~ired for health and safety
suppress ion)
Compressed Air Systems 'control and Required for operation of pneumatic control!.
suppression) for operation of pneumatically operatell too s
In-plant eon.a.nications Systems (tele- Required to facllitate and coordinate acU•,iUes
phones and intercoms)
Radiation Monitoring Systems Required for protection of personnel
Solid and liquid Contaminated Waste Required for treatment and disposal of potentially
Systens contaminated liquids and solids
Clean Scrap and Dirty Scrap Recovery Required for recovery of plutonilllll from liquid and
Systell$ incinerated wastes
Sewage Treatnoent Plant (septic tanks and Required for s-ge treatment
s-ge lagoon)
Essentially the sa~e environmental monitoring program carried on

during plant operation is continued during the dismantlement period. This
program is to identify and quantify any releases of radioactivity to the
surrounding areas resulting from the dismantlement activities. The proposed
program, detailed in Appendix F.5, is sufficient to permit evaluation of any
significant releases. For emergency situations involving radionuclide
releases from events such as fires or malicious acts that may necessitate
( prompt emergency action to minimize the risk to the public, additional
n short-term surveillance efforts may be added.
9-16
9. 1. 5 Security
Protection of the public (often against the consequences of their own
actions) is an important dimension of the security program-throughout the
decomissioning effort. Security during decJmmissioning is assumed in this
study to be similar to, but less than, tnat needed during plant production
operations. Security during the Interim Care period following Custodial
Safe Storage is modified and is discussed further in Section 9.3.3.
9.2 DECOMMISSIONING BY CUSTODIAL SAFE STORAGE

The goal in the Custodial Safe Storage mode for the decommissioning of
the reference mixed oxide fuel fabrication plant is to ach_ieve, with a modest
expenditure of effort, a condition that ensures >hat the safety of the public
is not endangered by the residual radioactivity at the site. Modifications
to the facilities are limited to those that ensure the security of the
buildings against intruders and those required to ensure containment of
radioactive or toxic material. The Custodial Safe Storage mode allows deferral
of the decision regarding final disposition until no further use is found
for the plant. To achieve this goal, the facilities are left structurally
sound. loose contamination and some equipment are removed. Glove bo;~
ports are sealed, and access into the building is limited. All systems anct
equipment that are not required to be in operation during the su~veillance
and maintenance period are deactivated. The preparations for safe storage
and the period of interim care that follows should be recognized as only
interim stages in the total decommissioning process. Current NRC philosophy
encourages a decommissioning approach ~~at ends in the termination of the
facility's nuclear license and the release of the property for unrestricted
use within a finite period of time. Thus, dismantlement or decontamin~tion
to de minimus levels is required eventually.
The major benefits gained from decommissioning the facility by the
Custodial Safe Storage mode are: l) postponement of irrevocable decornmis~
sioning activities, 2) reuse of the facility by the company if so desired,
and 3) low initial outlay of funds.
9-17
The Preparations for Safe Storage, when complete, confine all remaining
contamination and place the facility in a condition amenable to routine
surveillance and maintenance but generally unavailable for any other use.
Work sequences and procedures are presented in this section to achieve this
goal. These sequences and procedures are developed under the assumption
that the physical activities commence irrmediately fo11.:;wing plant shutdown
and the final operational inventory and cleanout operations.
The Custodial Safe Storage period may vary from a few years to a few
tens of years, depending on such variables as:
• societal concerns
• the risk to the safety of the public
• the occupational radiation dose commitment
• the cost of further decommissioning efforts
• the needs and desires of the facility owner.
It is estimated, based on detailo~ work plans, that approximately
12 months (from the time of initiat·on of physical decommissioning activities
for Preparations for Safe Storage} are requ·ired unti1 the facility enters the
period of Interim Care. Interim Care consists primarily of security, sur-
veillance and maintenance. Eighteen months prior to final plant shutdown
are devoted to planning and preparation. The time and work estimates assume
reasonable success with a minimum of delays and/or major unanticipated problems.
9.2.1 Program Plan
The Preparations for Safe Storage in the facility are generally divided
into five major phases:
• planning and preparation
• mechanical and chemical decontamination
• equipment deactivation
• isolation of contaminated areas
• final preparations for Interim Care (surveillance and maintenance).
In various facility locations, portions of these phases may overlap or
proceed concurrently. When these activities are completeds the facility is
placed under continuing surveillance and maintenance.
9-18
Th~ activities used to place the reference MOX plant in Custodia1 Safe Storage
include:
• chemical decontamination of the solvent extraction area, wet processing
area, clean and dirty scrap recovery areas, wall storage tanks, and the
liquid waste treatment system
• physical decontamination and removal of accessible contamination in the
rest of the facility, including exhaust ductwork, HEPA filters,
and gloves
• sealing all glove ports in the glo~e boxes and installing fresh
HEPA filters
• offsite disposal of radioactive and nonradioactive wastes in approved
repositories
• sealing or locking of entryways to prevent access into contaminated
areas
• operation and maintenance of protective systems, such as ventilation,
radiation detection, intrusion detection, and fire detection and alarm
systems, as well as electrical lighting and power distribution systems
• periodic surveys and inspections of the facility and site.
The final plant condition is one where most of the transportable radio-
activity is either removed or confined, and radioactivity is generally
thinly spread throughout the facility. The overall work schedule est~mates
developed for this study are given in Section 9.2.2.
The MOX plant building and fenced areas listed in the Custodial Safe
Storage decommissioning plan are kept in the re~tricted-use category, as
defined in Section 8. Restricted access is possible for maintenance and
routine inspections by authorized personnel, in accordance with the require-
ments ·of 10 CFR 20.103. The surveillance, maintenance, and security of the
MOX building and site are subject tG the provisions detailed in Sections
9.3. 1, 9.3.2, and 9.3.3.
Activities at the site during the Interim Care 1eriod that follows
Preparations for Safe Storage are limited primarily to operation of the
9-19
building vent~lation and utility systems, maintenance, building maintenance
and radiation monitoring of the facility, environmental radiation surveillance,
and security. The facility is manned by operations staff on a continuous
basis after being placed in Custodial Safe Storage. Periodic surveillance
and maintenance of the facility structures and of passive safety and security
related systems are also required. The outer perimeter site fence is main-
tained and no unauthorized entry is permitted. Detailed accounts of the
decommissioning operations are stored at the facility and made a part of the
public record. These accounts are required for use when final dismantlement
of the facility is performed.
9.2. 1.1 Planning and Preparation
The planning and preparation activities for Custodial Safe Storage are
carried out concurrently with the final 18 months of facility operation.
Figure 9.2-1 shows the time sequence work begins for the planning and prepara-
tion phase of decommissioning in the Custodial Safe Storage mode. Work begins
in the engineering and operations departments of the company organization to
prepare the analyses and documentation needed to convert the operating license
to a possession-only license following final plant shutdown.
PREPARE DECOMMISSIONING PLAN FOR NRC
PREPARE DATA FOR ENVIRONMENTAL IMPACT ASSESSMENT
NRC REVIEW, DEC()'w1MISSIONING LICENSE ISSUED

PREPARE TECHNICAL SPECIFICATION REVISIONS
PROCURE AND fiST SPECIAL EQU IPMEN1

SElECT SPECIALTY CONTRACTORS
FINAL INVENTORY CLEANOUT (NOT CHARGED r01

DECOMMISSIONING)
18 15 12 9 6 3 0
MONTHS BEFOP.E DECOMMISSIONING BEGINS

Phase of Custodial Safe Storage
This phase incl~Ades a.ll the activities required to prepare for Custodial
Safe Storage. Included in the requirements is the need for preparation of
changes in technical specifications (taking into consideration monitoring
requirements and specifications for equipment that must be maintained and
deleting those related to facility operati·;ln) and guidance for the preparation
and submittal of a MOP for NRC review and .approval. A detcr.iled compilation
and review of regulations and guides appl·icable to deco111n~ssioning is given
in Section 5, 11 Regulatory and Safeguard Considerations ... In addition, design
procurement and testing of any special dt:!Vices and equipment are initiated
during the 18-month period prior to fina·l plant shutd!own, to assure that work
can proceed without undue delay after shutdown.
Creation of a decommissioning orgarlization withir, the company is initi-
ated, with the structure and staffing rf~quirements id•.:mtified, and commitments
obtained from key engineering and operating personnel to fill critical posi-
tions. Orientation and training of personnel identified as members of the
decommissioning staff are carried on during the fina.l four months of plant
operation. The decommissioning staff draws on thei1r own experience anc'J on
the experience of the operations staff to assist in tht~ planning activities.
Before the plant is shut down, a ft!DP and safe'ty analysis report is
prepared, detailed working procedures atnd safety requirt~ments are developed,
and cost estimates are made. A variety of predecommissi:oning activities are
carried out as part of plant shutdown o~perations. These activities incl,Jde
reduction of inventories of bulk quantities of pr·ocess chemicals and nonessen-
tial materials and equipment, plutonium inventory cleanout and accountability,
and an engineering review of effluent control and safety systems that are
necessary for decommissioning.
The MOP, includit'lg overall deco111nissioning criteria ami- wo.rk.- 'tQ.It;~
is divided into manageable tasks, and av,ilab1.:..~tt•tontilg ·techniques
are carefully reviewed and deti$:.iOrtJ- ~-Lt'ftidt' Oft the general techniques
to be used to ~~~mp,l.tlft-u~rt task. Detailed procedures are developed,
ineluitng tftlte. ·fOr predeconrnissioning cleanup and product removal from the
facility. Equipment and material requirements, manpower estimates~ and work
schedules are prepared. The plan is documented in detail, necessary safety
9-21
analysis reports are prepared~ and all appropriate documents are submitted
for approval of plant management and regulatory agencies.
It is assumed that most of the planning and the actual decommissioning
activities will be performed by plant operating and maintenance personnel.
The various specialty contractors required for the decommissioning effort
are selected during the final four months of plant operation. The types of
specialty contractors required to place the facility in Custodial Safe Storage
are listed in Section 9.2.4.
Final preparatory steps to decommissioning are confirmation of radio-
active materials inventories and the comprehensive survey of radiation dose
rates and contaminated areas within the facility, taken. after plutonium
inventory cleanout and plant shutdown. This survey provides baseline data
needed for making decisions on: l) chemical and physical decontamination,
2} areas or equipment needing safeguarding or special attention to reduce
potential personnel exposure, and 3) ways of avoiding a nuclear criticality
incident. In addi' ;~m, a comprehensive radiation survey of the site will be
performed.
In many ways, the decommissioning activities fol~pwtryJ'.Jll.trft'$ih'ata~)Wn
to a
for Preparations for Safe Storage are ini~tt,,.,J:f~1 -W,l'OIDfAi normal, well-run
plutonium-inventory cleanolr~ tJ!d:!-4~1>::.··~rtng decommissioning, it is highly
important to .r.~9,1!tij~:-~f~·~oia···a~eas where additional manpower is required
and. t~.~-"!:·Nt'tP·f6f.~'that manpower. Such arrangements should include contractual
~tfat1ons ( Lc1v<fng incentive pay}, support facilities (such as shop areas
and eating facilities}, training, indoctrination, and any special qualifica-
tions for individuals retained.
9.2.1.2 Fin~l Processing Inventory Cleanout
Upon termination of routine plant production operations, an extensive
inventory cleanout and plutonium audit is conducted. These cleanout operations
are similar to those conducted periodically to audit plutonium content or to
minimize cross-contamination between differing isotopic mixtures or blends
of fuel. Based on plant experience, cleanout operations are estimated to
remove one-half of the residual plutonium and uranium plant inventory. Because
9-22
these cleanouts are done typically during plant production, they are also
considered a part of normal plant operations in this study and are not
charged to decommissioning. Details of the final inventory cleanout and
plutonium audit are found in Appendix G.l of Volume 2. Decommissioning
is assumed to start upon completion of the final cleanout.
9.2.1.3 Facility Decontamination
During the planning and preparation stage, procedures and results from
prior plant cleanup efforts are reviewed to obtain maximum benefit ft~om
previous experi~nce. Current as-built drawings are reviewed to identify
system piping deadlegs and other potential plutonium inventory areas and to
facilitate planning of system modifications required to achi$:v.~ Jj!$!QQyt~.~!l1h
nation. Existing procedures are reviewed for appl 't::t.bAi"lt·ty to t:htt, J'lrese~t
effort and modified as necessary. A tt•·t•·1·lt4.·~~tep .."by:;..step procedure is
developed for the decontanrhHtt•1tJ.m ~·~rnpafgn, with check lists for valve settings,
etG •• to .••,~~- lt~GpG"r operation of the systems.
' "'>' .
"t ". ··'t· '
;; . . · : ' ·'·•'!''it~'itility decontamination begins immediately after the final production

inventory cleanout. Initially, the comprehensive plant decommissioning
radiation survey is completed and facility housekeeping is accomplished.
Unnecessary noncontaminated equipment, chemicals, and materials are removed
and inventories of flammable articles are reduced to minimum levels.
Contamination outside glove boxes that cannct be readily removed is fixed
in place by painting over the contaminated area with a water-based coating.
Radiation warning signs are affixed near the painted areas. The location
and characteristics of each such area are noted in the permanent records of
the decommissioning operation. Decontamination of the glove boxes·and
individual rooms is accomplished as outlined in Appendices F.l. and G.2
of Volume 2.
Selected decontamination activities may proceed concurrently. The
primary concern is to ensure that no recontamination of clean areas occurs
and that air leaving a given area flows through the existing facility filter
system or, in the case of liquid effluents, through the existing contaminated
waste system. The equipment/systems are isolated as indicated in Section
9.2.1.4.
9-23
All liquid radioactive wastes generated during decommissioning operations
are sent to the plant 1iquid waste system. The 1iquid wastes are pt'Ot;~:;<;~4
through the waste concentration and cementing so 1idi fk~tJon All
systems designed to control the release . of httlQt'~Of~U!~ tr1~tetia'l to the environ-
ment, or to noncontaminattd, ptJI"''t1"0tV~ <tf .t'he faci 1i ty, are in operation during
the physical an~ <i.Mt~1~~.J decontamination activities And associated waste
f:H'fltt:tfk·~·~:"l~ ·1'~ t·adiation dose rates and contamination 1evel s expected to
" J,' ,•
b~ present in the facility prior to decontamination operations are described
in Section 7 and Appendix C.

In the complex glove box systems of the MOX plant, the Decontamination
Factor (OF) may vary up to factors of 10 or greater. For this study, an
"average" conservative OF of 2 has been assumed. The effectiveness of the
physical and chemical decontamination as measured by the OF is expressed here
as the ratio of the original quantity of radioactivity to that present after
decontamination.
In general, decontamination of glove boxes, dry processing equipment,
floors, walls, and other building surfaces is accomplished using direct
worker contact decc~tamination techniques. Most areas are cleaned using
simple "janitorial" techniques such as vacuuming, handwiping, sweeping or
scrubbing with organic or detergent cleaning agents that are compatible
with the waste treatment system. Acid-proof sponges soaked in decontaminating
solutions are used on small areas where chemicals are effective. Large or
complex internal glove box areas are decontaminated using a portabl~ variable
pressure decontaminating solution sprayer. Steam cleaning is used to
decontaminate one large mild steel glove box.
In the decontamination of glove box systems and equipment, priority is
given to radioactivity "hot-spots'; to aid in the recovery of plutonium, to
reduce background radiation levels, and to minimize potential personnel radia-
tion exposure. Radiation dose level, accessibility, and the pot::ntial for
radiation exposure during decontamination influences the selection of "hot-spots"
to be decontaminated first. In general, these selections are field decisions
baseu on the comprehensive radiation survey results.
9-24
Decontamination of Ventilation Systems. The exhaust ductwork from
glove boxes is decontaminated as required. Decontamination procedures
used during plant operations for inventory cleanout are generally followed.
Examples of the techniques used are given in Appendix G.2.1. It is expected
that the decontamination effort will use mechanical vibrators, rotating brushes
and swabbing techniques to remove plutonium, uranium powders, dir·t and grease
from ductwork. The intermediate HEPA filters {i.e., the first stage beyond
those at the exit of each glove box) are replaced after these activities.
Final stages of HEPA filters are replaced only if replacement is required due
to damage or high pressure drop.
Liquid Waste Handling. Final treatment of chemical solutions generated
during decontamination is accomplished via the existing plant evaporation
and concreting solidification systems. The final waste incorporated into
concrete is packaged at the concreting station for transport and disposition
offsite.
t·;~chanicalDecontamination and Fixing of Residual Contamination. Mech-
anical decontamination of structures, such as rooms, hallways and corridors,
is carried out only in areas that contribute significantly (i.e., ~5 mR/hr)(l}
to the radiation exposure of surveillance and maintenance personnel. Drilling
and rock splitting or jackhammering are two of the methods used to decon-
taminate these areas. The contaminated materials that are removed are packaged
and either shipped to a burial site or are temporarily placed in the storage
vault (Room 126), until ready for offsite shipment. Combustible materials
are packaged and shipped offsite for disposal. Typical mechanical removal
techniques are described more fully in Appendix F of Volume 2.
Some residual amounts of low-level plutonium or uranium contamination
may be present in areas outside the isolated areas. These areas typically
contain amounts of radioactivity that do not contribute significantly to
occupational radiation exposure levels in the facility unless inhaled. This
contamination is immobilized by covering it with paint or other protective
coatings to prevent the contamination from becoming airborne.
Final Preparation for Interim Care. Final preparations for Interim
Care of the MOX facility include the following items:
9-25
• installing and/or upgrading of plutonium san.·ol ing and moni taring
systems and radiation alarms
• installing or relocating intrusion alarms
• installing high-security locks on or spot welding selected exterior
and interior doors
• performing a comprehensive radiation survey.
9.2.1.4 Equipment Deactivation and Isolation of Corltaminated Areas
Essential safety systems, such as ventilation, lighting, utilities,
radiation detection alarms, security monitors, and fire detection and
portable fire fighting equipment, remain in operation during
..
the Interim Care
period. All other equioment and systems are placed in a condition that
provides maximum safety with m·inimum maintenance. When possible, equipment
is left in a condition that permits startup or salvage at a later date.
Deactivation and isolation techniques include closing and securing ~nstalled
valves, sealing glove ports, installing blank flanges and disconnecting electri-
cal power and other uti'lities. Equipment deactivation procedures are
coordinated with facility decontamination operations. A safety audit of all
systems is performed to ensure that all flammable and other potentially
hazardous materials have been removed. All deactivated equipment and systems
are tagged for identification and status.
The particular method used to deactivate each system or p~ece of equipment
is identified during the planning phase. In general, all systems not necessary
to prevent the spread of contamination are deactivated. (See Section 9.2.3
for systems retained.) All equipment, valves, circuit breakers, etc., are
tagged when dedctivated. These tags identify the piece of equipment, the
system it is in ar.d its condition.
The first step in equipment deactivation is a safety audit of all pumps
and pipes used for radioactive materials or chemicals to ensure that hazardous
or corrosive materials have been removed. Electrical service is disconnected
from all pumps not required to be in operation during the Interim Car~
(surveillance and maintenance) period.
9-26
Systems inside the MOX bui1ding are deactivated by a variety of methods.
Many piping systems are isolated using the installed valves, with handles or
valve operators removed. Pipes that lead from uncontaminated to contaminated
zones are blanked where flanges are readily accessible. Some uncontaminated
systems are drained and left open to the atmosphere. All cranes are disabled
by removal of their circuit breakers to prevent their unauthorized use during
the surveillance and maintenance period. Other electrical equipment that
should not be operated during the Interim Care period is disabled in a similar
manner. Electrical service is disconnected from instrumentation not required
to be in operation during the surveillance period.
Portior.s of the facility sections containing significant amounts of
plutonium contamination are isolated by the installation of high-security ·locks
on entryways or by spotwelding of doors. Indirect access routes, however
unlikelyt are investigated from as-built drawings and secured. Such routes
may inchide, but are not limited to, access through ventilation ductwork,
roof plugs or pipe trenches that could allow trespassing, willful or other-
wise. Temporary barriers are constructed and warning signs erected to
block potential pathways for unauthorized entry. Metal doors are secured by
welding them to the metal door frame. Spot welds are used when the intent
is to m~ke the door inoperative.
9.2.1.5 Disposal of Radioactive ~·1aterials
Wastes generated during Preparations for Safe Storage include HEPA and
roughing filters, solidified decontamination liquid wastes, and trash. All
these wastes are assumed to be packaged and shipped to a federal repository
for deep geologic disposal.
HEPA and Roughing Filters. One half of the 0.2 x 0.2 m (8 x 8 in.) HEPA
and roughing filters attached directly to glove boxes (mostly from the dry
processing areas) are assumed to be processed through dirty scrap recovery
during decommissioning by being cut up in a shearing device, calcined and
leached with the residue discarded as noncombustible waste. Approximately
half of the intermediate filters are assumed to be treated in the same manner
9-27
after the exhaust ductwork has been decontaminated. Roughing filters and HEPA
filters from the room air ventilation a~d Exhaust Air Fan Room systems are
packaged for disposal in stee1 boxes.
Solidified Decontamination Liquids. Oecont~mination liquids, including
those from electropolishing, are assumed to be processed by evaporation, with
the residues being solidified by incorporation into cement. Solidified decon-
tamination liquids are packaged for disposal in 208-£ (55-gal) steel drums.
Trash. Trash is essentially all other kinds of radioactive waste that
is generated. It consists of contaminated equipment, tools, rags, wipes, etc.
All trash is packaged for disposal in 208-£ (55-gal) steel drums.
9.2.1.6 Interim Care Activities
Surveillance activities for each portion of the facility begin as soon
as Preparations for Safe Storage have been completed. These activities include
operation of the ventilation system, routine inspection, preventive and
corrective maintenance on safety systems and a regular program of radiation
and environmental monitoring. In addition to these routine tasks, a compre-
hensive inspection of the facility is performed semiannually by qualified
professional third-party inspectors. Any unusual or potentially unsafe
condition detected during the surveillance program is corrected immediately.
The surveillance and maintenance programs are structured so that personnel
inspect various portions of the facility on a routine basis. Radiation
monitoring will be done at each pre-establis~ed surveillance point at least
nanth!y. These checks will be staggered so that the monitoring actually takes
place over severa·l days, distributed throughout the month. Preventive
maintenance activities and routine equipment inspections are also distributed
throughout the quarter. HEPA-filters, warning signs, and physical barr:ei~
are insp~~te:ci routinely a,,d repaired as necessary. The fire alarms, radiation
alarms and intrusion alarms oper·ating in the facility during thl surveillance
period are monitored continually at the site. Routine inspections of these
systems that were performed by outside experts during plant operation continue
on a reduced frequency in Custodial Safe Storage.
9-28
9.2. 1.7 Quality Assurance
An extensive quality assurance program, as described in Section 9.1.2,
is carried on throughout the decommissioning pffort to assure that the work
does not endanger public safety, to assure the safety of the decommissioning
staff, and to assure that all applicable quality assurance and quality control
regulations are met.
9.2.2 Work Schedule Estimates
A proposed overall schedule and sequer.ce of events for Preparations for
Safe Storage is presented in Figure 9.2-2. Initial work begins with planning
and preparation about 18 months prior to final plant shutdown. The activi-
ties and schedule for this time period are presented in Section 9.2.1.1 and
Figure 9.2-l, respectively.
Following planning and preparation, decommissioning begins with a more
extensive facility cleanout than was conducted for the final plutonium audit
and inventory cleanout. Decommissioning progresses from the more contaminated
zones in processing areas to the supporting areas, such as the laboratories,
the ma~ntenance room, and the exhaust ventilation system. As each area is
decontaminated, it is decommissioned as far as possible and prepared for the
Interim Care r~riod. The solvent extraction system, the wet processing area,
and the clean and dirty scrap recovery areas are chemically decontaminated,
while the dry processing areas are physically decontaminated.
As seen in Figure 9.2-2, about 12 months of effort is estimated to be
required after plant shutdown to complete Preparations for Safe Storage.
Specialty contractors are employed as required to perform unique services
during both the active decommissioning phase and the Interim Care period.
Table 9.2-1 shows the principal contractors for both periods.
9-29
WASlE
~Alll£COHTAMINATION
FUEl FABRICATION, SHIPPING,

ANO INS l>tCTI ON AREAS
PLAMiiNG AND STORAC£ VAUlT,
ROOMS 121-lZ3, 126
I
AND i
PflfPARATIOI.': DRY BLENDING
ROOM !55
f ' --·--"-··~-·----.---
!"'J.lETPROCESStllG. llifl~ie>'i>'11G
i l ROOM 124
"---..l,, _ _ _ _-...JL-..J..-..J..------·-•···•·
--.!1* I
. -··· ·-· I
PHYSiCAL DECONTAMINATION
WET Clf:MISTR~
DRY III.IJII!IIil(. AND COUNTING Li'BS MAINTENANCE CHECK SAF£TY
\D
I
AND UNHI~~
ROOMS ~~---
ROOM~ 129 AND 1341 ~ROOM 116 SYSTEMS. SECURE ENTRY
POINTS, INSTALL
w LABORATORIES W~Slt MISCELLANEOUS
r INTRUSION
0
•. I ..... · - I I
ROOMs 1»-m.
135-143
TREATNENT
ROOM 802
1. IJFH:crssARY
·YSltMS
.1',
""' :~ICAL
I ::~:L
I -.. fr
____
ALAR~. rn:. FINAL clf:cK-;..t!T OF
SAI'ETY, SECUR.TY
I.ND OPERATING
SYSltMS
..----...;-------..--------........ ----...--~............ ---.- I ,_--,
·U 0 5 10 IS .i!!i 25 30 35 40 45 50 52 55
'IIIU S AFTER PLANT SHUTDOWN
-FIGURE 9.2k2.
- Sequence and Schedule
Areas in the MOX Fuel
~f Activities for
f~ication Plant
Preparations for Safe Storage for Major
TABLE 9.2-1. Specialty Contractors Utilized During Decommissioning
by Custodial Safe Storage
Freparat :ons for Safe _ __
S~.?:;.;.r=ag;o,;;;e Interim Care Period
Hauling contractors, for transport of packaged Environmental surveillance as described in
radioactive waste materials from the facility Appendix F.5.
to authorized disposal site.
Quality assurance as described in Appendix F.4.
Temporary maintenance support, provide craftsmen
and other supporting services during routine or
emergency repair of operating equipment.
The criteria for services are established during bid solicitation and
remain as requirements during the job. Although the nature of the work
dictates varying requirements, contractors should be raqu1rel'J, as a minimum,
to:
• scope the job eht.td·Of time to enable adequate :;reparation
• provide their own equipment, tools, etc.
• if working on a critical path item, be capable of completion on
schedule of that item.
To ensure that no radioactive or hazardous materials are released to
the environs, certain of the facility system and services must remain in
place until radioactive and/or contaminated materials are either chemically
decontaminated, fixed in place, or removed and packaged. Also, certain of
these systems are needed to facilitate the cleanup and Preparations for Safe
Storage efforts. These systems are identical to those required for Immediate
Dismantlement, as described in Section 9.1.4, and are not repeated here. As
areas within the facility are readied for the Interim Care period, the exten-
sions of these services into those areas are deactivated and secured as
required by Preparations for Safe Storage procedures, while maintaining con-
tinuity of the servic:e to the remaining work areas.
9.3 INTERIM CARE FOR CUSTODIAL SAFE STORAGE

Activities at the site duri119 the Interim Care period that follows
Preparatior•s for Safe Storage are 1imited primarily to venti.lation and
9-31
services operations, security, building and equipment maintenance, radiation
monitoring of the facility, and environmental radiation surveillance.. l~
facility is manned on a continuous basis after being pla\~ed 11'1 Custodial
Safe Storage. Periodic survei lla.nce end mtit:littfH!trtte of the faci 1i ty
structures and of activ~. ifHt, pat~·iVtl t&f'ety and security related systems are
requir~d. The GU'ItiiY ptr1meter site fence is maintained and no unauthorized
~.ntry. h. permitted. Detailed accounts of the decorrmissioning operations
are stored at the facility and made a part of the public record. These
accounts are require~ for use when final dismantlement of the facility is
performed.
The facility is divided into five major sections for the purposes of this
plan. These are:
• processing areas
• laboratories
• support areas (fan and mechanical rooms, etc.)
• offices (security, lunch room, lockers, lavatories, etc.)
• facility site. (a)
9.3.1 Surveillance and Maintenance Activities
The surveillance and maintenance programs are structured so that personnel
inspect various portions of the facility on a routine basis. Radiation
monitoring is done at each pre-established surveillance po'int at least monthly.
These checks are staggered so that the monitoring actually takes place over
several days, distributed throughout t:1e month. Preventive maintenance
activities and routine equipment inspections are also distributed throuQhout
the Interim Care period. Warning signs and physical barriers are inspected
routinely and repaired as necessary. The venti1~tioil system, electrical
distribution system, fire alarms, radiation alarms and intrusion alarms
operating in the facility during the Interim Care period are operated and
(a}The site is surveyed and any areas outside the exclusion area found to
have contamination levels greater than those permitted for unrestricted
use, as defined in Section 8, are assumed to be decontaminated by approp-
r~ate means. Within the exclusion area, contamination levels may exceed
unrestricted use levels but the radioactivity is made nondispersible.
9-32
monitored continuously. Routine inspections of these systems that are
performed by outside experts during plant operation continue on a reduced
frequency in Custodial Safe Storage.
9.3.2 Environmental Surveillance Program
A somewhat abbreviated version of the environmental monitoring program
conducted during plant operation is carried out during the Interim Care
period. This program's purpose is to identify and quantify any releases of
radioactivity to the environment. The surveillance program will be adequate
for evaluating most potential nonroutine or accidental releases. For
situations involving releases from events such as fire or malicious acts
th~t may require prompt emergency actions to minimize public risk, special
surveillance requirements would be added. This program is discussed in more

detail in Appendix F.5.
9.3.3 Security
The protection of the public, principally against the consequences of
their own actions, is an important dimension of the security program used for
the Interim Care period following Preparations for Safe Storage. Conventional
security detection and itotification systems normally used to protect the
utility against loss or damage are augmented by audible alarms. These a1arms,
strategically located outside secured radiation zones, loudly warn an intruder
of his potential danger. Silent sensors simultaneously alert onsite and
offsite security personnel.
Routine patrol checks are carried out by onsite guards. In addition,
the services of a reputable private security agency is contracted to ensure
adequate surveillance during non-day-shift hours and prompt response to
alarms. Liaison with local law enforcement agencies is maintained and their
assistance· is called for only when necessary.
Security is provided during the Interim Care period by two basic methods:
onsite guards and security systems. An onsite guard and lock on the fence
around the decommissioned facility provide the first line of defense. The
fence is maintained in good condition throughout the surveillance and main-
tenance period. Facility security is maintained at all times by installed
9-33
intrusion alarms and high-security locks on exterior doors that are not spot
welded. Intrusion, fire, and radiation alarms are monitored continuously by an
onsite security guard during the day shift. Depending on the situation indi-
cated by the alanms, offsite security agency personnel are available to
respond immediately when assistance is required.
Physical security to prevent inadvertent radiation exposure of surveil-
lance and maintenance personnel is provided by multiple-locked barriers. The
presence of these barriers makes it extremely difficult for an unauthorized
person to gain access to areas where radiation or contamination is present.
The facility manager and onsite guard are responsible for controlling
authorized access into and movement within the facility. The facility manager
is further charged with the responsibilities of appropriate actions and noti-
fications regarding breaches of security, upkeep of plant surveillance and
maintenance progra.as. He is also charged with administrative reporting of
these e·vefits, as required by state and federal regulations.
9.3.4 Quality Assurance
A modest quality assurance program, as described in Section 9.1.2, is
carried on throughout the Interim Care period to assure that the surveillance,
security and maintenance work does not endanger public safety or the safety
of the decommissioning staff. This program also assures that all applicable
quality assurance, quality control, and record-keeping regulations and
requirements are met.
The support systems requiring surveillance and maintenance during the
Interim Care period are listed in Table 9.3-1. These systems remain in
operation throughout the Interim Care period. These systems, in combi1ation
with inherent facility structural integrity, provide the primary means for
minimizing the release of hazardous material to the environment. The
equipment in these systems is inspected and renovated to ensure adequate
equipment reliability before the surveillance and maintenance period begins.
In addition, the intrusion alarm system w~thin the facility and on the
perimeter fence are both modified to pr'ovide offshift surveillance capability
by a commercial security agency.
9-34
TABLE 9.3-1. Systems and Services Required During the Interim
Care Period of Custodial Safe Storage
Systems or Components Just1ficat1t.~n
Electric power and e~~~ergency po.er are: 1111tntainl'd for ven-

Nort~~~~l
tilation systems, radiation MOnitoring sys~ and
alams, for lighting circuits, for fire P.rotection
systems and ahnns, and for surveillance 1110nttor-
in9 systems and alanns. Switchboards are aligned
so that no electrical po~«~r is fed to deactivated
systems.
Fire Protection System Portable fire extinguishers remain at selected
(detection and suppression) locations and fi1e detection systems remain in
operation as required for safety.
In-plant Communication Systems Required for nonmal communication.
Ra~tation Monitoring Systems Radiation monitors and alanns remain in operation
at strategic locations throughout the facility
sections. The locations of some devices may be
installed to ensure that important areas are
adequately covered. Selected monitoring programs
are also continued.
HVAC Systems The ventilation system remains intact and in
operation during interim care. Fan systems are
maintained and repaired as necessary. HEPA filters
are monitored continuously and chang~J if necessary.
Security Systems On~tte security guard. Also, security devices and
alarms (provided with both normal and backup emer-
gency power) are maintained by a security agency
subcontractor. In ~~~1t1on to intrusion system
monitoring and maintenance, it ~s postulated that
the security agency responds appropriately to
onsite security personnel.
9.4 DECOMMISSIONING BY DEFERRED DISMANTLEMENT

As defined in Section 4, Deferred Dismantlement is the final stage of
decommissioning when Custodial Safe Storage is utilized. The faciJj_ty and
site must be shown to have residual radioactivity levels sufficiently low
to permit unrestricted use (as defined in Section 8) when dismantlement is
complete.
The same basic operations are performed during Deferred Dismantlement
as were performed during Immediate Dismantlement. The primary chemical and
J
physical decontamination done for Preparations ·for Safe Storage will not
need rep~ating. A modest amount of additional manual decontamination and
cleanup effort is performed in the interior of the glove boxes to collect
loose smearable contamination that may have moved during the. Interim Care
period. Some sealed areas will need to be unsealed. The same disassembly
and cutting techniques and contamination control methods are required. An
electropolishing station and a trash compactor are still assumed to be
used. For auditing and accounting purposes, all the systems have to be
9-35
disassembled and measurements for plutonium made on the surfaces of the
equipment and components. Differences in uranium and plutonium radiation
levels will generally be negligible for the Interim Care period. For no
more than 30 years, there is a modest increase in radiation dose, due to
the ingrowth of 241 Am from 241 Pu.
It is anticipated that a new staff will be needed for Deferred Dismantle-
ment. fhe hiring could be done by the facility operator or the decommissioning
contractor. Extensive training and familiarization of the decommissioning
staff with the facility will be necessary, because of loss of personnel from
the operations staff during the extended period of Custodial Safe Storage.
Additional effort will be required to restore some services needed for
dismantlement and to remove the various welded enclosures, doors, locks, and
temporar~' barricades used to secure the facility from unauthorized entry
during Custodial Safe Storage.

In view of the considerations given above, it is reasonable to assume
that a work force of the same size as was utilized in Immediate Dismantlement
will be required for Deferred Dismantlement, and over approximately the
same time period. Essentially, the same volumes of contaminated and uncon-
taminated materials must be removed and transported to an authorized burial
site, except for those materials removed during decontamination for Preparations
for Safe Storage. The items that will increase the costs of Deferred Di~)mantle
ment with respect to Immediate Dismantlement are the labor costs associated
with training a decommissioning staff, restoring services needed for dismantle-
ment, and cleanup of smearable loose contamination in the glove boxes.
9.4.1 Program Plan
As discussed above, the same basic plan is required to dismantle the
MOX plant,_ regardless of when the dismantlement takes place. The program
~lan outlined for Immediate Dismantlement in Section 9.1.1 is assumed
to be valid, except for the decontamination done during Preparations for
Safe Storage.
g..36
The work schedule estimates are essentially the same as shown in
Figure 9.1-2 and discussed in Section 9.1.3 for Immediate Dismantlement.
Before dismantlement operations begin, additional training of decommission~ng
staff, restoration of some services, and removal of welded doors and temporary
barricad~s will be required. These activities are not expected to take the
place of dec~ntamination performed for Preparations for Safe Storage.
9.5 DECOMMISSIONING BY ENTOMBMENT

fhe goal in the Entombment mode for decommissioning the reference mixed
oxide fuel fabrication. plant is to achieve a condition that ensures the
safety of the public is not endangered for an extended period of time
(>>100 yrs).
The major benefits gained from decommissioning the facility by the
Entombment mode are: 1) low initial outlay of funds, 2) low radiation dose
to workers, 3) low initial potential hazard to the public, and 4) use of the
remainder of the site by the company if so desired.
Activities for Entombment of the facility are generally divided into
five major phases:
• planning and preparation
• decontamination and transfer of contaminated equipment
• equipment deactivation and isolation of contaminated areas to
be entombed
• placement of foundation grouting and entombing concrete
• burial of concrete monolith in earthen mound.
In various facility locations, these phases will overlap or proceed concur-
rently. Upon completion of these activities, the facility is placed under
continuing surveillance and maintenance for as long as institutionally pos-
sible.
The heavily contaminated rooms of the facility are completely encased in
concrete to ensure ~ong-term containment of radioactive or toxic materials
~-37
(and to secure the structure against all but the most determined intruder).
Entombment is considered in this study to be a final decommissioning step,
though it may be possible to dismantle the entombed structure. The site is
considered to be dedicated in perpetuity to the co~t4inment of radionuclides
and toxic materials and in this sense can be likened to a deep geologic
disposal site. Entombment as postulated in this study does not require even-
tual dismantlement or site (the area occupied by the entombed facility)
cleanup to de minimus levels. (See Section 4.1.2 for further discussion of
the definition of and rationale for Entombment).
Based on detailed work plans, it is estimated that approximately 34 weeks
are required to entomb the facility. Another four weeks are needed to bury
the concrete monolith in a protective earthen mound. ~The time and work
estimates assume reasonable success with a minimum of delays and/or major
unanticipated problems.) Eighteen months are devoted to planning and prepara-
tion for Entombment, prior to final plant shutdown.
9.5.1 Program Plan
Activities used to place the reference MOX plant in Entombment include:
e spray painting of all contaminated surfaces in the areas to be
entombed
• pressure grouting of floors and foundations
• physical decontamination and transfer of contaminated equipment and
materials into the areas to be entombed
• sealing of old and cutting of new entryways into contaminated areas
• drilling of concrete pour holes
• modifications of exhaust air systems
• concrete entombment of the facility
• offsite disposal of radioactive and nonradioactive wastes in
approved repositories
• periodic inspaction and survey of the entombed structure
• burial of concrete monolith in an earthen mound.
9-38
The final plant condition is one where the concrete entombed structure
is buried beneath at least four meters of compacted soil. Native grasses are
planted on the gently sloped surface of the mound. The earthen mound is
dedicated as a "permanen•" radionuclide repository. The mound is inspected
periodically and its access restricted for as long as institutionally possible.
9.5.1.1 Planning and Preparation
The planning and preparation activities for Entombment are carried out
concurrently with the final 18 months of facility operation. Figure 9.5-1
shows the time sequence work begins for the Jlanning and preparation phase of
decommissioning in the Entombment mode. The planning and preparation phase
for Entomttnent is essentially identical to that for the Custodial Safe Storage
mode, as given in Section 9.2.1.1.
9.5.1.2 Final Processing Inventory Cleanout
Final processing inventory cleanout operations for the Entombment mode
are identical with those for the Custodial Safe Storage mode given in
Section 9.~.1.2.
PREPARE DECOMMISSIONING PlAN FOR NRC
PREPARE DATA FOR ENVIRONMENTAL IMPACT ASSESSMENT I
NRC REVIEW, DECOO.WISSIONING LICENSE ISSUED
PREPARE TECHNICAL SPECIFICATION REVI<;JONS
PROCURE AND TEST SPECIAL EQUIPMENT
SELECT SPECIALTY CONTRACTORS I
FINAL INVENTORY CLEANOUT !NOT CHARGED TOI 1----------;

DECOMMISSIONING)
. _ __ _. , _ _ t_ __..t_ _ _"--1--.L~..-_--L.I_,_ __.
18 15 12 9 6 3 0
MONTHS BEFORE DECOMMISSIONING ~(;INS

Phase of Entombment
9-39
9.5.1.3 Facility Decontamination
During Entombment of the reference MOX facility, decontamination and
disassembly operations are kept to a minimum.
In the planning and preparation phase, procedures and results from prior
plant cleanup efforts are reviewed to obtain maximum benefit from previous
experience. Current as-built drawings are reviewed to identify exhaust system
or piping deadlegs and other potential plutonium inventory areas and to facili-
tate planning of any system modifications required to spray paint and disas-
semble systems. Existing procedures are reviewed for applicability to the
present effort and modified as necessary. A detailed step-by-step procedure
is developed for this modest decontamination and disassembly campaign, with
check ~ists for equipment and instruments to be used, etc., to ensure proper
op~ration of all systems.
Spray painting and decontamination t~erations begin immediately after the

final production inventory cleanout. Initially, the comprehensive plant
decommissioning radiation survey is completed and facility housekeeping is
accomplished. Unnecessar·y noncontaminated equipment, ..:hemicals, and mateti~1s
are removed and inventories of flammable articles are reduced to minimum
levels. Contamination outside glove boxes in the area to be entombed is
first fixed in place by spray painting over the contaminated area with a
nonflammable water-base coating. The inside of glove boxes, equipment, and
individual rooms are next spray painted. Contaminated equipment lying out-
side the entombment area is spray painted, disassembled and transfer·red to the
entombment area as space permits. Radiation warning signs are affixed near
the painted areas. The location and characteristics of each such area are
noted ·in the permanent records of the decorrvnissioning operation. Additional
details regarding these decommissioning activities are provided in Volume 2,
Section G.4.
Selected decontamination activities may proceed concurrently. The pri-
mary concern is to ensure that no recontamination of clean areas occurs and
that air leaving a given area flows through the existing facility filter
system. Any liquid radioactive wastes generated during deconmissioning
9-40
operations are cemented using the w~ste solidification station. Ali systems
designed to control the release of hazardous material to the environment, or
to noncontaminated portions of the facility, are in operation during decom-
missioning operations.
Decontamination activities, necessary in the areas to be released for
unrestricted use, are accomplished using direct worker contact decontamination
techniques. These areas are mostly cleaned using simple "janitori&l" techni-
ques such as vacuuming, hand wiping, and sweeping or scrubbing with cleaning
agents that can be solidified in cement at the waste solidification station.
For areas where surface cleaning is not satisfactory, such as contaminated
concrete walls, drilli.ng and rock splitting or jackhammering techrt.~lues are
used to remove the contaminated concrete. All contaminated materials genera-
ted at this point are packaged for burial within the entombed portion of the
facility. Typical mechanical removal techniques are described more fully in
Appendix F of Volume 2.
9.5.1.4 Equipment Deactivation and Isolation of Contaniinated
Areas to be Entombed
(ssential safety systems, such as ventilation, lighting, utilities,
radiation detection alarms, security monitors, and fire detection and portable
fire fighting equipment, are kept in operation as long as possible before
Entombment. All other equipment and systems in the areas to be entombed are
deactivated and placed in a condition that provides maximum safety during
entombment activities. Deactivation and isolation of e~uipment include~:
closing and securing installed valves, sealing and reinforcing glove ports,
installing blank flanges, and disconnecting electrical power and other
utilities. Equipment deactivation procedures are coordinated with facility
decontamination, disassembly, and entombing operations. A safety audit of all
systems is performed to ensure that flammable and other potentially hazardous
materials are properly packaged and disposed of (generally within the portion
of the facility to be entombed). All deactivated equipment and systems are
tagged for identification and status.
The particular method used to deactivate each system or piece of equip-
ment is identified during the planning phase. In general, all systems not
9-41
necessary to prevent the spread of contamination are deactivated. (See
Section 9.5.3 for systems retained.) A11 equipment, va 1ves, circuit breakers,
etc., are tagged when deactivated. These tags identify the piece of equipment,
the system it is in and its condition.
The first step in equipment deactivation is a safety audit of all pumps
and pipes used for radioactive materials or chemicals to ensu~e that hazardous
or corrosive materials have been removed. Electrical service is i1nmediately
disconnected from all equipment not required to be in operation during Entomb··
ment.
In the areas where contaminated equipment and materials are to be disas-
sembled and removed for entombment, the air supply systems remain intact. The
contaminated laboratory hoods, glove boxes and associat0d exhaust ductwork ay
spray painted and disassemb'led in a greenhousl~ and trans·ferred to the entomb·
ment area. The assoc1ated room walls,.floors and cei'ling are then decontami-
nilted, spray painted and released for unrestricted use. Contaminated materials
generated during these operations are either cemented ir or placed in 208-9-
(55-gal) drums for eventual entombment.
When the MOX facility is ready to be entombed, existing doorways and
accessways are plugged with reinforced concrete. New accessways are provided
where necessary to allow transfer of equipment and personnel access. Details
of these efforts are provided in Sections G.4.5 and G.4.6. The old entries
from the basement (including air exhaust ducts into the mechanical tunnel)
are plugged after a new entryway is cut in the ea~t wall of the tunnel. When
the basement areas are filled with concrete, new entries are cut through the
cinderblock curtain ~1lls between the various rooms to be entombed and the old
main-floor access doors, and the corridor between Rooms 124 and 126 is plugged
with concret~. Concrete is then placed in 30.5-cm (1-ft) lifts until the
facility is completly entombed. The old bituminous roof is then removed and
a 61-cm (2-ft) reinforced concrete Wirand cap is placed over the entire
entombed structure. Wirand provides an extremely tough and durable top to the
final structure.
9.5.1.5 Disposal of Radioactive Materials
Wastes generated during Entombment inc·iude HEPA and Rougling filters,
solidifi~d contaminated liquid wastes and miscellaneous trash. All these
wastes, except the final HEPA filters in Room 201 and some minor amounts of
contaminated trash generated during the final stages of Entombment, are placed
in boxes or steel drums· and entombed within the facility. Room 201 HEPA and
Roughing filters and a small amount of contaminated trash are packed in steel
boxes and shipped to a f~deral repository for deep geolog·ic disposal.
9.5.1.6 Quality Assurance
An appropriate quality assurance program, as described in Section 9.1.2,
is carried on throughout the decommissioning effort to assure that the work
does not e~danger public safety or the safety of the decommissioning staff.
This program also assures that all applicable quality assurance and quality
control regulations are met.
A proposed overall schedule and sequence of events for Entombment is
presented in Figure 9.5-2. Initial work begins w·ith planning and preparation
about 18 months prior to final plant shutdown. The activities and schedule
for this time period are presented in Section 9.5.1.1 and Figure 9.5-l,
respectively.
Following planning and preparation and final inventory cleanout, decctn··
missioning begins with spray painting and decontamination and transfer of
outlying contaminated equipment to the area to be entombed. Foundations and/
or main and basement floors ot the building are pressure-grouted to enable
them to withstand the increased weight of the entombing concrete. New access-
ways are cut and old entryways are plugged in preparation for concrete place-
ment. The facility is then entombed in concrete, covered with a protective
61-cm cap of Wirand concrete and finally buried in an earthen mound.
As Figure 9.5-2 shows, about 34 weeks of effort are estimate~ to be
required to complete Entombment, following plant shutdown. An additional
4 weeks are required to bury the entombed structure with earth.
9-43
PlANNING ANIJ PREPMATION
SPRAY PAINT CONTAMINATED ARE'S
DEI'~ONTAMINATt AND TRANSFER EQUIPMENT
PRESSURE GROUT Eilt'TOMBMENT AREA

CUT EAST ACCESS DOOR TO MECHANICAL TUNNEL
PLUG NlRlH DOOR TO MECHANICAL TUNNEL
EXCAVAlE FLOOR DRAINS
MODIFY AIR EXHAUST SYSTEM ...,..._.
PREPARE ACCESS 10 FIRST-FlOOR ENTOMBMENT AREA ......
PLUG FIRST-FLOOR ENTOMBM~NT EXITS ~
DRill POUR HOLES OVER BASmENT AND 1N .C.OOF _,..

POUR CONCRETE IN BASEMENT ~
POUR CONCRETE IN FIRST-FlOOR ROOMS

CAP ROOF WITH WI RAND CONCRETE ~
F'CKAGE AND SHIP CONTAMINATED MAHRIALS 1---t

DECONTAMINATE SITE
J.._____, ;J..._ __..L_,' - _ _,___ ___.__
......
n c s ro 15 20 25 JJ 35
TIME. weeks
FIGURE 9.• -2. Work Scheduj~ ~stimate for Entombing the Reference
r~ox Fac~ 1i ty
9.5.3 Essentia; Systems and Services

Specialty Contractors are employed as required to perform unique services
dur·;ng both t~e active decommissioning phase and the surveillance period.
Table ~.5-l shows the principal contractors for both periods.
TABLE 9.5-l. Spt:cialty Contractors Uti1ized During Entombment
Service
Foundation a:1c F1ocr Grouting Determines need for reinforcinq

Consultant and Contractor foundations and floots to support
weight of entor.~i.•s structure
Concrete and Concrete Equipment Supplies concrete and concrete
Supplier and Contractor moving and placement equipment at
facility site
Transpor~ Contractor Hauls puckaged radioactive waste
from facility to authorize0 dis-
posa 1 site
Earth Hauling anC! Bliri3l Contractor Budes entombed structur·E: with
earth and establishes cover o•
native grasses
Environmental Surveillance Periodically inspects earth mound
Contractct· and grnss cover, and ascertains
the effects of weathering upon
the earthen mound
9-44
The criteria for services are established during bid solicitation and
remain as requirements during the job. Although the nature of the work indi-
.,
cates varying requirements, contractors should be requir~d, as a minimum, to:
• scope the job ahead of time to enable adequate preparation
• provide their own equipment, tools, etc.
• if working on a critical path item, be capable of completion on
schedule of that item.
To ensure that no radioactive or hazardous materials are released to
the environs, certain of the facility system and services must remain in place
until radioactive and/or contaminated mater als are either decontaminated,
fixed in place, or removed and kaged. A 0 certain of these systems are
3
needed to facilitate the cleanup entombrnent efforts. The systems needed

during Entombment are presented in Table 9.5-2. As areas withlrg the facility
TABLE 9.5-2. Systems and Services Required During Entombment
Systems or Components Justification

Electrical power, including emergency Required for HVAC, lighting and radiation moni-
diesel backup system toring
HVAC Systems Required for ventilation and contamination
confinement
Environment~] Surveillance and Safe- Required to identify and quantify any rEleases
guards Prograrr• of radioactivity to the environs from dismantle-
ment activities and to identify and safeguard
any significant quantities of plutonium dis-
covered during dismantlement
Water Supply (se:·vice and domestic Requir.._j for decontamination, cleanup,
systems l fire protection, and general potahle water usage
Fire Protection System (direction and Required for health and safety
suppt·ession)
Compfessed Air Systems (control ~nd Required for operation of pneumatic controls,
suppression) for operation of pneumaticdlly operated tools
In-plant C<lnwra.mications Systems (tele- Required to facilitate and coordinate activities
phones and intercoms)
Radiation Monitoring Systems Required for protection o;- personnel
Contaminated Waste Solidification Required for treatment and solidification of
Station potentially contaminated 1iquills and sol iois
Sewage Treatment Plant (septic tanks and Required for sewage treatment
sewage lagoon)
9-45
are prepared for entombment and are entombed, services to the areas are indi-
vidually eliminated as required. Those services needed in the remaining work
areas are maintained or established as required.
9.5.4 Environmental Surveillance Program
A periodic environmental monitoring program is conducted to ensure that
the earthen mound with its grass cover remains intact. Some additional
stabilization of the mound may be required in the distant future to ensure
that the concrete structure remains isolated from the effects of weathering.
It is anticipated that a pattern of wear-bars will be established on the
earthen mound to allow the accumulative effects of weathering to be determined.
Twice a year the grid will be checked to determine those effects. If necessary,
remedial actions will be taken to prevent exposure of the concrete monolith.
9-46
REFERENCES
1. U.S. Nuclear Regulatory Commission! T~rmination of Operating License for

Reactors. Regulatory Guide 1.86, p. 1.86-2, June 1974.
9-47
10.0 DECOMMISSIONING COSTS
This section presents estimates of manpower and material requirements,

waste disposal requirements, and costs for decommissioning the r·eference small
MOX fuel fabrication plant. Cost estimates are made for Immediate Dismantle-
ment, Preparations for Safe Storage, Interim Care, Deferred Dismantlement,
and Entombment. The costs are based on decommissioning procedures developed
in detail in Appendix G and summarized in Section 9. Costs are included for
direct support and decommissioning worker labor, equipment and materials,
contaminated waste packaging, transportation and disposal, utilities and
other miscellaneous owner expenses, and specialty contractors. All costs
are in 1978 dollars.
The basic cost estimates presented in this section assume relatively
efficient performance of the decommissioning activities. A 25% contingency
is added to the cost estimate totals as an allowance for unforeseen problems
or scheduling delays that may arise during the decommissioning. The total
costs presented are therefore believed to be representative of actual
expenses that would be incurred to decommission the reference facility using
the methods described in this report.
10.1 COST ESTIMATES FOR IMMEDIATE DISMANTLEMENT

The estimated costs for Immediate Dismantlement of the reference small
t~OX plant are summarized in Table 10.1-1. Immediate Dismantlement is
estimated to require about 1.6 years {plus two years for planning and prepar-
ation) at a cost of approximately $7.7 million.
Manpower costs inc~ude both support staff and decommissioning workers
and represent about 66~~ of the total cost of Immediate Dismantlement. In
Table 10.1-1, manpower costs are shown separately for the planning and
preparation und the decommissioning phases of Immediate Dismantlement. These
costs include onsite labor for packaging radioactive waste materials for
shipment. Labor costs related to radioactive waste transportation are
included in waste management costs since transportation is performed by a
specialty contractor.
10-1
TABLE 10.1-1. Summary)of Estimated Immediate Dismantlement
Costs,a
Cost 1n MillioQs of Percent of
Cost Ca te.gor .t 197H Dollarslb) To•.a 1
,.;..,r>power -
Planning and Preparation 0. 703 11.3
Decorrrn Iss I on i ng 3.382 '..4.6
[Quirmerot and Supplies 0.879 14.?
Disposal of Rarlioactive Material 0. 577 9.3
Mi see J 1ar1eous Owner l xpense 0.484 7.8
\pecialty Contrattors c. 112 2.H
Subtotal 6.197 100. \J
('> Contingency 1. S49
Total Decou1nissioning
Cost~ !.7
Structure Demolition
and Site Restoration 0.1
Total Cost~ Including
Site Restoration 7. fl
(a) S•m111ary does not include the cost of packaging and disposal to shallow land burial
of the sludge from the sewage lagoons that would add an addltional SO. 75 ~ill ion
in waste disposal and contingency costs.
(b) Number of fiqures shown i~ for computational ilccuracy and does not imply precision
to the neare~t thousand dollars.
Waste management accounts for about 9% of the total cost of Immediate

Dismantlement. Waste management costs include shipping container costs,
transportation charges, and fees for waste disposal at commercial shallow
land burial sites or at a federal repository for deep geologic disposal.
Container costs, transportation charges, and disposal fees are all significantly
higher for wastes shipped to deep geologic disposal than they are for wastes
sent to shallow land burial. For Immediate Dismantlement, if all radioactive
wastes except the sludge from sewage lagoons were sent to deep ge~logic
disposal, the additional costs would be an estimated $0.9 million. Electro-
polishing of stainless steel wastes reduces radioactive surface contamination
to levels that permit shallow lar,d burial of these wastes. The approximately
$0.9 million cost saving in waste management that results from electropolishing
is partially offset by the cost of purchasing and operating the electro-
polishing system (a total cost in the order of $0.2 million).
10-2
If the contaminated sludge in the sewage lagoon requires treatment and
disposal, the cost, including contingercy, of packaging, shipping and disposal
of the sludge is estimated to be about $0.75 million, or about equal the
other waste ~anagement costs for Immediate Dismantlement. Thus a substantial
increase in decommissioning costs results if the sludge in the lagoon requires
disposal. In this study, it is assumed that the sludge is left in place and
covered by a mound .of soil (see Section G.3.3.2). The cost of this treatment
option is summarized in Section 10.1 . 5.
The costs associated with demolition of the decontaminated and dismantled
structure, rubble removal, backfilling to grad~ levels, and grading and reseeding
of the site are listed separately as Structure Demolition and Site Restoration.
Demolition of the contaminated structure is not an NRC requirement for
decommissioning but is included here to give a complete picture of the
potential total cost should the facility owner choose to completely clear
the site.
10.1.1 Manpower Requirements and Costs for Immediate Dismantlement
Estimates are made of the work force required to plan and execute the
decommissioning activities for Imn1ediate Dismantlement described in Section 9.1.
These work force estimates are used, together with the unit manpower costs
given in Appendix tl.l~ to estimate Immediate Dismantlement manpower costs.
The bases for these manpower estimates and the results in terms of decommis-
sioning manpower costs are described in this secti0n.
10.1.1.1 Manpower Requirements
The decommissioning work force organizational chart for Immediate
Dismantlement is shown in Figure 10.1-1. The work force is described in
two parts: 1} the decommissioning support staff that plans. supervises and
provides supporting activities for the decommissioning activities, and 2)
the decommissioning workers who perform the actual decommissioning activities.
The seven general types of functions performed during decommissioning are
described briefly below:
10-3
CORPORATE
HEADQUARTERS
SAfETY
REVIEW
COMMITTEE
PROJECT
MANAGER
SECRETARY
tEALTHAND CONTRACTS AND Stlt'l ACCOUNTit«l PROJECT

SAFETY ACCOUNTII'«l SPECIALIST ENGINEER
SUPERVISOR SPECIALIST
HEALTH RADIOACTIVE
PHYSICS SNM ACCOUNT! t«l SHIPMENT
ACCOUNTANT CLERK
TECHNICIAN-4 SPECIALIST
PLANNING OPERATIONS
Et«liNEER SUPERVISOR
Et«liNEERit«l
TECHNICIAN
0 ISMANTLEMENT
MODE
,------------------
________ 1 _______ ,
I 1
I I
I I
I
'-
______ T______ .J I
I I I I
DRY PROCESSit«l WET PROCESSit«l SHIPPING CREW
ROOMS DISMANTLEMENT ROOMS DISMANTLEMENT ELECTRO POll SH lNG
CREW I DEEP GEOLOGICAL
CREW CREW DISPOSALI
f- FOREMAN FOREMAN FOREMAN FOREMAN

TECHNICIAN-4 TECHNICIAN-4 TECHNIC IAN-3 -TECHNIC lAN-2
HEALTH PHYSICS HEALTH PHYSICS HEALTH PHYSICS HEALTH PH
TECHNICIAN (at TECHNICIAN tal TECHNICIAN tal i- TECHNICIA
cRAFTSMEN Ial 1- CRAFTSMEN tal ... CRAFTSMEN Ia I 1.. CRAFTSMEN (al
tal ASSIGNED TO WORK CREWS AS WORK Sl:nJATI<»> DEMANDS. COtmED <H.YONCE.

I I
SECURITY QA
FORCE ENGINEER
SUPERVISOR
I
SECURITY
PATROu.\AN-8
I
MAINTENANCE AND
CRAFTS SUPERVISOR
I
"" MAINTENANCE 1- WELDER
MAN
- PIPEFimR
'- CUSTODIAN
- El.ECTR IC IAN
,.. INSTRUMENT TECHNICIAN
1- CARFENTER
DECONTAMINATION
-------------------, I
,--·---------~
MODE
I 1
I
!_ __________ JI
CHEMICAL PHYSICAL
DECONTAMINATION DECONTAMINATION
CREWS- 4 CREW
FOREMAN FOREMAN FOREMAN
TECHNIC IAN-4 TECHNICIAN-3 TECHNIC IAN-6

HEAlTH PHYSICS HEALTH PHYSICS HEALTH PHYSICS
TECHNICIAN (a) TECHNICIAN (a) TECHNICIAN (a)
CRAFTSMEN (a) CRAFTSMEN lal CRAFTSMEN tal FIGURE 10.1-1. Postulated Organization
Chart for ImmediatE
Dismantlement
10-5
• Project Management - prepare and implement the decommissioning plan in
a safe and cost-effective manner.
• 9uality Assurance (QA) - develop the QA plan and monitor the safety and
performance of the decommissioning activities.
• Decommissioning Operations - develop the decommissioning plan and carry
out the actual decommissioning activities.
• Plant Operations and Maintenance - operate and maintain plant equipment
that must be operated during the decommissioning.
• Health and Safety Protection - develop methods to assure the protection
of the health and safety of the public and decommissioning workers.
• Safeguards and Security - provide protection of the site and facility
from unauthorized entry and safeguard Special Nuclear Material (SNM).
• Support Services - provide accounting, procurement and stores,
secretarial and clerical services in support of the decommissioning
activities.
Job description details for key individuals in the dismantlement staff
organization are given in Appendix H.2.
Actual decommissioning activities are carried out by decommissioning
crews that consist of a foreman, two to six decommissioning technicians,
and health physics technicians and craftsmen who are added to the crews
as the work situation demands.
A key assumption in estimating the manpower and time for the basic
events is that the decommissioning work force is composed primarily of former
plant operating and maintenance personnel. The decommissioning workers are
therefore familiar with plant facilities and equipment and experienced with
radiation working procedures. The duties and experience of the msmbers of
the basic decommissioning crew are outlined below.
Foreman. This person supervises the performance of all decowmissioning
activities. He coordinates with the engineering staff through the operations
supervisor to plan and execute each day's activities. He assembles the
10-7
crew and equipment required to perform these activities and instructs th~
t.rew on the procedures and safety precautions to be followed. The foreman
·is assumed to perform some of the actual deconmissioninq activities as well
as st.:pervise other members .of his ..:r~w. It is anticipated that the foreman
would have been employed in a position comparable to a process shift super-
visor or maintenance supervisor during plant operations, so that he has detailed
knowledge of plant systems and equipment.
Decommissioning Technicians. These people perform the bulk of the actual
decommissioning oper·ations. They are assum1?.d to possess a variety of ski 11 s
either through past a~~erience in the plart or through specialized training
prior to or during the decomm!s~;~itmin<g. technicians are assumed to have
been employed in positions compar:Jble to !'Ocess operators, maintenance
technicians or mechanical technicians during plant operations. It is anti-
cipated that they would be qualified in several craft discip"lines, including
operation of much of the plant equipment .
.Health Physics Technician. This person is assigned to the work crews
as the work situation demands to provide instruction in radiation and indus-
trial safety precautions to be followed for each task and to monitor compliance
with written radiation working procedures for the task. He performs on-the-
job radiation measurements and has the authority to stop work on the job
if any potentially unsafe situation arises.
Craftsmen. These are people who are added to the basic crew to carry
out particular tasks that require assistance of a:
• Welder,
• Pipefitter,
• Carpenter,
• Electrician, or
• Instrument Technician.
The deconmissioning staff is assemb"led during the planning and prepara-
tion phase. Initial management staff consists of the project manager, project
engineer, quality assurance supervisor and operations supervisor. Other
staff personnel are added as their services are required during the planning
10-8
and preparation phasP. Planning and preparation activities take place during
the final two year·s of plant operation. Therefore, support activities such as
plant maintenance and plant security are available as part of plant operations
and are not charged to decommissioning during the planning and preparation
phase.
In order to minimize owner overhead and support staff labor costs, the
decommissioning staff is generally sized and structured on a two-shift, five-
day week. Certain operations such as chemical decontamination anc security
are carried out on a four-shift, seven-day week. Decommissioning activities
require that workers wear protective clothing, and in some cases, air-support
bubble suits. Because of the inconveniences of the physical enviTonment
in which decommissioning tasks are carried out, manpower requirements are
developed on the basis of an assumed worker time efficiency of 75%.
Manpower requirements are greatest at the beginning of decommissioning
activities during the chemical and physical decontamination phases of dis-
mantlement. (See the manpower organizdUc~al chart:for dismantlement,
. '•.
Figure 10.1-1). During the approximately 1.5-year period following chemical
decontamination, during which most of the dismantlement of glove boxes and
equipment takes place, the staff size is estimated to remain approximately
constant.
10.1.1.2 Manpower Costs
Table 10. l-2 shows manpower ~nd associatea cost estimates for the
planning and preparation phase of Immediate Dismantlement, and Table 10.1-3
shows manpower requirements and costs for the decommissioning phase. A
total of about 17 man-years is estimated to be required for planning and
preparations, at a labor cost of about $0.7 million. A total of about
115 man-years is estimated to be required to decontaminate and remove
contaminated mater·ia·ls from the facility~ at a labor cost of about $3.4
million. The total labor cost for Imm~diate Dismantlement is thet·efore about
$4.1 million without cor.tingencies. Manpower costs shown in Table 10.1-3
include labor costs for packaging radioactive waste materials for shipment.
These costs do not include specialty labor costs discussed in Section 10.1.3
for transportation and in Section 10. 1.5 for other specialty contractors.
10-9
TABLE 10.1-2. Surmtary of Manpo\'.·er Utilization and Staff Costs
for Planning and Preparation Phase of Immediate
Dismantlement
Title or Function Man-Years Co:t ($ Millions}(a,b)
Project Manager 2.00 0.149

Project Engineer 2.('') 0.127
Health and Safety Supervisor 0.50 0.024
Contracts and Accouting Special- 1. ou 0.032
ist
Accountant 0.50 0.012
Radio,\ctive Shiplflent Specialist 0.25 0.008
Q.A. Engineer 1.00 0.038
Planning Engineer 2.00 0.088
Engineering Technician 1.00 0.027
Operations Super\'i s~r 2.00 0.088
Foreman 1.50 0.049
Secretary 3.00 0.061
Total Man-Years 16.75

Total Cost 0.703
(a) Number of figures shown is for computational accuracy and does not
imply precision to the nearest thousand dollars.
(b) Co11tingency of 25% is not inc·luded in these coste;.
It should be recognized that completion of decommissioning activities

will occasionally take longer than anticipated, resulting in increased labor
costs. Often, these cost increases can be offset by reducing the labor force
after the most labor-intensive tasks are completed. The final deactivation
and cleanup activities, for example, can be accomplished by a relatively small
group.
10-10
TABLE 10.1-3. Summary of Manpower Utilization and Staff
Costs for the Dismantlement Phase
Title or Function Man-Years(b) Cost {$ Mi11ions)(a,b,c~

Project Engineer 1.58 0.100
Health Physics Technician 10.17 0.256
Security Force Supervisor L58 0.054
Security Patrolman 12.64 0.269
Contracts and Accounting Specialist 1.58 0.051
Accountant 0.79 O.Oi9
SNM Accounting Specialist 1.58 0.061
SNM Accounting Clerk 0.79 0.019
Radioactive Shipment Specialist 1.58 "~?
"V•'---
Q.A. Engineer 1.58 0.069

P1annin9 Engineer 1.58 0.069
Engineet·ing Technician 0.79 0.021
Maintenance and Crafts Supervisor 3.00 0.122
Maintenance Man 3.00 0.078
Custodian 1.58 0;038
Craftsman 15.00 0.405
Operations Supervisor 3.00 0.131
Foreman 10.42 0.343
Technician 35.85 0.968
Secretary 3.16
--- 0.064
Total Cost 3.382
imply precision to the nearest thousand dollars.
(b) Information given is for support staff and decommissioning workers.
(c) .Contingency of 25% is not included here.
10-11
10.1.2 Material and Equipment Requirements and Costs for Immediate
Dismantlement
Estimates of material and equipment requirments and costs for Immediate
Oismantlament ~re sha~n in Table 10.1-4. Equipment requirements are based
on decommissioning procedures described in detail in Appendices F and G and
summarized in Section 9.1. Costs of decontamination chemicals are calculated
on the basis of quantities required for decontamination and unit costs given
in Appendix H.l. Cleaning supplies represent a major cost item and include
assorted cleaning agents, rags, mops, brushes, plastic bags, plastic sheeting,
etc. The cost of protective clothing includes the cost of laundering the
clothing by an outside contractor and is estimated to be about $1,000 per
week. The total cost of material and equipment for Immediate Dismantlement
of the reference MOX plant is estimated at about $0.9 million without con-
tingency.
TABLE 10.1-4. Estimated Material and Equipment Requirements
and Costs for Immediate Dismantlement
htimated Estimated
Unit Cost Total Cost
·-··--- ~ -· . _Oe:;_c!JJ>.t_~o_n --------- .. ---- !hl_a_n_t!_~ l S th<)_~S~Il_d_s} U!_h_f!.~.n_~J
Oxyacetylene Torch 2 ea.

Portable Plasma Cuttinq Torch 4 ea. ~0 80
Arc Saw 1 ea. 100 100
Guillotine Pip~ Saw l ea. 2
Tube Cutter 2 ea. 0. J 0.6
Ratcheting Pipe Cutter 6 ea. 0.05 O.J
Reciprocatinq Saw 4 ea. 0.5 2
Nibb~er l ea.
,;.1'
Hign·Yeloclty liquid Jet I ea. .
Low-Velocity Liquid Jet
Hydraulic Concrete S.urfdte Spalling Device
Concrete Dri 11
2 ••.
I ea. 5
1 .
.
.
2 ea. 0.2 0.4
Elec:tric/Pneumatic Harm~er Z ea. 0.5
Portable Filtered Ventilation Enclosure 1 ea. 1.5 1.5
Supplied AI" Bubble Suit 200 ea. 0.05 10
Flectropolishing System 1 ea. 100 100
Portable Fume Exhaustor I ea. 7
Waste C001pac tor 1 ea. 12 12
HEPA Filter 50 ea. 0.15 7.5
Roughing Fi Iter 50 ea. 0.05 2.5
Decontamination Chemicals 26.5
Cleaning Supplies 250
Expendable Tools 100
Protective Clothing (including laundry) 82
Office Supplles •
Planning and Preparation 50
Decommissioning 25
Cement 10 ml 0.07 . ..Qd.
Total(a) 879.
(a) Total is shown as direct addition of prior numbers to retain calculationll infonnation.
Preclsi.on is less than shown.
(b) Contingency of 251 is not Included here.
10 ... 12
10.1.3 Waste Management Requirements and Costs for Immediate Dismantlement
Estimates are made of the quantities of radioactive wastes generated
during Immediate Dismantlement of the Reference MOX plant and of packaging,
transportation and disposal requirements and costs for managing these wastes.
These estimates are based on dismantlement procedures described in Section 9.1
and on unit waste management costs given in Appendix H.l. Waste management
requirements and costs for Immediate Dismantlement are described in this
section.
10.1.3.1 Waste Mana9ement Re~uiremen~~
Large quantities of radioactive wastes are generated during the dismantle-

ment of a MOX fuel fabrication plant. These wastes must be properly packaged
and shipped to an authorized disposal site.
Radioactive wastes generated during the dismantlement of a ~mall MOX
plant include:
• solidified liQuids from chemical decontamination activities
• contaminated process equipment, tanks, glove boxes, and piping
• concrete rubble from the mechanical decontamination of contaminated
floors and walls
• HEPA and roughing filters
• sections of ventilation ductwork
• combustible and nonc·Jmbustible trash (protective clothing, contaminated
tools, rags, paper, plastic, metal scrap, etc.)
• possibly, sludge fnm1 the sewage lagoons.
The bulk of the material that must be packaged for disposal will be
contaminated with plutonium and uranium. The NRC has proposed adoption of
a rule requiring that all wastes contaminated with more than 10 nanocuries of
transuranic elements per gram of waste be classified as TRU wastes{l) and
shipped to a federal repository. Non-TRU wastes are Assumed to be disposed
of at shallow land burial sites.
10-13
In this study, it is assumed that most decommissioning wastes initially
have levels of plutonium contamination that would require the wastes to be
disposed of at a federal repository. Electropolishing is used in this study
to reduce plutonium contamination levels on some of these wastes so that they
can be disposed of by shallow land burial. Details of assumed waste volumes
for contaminated process equipment, tanks, and glove box sections postulated
to require disposal at a federal repository or a shallow land burial ~tte are
given in Table H.2-6 of Appendix H. All of the contaminated ductwor'~ and
piping is electropolished. The level of plutonium contamination in the
sludge from the sewage lagoons is assumed to be low enough to leavt~ the sludge
in place. Alternatively, if sludge removal is required, it is assumed to be
disposed of by shallow land burial. All other decommissioning wastes are
postulated to require disposal at a federal repository.
Only solid wastes are assumed to be transported to a commercial burial
ground or federal repository. Radioactive liquids generated d~ring ch~mical
decontamination activities are concentrated by evaporation and solidified
by mixing with cement. The resultant solid is packaged in 208-~ (55-gal)
steel drums and shipped to deep geologic disposal.
Non-TRU wastes from decommissioning operations are packaged for shipment
in 208-~ (55-gal) steel drums or in plywood boxes. Package surface dose
rates vary from a few micro-roentgen per hour to a few milli-roentgen per
hour. Shipment is by truck in sole-use closed vans. The distance from the
MOX plant to a shallow land burial site is assumed to be 800 km (500 mi).
TRU-contaminated decommissioning wastes are packaged in DOT specification
7A steel boxes< 2) or in DOT specification 17C 208-~ (55-gal) steel drums.< 2)
Drums and boxes are placed in a Super Tiger overpack and shipped by truck
to a federal repository. (The Super Tiger is described in Appendix F.3.2)
The distance from the MOX plant to the federal repository is assumed to be
2,400 km (1,500 mi).
All shipments of decommissioning wastes are made in compliance with
federal, state and local regulations as described in Appendix F.3.2.
10-14
Table 10.1-5 gives estimated weights and volumes of decommissioning wastes
from Immediate Dismantlement of the reference MOX fuel fabrication plant~
together with packaging, shipping and disposal requirements for these wastes.
Detailed information about waste quant1ties is given in Appendix H.2. It is
assumed that the sludge from the sewage lagoon would not require removal.
However, an estimate of packaging and shipping requireme~ts for removal of
contaminated sludge from the sewage lagoon is given separately, in the event
that sludge removal is required.
TABLE 10.1-5. Waste Disposal Requirements for Immediate Dismantlement(a)
Shipping Shipping Number Containers Number of

Weight Volume Container of per Truck
~~- Jl<.l!l.__ ~_(_m3j__~ ____ __Tj'y_e__ --~ _ C_<_>ll_t~i_n_~E? __s_~_i ,PI_l1_£_n_t__ S_tl.!p_!11_e_!1_t_s
9~~~.2_l_Qgj~osa 1.
Glove Boxes and tioods 45,000 40.b 1.2 X 1.2 X 1.8-m 16 3 6

Steel Box
Tanks and EQuipment 7,000 6.4 1. 2 X 1. 2 X 1. 8-m 3 3
Steel Box
HEPA and Roughing Filters 11,000 34.3 1.2 X 1.2 X 1.8-m 14 3 5
Steel Box
Concrete Rubbie 24,000 20.0 208-1. ( 55-ga 1 ) 100 42 3
Steel Drum
Soliditied Decontamination 46,000 14.4 208- z ( 55-ga 1 ) 72 24(c) 3
Liquids Steel Drum
Trash 38,900 48.6 243 42 6
Totals 172,000 164 33 boxes 24
415 drums
pisQOSal b~ Shallow Lan~~~J_
~love Boxes and Hoods 106,000 94.2 2.6-m 3 Plywood Box 36 6 6

Tanks and Equipment 114,000 101.8 2.6-m 3 Plywood Box 40 6 7
Piping, Valves and Ductwork .. 80,000 71.0 2.6-m3 Plywood Box 28 5
Tota 1s 300,000 267. 104 18
Sludge from Sewage Lagoon(b) 3,500,000 2,930 2.6-m3 Plywond Box 1,127 6 188
(a) Number of fiqures shown is for computational accuracy and does not imply accuracy to three or four
significant fi9ures.
(b) Listed for information purposes in the event that sludge removal is required. Not included in totals.
(c) Number of contain~rs. per shipment is limited by weight rather than by volume.
I 10-15
10.1.3.2 Waste Management Costs
The estimated costs of container, transportation and disposal of the
radioactive wastes from Immediate Dismantlement of the reference small MOX
fuel fabrication plant are sull1Tiarized in Table 10.1-6. Cost estimates are
based on projected packaging and shipping req•Jirements sui11Tlarized in
Table 10.1-5 and on waste management cost data in Appendix H.l. Waste
management cost details a•'e g1ven in Appendix H.2.
The total waste management cost for 1111Tlediate Dismantlement is estimated
to be about $0.6 million without contingency. If packaging and disposal of
the sludge in the sew.age lagoon is required, it would add about $0.6 million
(without contingency} to th i s cos L
TABLE 10.1-6. Estimated Costs for Packaging, Transportation and

Disposal of Radioactive Material from Immediate
Dismantlement
Costs in Thousands of 1978 Do11ars(a)
Waste Category Container Transportation _Buriaj_ ToTa11C)
Deep Geologic Disposal

Glove Boxes and Hoods 20.8 24.1 87.4 132.3
Tanks and Equipment 3.8 4.0 16.4 24.2
HEPA and Roughing Filters 18.0 19.0 76.4 1 13.4
Concrete Rubble 4.4· 12.7 44.1 ~!. 2

Solidified Decontamination Liquids 3.8 13.4 31.8 49.0
Trash 9.7 24.1 107.2 llll .0
Subtotals 60.5 97.3 363.3 5ll
Disposal By Shallow Land Burial
Tanks and Equipment 5.20 6.70 9. 78 21.7
Piping, Valves and Ductwork 3.64 4.78 6.84 15.2
Subtotals 13.5 17.2 25.4 56.1
Totals w/o Sludge 74.0 114.5 388.7 577
Sludge from Sewage l.agoons(b) 146.5 180.0 275.4 602
Totals with Sludge 220.5 294.5 664.1 1179
(a) Number of figures shown is for computational accuracy and does not imply three or
four place accuracy in waste management cost figures.
(b) Listed for information pruposes in the event that sludge removal is required.
(c) Contingency of 25% is not included here.
10-16
Waste management costs for wastes shipped ~o deep geologic disposal
are significantly higher than they are for wastes sent to shallow land burial
sites. For example, the total cost of the container, transportation and
disposal of a 2.6 m3 plywood container of contaminated glove box sections
sent to shallow land burial is estimated to be about $530. The total cost
of the container, transportation and disposal of a 2.6-m 3 steel container of
contaminated glove box sections sent to deep geologic disposal is estimated
to be about $8,300. Most of this cost differential is due to the greater
disposal cost assumed for deep geologic disposal {$2,100/m3) compared to the
disposal cost assumed for shallow land burial ($94/m3 ).
10.1.4 Miscellaneous Owner Expe~!~~.? for ImfTI~diate Dismantlement
Estimated miscellaneous owner· expenses for Irrmediate Dismantlement are
shown in Table 10.1-7.
Utilities costs and property tax charges arc based on actual experience
at the reference plant. Utilities costs are based on an average charge of
about $5,000 per month, and property taxes are based on a charge of approxi-
mately $12,000 for calendar year 1977.
TABLE 10.1-7. Estimated Miscellaneous Owner Expenses

for Immediate Dismantlement
Cost in ThousaQdS Qf
Cost Category 1978 Dollars(a,bJ
Utilities 100
Taxes 18
license Fee 216
Insurance 150
Total 484
(a) Number of figures shown is for

computational accuracy and does
not imply precision to the nearest
thousand dollars.
(b) Conth,gency of 25% is not included
here.
lb-17
The operating license fee for a MOX plant is currently set by the NRC
at $215.000 per year< 3>. ThE: :~mount of this fee that would have to be p:Jid
during the decommissioning period has not been determined. For estimating
deconvnissioning costs, it is assumed that the full fee would be paid during
the first year, while the scrap recovery and waste treatment facilities of
the plant are being used to recover plutonium from decommissionin} wastes.
Thereafter the fee for a possession-only license ($600 per year{ 3 ) or a modi-
fied operating license is assumed to be applicable.
The cost of nuclear liability insurance for a facility being decommis-
sioned has also not been determin12d. Anal m'llance of $100,000 is included
for the annual insurance premium r nuclea iability and conventional
insurance.
10.1.5 Specialty Contractor Co:~_______.for L'!!!leo~i.ate Di~;mantlement
Specialized services are required to accomplisll the dismantlement of the

reference sma~l MOX plant. These services are assumed to be supplied by the
specialty contractors listed below. Costs shown do not include the 25%
contingency used when adding the total decommissioning costs in this study.
Electropolishing
An electropolishing unit is installed in Room 123 to decontaminate
piping, ductwork, tank sections and glove box sections to levels that allow
d·isposal by shallow land burial. Electropolishing of some larger tanks is
carried out in place. It is assumed that a consultant is hired for a period
of three months to assist in setting up the electropolishing unit, train
the crew, and supervise the initial operation of the system. Total cost
of the consultant is estimated to be $16,000, based on a fee of $250 per day.
Removal of Wall Tanks
A crane is used to lift the vault storage tanks and the large liquid
waste tanks in Room B02 through openings in the roof of the building. Estimated
costs of the crane and of operating personnel are presented below. Labor
costs are takan from Reference 4 and have been increased by 30% to allow for
inflation to 1978 dollars. Work is assumed to be performed on a two-shift
per day basis, the same as for other decommissioning activities.
10-18
Crane Rental - $3~500/wk x 16 wks ::: $56,000
Foreman (2) - $900/wk x 16 wks = 28,800
Equipment Operator ( 2) - $750/wk x 16 wks = 24,000
Laborer ( 4) - $550/wk x 16 wks = 35,200
Total $144,000
Decommi~sion Sanitary Lagoon

As described in Section G.3.3.2, the Sanitary Lagoon is decommissioned
by allowing the water in the ponds to evaporate, after which the polyvinyl
chloride liner is punctured to provide a path for water to pass through the
liner. The ponds are backfilled w th soil a total thickness of about
0.6 m (2ft) above grade level. the soi p is compacted and mounded.
Grass is planted to reduce erosion and con water runoff.
Estimated costs of decomm·issioning the sanitary lagoon are presented
in Table 10.1-8. Labor costs are taken from Reference 4 and have been
increased by 30% to allow for inflation to 1978 dollars.
TABLE 10.1-8. Subcontractor Costs to Decommission

the Sanitary Lagoon
Activity Basis Cost ($) (a)
Backfilling $7,400 m3 at $0.50/m3 $ 3,700

Grader $500/wk for one week 500
Dump Truck $500/wk for one week 500
Loader $1,000/wk for one week 1,000
Foreman $900/wk for one week 900
Equipment Operator Two men at $750/wk for 1,500
one week
Laborer Two men at $550/wk for 1,100
one week
Grade, Seed, Fertilize 3,700 m2 at $0.80/m2 3,000
Total $12,200
(a) Contingency of 25% is no~ included here.
10-19
10.1.6 Building Demolition and Site Restoration
Costs of demolition of the decontaminted and dismantled MOX plant, rubble
removal~ backfilling of the building basement to grade level, and of grad-
ing and reseeding the area on which the building was located are listed in
Table 10.1-9. Demolition of the decontamir.ated structure and site restoration
are not NRC requirements for decommissioning but are included in this study
to give a complete picture of the potential total cost should the facility
owner choose to completely clear the site.
TABLE 10.1-9. Costs of Building Demoli on and Site Restoration(a)
Building Demolition 1,500 m3 cf concrete of $651m 3 $ 97,500

Backfill Building Cavity 3,600 m3 ;;t $0.50/m 3 1,800
Site Restoration
Scraper $2,500/wk for one week 2,50(1
Dozer $1,800/wk for one week 1,800
Grader $500/wk for one week 500
Dump Truck $500/wk for one week 500
loader $1,000/wk for one week 1,000
Foreman $900/wk for one week 900
Equipment Operator (3) $750/wk for one week 2,250
Laborer (2) $550/wk for one week 1 '1 00
Grade, Seed, Ftr~ilize 3,000 m2 at $0.80/m 2 __1_,400 ..
Subtotal 5112,000
25'X Contingency -~·000
Total $140,000
(a) labor and equipment costs are taken from Reference 4 and have been
increased by 30% to account for inflation.
10.2 ESTIMATED COSTS OF PREPARATIONS FOR SAFE STORAGE

The estimated costs of preparing the reference small MOX plant for
Safe Storage are summarized in Table 10.2-1. These decommissioning activities
are estimated to require about one year (plus 1.5 years for planning and
preparation) at a cost of approximately $3.5 million.
10-20
TABLE 10.2-1. Summary of Estimated Costs of Preparations for Safe Storage
Cost in Millions of Percent of

_____c_o_st Category 1978 Dollars(a) Total
--
Manpower -
Planning and Preparation 0.463 16.6
Decomm.;ssioning 1. 365 48.8
Equipment and Supplies 0.380 13.6
Disposal of Radioactive Material 0.169 6.1
t1iscellar:eous Owner Expense 0.387 13.9
Specialty Contractors 0.027 1.0
- -
Subtota 1 2. 791 100.0
25% Contingency 0.698
Total Costs of Preparations for Safe Storage 3.5
imply precision to the nearest thousand do1lars.
Manpower represents about 65% of the total cost of Preparations for

Safe Storage. Manpower costs include both support staff and decomt11issioning
worker labor. In Table 10.2-1, manpower costs are shown separately for plan-
ning and preparation activities and for decommissioning activities. Manpower
costs include onsite labor for packaging radioactive waste materials for
shipment. Labor costs related to radioactive waste transportation are
included with waste management costs, since transportation is performed by
a specialty contractor.
Waste management 3ccounts for about 6% of the total cost of Preparations
for Safe Storage. Waste management costs include shipping container costs,
transportation charges, and fees for waste disposal. All radioactive wastes
generated during Preparations for Safe Storage are assumed to go to deep
geologic disposal.
There are no structure demolition or site restoration charges for this
phase of decommissioning. The annual costs of Interim Care during Safe
Storage are described in Section 10.3.
10-21
10.2.1 Manpowe~ ~egyirements and Costs of Preparations for Safe Storage
Preparations for Safe Storage described in Section 9.2. These work force
estimates are used, together with the unit manpower costs given in Appendix H.l,
to estimate manpower costs. The bases for these manpower estimates and the
results in terms of decommissioning manpower costs are described in this
section.
The organizational chart of the decommissioning work force for Preparations
for Safe Storage is shown in Figure 10.2-l. This work force includes the
support staff that plans, supervises and provides support for decommissioning
activities and the workers who perform the actual decommissioning activities.
Job description details for key individuals in the decommissioning work force
are given in Appendix H.2.
The decommissioning staff is assembled during the planning an. preparation
pha~e that takes place during the final 1.5 years of plant operation. Initial
managemen~ staff r.onsists of the project manager, project engineer, quality
assurance supervisor and operations supervisor. Other staff personnel are

added as their services are required during the planning and preparation
phases.
r.ctua 1 decommi ss ionin.1 activities require approximately one year following
plant shutdown. Chemical d~contamination activities are carried out by four
shifts operating on a 24"'hout day, seven-day week basis. After chemical
decontamination activities are completed, the size of the decommissioning
work force is reduced in accordance with the plan used in this study. Physical
decontamination and facility deactivation activities are performed on a one-
shift five-day week basis. Perforrnance of these activities on a two-shift
five-day week basis could result in a reduction of owner overhead and support
staff labor costs, with a potential sa\ings of about $0.4 million in the total
cost of preparing the facility for Safe jtorage.
10-22
I CORPORATE
HEADQUARTERS
1-.---.---l
SAFHY REVIEW I I
COMMiffiE
PROJECT
MANAGER
SECRETARY
HEALTH
PHYSICS
ACCOUNTANT
TECHNICIAN-3
.....
0
I
N
w PIPEFimR
ELECTRIC !AN
INSTRUMENT TECH
SCRAP RECOVERY
AND WASTE
I CHEMICAL
DECONTAMINATION
PHYSICAL
DECONTAMINATION
HANDLING CREW CREWS-4 CREW
FOREMAN FOREMAN -FOREMAN
OPERATORS-4 OPERATORS-3 OPERATORS -6

- HP TECH 1a1 HP TECH Ia! !iP TECH 1a1
L CRAFTSMANial CRAFTSMAN Ia! - CRAFTSI\'\AN Ia 1
(aiASSIGNED TO WORK CREWS AS WORK SITUATION DEMANDS

COUNTED ONLY ONCE
FIGURE 10.2-1.. Postulated Organization Chart for Preparations for Safe Storage
Tab1e i0.2-2 shows manpower anr! associated cost estimates for the planning
~nd preparation phase, and Table 10.2-3 shows support staff and worker man-
power requirements and costs for the active decommissioning phase of Prepara-
tions for Safe Storage. About 10 man-years are estimated to be required for
plannin. and preparations, at a labor cost of about $0.5 million. About
45 man-years are estimated to be required to chemically and physically
decontaminate and deactivate the facility, at a labor cost of about $1.4
million. The total labor cost for placing the facility in Safe Storage is
therefore about $1.9 million without contingencies.
TABLE 10.2-2. Summary of Hanpo\'Jer Utilization and Staff

Costs for Planning and Preparation Phase
of Preparations for Safe Storage
Title or Function Man-Years Cost ($ Mi11ions)(a,b}

Q. A. Engineer 0.75 0.033
Radioactive Shipment Specialist 0.25 0.008
Foreman 0.75 0.025
Secretary 2.00 G.040
Total Cost 0.463
(a) Number of figures shown is for computational accut·acy and does not imply
precision to the nearest thousand dollars.
(b) Contingency of 25% is not included in these costs.
10-24
TABLE 10.2-3. Summary of Manpower Utilization and Staff Costs for
Decommissioning Phase of Preparations for Safe Storage
ProJect Manager 1.00 0. 074

ProJect Engineer 1.00 0.064
Health Physics Technician 3.00 0.076
Seturity rorce Supervisor 1.00 0.034
Secur~ty Patrolman 8.00 0.170
Contracts and Accounting Speci"llst 1.00 0.038
SNH Ae<ounting Special 1st l.OD 0.038
Q.A. Eegineer 1.00 0.044
Radloactl11e Shipment Speclali~t 1.00 0.033
Pldnnlng fr.qi"leer 1.00 O. .J44
Maintenance and Craft.'o. ~,uperv1sor l.OO 0.041
Mc\l.ntenc.nce Mdn ~ .00 0.026
(ustodit!n C.G24
(raft smdn 4. 00 O.lOR
Coeratlons SuperviSOr 1.no 0.044
t o:-eman i .BB l/.095
Technic ian 11.56 0. 31?
Secretary .?_jl_O 0.04_0
1 ota1 Man- Years 44.94
Tc:.al Co't l.Jb5
(a} Number of f1gures shor.o..... 1s for computational accuracy and does

not imply precision to thE' nearest thousand dollars.
{b) Information given ls for support staff and decorrmiss1oning workers.
{c) Contingency of 25< is not included here.
10.2.2 Estimated Material and Equipment Requirements and Costs

of Preparations for Safe Storage
Estimates of material and equipment requirements and costs of preparing
the reference MOX plant for Safe Storage are shown in Table 10.2-4. Equipment
requirements are based on decommissioning procedures described in detail in
Appendices F and G and summarized in Section 9.2. Many HEPA and roughing
filters are replaced before beginning the Interim c~:e period. The total
cost of material and equipment for placing the reference MOX ;Jl11it in Safe
Storage is estimated at about $0.4 million without contingency.
10.2.3 Estimated Management Requirements and Costs of Preparations
for Safe Storage
Estimates are made of the quantities of ·"adioactive wastes generated
during Preparations for Safe Storage at the reference MOX plant and of waste
container, transportation and disposal requirements and costs of managing
these wastes. These estimates are based on procedures described in Section 9.2
10-25
and on unit waste management costs given in Appendix H.l. Waste management
requirements and costs are summarized in this section.
TABLE 10.2-4. Estimated Costs of Equipment and Supplies

for Preparations for Safe Storage
Estimated Estimated
Unit Cost Total Cost ( )
Description Quantity {$ Thousands) ~$ Thousands) b
Arc Welder 2 ea 2
Paint Sprayer 2 ea 2
Ratcheting Pipe Cutter 6 ea 0.05 0.3
High Velocity liquid Jet 1 ea 5 5
Low Velocity liquid Jet 2 ea 2 4
Waste Compactor 1 ea 12 12
HEPA Fi Iter 326 ea 0.15 49
Roughing Filter 313 ea 0.05 15.6
Decontamination Chemicals 10
Expendable Tools 25
Protective Clothing (including la~.;.1dry) 50
Cement 0.2
Intrusion Alarm System 50
Office Supplies
Deconmissioning 20
Total J80{a)
(a) Total is shown as direct addition of the prior numbers to retain calculational information.
Precision is less than shown.
(b) Contingency of 25% is not included here.
10... 26
10.2.3.1 Waste Management Requirements
Radioactive wastes generated during Preparations for Safe Storage include:
• HEPA and roughing filters
• solidified 1iquids from chemical decontam·ination
activities
• combustible and noncombustible trash (protective clothing,
contaminated tools, rags, paper, plastic, metal scrap, etc.).
Because the levels of plutonium contamination are expected to exceed
10 nanocuries per gram of waste, the wastes are all assumed to be packaged
in steel boxes and steel drums and shipped to a federal repository for deep
geologic disposal. Details of packaging and shipping requirements for TRU
wastes sent to deep geologic disposal are given in Section 10.1.3.1.
Table 10.2-5 gives estimated weights and volumes of decomn1issioning
wastes generated during Preparations for Safe Storage at the reference MOX
plant, together with packaging, shipping and disposal requirements for these
wastes. Detailed information about waste quantities is given in Appendix H.3.
TABLE 10.2-5. Waste Disposql R~quirements of Preparations for

Safe Storage{a,bJ
Waste Category __l!gL_ -~ Type Con to 1_ners Shipment Shipments
HEPA and Roughing Filters 8,300 26.1 1.2 X 1.2 X ].8-m 11 3 4

St ..el Box
Solidified Decontamination Liquids 4,5Q:) 1.4 208-f (55-gal)Drums 7 24(c)
!I Trash 19,400 24.3 208-g (55-gal )Drums 122 42 3
Tota 1s 32,200 51.8 11 boxes 8
129 drums
(a) All wastes are disposed of by deep geologic disposal.

(b) Number of figures shown is for computational accuracy, and does not imply precision to three significant figures.
(c) Number of containers per shipment is limited by weight rather than by volume.
10-27
10.2.3.2 Estimated Waste Management Costs
The estimated costs for containers, transportation and disposal of the
radioactive wastes from Preparations for Safe Storage are summarized in
Table 10.2-6. Cost estimates ~re based on projected packaging and shipping
requirements summarized in Table 10.2-5 and on waste management cost data
in Appendix H.1. The total cost of waste management for placing the
reference MOX plant in Safe Storage is estimated to be about $0.2 million
'
without contingencies.
10.2.4 Miscellaneous Owner EXJ2_enses for ~repar'ations for Safe Storage
Estimated miscellaneous owner expenses for preparing the reference MOX
plant for Safe Storage are s in 0.2-7. These expenses are calcu-
lated on the same bases as weTc~ similar :xpenses for Immediate Dismantlement
(see Section 10.1.4), except that the time period is only one year.

Disposal of Radioactive Material from Preparations
for Safe Storage
Costs in Thousands of 1978 Dollars(a,b)

Waste Category Container Transportation Burial Total

Solidified Decontamination
Liquids 0.94 4.47 3 8.4
HEPA and Roughing Filters 14.2 15.2 60 89.4
Trash 4.84 12.0 54 70.8
Totals 20.0 31.7 117 169
(a) Number of figures shown is for computational accuracy and does not imply
three place precision in waste management cost figures.
10-28
TABLE 10.2-7. Estimated Miscellan~ous Owner Expenses During
Preparations for Safe Storage
Cost Cost in Thousa?dS Qf

Category 1978 Dollars\a,b)
Utilities 60
Taxes 12
License Fee 215
Insurance 100
Total 387
(a) Number fiyures is for

comptl 1on a 1 ace' does<.<nd
not i preC'i s r to the near-
est t.sand doll rs.
(b) Contingency of 25% is not included
here.
License fees to be paid during the decommissioning of a nuclear facility

have not been set by the NRC. In estimating the applicable license fee during
Preparations for Safe Storage, it is assumed that the full operating fee
would be paid, because scrap recovery and waste treatment facilities at the
plant would be used during decommissioning to recover plutonium from decom-
missioning wastes. The annual insurance premium for nuclear liability and
conventional insurance is assumed to be the same as tor Immediate Dismantlement.
10.2.5 Specialty Contractor Costs for Preparations for Safe Storage
Specialized services are required to prepare the reference small MOX
plant for Safe Storage. These services are assumed to be supplied by the
specialty contractors listed below. Costs shown do not include any con-
tingency ..
Intrusion Alarm System
An alarm system is installed at the decommissioned plant to detect
attempts at unauthorized entry into the facility dudng the Interim Care
period. The cost of the alarm system is included as an equipment item in
Table 10.2-4. The cost of installation and testing of the system by an out-
side contractor is estimated to be $15,000.
10-29
'"
'
Decommission Sanitary Lagoon

The sanitary lagoon is decommissioned as described in Section G.3.3.2.
Cost for this activity is estimated in Section 10.1.5 to be about $12,200
without contingency.
10.3 COST ESTIMATES FOR INTERIM CARE

This section presents estimates of the annual manpower and material
requirements and costs for the Interim Care phase of Custodial Safe Storage.
Activities carried out at the MOX plant to assure the continued protection
of the public health and safety during this phase include:
• monitoring of operating equipment and alarm systems
• periodic radiation surveys of the facility
• periodic environmental surveys
• maintenance of operating equipment, alarm systems and
protective barriers
• inspection of facility structures, protective barriers
and operating equipment and alarm systems
• site and facility security
• fulfillment of regulatory requirements.
The annual costs of Interim Care are summarized in Table 10.3-1. Interim
Care is estimated to cost about $0.60 million annually in 1978 dollar:;. Staff
labor costs represent over 80% of this total.
10.3.1 Manpower Requirements and Costs for Interim Care
Annual manpower requirements and costs for Interim Care are described
in this section. The work force required to perform Interim Care activities
at the decommissioned MOX fuel fabrication plant is shown in Figure 10.3-1.
Surveillance and maintenance activities are supervised by a full-time
facility manager who reports directly to corporate headquarters. This person
10-30
TABLE 10.3-t. Estimated Annual Costs of Interim Care
Annual Cost in Thou~ands Percent
Cost Category _ __ of 1978 Dollarslal 9f Total
Staff Labor(b) 391 81.6

Supplies and Equipment 2 0.4
Annual Allowance for Repairs 3 0.6
Utilities 60 12.5
Taxes 12 2.5
Insurance 10 2.2
license Fee 1 ·- 0.2
Subtotal 479 100.0
25% Contingency ]20
Total Annual Cost 599
imply precision to the nearest thousan~.doll,rs.
(b) See Table 10.3-2 for cost details. ·· ·
CORPORAl£
HEADQUAR1£RS
THIRD-PARTY
INSPECTIONS 1£AM ..,..__ _-I
SECRETARY
U/2 Tlr.f:l
FIGURE 10.3-1. Postulated Organization Chart for Interim Care
10-31
coordinates the personnel who monitor the operation of the ventilation
system and other operating safety systems; schedules routine and corrective
maintenance and radiation and environmental surveys; performs routine
physical inspections of the facility; arranges for third party inspections
of facility structures and equipment; assures that all regulatory requirements
are fulfilled, and makes routine reports to corporate headquarters and regu-
latory agencies.
A maintenance and operations supervisor and staff of four technicians
are required to monitor the ventilation system and other operating safety
systems on a 24-hour day, seven-day week basis. The technicians are assumed
to be capable of performing routine maintenenace and minor repairs to these
systems.
One full-time employee is required to provide health physics services
and perfonn the radiation and environmental surveys at the facility.
A security force supervisor and staff of four security patrolmen are
required to provide security at the plant on a 24-hour day, seven-day week
basis. During business hours, a patrolman is assumed to be stationed at
the entrance of the building.
Third party inspections are assumed to be carried out by a two-man team
on a semi-annual basis.
Table 10.3-2 shows annual manpower requirements and costs for Interim
Care. Manpower requirements are based on the Interim Care staff organization
chart shown in Figure 10.3-1. Costs are based on unit cost data in Appendix H.1.
Third party inspection costs are based on an assumed cost of $500 per man-
day.
10.3.2 Material and Equipment Requirements and Costs for Interim Care
An annual allowance of $2000 for equipment and supplies is included in
the material and equipment cost estimate. This allowance includes funds for
filter replacement, monitoring supplfes, secretarial supplies, etc •
... j
10-32
TABLE 10.3-2. Estimated Annual Staff Requirements for Interim Care
Annual Cost irJ .
Title or Function Man-Years[Year 1978 Dollars \a,b)
Facility Manager 1.0 63,600

Maintenance Operations Supervisor 1.0 38,400
Maintenance Technician 4.0 108,000
Health Physicist 1.0 36,000
Security Force Supervisor 1.0 34,000
Patrolman 4.0 85,200
Custodian 0.5 12,000
Secretary 0.5 10,100
Third Party Inspection Team(b) 0.03 4,000
Total Man-Years/Years 13.03
Total Costs/Year 391,000
(a) The number of figures carried is for computational accuracy and does
not imply precision to the nearest dollar.
(b) Third party inspection costs are based on an assumed $500 per man-day.
(c) Contingency of 25% is not included in these costs.
Major repairs to monitoring instruments, ventilation equipment, security

alarm systems. etc., are assumed to be made by outside contractors. An
annual allowance of $3000 for major equipment repairs is included in the
cost estimate.
10.3.3 Miscellaneous Owner Expenses During Interim Care
Miscellaneous owner expenses during the Interim Care_phase of Custodial
Safe Storage include the costs of utilities, taxes, license and insurance.
Annual cos·ts for these items are assumed to be comparable to annual costs
during Preparations for Safe Storage, except for the license fee.
10.4 ESTIMATED COST OF DEFERRED DISMANTLEMENT

The estimated costs of Deferred Dismantlement following Custodial Safe
Storage of the reference small MOX plant are summarized in Table 10.4-1.
10-33 l .• •' ~;~ ~-;~;~;~~

. l. ,~, ::~!fWtrL· .·
r;,.'·
~'';".
':·:·
c: .
TABLE 10.4-1. Summary of Estimated Deferred Dismantlement Costs{a)

Cost in Hi Ill OIJS )of Percent of
Cost Category 1978 Dollars Ill Total
Manpower
Planning and Preparation 0.740 12,7
Oec011111tssloning 3.087 53.1
EquiiJIIent and Supplies 0.796 13.7
Disposal of Radioactive flaterlal 0.547 9.4
Miscellaneous ONner Expense 0.484 8.3
Specialty Contractors 0.160 .1._,!
Subtotal 5.1114 100.0
25:: Contingency 1.454
Total Deconmlssloning Costs 7.3
Structure Denolltton and Site Restoration ~
Total Costs Including Site Restoration 7.4
(a) Su111111ry does not include the cost of packaging and disposal to shallow land
burial of the sludge fi'CIIII sewage lagoons that would add an additional
S0.75 mtlllon in waste disposal and contingency costs.
(b) Number of figures shown is for computational accuracy and does not Imply
precis fon to the nearest thousand do liars.
Deferred Dismantlement is estimated to require about 1.5 years (plus""·two

years for planning and preparation) dt a cost of approximately $7.3 million.
Manpower costs represent about 66% of the total cost of Deferred Dis-
mantlement. Manpower costs include both support staff and decommissioning
worker labor costs. In Table 10.4-1, manpower costs are shown separately
for the planning and preparation and the decommissioning phases of Deferred
Dismantlement. Details of manpower requirements and costs for Deferred
Dismantlement are given in Section 10.4.1.
Material and equipment costs represent about 14% of the total cost of
Deferred Dismantlement. Details of material and equipment requirements and
costs are given in Section 10.4.2.
Waste management costs represent about 9% of the total cost of Deferred
Dismantelment. Details of waste management requirements and costs are given
'in Section 10.4.3 •
. J,
Miscellaneous owner expenses and the costs of structure demolition and

,f...
site restoration are assumed to be the same for Deferred Dismantlement as
,, ~· they are for Immediate Dismantlement, measured in 1978 dollars. Specialty
~~:
-~
f.,
;~
10-34
.I
:_~~-?~\~B~%~~~
:-.:?.i
. i•:· -~
.... ;_
contractor costs are also the same, except for those costs resulting from
decommissioning the Sewage Lagoon during Preparations for Safe Storage.
10.4.1 Manpower Requirements and Costs for Deferred Dismantlement
decommissioning activities for Deferred Dismantlement. These work force
estimates are used, together with unit manpower costs given in Appendix H.l,
to estimate Deferred Dismantlement manpower costs. It is assumed that the
work force organizational chart for Deferred Dismantlement is similar to that
for Immediate Dismantlement shown in Figure 10.1-1. The same basic operations
are performed during Deferred Dismantlement as are performed during Immediate
Dismantlement, with the following exceptions:
• The chemical and physical decontamination performed during Preparations
for Safe Storage will not need to be repeated.
• Decommissioning of the Sanitary Lagoon will have been performed during
Preparations for Safe Storage.
• Additional time and manpower (about 16 man-weeks) will be required to
remove seals and barricades erected during Preparations for Safe Storage,
to restore services, and to perform a modest amount of manual decontami-
nation and cleanup.
• All ventilation filters in the bu.ilding will need to be tested and
replaced as necessary. This will require about 16 man-weeks of effort.
• Because Deferred Dismantlement occurs 10 to 30 years after plant
shutdown, training of the decommissioning staff will be necessary during
the planning and preparation phase.
Table 10.4-2 shows manpower requirements and costs for planning and
preparation, and Table 10.4-3 shows manpower requirements and costs for
the decommissioning phase of Deferred Dismantlement. A total of about 18
man-years is estimated to be required for planning and preparation, at a
labor cost of about $0.74 million. In order to minimize owner overhead
and support staff labor costs during dismantlement activities, the decom-
missioning staff is generally sized and structured on a two-shift, five-
day week. A total of about 105 man-years is estimated to be required for
10-35
dismantlement activities, at a labor cost of about $3.09 million. The
total labor cost for Deferred Dismantlement is therefore about $3.8 million
without contingencies.
TABLE 10.4-~. Summary of Manpower Utilization and Staff Costs for

Planning and Preparations Phase of Deferred Dismantlement
C.!!.l.J!.!!!)l.lpn•l'•·bl
Projett ll.:lnagtr 1.00 0.149
ProJect Engineer 2.00 0.111
Health and Safttt 'iupervl,or 0.\11 0.024
tontrec:U and Atc011nUnq SPt'tlalist 1.00 0.032
Aclountant 0.\11 0.012
Aadtoac:tlll'l \Mpnent Spetlalht 0.21 0.008
Q.A. !oglneer l.lJfJ 0.018
Planntn9 (nr,tneer 1.00 0.088
[nf11netr1ng lechntc.tan 1.00 0.021
Matntenanc.e and Crdts Supervhor 0.21 0.010
Operations. Suptrvhor 2.00 0.088
Foreaan 1.\11 0.049
rec.hnltlln 1.00 o.on
Soe<rf'Ury J.r)~ O_.O_L_I
Toul Mtn·1ear\ 18.00
Total Cost 0.140
{a J ~=~r p~!c!!Y~~e: 0\~~;" n!!,.!:~ ~=~::~ t::;:,:~~urtty "'d dot\ not

(b) Conttnqency of 25t h not included tn the\e co\h.
TABLE 10.4-3. Summary of Manpower Utilization and Staff Costs for

Decommissioning Phase of ueferred Dismantlement
HUe or Function Min-Years
Project Klnager 1. SO 0.112

Project £nqtneer I, 50
0.091
Health and Slfety S11pervts.or I.SO 0.011
Health Phy~;fcs. Technician 9.00 0.221
!!.ecurlt)' Foret Supervisor l.SO 0.0!1-1
Security Patro1tnllln 12.00 0.256
Contracts. and Accounting SpechHst I. SO 0.048
Accountant 0.7S
0.010
Sldl AccOI••ltlng Sprcla1tst l.SO
0.0511
SHH Accovnttng Clerk D.71!1
0.018
Rtdtoactlve Shiprrent Specto~1ht I. !tO
0.049
Q.A. Engineer 1. so
0.066
Pldnntng lngln-rer 1. SO 0.066
tnylnHrlng Technician 0. 75
0.020
ttatntenance and Crafts Supervhor 1.'!!0 0.061
Ha tntenance Man 3.00 0.078
CustOdian L!u) 0.036
Craftsrun 15.00 0 .•05
'"'· Operat tons Supervhor l.OO
0.131
forem.n 9.00 0.196
lechniun Jl.OO
-t?' 5ecretlrY 3.00
0.864
0~
Total Htn-Yean 104,75
' ~-
r..
fatal Cost 3.087
\·' (a) ~umber of figures shown h for CQIIIJ!IutatiOJII1 accuracy and does not IIIIPIY
Jj pre~: Is ton to tht ne1rest thouSind dollars.
/: (b) Jnfonllltlon given ts for support staff ud dec:anatsstonlag MOrken.
(t) Contingency h not Included litre.
~
t;
f
~ 10-36
i
I
10.4.2 Material and Equipment Requirements and Costs for Deferred
Dismantlement
Estimates of material and equipment requirements and costs for Deferred
Dismantlement are shown in Table 10.4-4. Material and equipment costs are
expected to be about the same for Deferred Dismantlement as they are for
Immediate Dismantlement, except for slight decreases in the requirements
and costs for decontamination chemicals and cleaning supplies. HEPA and
roughing filters will have been replaced as needed during Interim Care
activities. It is estimated that about 10% of these filters will need to
be replaced at the start of final dismantlement activities.
10.4.3 Waste Management Requirements and Costs for Deferred Dismantlement
Table 10.4-5 gives estimated weights and volumes of decommissioning
wastes from Deferred Dismantlement .of the reference MOX plant, together
with packaging, shipping and disposal requirements for these wastes. The
estimated costs of containers, transportation and disposal of the radioactive
wastes from Deferred Dismantlement are summarized in Table 10.4-6. Cost
estimates are based on projected packaging and shipping requirements in
Table 10.4-5 and on waste management cost data in Appendix H.l. The total
waste mandgement cost for Deferred Dismantlement is estimated to be $0.5
million without contingencies.
10-37
TABLE 10.4-4. Estimated Material and Equipment Requirements and Costs
for Deferred Dismantlement
Estimated Estim~ted
- - - - - - Descri ..::Pt:.:i""on"-------- guitntit~ {~ Thousand!l U Tl;ausand.tl.
_2xra..cetyle~e Tor_ch , ., ·-··· 2. ea '"'~_, l,. ·-~· . .• ·.,J·· t'· ' ....1 ..
Portable Plasma Cutting Torch 4 ea 20 80
Arc Saw 1 ea 100 100
Guillotine Pipe Saw 2 ea 1 2
Tube Cutter 2 ea 0.3 0.6
Ratcheting Pipe Cutter 6 ea 0.05 0.3
Reciprocating Saw 4 ea 0.5 2
Nibbler 2 ea 1 2
High Velocity Liquid Jet ea 2 5
Low Veloci~J Liquid Jet 1 ea 2 ..
~
Hydraulic Concrete Surface Spalling Device 1 ea 5 5

Concrete Od 11 2 ea 0.2 0.4
Electric/Pneumatic Hammer 2 ea 0.5 1
Protable Filtered Ventilation Enclosure 1 ea 1.5 1.5
Supplied Air Bubble Suit 200 ea 0.05 10
Electropolishing Decontamination System 1 ea 100 100
Waste Compactor 1 ea 12 12
HEPA Fi 1ter 25 ea 0.15 3.75
Roughing Filter 25 ea 0.05 1.25
Decontamination Chemicals 12
Expendable Tools 100
Protective Clothing (including laundry) 78
Office Supplies
Dismantlement 25
Cement 0.7
Total 796(a)
(a) Total is shown as direct addition of the prior numbers to retain calculational information.
Precision is less than shown.
10-38
TABLE 10.4-5. Estimated Waste)D1sposal Requirements for Deferred
Dismllntlement(a

'
waste Category (kg) -~ Type Containers Shi1111ent Shi!!!l!ents
G) gye 80KJ!S and Hoods 4S,OOO 40.§.. ).2 X 1.2 X 1.8-m ~6 3 6

Steel Box
Tanks and Equipment 7,000 6.4 1.2 X 1.2 X 1.8-m 3 3

Steel Box
HEPA and Roughing Filters 11,000 34.3 1.2 X 1.2 X 1.8•m 14 3 5

Steel Box
Concrete Rubb 1e 24,000 20.0 208·1 (55-gal) 100 42 3

Steel Drum
Solidified Decontamination 41,600 )3.0 208- t ( 55-ga 1) 65 3

Liquids Steel Drum
Trash 208-t (55-gal) 42
Steel Drum
Totals 160,000 153. 33 boxes 23
360 Drums
Disposal by Shallow Land Burial
G1ove Boxes and Hoods 106,000 94.2 2.6-m 3 Plywood Box 36 6 6

Tanks and Equipment 114,000 101.8 2.6-m 3 Plywood Box 40 6
Piping, Valves and Ductwork 80,000 ..1..L.Q. 2.6-m 3 Plywood BCIX ..1!! 6 2
Totals 300,000 267. 104 18
Sludge from Sewage Lagoon(b) 3,500,000 2,930 2.6-m3 Plywood Box 1,127 6 188
(a) Number of figures shown is for computational accuracy and does not imply precision to three or four
significant figures.
(b) Listed for information purposes in the event that sludge removal is required. llot included In
totals.
(c) Number of containers per shipment Is limited by weight rather than by volume.
10-39
-. ·~······-·· ------·-----. --- - - - - - - - - - - - - - - - - -

.,.
IT'
:~,.'C.
TABLE 10.4-6. Estimated Costs for Packaging, Transportation

and Disposal of Radioactive Material from
Deferred Dismantlement
Costs in T~ousands of 1973 Dollars(a)
Waste Category Container Transportat1on Burial__ Totals(c)

Tanks and Equipment 3.8 4.0 16.4 24.2
HEPA and Roughing Filters 18.0 19.0 76.!1 113.4
Concrl!te Rubble 4.4 12.7 44.1 61.2
Solidified Decontamination 3.7 13.4 28.7 45.8
liquids
Trash 7.9 20.0 86.0 113.9
Subtota 1s 58.6 93.2 339.0 491.
Disposal by Shallow Land Burial
Tarl.:s and Equipment 5.20 6.70 9.78 21.7
Piping, Valves and Ductwork 3.64 ~ ~ ____1hl
Subtotals _1_l,.i_ ...lh?._ 25.4 ~
Totals w/o Sludge 72 110 364 547
Sludge from Sewage Lagoons(b) 146.5 180.0 275.4 602
Totals with Sludge 219 290 640 1 ,149
(a) Number of figures shown is for computational accuracy and doe~ not imply three-placa
precision in waste management cost figures.
(b) Listed for information purposes in the event that sludge removal is· required. Not
included in totals.
(c) Costs do not include 25% contingency .
..
f•
10-40
10.5 COST ESTIMATES FOR ENTOMBMENT
The estimated costs for Entombment of the reference small MOX plant
are summarized in Table 10.5-1. Entombment is estimated to require about
0.65 years (plus 1.5 years for planning and preparation) at a cost of approxi-
of
.. mAtely $2.4 million. ···rhis-cost does not.. iriclude the-co~ts .. demoliti~n dt . ·-
the unrestricted portion of the facility or of burial of the entombed portion
under an earthen mound. These activities are postulated to occur at some
future time (see Section G.4. 10) and are estimated to cost an additional
$0.4 million in 1978 dollars.
TABLE 10.5-1. Summary of Estimated Entombment Costs(a)

Cost in Millions Percent of
Cost Category of 1978 Dollars(b) Total
Manpower -
Planning and Preparation 0.447 22.9
Entombment 0.845 43.3
Equipment and Supplies 0.379 19.4
Disposal of Radioactive Material 0.072 3.7
Miscellaneous Owner Expense 0.113 5.8
Specialty Contractors 0.096 4.9
Subtota 1 1. 952 100.0
25% Contingency 0.488
Total Decommissioning Costs 2.440
Future Burial of Concrete
Monolith in Earthen Mound 0.386
Total Costs Including Future Site Work 2.8
(a) Summary does not include the cost of packaging and ~isposal to shallow
land burial of the sludge from sewage lagoons that would add an additional
$0.75 million in waste disposal and contingency costs.
(b) Number of figures shown is for computational accuracy and does r~t imply
HHl
I;:,m,~~j
Manpower costs include both support staff and decommissioning workers and
represent about 66% of the total cost of Entombment. In Table 10.5-1,
manpower costs are shown separately for the planning and preparation and the
decommissioning phases of Entombment. These costs include onsite labor for
packaging radioactive waste materials for shipment. Labor costs related to
radioactive waste transportation
.. ._,_ are
.
included in waste management
.- .. . ··-co~ts.
~ -· ·~
since transportation is performed by a specialty carrier.

The Wirand concrete,( 5 ) which is listed in Table 10.5-4, is expens.ive
(about $100/m3 ) but provides an extremely durable cap for the entirP. entomb-
ment. Conventional concrete for the bulk of the entombment project can be
designed for long-range durability at conventional concrete prices. ( 6) Conven-
tional concrete, when protected by a protective cover Of earth, has been obser-
ved to last for more than 20 centuries. <7>
Waste management accounts for about 4% of the total cost of Entombment.
Waste management costs include shipping container costs, transportation charges,
and fees for waste disposal at commercial shallow land burial sites or at a
federal r·~pository for deep geologic disposal. Container costs, transportation
charges, and disposal fees are all significantly higher for wastes shipped
to deep geologic disposal than they are for wastes sent to shallow land burial.
For Entombment, contaminated equipment and materials are largely buried
in concrete within the building structure.<a,g) Only the last bank of HEPA
filters in the exhaust system and the exhaust fans remain to be disposed of as
contaminated waste. The roughing and HEPA filters are shipped to deep geologic
disposal. The exhaust fans and associated ductwork are sent to shallow land
burial.
If the contaminated sludge in the sewage lagoon requires treatment a~d
disposal, the cost (including contin9ency of packaging, shipping and disposal
of the sludge) is estimated to be about $0.75 million. Thus, a substantial
increase in decommissioning costs results if the sludge in the lagoon requires
disposal. In this study, it is assumed that the 5ludge is left in place and
covered by a mound of soil (see Section G.3.3.2}. The cost of this treatment
option is summarized in Section 10.1.5.
10-42
10.5.1 Manpower Requirements and Costs for Entombment
decommissioning activities for Entombment described in Section G.4. These
work force estimates are used, ~ogether with the unit manpower costs given
in Section H.l, to estimate Entombment manpower costs. The bases for these
manpower estimates and... .the__ results in term~ .of decommissioning manpower costs
,, ~
.. . ... ~ • • - ~· i
are described in this section.

The decommissioning work force organizational chart for Entombment is shown
in Figure 10.5-1. The work force is described in two parts: 1) the decommis-
sioning support staff that plans, supervises and provides supporting activities
for the decommissioning activities, and 2) the decommissioning workers who
perform the actual decommissioning activities. The seven ~eneral types of
functions performed during decommissioning are described briefly below:
• Project Manager - prepare and implement the decommissioning plan
in a safe and cost-effective manner.
• ~lity Assurance (OA) - develop the QA plan and monitor the safety
and performance of the decommissioning activities.
• Decommissioning Operations - develop the decommissioning plan and
carry out the actual decommissioning activities.
• Plant Operations and Maintenance - operate and maintain plant
equipment that must be operated during_ the decommissioning.
• Health and Safety Protection - develop methods to assure the
protection of the health and safety of the public and decom-
missioning workers.
• Security and Safeguards - provide protection of the site and
facility from unauthorized entry and safeguard Special Nuclear
Material (SNM).
• Support Services - provide accounting, procurement and stores, and
secretarial and clerical services in support of the decommissioning
activities.
10-43
I CORPORATE
HEADQ~RTERS
I
SAFETY
REVIEW !"'-
CCX\WITTEE
..,....,.. ---- ·- . ..,... - • .. _., -.:.l.--

·- :!!:,; ~.., .. - ••.• -
~ I
PROJECT
MANAGER
1 SECRETARY r
I I I I
HEALTH AND CONTRACTS AND SECURITY
QA
SAftTY ACCOUNT! NG FORCE
ENGI~ER
SUPEitvl SOR SPECIALIST SUPERVISOR
I I I
HEALTH
PHYSICS
TECHNIC IANS-4
ACCOUNTANT SECURITY
PATROLMEN-8
I
PLANNING PROJECT ENGINEER
IDAY SHifT) SECRETARY
ENGINEER
ASS I STANT PROJECT ENGINEER
!NIGHT SHIFTI
J
I
MAINTENANCE AND
CRAFTS SUPERVISOR
-WELDER
I I TYPICAL
DECOMMISSIONING CREW
-FOREMAN
I SPECIALTY CONSTRUCTION
_
CONTRACTORS
PRESSURE GROUT It£ 0 F FLOORS
- PIPEFITTER f-- 4 TECHNICIANS AND FOUNDATIONS
~ SUPPLY CONCRETE FOR
-ELECTRICIAN f-- HEALTH PHYSICS TECHNICIAN lal
ENlOMBMENT
-CARPENTER ~ CRAFTSMAN lal
CONSTRUCTION OF EARTHEN "'lUND
- MAINTENANCE MAN ......._ OVER ENlOMBED STRUC JURE
- CUSTODIAN
'lij.:
tal ASSIG~D TO WORK CREWS AS WORK SIT~TION
DEMANDS: COUNTED ONI. YONCE
FIGURE 10.5-L Postulated Organization Chart fo1· Entombment
10-44
Job description details for key individuals in the dismantlement staff
organization are given in Section 10.1 and Section H.2 (Vo1ume 2).
Actual decommissioning activities are carried out by crews that consist
of a foreman, two to six decoJnmissioning technicians, and health physics
.. technicians and craftsmen who are added as the worl: situatjo.'l-demands.
- ...., . . . .- ;..· • • ··- -· w -.--- ·-· _, . . . . : - - -r •• -··-- - -
A key assumption in estimating the manpower and time for the basic events
is that the decommissioning work force is composed primarily of former plant
operating and maintenance personnel. The decommissioning workers are there-
fore familiar with plant facilities and equipment and are experienced with
radiation working procedures.
The decommissioning staff is largely designated during the planning and
preparation phase, while they are still employed in operations work. Initial
decommissioning management staff consists of the project manager, project
engineer, quality assurance engineer and the operations supervisor who becomes
the maintenance and craft supervisor during decommissioning. Other staff
personnel are added as their services are required during the planning and
preparation phase. Planning and preparation activities take place during the
final 18 months of plant operation. Therefore, support activities such as
plant maintenance and plant security are available as part of plant operations
and are not charged to decommissioning during the planning and preparation
phase.
In order to minimize owner overhead and support staff labor costs, the
decommissioning staff is generally sized and structured on a two-shift, five-
day week during the first 18 weeks and then on a one-shift basis for the
remaining 16 weeks. Occasional maintenance and craft work is scheduled for
the night shift during the final 16 weeks. Security is carried out on a four-
shift, seven-day week. Decommissioning activities require that workers wear
protective clothing, and in some cases, air-support bubble suits. Because
of the inconveniences of the p~sical environment in which decommissioning
tasks are carried out, manpower requirements are developed on the basis of
an assumed worker time efficiency of 75%.
10-45
,
'•.·.·
'
'

Table 10.5-2 shows manpower and associated cost estimates for the planning
and preparation phase of Entombment, and Table 10.5-3 shows manpower require-
ments and costs for the decommissioning phase. A total of about 9.5 man-years
is estimated to be required for planning and preparations, at a labor cost of
about $0.45 mill im·~- ... .A.. tot.al of--abGir~---;re.,,.a~~years Is ·estia1ated to be-required
to entomb the facility, at a labor cost of about $0.85 million. The total
labor cost for Entombment is therefore about $1.3 million without the cost of
specialty contractor personnel or contingencies. Manpower costs shown in
Table 10.5-3 include labor costs for packaging rildioactive waste materials
for shipment. These costs do not include labor costs for transportation of
the wastes o• for specialty contractors.
TABLE 10.5-2. Summary of Manpower Utilization and Staff Costs

for Planning and Preparation Phase of Entombment
Title or Function Man-Years Cost {$ Millions)(a,b)

Assistant Project Engineer 0.50 0.032
Foreman 1.00 0.033
Secretary 1.50 !).031
Total Cost 0.447
" (a) Number of figures shown is for computational accuracy and does not imply
(b) Contingency of 25% is not included in these costs.
10-46
TABLE 10.5-3. Summary of Manpower Utilization and Staff Costs
for the Entombment Phase
Title or Function Man-Years(a) Cost ($ Millions)(b,c)
... ProJ.,oot··E~1neer ... · -- · •. ·--··-· -·- ,._ ·--· -- .9. 6$ -0.041 . ·- ................
Assistant Project Engineer 0.35 0.022
Health P~sics Technician 1.72 0.043
Security Force Supervisor 0.65 0.022
Security Patrolman 5.20 0.111
Planning Engineer 0.65 ·":
0.029
Maintenance and Crafts Supervisor 0.65 0.026
Maintenance Man 0.65 0.017
· Custodian 0.65 0.016
Craftsman .- 2.68 0.072
Foreman 2.14 0.070
Technician 7.88 0.213
Secretary 1.30 0.026
Total Cost 0.845
(a)Information given is for support s~ff and for decommissioning workers.

(b)Number of figures shown is for computational accuracy and does not imply
precision'to the'nearest thousand dollars.
(c)Contingency of 25% is not included.
It should be r~cognized that completion of decommissioning activities will

occasionally take longer than anticipated, resulting in increased labor costs.
Often, these cost increases can be offset by reducing the labor force after
the most labor-inte~sive tasks are completed. The final deactivation and
cleanup activities, for example, can be accomplished by a relatively small
group.
10-47
10.5.2 Material and Equipment Requirements and Costs for Entombment
Estimates of material and equipment requirements and costs for Entombment
are shown in Table 10.5-4. Equipment requirements are based on decommission-
ing procedures described in detail in Appendi~ G. Cleaning supplies include
assorted cleaning agents. rags, mops. brushes. plastic bags. pla,~tjc sheeting..,.
<f -· ..... ~- -·· • -··P· '.. •· . '' • . ..-
• • •• •·&::.,•• .,.-•·· -
etc. The cost of protective clothing includes the cost of laundering the
clothing by an outside contractor and is estimated to be about $500 per week.
The total cost of material and equipment for Entombment of the reference MOX
~lant is estimated at about $0.4 million without contingency.
TABLE 10.5-4. Estimated Material and Equipment Requirements

and Costs for Entombment
Estimated Estimated
Descri~tion guantitl {$ Thousands) {$ Thousands)
Oxyacetylene Torch 1 ea. 1.0

Hydraulic Concrete Surface 1 ea. 1 1.0
Hydraulic Concrete Surface 1 ea. 5 5.0
Spall ing Device
Concrete Drill 1 ea. 0.2 0.2
Track Drill (1 mo. rental) 1 ea. 0.4 0.4
Electric: Pneumatic Hammer 1 ea. 0.5 0.5
Supplied Air Bubble Suit 20 ea. 0.005 1.0
Decontamination Supplies 10.0
Expendable Tools 10.0
Protective Clothing (including
laundry) 17.0
Office Supplies -
Planning and Preparation 25.5
Dec:011111iss ion i ng 10.0
Concrete 4100 m3 0.05 205.0
lfirand Concrete 300 m3 0.10 30.0
Paint 8400R. $2.65/1 22.3
Materials for greenhouses. plastic ____1Q_,_Q_
temporary exhaust ducts and con-
cretf= fonn 1umber
Total 379.(a.b)
·'
(a) Total is shown as direct addition of prior numbers to retain calculational

information. Precision is less than shown.
(b) Contingency of.25S is not included here •
. 10-48
10.5.3 Waste Management Requirements and Costs for Entombment
Estimates are made of the quantities of radioactive wastes generated durtng
Entombment of the reference MOX plant and of packaging, transportation and
disposal requirements and costs for managing these wastes. These estimates
···----!!:~.J)_as~d..JUI. et:~:!;QitJIKger:tt NP.C..Q.(i.W'...BL.t:l.escribed in ..Sec.t.i!Jr.t .G.4 and oo--untt \'laste • ... --- ._.,..
management costs given in Section H.l. Waste management requirements and costs
for Entombment are described in Section H.4 and summarized here.
10.5.3.1 Waste Management Requirements
Contaminated wastes are managed for Entombment in the following manner:
• Prior to placement of concrete, contaminated equipment and exhaust
ductwork from Fabrication Room 123, Maintenance Room 116, and the
laboratory areas are transferred into the entombment area.
• The exhaust ductwork in the space over the East-West Corridor
is removed, cut into small sections that can be stacked vertically,
and filled with concrete.
• Roughing and HEPA filters are entombed, except for the final
exhaust filters in Room 201. These are shipped to deep
geologic disposal.
• The contaminated locker-room floor drains and associated piping
are excavated and entombed.
• Contaminated work clothing, materials used in greenhouses, decon-
tamination materials, and broken tools become "trash" and are
cemented into 208-1 (55-gal) drums and transferred into the
entombed area. Trash occurring too late to be entombed is
sent to deep geologic disposal.
• The contaminated equipment and structures of Room 124, 125, 126,
127, 128, 155, 156, B-01, B-02 and B-05, plus the contaminated
equipment mentioned as being moved into these rooms, are entombed
in place.
10-49
...
,
~- .
'
'
',
• Possibly, sludge from the sewage lagoons may have to be removed. (See
Sections H.4.2.1 and G.3.3.2 for discussions of this possible problem.)
• The soil from excavation of sewage drain lines is surveyed for contami-
nation. No contamination is expected, but a small quantity of soil
may have to be packaged and shipped to shallow land burial.
, .. ~<»- •• • ··~··--· • l'he.bulk of the material that'musTbe- pickaged for disp~~~l will be
contaminated with plutonium and uranium. The NRC has proposed adoption of
a rule requiring that all wastes contaminated with more than 10 nanocuries
of transuranic elements per gram of waste be classified as TRU wastes(l) and
shipped to a federal repository. Non-TRU wastes ~re assumed to be disposed
of at shallow land burial sites (see Section 10.1.3.1).
All shipments of decommissioning wastes are made in compliance with
federal, state and local regulations as described in Section F.3.2.
Table 10.5-5 gives estimated v1eights and volumes of decommissioning
wastes from Entombment of the reference MOX fuel fabrication plant, together
with packaging, shipping and disposal requirements for these wastes. Detailed
information about waste quantities is given in Section H.4. It is assumed
that the sludge from the sewage lagoon would not require removal. However,
an estimate of packaging and shipping requirements for removal of contaminated
sludge from the sewage lagoon is given separately in the event that sludge
removal is required.
10.5.3.2 waste Management Costs

The estimated costs of container, transportation and disposal of the
radioactive wastes from Entombment of the reference small MOX fuel fabrication
plant are summarized in Table 10.5-6. Cost estimates are based on projected
packaging and shipping requirements summarized in Table 10.5-5 and on unit
cost data in Section H.l. Waste management cost details are given in
Section H.4.
10-50
TABLE 10.5-5. Waste Disposal Requirements for Entombment{a)
i
'I
~
Shipping SMpping Number Containoi!rs Number of

Weight Vol~me Container of per i Truck
Waste Categor~ (kg) (m ) T~l!e Containers Shi(!!!!e'~t Shipments
;
Dee2 Geologic Disl!osal
Exhaust HEPA and Rough-
ing Filters 6,000 18.7 1.2 X 1.2 X 1.8-m 8 3 3
Steel Box
Trash 3,800 __bi 208-R. (55-gal) 12 42 t Q.(cj
Steel Drum ,
i
Totals 9,800 21.1 20 • 3
Dis2osal b~ Shallow Land Burial
Exhaust Fans 1,600 4.5 2.6-m3 Plywood &ox 2 6
Sludge from Sewage Lagoon(b) 3,500,000 2,930 2.6-m3 Plywood Box 1,127 6 • 188
-'
~ (a)Number of figures shown is for computational accuracy and does not imply accuracy to three or four significant
~ figures. ~
(b)Li~ted for information purposes in the event that sludge removal is required. Not included in totals.
(c)Tra..t1 is shipped with partial shipment of HEPA and Roughing Filters. \
~.~4~~ ,. ··' .....
-~~j;;t.:
=~~·.~;."'.-=-
Disposal of Radioactive Material from Entombment
Costs in Thousands of 1978 Oollars(a)

Waste Category Container Transportation Burial Total
Dee2 Geologic Dis~osal
HEPA and Roughing Filters 10.4 11.4 43.7 65.5

Trash _Q_:]_ _o.o(d) _5.3 -~~
Subtotals 10.7 11.4 49.0 71.1
Ois~osal 8~ Shallow Land Burial
Exhaust Fans 0.3 0.6 0.5 1.4
Subtotals w/o Sludge 11.0 12.0 49.5 n.5
Sludge from Sewage Lagoons(b) 146.5 180.0 275.4 §01.9
Totals with Sludge{c) 157.5 192.0 324.9 674.4
{a) Number of figures shown is for computational accuracy and does not imply
three or four place accuracy in waste management cost figures.
(b) Listed for information purposes in the event that sludge removal is required.
(c) Contingency of 25% is not included here.
(d) Transportation charges for trash are included with charges for shipment
of filters.
The total waste management cost for Entombment is estimated to be about

$0.07 million without contingency. If packaging and disposal of the sludge
in the sewage lagoon is required, it would add about $0.6 million {without
contingency) to this cost.
10.5.4 Miscellaneous Owner Expenses for Entombment
Estimated miscellaneous owner expenses for Entombment are shown in
Table 10.5-7.
Utility costs and property tax charges are based on actual experience
at the reference plant. Utility costs are based on an average charge of
~bout $5,000 per month. and property taxes are based on a charge of approxi-
i- m~tely $12,000 for calender year 1977.

1'·
t
~;
W.·
~·'
~'
ri;
tl: 10-52
l{i
t,q
TABLE 10.5-7. Estimated Miscellaneous Owner
Expenses for Entombment
Cost 1n Thous4nds of
Cost Category 1978 Oollars{a,b)
UtHities 39
Taxes a(c)
License Fee l(d)
Insurance 65(c)
Total 113
(a) Number of figures shown is for com-

putational accuracy and does not
imply precision to the nearest
thousand dollars.
(b) Contingency of 25% is not included
here. .
(c) Based on estimated time period.
(d) Assumed fee for a "possession only"
license.
The operating license fee for a MOX plant is currently set by the NRC
at $215,000 per year.( 3) The amount of this fee that would have to be paid
during the decommissioning period has not been determined. For estimating
decommissioning costs,· it is assumed that the fee for a possession-only
license ($600 per year)(J) or a modified operating license is applicable.
The cost of nuclear liability insurance for a facility being decolllllis-
sioned has also not been determined. An allowance of $100,000 is included
for the annual insurance premium for nuclear liability and conventional
insurance. For the 34 weeks needed to entomb the reference MOX facility,
this cost is estimated to be $65,000.
10.5.5 Specialty Contractor Costs for Entombment
Specialized services are required to accomplish the entombt!lent of the
reference small MOX plant. These.servir.es are assumed to be supplied by the
specialty contractors listed below. Costs shown do not include the 25% con-
tingency used when summing the total decommissioning costs in this study.
10-53
10.5.5.1 Foundation and Floor Grouting Contractor
The cost estimate for the services of the foundation and floor g1·outing
contractor is shown in Table 10.5-8.
TABLE 10.5-8. Cost Estimate for Foundation and

Floor Grouting
Item Basis Cost ($fa)
Grout needed for floor

repair 76.0 m3 at $72tm3 5,472
Grout needed for founda-
tion repair 22.5 m3 at $72/m 3 1,620
Equipment rental 5,000
One (1) foreman 35 days at $130/day 4,550
Four (4) laborers 35 days at $114/day ]5,960
Subtotal 32,602
Add 10% Overhead -3,260
35,862
Add 10% Profit 3,586_
Total 39,448
(a} Number of figures shown is for computational accuracy and

does not imply accuracy to three or four significant figures.
10.5.5.2 Foundation Consultant

An expense related to Section 10.5.5. 1 is a specially qualified founda-
tion expert who guides and inspects the work of the foundation and floor
grouting contractor. Such a qualified expert is available from the Portland
Cement Association, Skokie, Illinois. We estimate his services at $400 per
day for 35 days, at a total cost of $14,000.
10 .. 5.5.3 ~rane Rental
io assist in the placement of the concrete in the basement, the first
floor and the Wirand concrete cap on the roof, a crane is rented, the cost
of which is estimated as follows:
10-54
Activity Basis - - - Cost
Crane Rental $3,500/wk x 10 wks = 35,000
Equipment Operator (2} - $750/wk x 10 wks = 7,500
Total $42,500
10.5.6 Building Demolition, Earth Protective Cover for Entombment and

Site Restoration
The estimated costs of demolition of the portion of the MOX plant released
for unrestricted use and of the earth protective cover for the entombed
structure are listed in Table 10.5-9. The walls and roofing of the conventional
structure are removed. The slab-on-grade floors and the foundations are left
in place and are enclosed within the earth mound. The pre-stressed concrete
panels from the roof and outside walls are available for salvage. Concrete
rubble can be used as part of the earth mound.
10.6 COST CO~lPARISONS
Table 10.6-1 compares total estimated decommissioning costs for the

Deferred Dismantlement and Entombment decommissioning options with the
estimated cost of Immediate Dismantlement. All cost estimates are shown in
1978 dollars and include 25% for contingencies. Costs are shown for dismantle-
ment deferred for 10 years and for 30 years.
Activities incl~ded in the decomm~ssioning cost estimates for Deferred
Dismantlement include preparation of the facility for Safe Storage, Interim
Care, and Final Dismantlement. The total costs for decommissioning the
reference small MOX plant, measured in 1978 dollars, are significantly higher
for Deferred Dismantlement than they are for Immediate Dismantlement. The
cost of Entombment is the smallest, but requires that the site be dedicated
as a nuclear wa~te disposal site in perpetuity.
.~
10-55
l·'
r,._
~·.- . .
... ·._
.·. ~-
..
TABLE 10.5-9. Costs of Building Demolition, Earth Protectivt

Cover for Entombment and Site Restoration\a,b}
(a) For a discussion of h~w to provide for this future expense, see Section 6.
(b) Labor and equipment costs have been taken from Reference 4 and have been
increased 30% for inflation.
10-56
· - - - - ------==============::;:·.-: :. ·. •c..J
'::::J•
""'--- -· --::.-:::~-::::-::::;-~::.::.::-=====:::...:-.· - ·-· ··-·- ·-·~~-
TABLE 10.6-1. Cost Comparison for Decommissioning Options

Estimated Costs in Millions of 1978 Dollars(a)
Custodial Safe Stor-
age with Deferred(")
Dismantlement After b
Immediate
Item Dismantlement 10 Years 30 Years Entombment
-
0
I
U1
......
Initial Decommissioning
Interim Care
7.7 3.5
5.4
3.5
17.4
2.4
<0.1
Deferred Dismantlement 7.3 7.3
Burial (onsite) 0.4
Total Costs
-
7.7
--
16.2
---
28.2 2.8
(a) Costs include 25% contingency. Structure demolition and site restoration not
included.
(b) Includes nine years of Interim Care.
:·:.
jJ
.i>il"'~",;;....~ .
~.
. ·i~ r~ ~
..
-
~::tt~~
~EFERENCES
1. Proposed Rulemaking on Transuranic Waste Disposal. Published in

Federal Register, Volume 39, No. 32922, September 12, 1974.
2. D. A. Edling and J. F. Griffin, Certification of ERDA Contractors
Packaging With Respect to Compliance with DOT Specification 7A
Performance Requirements, MLM 2228, Monsanto Research Corporation,
Mound Laboratory, Miamisburg, OH, June 1975.
3. Title 10, U.S. Code of Federal Regulations. Part 170.21, Revised
January 1977.
4. R. S. Godfrey, ed., Building Construction Cost Data 1975, R. S. Means
Co. , Duxbury, MA, 1975.
5. WIRAND CONCRETE - State of the Art:
{a) P. J. Robins and R. W. Calderwood, "Explosive Testing of
Fibre-Reinforced Concrete," Concrete, January 1978.
(b) C. D. Johnston, "Steel Fiber Reinforced Mortar and Concrete -
a Review of Mechanical Properties," in American Concrete
Institute Publication SP-44, pp. 127-142, 1974.
(c) State-of-the-Art Report on Fiber Reinforced ,Concrete, ACI
Committee 544, Title No. 60-65, Journal of the American
Concrete Institute, 1973. In ACI SP-44, 1974, pp. 535-550.
6. ACI Manual of Concrete Practice 1974 Part I Materials and Properties
of Concrete, p. 201-1, American Concrete Institute, Redford Station~
Detroit, MI .
1. M. Andronicos, "Regal Treasures from a Macedonian Tomb," National
Geographic, July 1978.
8. Design and Control of Concrete Mixtures, Eleventh Edition, Portland
Cement Association, 5420 Old Orchard Road, Skokie, IL.
9. R. 0. Lokken, A Review of Radioactive Waste Immobilization in Concrete,
PNL-2654~ Batte'lle, Pacific Northwest Laboratories, Richland, WA,
June 1978.
10-58
11.0 PUBLIC AND OCCUPATIONAL SAFETY OF DECOMMISSIONHJG A
REFERENCE SMALL MOX Fl!El FABRICATION FACILITY
Public and occupational safety impacts from decommissioning activities

at the reference small MOX fuel fabrication plant are identified and evalu-
ated, and are summarized in this section. The safety evaluation includes a
consideration of the imr)acts of public radiation exposure, occupational
radiation exposure, industrial accidents, and chemical pollutants. This
evaluation utilizes cut•rent data and state-of-the-art methodology to estimate
the information required. A conservative approach, using parameters that tend
to maximize the consequences, is used to evaluate the safety impacts of each
decommissioning activity. Safety assessment details are provided in Appendix I.
.,
I
.i
The safety evaluation is divided into three major parts: 1) Public
'I
Safety, 2) Occupational Safety, and 3) Transportation Safety. Within each of
f the!>w major parts ar-e discussions of the radiological and nonradiological
impacts of both routine and accident situations. Public radiological con-
siderations are determined by using the atmospheric release scenarios in
Appendix 1 and the radiation dose methodology presented in Appendix E of
Volume 2. Occupational radiation doses are estimated using information about
expected dose rates and man-hour job requirements discussed in Appendices C,
G and JL
The decormtissioning modes selected for analysis are Immediate Dismantle-
ment, Custodial Safe Storage with Deferred Disman~lement, and Entombment, as
discussed in Sections 4 and 9.
The radiological saf~ty evaluation is accomplished by calculating radia-
tion dos.es to the public from airborne radionuclide releases, and to the
deconmissioning workers from external exposure to surface contamination. For
Immediate Dismantlement, the 50-year population dose commitment to the bone
I from routine airborn~ release (i.e., does not include transportation) is cal-
l culated to be about 2.2 man-rem, and the 50-year dose commitment to the
~ maximum-exposed individual from the worst postulated accident is calculated to
be about 0.11 rem to the maximum-exposed organ (bone). Radiation doses to the
11-1
•.
public resulting from Preparations for Safe Storage and Entombment (short
term) are about a factor of 20 less than those calculated for Immediate
Dismantlement. The safety implications of entombing and storing long-lived
(>>100 years) rad1onuc11des on the surface of the earth are not analyzed.
Analysis of these future safety impacts over the time period (tens of thou-
sands of years) needed to allow plutonium to decay is beyond the scope of
this study. However, an extremely conservative case is examined for the
likely eve~t of mar. ;ntrusion into the entombed facility after knowledge of
the :ac1lity i~ deemed to be lost (>1000 years.) For this extreme case, the
intruder receives a potential 50-year radiation dose commitment to the bone
Of 7.0 X 105 rem.
The estimated occupational radiation dose is calculated to be about

70 ;nan-rem for either Immediate or Deferred Dismantlement; about 23 man-rem
for Preparations for Safe Storage, plus about 7.1 man-rem for each year of
Interim Care; and about 9.4 man-rem for Entombment.
Radioactive waste material transportation activities associated with
decommissioning are estimated to give radiation doses to the total population
along the transport. route of about 1.5 man-rem for Immediate or Deferred
Dismantlement, about 0.4 man-rem for Preparations for Safe Storage, and about
0.15 man-rem for Entombment. Occupational doses from the transportation of
radioactive wastes are estimated to be about 6.4 man-rem from Immediate or
Deferred Dismantlement sh1pments, about 1.7 man-rem from Preparations for
Safe Storage shipments, and about 0.63 man-rem from Entombment shipments.
These radiation doses are either comparable with or less than radiation
doses calculated for similar activities (i.e., decontamination, maintenance,
waste handling) at an operating small MOX plant, because of the reduced radio-
nuclide inventory during decommissioning, carefully designed procedures that
minimize atmospheric releases. and the utilization of existing process and
building ventilation filtration systems.

The results of the safety evaluation. which are summarized in this section,
are based on the following key assumptions.
11-2
1. The maximum potential radiological consequences of a decommissioning
operation are assumed to be associated with performing the activity 1n
the area of the MOX plant with the highest radionuclide inventory.
2. The maximum release of ra~ioactivity for a specific type of decommissioning
activity is assumed to apply to that activity whenever it is used in
the facility. In performing the dose calculations for releases of radio-
nuclides from normal activities, the estimated releases for the entire
decommissioning period are summed and assumed to be released during a
one-year period. Estimating the releases and their consequences in such
a manner is conservative. but a conservative estimate compensates
for uncertaintie~ in the analysis.
3. ~1onitoring,ventilation and other support systems required during any
given decommissioning phase are assumed to be functional with their
operability confirmed prior to the start of a decommissioning operation.
4. Inhalation of airborne radionuclides is assumed to be the dominant
radiation exposure pathway to members of the public for radionuclide
releases from routine decommissioning operations or fr·om potential
accidents.
5. The dominant radiation exposure pathway to the decommissioning worker
is assumed to be the external radiation exposure received during
normal decommissioning operations. It is assumed that workers wear
adequate respiratory protection gear to prevent significant internal
deposition of radionuclides.
6. Because the radioactivity in the plant is mainly from long-lived radio-
nuclides. the radionuclide releases from normal activities and potential
accidents for the case of Deferred Dismantlement after an Interim Care
period are assumed to be identical to those during Immediate Dismantlement.
7. External radiation exposures to the public and to transportation workers
from transportation activities are generally based on the maximum allow-
able dose rates from shipments of radioactive material in exclusive-use
vehicles. This basis is highly conservative for the reference radio-
nuclide mixture in the MOX facility.
11-3
8. All liquid radioactive wastes generated during decommissioning are
assumed to be sent to the plant liquid waste storage system for eventual
processing through the waste concentration and solidification systems.
The only liquid releases from the plant to the environment are those
associated with the operation of lavatories, showers, kitchen, and
drinking water fountains.
9. Decommissioning and radiation protection philosophies and techniques
applied are assumed to conform to the principle of keeping occupational
radiation doses As Low As is Reasonably Achievable (ALARA).
10. The radionuclide releases from normal activities and postulated accidents
for the case of Deferred Dismantlement after a period of Interim Care
are not calculated in this analysis because future p~~ulations are
unknown. The evaluation of public safety for dismantlement was done at
shutdown only.
The public radiological safety evaluation is based on airborne radionuclide
release scenarios for both routine and accident situations. These airborne
release scenarios are discussed in Appendix I and listed here in Tables 11.1-1
and 11.1-2. These two tables show the calculated radioactivity releases
for each individual decommissioning activity or postulated accident, and
show the rate of radionuclide release for each event on the basis of the
radioactivity estimated to be present. The assumptions made are conservative
and probably overly pessimistic, but the release conditions are too uncertain
to permit the use of more realistic estimates.
A more complete discussion of the occupational radiation dose calculations
is contained in Appendices E and I of Volume 2. The occupational radiation
doses are based on the estimated radiation levels in the reference facility,
given in Section 7 and Appendix C, and the man-hour job estimates for the decom-
missioning activities considered, given as Appendix H.
Transportation activities are examined to evaluate the safety impact of
routine and accident situations. Radiation and nonradiation transportation
safety impacts are evaluated for both the public and transportation workers.
11-4
TABLE 11.1-1. Anticipatet Ai~borne Radioactive Releases During Routine Decommissioning
Activities a,b (~Ci of mixed oxide)
Total ,\irbome Preparations for

Airborne Radioactivity Dismantlement Safe Storage EntOIIDient
Radioactivity in !lutlding
Generation Rate During Entire Estimated AtMospheric Estimated Atmospheric Estimated Atlospheric
!!2!rati~ !!Ci Mixed Dxide£min ____QI!!,ration Radioactive Release Radioactive Release Radioactive Release
Chelntcal Decontamination
Electropolishing (Statton) 2.2 4.2 lC 105 210 (c)
Electropolishing (In sttu) 2.4 lC 10" 2 43 2.1 lC10"2
Surface Cleaning Operations
Spray Decontlnination of Dry
Proce~sing 610¥e Bo~ees 20 1.9 lC 104 4.6 lC 10-3 4.6 lC 10-3
Spray Decontminatton of wet r
Processing Glove Bo~ees 11 4.9 lC 104 1.2 lC 10-2 1.2 X 10•2
Physical Decontamination of Surfaces
Scraping Metal Surfaces 3.2 lC 103 1.2 X 106 0.29 0.29
....
.... Scraping Firebrick 5.1 lC 102 2.2 X 106 0.55
I
c.n Concrete Removal (Drilling) 2.8 X 103 6.8 lC 105 340 - 85
Exhaust Duct Decontamination 2.1x108 2.1x108 52 52 52
(total release)
Seg~enttng and Transfer of Equipment
Arc Saw 1.9 X 1o2 1.9 lC 105 97
(11Ci Pu/min)
Plas.a Torch 5.1 1,04
lC 4.1 lC 107 2.1 lC 104
Exhaust Filter Reloval 3.5 X 104 ?.II X 106 9.9 X 102 9.9 X 102 9.9 X 102
(pCi Pu/min)
TGTALS
----
22,700 1,040 1,130
Interim Care (Safe Storage) 6.1 X 102 - 80 11Ci/yr
(a) Tile first-year dose and fifty-year dose CDIIIIitlllents calculated for the maxinn-exposed individual and the population are listed h
Tables 1.4-1 through I.4-6
(b) For reference radtonuclfde inventory, refer to Table C.2-1
(~} A dash indicates that tile activity does not apply to this deCOIIIIissioning mde.
•
§.4:.tL~,_:;;:~·,;:~ .t.-· .. ···--· ~"- ....... .. ...;.;:"'
..
,~{~~fj.'f;f.i.~FJ~::,~::S5:.~··.._ ~·~. :~~,~:;: ~._ . .,....t ~-":'
TABLE 11.1-2. Postulated Acci~en~'l Airborne Radioactive Releases During

Decommissioning a, (~Ci of mixed oxide)
Preparations
Dismantlement for Safe Storage En talnllnent
Airborne Radioadive Estimated Radioacti•e Esti1111ted Radioactive Esti11111ted Radioactive Estimated Frequfc~Y
Incident Release in Building Release to Atmosphere Release to Atmosphere Release to Atmosphere of Occurrence c
Loss of Intennedfate-Stage HEPA
Fflter after Duct Decontamination 2.1 X 107 1.0 X 104 1.0 X 104 1.0 X 104 Hig!l
Inadvertent Cutting of Undecontaminated
Metal 3.1 X 105 1.6 X 102 _(d)
- Hish
Explosion and/or Fire of Ion Exchange
Resin J,g X 104
(•u only)
83 83 - Medium
Inadvertent Dumping of Co.Jtaminated

Solid ~~~~tes
A~raded Firebrick 2.8 X 104 14 - - High
CGncretP. Dust 2.8 X 103 1.4 - 1.4 High
Condensed Metal Vapor 1.4 X 102 7.0 X 10" 2 - - High
--
I
0'1
Loss of LO«l Airborne Contillllinati"'l
Control/Loss of Vacuwn Filter
Temporary Loss of Services
7.1 X 103 3.5 3.5 - High
Electricity (Nol'llllll and Emergency) 1.4 1.4 1.4 Medi~m
Liquid Leak
Chemical Decontamination 3.3 X 104 16 16 - High
E1ectropoli shi ng 55 2.8 X 10" 2 - - Medium
Fire Involving ContUJinated Clothing
or Cantlustible Waste 210 0.11 0.11 0.11 Medium
Explosion of Hydrogen During
El ectropo 1i shing 14 7.1 • lo-3 - - · High
Men Intrusion 290 ~Citm 3 High
(a~ Tile first-year dose and fifty-year dose c~a~ftlnents calculated for the maxiiiiJm-exposed individual are listed in Tables 1.4-7 through 1.4-9
(b For reference radfCN~c11de inventory, reffr to Table C.2-1.
(c Frequency of occurrence: Hfgh <1.0 x 10" ; Medium 1.0 x Jo-2 to 1.0 • lo-5; low <l.Q x 1o·S per year. A dash in this column means that
no estt•te was •*
for the speclftc 1ccident 1 tsted.
(I) A dish tndtcates that the postulated 1ccident does not apply to this dec011111issiontng mode.
11.2 PUBLIC SAFETY EVALUATION OF DECOMMISSIONING THE REFERENCE SMALL MOX
FUEL FABRICATION FACILITY
The impacts on public safety of decommissioning the reference MOX facility
by Immediate Dismantl~ment. Preparations for Safe Storage, Interim Care. and
Entombment are evaluated for both radiological and nonradiological events.
This analysis includes consideration of routine activities and of postulated
accidents.
Airborne radionuc1ide releases are calculated on the basis of radionuclide
inventories shown in Table C.3-l of Volume 2. The consequences of the airborne
radionuclide releases from routine decomn1issioning activities are calculated in
terms of the radiation dose to the maximum-exposed member of the public and to
the population residing within a circle of 80-km radius centered at the reference
facility. The consequences of postulated accidents are calculated in terms
of the radiation dose to ~he maximum-exposed individual. Both dose calculations
use the radiation dose models and data discussed in Appendix t. An estimate
of the frequency of occurrence for the accidents is given in Appendix I as
being high (greater than 10- 2 per year), medium (between 10-2 and 10- 5 per
year), or low (less than 10- 5 per year) based on published values or engineering
judgment or experience. A rigorous probabilistic risk assessment is beyond
the scope of this study. Inhalation of airborne radionuclides is found to
be the dominant radiation exposure pathway to members of the public for
most releases.
Nonradiological safety areas considered include the effects of chemical
residues from plant operations and chemicals used during decommissioning.
11.2.1 Radiological Safety Evaluation of Routine Decommissioni~erations
As in an operating MOX facility, the primary radiological concern to

the public· is the loss of containment of radioactive material that could result
in public exposure to abnormally high levels of radiation. The estimated
concentrations of radiation during the· majority of decommissioning activities
are lower than for the operating MOX facility, because of the removal of most
of the plant inventories of plutonium and uranium during final inventory clean-
out and decontamination. However, decommissioning activities are less routine
11-7
than are production operations, which may tend to increase the radionuclide
releases during decommissioning. Due to the high degree of conservatism built
into the safety analysis, estimates of the routine radionuclide releases to
the environment from decommissioning activities generally appear higher than
those measured and known to occur routinely for an operating plant. Thus,
the cumulative effects of all these ccnservative assumptions make it appear,
when compared to known or actual routine radionuclide releases from an opera-
ting plant, that decommissioning activities violate ALARA conditions for a
normal operating plant. In reality, when compared to an operating plant, a
net reduction in radionuclide releases should occur from decommissioning
activities.
The primary sources of radioactive effluents from~routine deconnissioning
operations are the release of contaminated vaporized metal during plasma arc
cutting and equipment removal, the release of contaminated collected dust
during change-out and replacement of HEPA filters, the release of contaminated
concrete dust during decontamination or removal of concrete structures, and
the release of contaminated liquid aerosols during electro-chemical decontami-
nation of metals in the electropolishing sta~ion and during spray decontami-
nation of glove boxes. Equipment and concrete removal operations are held
to a minimum during Preparations for Safe Storage. Decontamination operations
are held to a minimum during Entombment. Electropolishing operations ar~
not conducted during Preparations for Safe Storage or Entombment.
A complete listing of the radiation doses calculated for the airborne
releases from routine decommissioning operations that are listed in
Table 11.1-1 is found in Appendix I of Volume 2, Tables 1.4-1 through 1.4-6.
Tables 11.2-1 and 11.2-2 contain summaries of the calculated radiation doses
for Immediate Dismantlement, Preparations for Safe Storage, and Entombment.
The radiation doses given in these tables are all very small compared to the
average background radiation exposure of 80 to 170 mrem per year received by
members of the public from natural sources.(l) The radionuclide releases and
' '
'
radiation doses are low, largely because of the care used in designing and
implementing dismantlement procedures, the greatly reduced inventory of
radionuclides, and the utilization of efficient process and ventilation
filtration systems.
11-8
TABLE 11.2-1. Summary of Radiation Doses to the Maximum-Exposed Individual from
Airborne Radionuclides Released During Normal Decommissioning Activities
·-
Ot ....tl.-nt
'ifqo-Yar tiSi
Pnearat'IOfts far SlfJ,ff-;1, lise En-
fiftJ<o-JHr tilt
Ftrst•Y-.r DD11 1 . . . ec-t-.nt .....
Rtluse to
F1rst.-'l'ur 0Ds1 1 lll"'t!!l ea-ttaent 1 ... Ftf'St-lar Dote. 111"1111 c-1-•. -
Rele11t to AllHSe to
Act1wttr or LOcation
ct•tal ~natton:
...........
___.M!L ~ ___j,!!J!J_ __!~!!!_ __l,.o!!!!_ ___.M!L __...!!!!!!_ __l,.o!!!!_ ~ ___..!,g_ ____M!L ~ _J.!!!!L._ __!!!!!!.. - --l.!!!!l._ ·-·""""'
£1ect....,.1tshlog (s.. tiOft) 210 6.& • 4 w 1.0 a 1o· 3 4,9 • 1o·Z 1.3 Jl 1o·3
E11CtrollllltShlog (ln•Situ) 2.1 • 10"2 6.6 • 1o·8 1.0, 1o·7 4.9, 10-6 1.1 • 1o·7
SorfoceCTHnlog:
Spray -r.tnotton (Dry
PrGcnslng Glowe lloaa) 4.6 , 10", 8.1 , 1o·10 6.2 , 10-a 1.8 • 1o· 7 2.e , 1o·7 4.6 , 1o· 3 8.1 • 10" 10 6.2 • 10-a 1.a • w7 2.a , 1o·7
s.wu -llltiiMI (Wet
Processtl'lg G1owe lo&es) 1.2 Jl 1o·2 3.7 Jl 10-o s.a • 1o·8 2.1 11 ta·& 7.4 • 1a·8 1.2. to·Z 3.7 • 10-a 5.8 • 1o·8 2.8 • ta-' 1.1 a 10-8
PIIJ$ica1 Dlcantututton:
Sc..,log lloto1 Soorf•- 2.9 5.4 • 10-8 1.8 • 1o· 6 2.4 a 1o· 5 1.8 • 1o·5 2.9 5.1 • 10-8 3.8 • 10"6 2.4 • 10" 5 1.8 • 10"5
SCrcplog Fl ....... ct 5.5 9.7 II 10-8 7.2 • 10-6 4.7 • 10" 5 J.4 • 10"5
c-rete-•1 340 6.4 • 10"5 •·• • 1o·1 2.1 • 1a· 2 z.1 • 10-2
Edlust Duct Dlc:Ofltllttfllt'lon 52 9.2 • 10-6 6.8 • 10 4 4.4 • 1o· 3 1.2 a 1o·3 52 i.Z a 10·6 &.8 • to·• •·• • 1o·1 3.2 • 1o·3 52 9.2 • 10" 6 6.8 • 10-4 4.4 • 10" 3 3.2 • 10" 3
""'•nw Drilling:
I"*• holes)
......
I
Floors
~tlog
Arc Sow
[qui-t:
97 1.7. 10" 5 1.1 • 1o· 3 8.0 • 1o" 3 5.9. 1o·3
85 1.6 • 1o·5 1.1 • 1o· 5 7.0 • 1o"3 5.3 • 10" 3
U) PliSM Tordl 2.1 • 104 3.8 a 10"3 2.8 1.7 l.J

Filter Reolo.-t _m__ 1.8 • 10"4 u, 1o· 2 7.9 • 10"2 6.2 • 1o· 2 ___!!!!___ 1.8. 10-· 1.3. 10"2. u. 10"2 1••• 10-2 _!!! 1.1 • 10-4 1 . .1 • ;a·2 r._•" to•2 1.2 • 1o·2
TOT-._5 2.25 ' lrf u • 10"1 2.9 1.9 1.4 1,042 1.9 • 1o·• 1.3 • 1o· 2 a.z " ta· 2 1.0 1.127 2.1a104 1.4a1o·2 9.0a10"2 7.1x10"2
·~...w;..:~-··
::~;;.:::~~:_; . -
i"~~::~
.~2%:: ..
;..":'
·· .. ,.
~~"{~~~f,~~~~/l~f"t~~~~~i\-r-·~~... ~~.....
TABLE 11.2-2. Summary of Radiation Doses to the Population from Airborne

Radionuclides Released during Normal Decommissioning Activities
DtSIIIrttl.-M P~rations for Safe Storal! Eo-

F1fty.Yur DDSi Fifty-Yetr bOSe F1f~·YHr DDii
Ftrst-Yeu· Oost1 •n-re~~ ec-itllellt 1 •n-r&~ Ftrst-Year DDse 1 •n·rl!lll C:O.t~t 1 111111'1-ra F1r'St-YHr Doset .,....,.. ea-1 e.tnt. 1 •n·NII
ReltiSt to ReleiSe to Release t~
A•splltre Ae.osphere At..osphere
Act1Y1 ~ QP' LOCition __M!L --!!!!!L. .....!.!!!!S..- --l!!!!!._ _!!!!!9_ __M!L _!l!!!!.._ ~ ---l!2!!!...._ _..!l!!!i_ ______{jilll__ _!l!!!!.._ ~ ---l!2!!!...._ ___b!!!!l_
a.e.te~l Decorlt.1Nt1on:
£1ectntpo11sh1ft!J (st.-t10fl Z10 7.2. 10"' 4 1.2 .. 10-4 5.3 X 10"'2 1.4 X JQ"']
Electrapo11stJing (tn-sttu) 2.1 11 10"' 2 7.2 X 10·S 1.2 ll to• 7 S.l a 10-6 1.4 .w. 10-J
Surface Cluntng:
Spra.t DKonu.tn.ttfOI'I {Dry
Procesilrtg Glu.e loaM) 4.6 l 10"' 3 9.0 x 10'" 10 7.1 J. 10"'8 4,3 X 19"' 7 J.Z X 10-J 4.6 J. 10"' 3 9.0 lL JQ•lO 7.1 X 10"' 8 c.J x to"' 7 J.z • 1o· 7
Spray Oecanu.tnatian {wet
Proc:.sstng Glawe Sci1es) 1.2 X 10"' 2 4.1 I 10--8 6.6 X 10"'8 3.0 I 1~-6 8.3 ll 10-8 1.2 X 10"'2 4.7 X JQ"'B 7,6 .. 10"' 8 J.s. to"'6 9.5 x 1o·8
Physte~l Dtconu.t~~o~tton:
Sc:r&p1ng MeUil Surfaces 2.9 5.9 • 10" 8 4.4 X 10• 6 2.7 J; 10· 5 z.o .. 1o· 5 Z.9 s.9 x 1o·8 4.4 a 10· 6 2. 7 X 10-$ 2.0 X 10• 5
Scr1ptng Firellrid: s.s 1.1 X 10• 7 B.Sx1o·6 5.1 .. 10' 5 3.9 l 10- 5
Concrete Raoval 340 6.9 • 1o·5 5.1 X 10• 3 J.2 • 1n·2 2.4 , 1o· 2
Exhaust Duc1 Dtcontllltn.t1on 52 1.0 X 10• 5 !IJ.O x 10-l 4.8 X 10•J 3.6 X 1!:1-J 52 1.0 • 1o· 5 8.0 J. 10- 4 4.8 l 10-J 3.6 X 10-J 52 1.0 a 1o· 5 s.o, 1o·4 4.8 a 10-J 3.6 x 10· 3
Concrete Drill lng:

Fl oars ( Pollr Holes) 85 1. 7 l 10' 5 1.3 l 10-l 8.0 x 1o· 3 6.0 • 1o· 3
-t1"9EC1UI-o
..... Arc Sow 97 1.9 a 10· 5 1.5 .. 10- 3 8.9 .. 10-J 6.7 ll 10-l
.....I Pl1S111 Torch 2.1 .. 104 4.2 x 1o· 3 0.32 2.0 1.5
0 Filter lleplltaent ~ Z.Ox1o·• 1.5 .It 10' 2 9.2 • 1o· 2 L..Q....!.. ~o·Z -~ 2.0 •. 1o·• 1.~.1o· 2 9~2 • 1o·Z '!.u , 10" 2 _m 2.0 ~~ to-' 1.~. 1o·2 9.2 • 10-2 7.0 • 1o- 2
TOTALS 2.2s • 104 s.s .. 1o· 3 3.4 .It 10-l 2.2 1.6 1,0.2 2.1k10-4 1.6 • 1o· 2 ' · ' J. 10- 2 7.4 .It lo- 2 1,127 2.3 x 10_. 1.7 a 10· 2 0.1 8.0 • 1o· 2
·----------------..,.---:'""""=,
Estimates of the radiation doses to the public from routine Immediate

Dismantlement activities are about 20 times larger than similar estimates for
Preparations for Safe Storage and Entombment, as shown in Tables 11.2-1 and
11.2-2. Expected radiation levels are not significantly reduced with time.
Thus, public and occupational radiation doses for Deferred Dismantlement are
considered to be the same as for Immediate Dismantlement.
The release of radionuclides from normal Interim Care activities is
calculated to be 16 ~Ci/yr, which is negligible compared to the low releases
during Preparations for Safe Storage. Because of the operation of the venti-
lation system and the surveillance, security and maintenance activities per-
formed during Intefim Care, the airborne radionuclide releases from normal.
Interim Care activities are expected to be extremely small, and the radiation
dose to the public is expected to be negligible.
11.2.2 Radiological Safety Evaluation of Postulated Decommissioning
Accidents
The primary impact of decommissioning accidents is the release of radio-
active materials to the environs and the resulting public radiation exposure.
Decommissioning procedures are analyzed and accidents are postulated th~t
result in the airborne radionuclide releases developed in Append.b I. A
summary of the accidents and releases is given in Table 11.1-2. A wide
spectrum of accidents is considered in Appendix I, along with the calcula-
tions, bases, assumptions. and resulting radiation doses to the maximum-
exposed individual. Table 11.2-3 contains-a summary of the higher consequence
accidents postulated for Immediate Dismantlement. Preparations for Safe
Storage, and Entombment, with the associated calculated radiation doses. A
complete listing of the radiation doses considered is found in Appendix I,
Tables 1.4-7 and 1.4-9.
The major accident postulated for both Immediate Dismantlement and
Preparations for Safe Storage is the loss of the intermediate HEPA filter
immediately following decontamination of the upstream ductwork. It is postu-
lated that loose contaminated dust resulting from the mechanical decontamina-
tion of the exhaust duct is made airborne by the mechanical and aerodynamic
forces created by the decontamination process. The rupture of the HEPA filter I
11-ll
. ·.. · ·. .·':,:.~t.-,·~.-.
''4··:·t_!''f?:'·•.
. -,,·~ .
TABLE 11.2-3. Summary of Radiation Doses to the Maximum-Exposed Individual from

Accfdentdl Airborne Radionuclide Releases During Decommissioning Activities
01S.IIIt1_,.t Pree;!ratfDfts far" Sde Stof'l!iJ! En~t

F1fcy-iur bOSe F1ft,r-Yor bOse Ftfty·YIIr Cliise
F'tf"St·YNr Dose • . _ eo.1 taent. W!llr F1rst-Yeer Dose 1 llr!ll eo.t!!!l!!t....... Ftrst•YHr Do5e 1 .ra C:O.ft.ftt. - -
bl•se to [x;JII:tlld
:nctdeftt A~~j'e ~ --.!:!!!L_ ~ ~ ~ ~ --1!!!!!_ __!:..Y!!i...._ ----!!!!!!.__ ~ ~ __....b.!!!!1._ a:a.'"::t:f
Loss of Jnterwc~tate--Stage Hf'P'A Filter
Afhf' Exhlult Duct Dlcoftt.1ftlt1on 1.0 .I 104 5.2 • 10-l 12 1.1 • 102 78 5.2 32 1.1 • 102 77 5.2 32 1.1 • ,a~ 78 Mlgh
INdverurtt; Cuttt~ of
-~Mtlldllotol 1.6 lit 102 8.5 • 10-l 5.0 1.8 1.3 Htgft
E.lploston •rwJJor Ftre of Ion

Exchlrl~ Resin Bl 7.o .I 10'"2 <Oi,6 ,. lo- 2 2 .s 6.6. 1o· 2 1.0 • 1o·2 6.6 ... to·Z 2.5 6.6 • 10- 2 ....u ..
1-t-lngof
COnu.taated SOlid Wlstes:
Mo-lded flrebr1 ct 14 7.4 Jl to 4 4.4 l 10'" 2 1.5 1.1 High
tonc;:rete Oust 1.4 7.4 lt 10'" 5 4.4 a 10-J 1.5 x 10-Z 1.1 x 10·Z 7.6 • 10-S 4, .. x 10'" 3 1.5 ll 10'"2 1.1 a 10-z t'ltgtl
Condensed Metll Y1por 7.0 X lQ..z 3.8 a 10'"6 2.2 I 10-' 7.9 .1 10-t 5.7 Jt HJ'" 4 Htgh
LOSS Of Loal Airborne CCM1r..ltt\lt1on

Control/Loss of Vecuu. Ftlte,. 3.5 1.9 ll 10-4 1.1 I 10• 2 ).8 I 10'"2 2.8 x 10· 2 1.9 X 10-C 1.1 • 1o·2 3.9 a 1o·2 2.8 1 10-2 High
Tl!llpOrlry LOss of Senoices:

Eloctnclty (""""1 on4 &oe"'le•c;y) 1.4 7.4 a to- 5 "·", 1o· 3 1.s, 1o· 2 1.1 x to· 2 1.c .. 1o· 5 c.• • 1o·3 1.5. to- 2 1.1 x to·2 1.c .. 1o· 5 •·• 1111o·l 1.s x 1o· 2 1.1. 1o· 2 llldi . .
.....
.....
.....
I
Liquid LHt:
Cla'tcal Decontllt1rtat1Dn
E1ect~po11shtng
16 1.4 • 1o· 2 1.3 • 10-l 4.8 l.l ll 10- 2 1.4"
2.8 X 10• 2 5.4 lt 10• 6 5.1 I 10• 6 1.9 X 10•ol 5.1 X 10•6
Jl 10- 2 l.J • 10'" 2 ... 1.3 ll 1o·2 HI gil
111<11•
N Ftroe Jnvohtng Cont.-IMtld Clothing
or COibusttble IIISte (].11 9.6. to• 5 9.2 I 10- 5 3.4 Jl 1o· 3 9.2 Jl. 10-5 9.2 a to• 5 8.8 • 10'" 5 3.3. lo· 3 8.8 X to• 5 9.6 • 10"' 5 9.2 Jl 10-s 3.6 Jl 10-J 9.2. 10"' 5 lied I •
Eaploston of HJdrogen During
Eloctropoll .. lng 1.1 • 1o· 3 5.9. •o- 6 s.s. 1o· 6 2.1 a to·• 5.9 x 1o- 6 HI gil
Min lntrus ton (b) 3.5. 106 2.1 .. 108 1.0. 108 5.2 ' loS low
(a) F~ of Occurrenc:es: H1gb )1,0 .w. 10-2 o Mecli~ 1.0 a1o· 2 to 1.0 • 10· 5 • Low <l.o'x 10· 5 Pf" yur.
(b) Ass.-s • 410-IM:Iur ttPuSure to 1ft avertg• atr conat~tratton of 290 ~o~Ct/.-1.
y --::;.~·:·-;·:~~;-~~
L ·-··
·' :~- ·,~
is assumed to be caused by a buildup of moisture in the filter, and/or the

mechanical or aerodynamic forces created during exhaust duct cleanout. The
final bank of HEPA filters tn the exhaust fan room is assumed to remain intact.
The quantity of radionuclides released directly to the atmosphere ts calculated
to be 10.000 llCi. The freauenc.v of occurrence for this accident with this
severity is estimated to be in the htgh range (greater than 10-2 per year).
The major accident postulated for Entombment is a deliberate but ignorant
intrusion by man into the facility after knowledge of the facility•s purpose
is lost. An extreme case is postulated where the intruder is exposed for
40 hours to the area of highest plutonium contamination while salvaging equip-
ment. For this extreme case, the potential radiation dose to the intruder is
over 108 mrem to the lungs and bone (50-year dose commitment). This potential
radiation dose to the lungs is approximately six orders of magnitude higher
than the average radiation dose of approximately 200 mrem per year to the
lungs from natural sources. The frequency of occurrence for an accident with
this severity is estimated to be in the low range (<10- 5 per year).
Radiation doses to the population are not calculated for decommissioning
accidents. The segment of population exposed under accident conditions is
different for each site sector. A conservative upper limit estimate can be
made of the radiation dose to the population by comparing Table 11.2-3 with
Tables 11.2-1 and 11.2-2. For a release with the same spectrum and quantity
of radionuclides, the ratio of the radiation dose to the maximum-exposed
individual for an accident to the dose from routine operations can be calcu-
lated. This ratio times the population radiation dose for the release from
routine activities. gives an upper limit for population radiation dose from
an accidental release. The actual population radiation dose for an accidental
release of radioactivity is expected to be below this upper value.
Contamination remaining in the facility during the Interim Care period is
contained and is not readily available for airborne release. The MOX facility
services are almost entirely operational during Interim Care, with the venti-
lation system and its HEPA filtering system acting as a barrier between the
remaining radioactivity in the building and the environment. Only low proba-
bility events with causes external to the plant, such as tornadoes and
11-13
earthquakes. or certain man-related events. such as deliberate intrusion into
the facility, appear to have the potential to release potentially important
amounts of radioactivity into the environs. The combination of low probability
of the initiating events. low radionuclide concentration per unit area. and
active operation of plant contamination control systems reduces the impact of
postulated accidents during Interim Care to levels far below those postulated
for other decommissioning activities.
11.2.3 Nonradiological Safety Evaluation
Chemical polltitants that could be released during decommissioning activities
are examined and the quantities released are found to have an insignificant
safety impact on the public. Potentially hazardous chemicals are found to
come from two sources: 1) residuals from MOX plant production operations
and 2) chemicals employed to chemically and physically decontaminate the plant.
The relatively small quantities of hazardous chemicals used, the low likeli-
hood of their dispersal into the environs, and the dilution factors involved
in the dispersal of hazardous materials from the plant to the environs suggest
that chemical pollutants from decommissioning operations do not rose a signi-
ficant public hazard.
11.3 OCCUPATIONAL SAFETY EVALUATION OF DECOMMISSIONING THE REFERENCE

MOX PLANT
Occupational safety impacts for Immediate Dismantlement, Preparations for
Safe Storage, and Entombment are evaluated for both radiological and nonradio-
logical events. The analysis considers routine radiological events and postu-
lated nonradiological accidents.
Radiation doses to workers are calculated based on the estimated r~diatjon
levels in various areas of the reference MOX plant, and the estimated labor
requirements to perform the decommissioning work. Summaries of the appropriate
detailed information in Appendices C and I are given in this section. An
estimate of worker injuries and fatalities resulting from decommissioning
activities is made and presented, based on nuclear industry experience.
11-14
.. ·. :.·
11.3.1 Radiological Safety Evaluation of Routine Decommissioning Activities

Summaries of the estimated external occupational radiation exposure for
Immediate Dismantlement, Preparations for Safe Storag~. and Entombment are
given in Tables 11.3-1 through 11.3-3. These tables summarize the decontami-
nation and dismantlement or deactivation tasks in each of the reference MOX
rooms, man-hour estimates for each task, and man-rem estimates of the accumu-
lated external radiation dose to all workers doing each task.
The radiation doses to decommissioning workers are calculated using the
man-puwer requirements estimated for each job and estimates of the average
radiation dose rates associated with each job. The dose rate estimates are
based on the data given in Appendix c. The radiation doses computed in
Appendix I are based on constant values of dose rates for a glove box or room,
regardless of where the worker is located with respect to the glove box or
within the room.
The half·lives of the major radionuclides within the facility are long,
and thus they do not decay significantly within the few tens of years considered
in this study. Therefore, occupational radiation doses do not decrease with
time.
The total occupational radiation dose for in-plant decommissioning
activities for Immediate Dismantlement is estimated to be about 70 man-rem.
Specific decommissioning activities that result in the highest accumulative
worker radiation doses are: 1) decontamination activities associated with
the operation of the electropoli~hing station, 2) segmentation and packaging
activities, 3) scrap recovery and waste treatment activities, 4) removal and
decontamination of the wall storage tanks, and 5) decontamination of wet
processing systems. The estimated Jccupational dose for in-plant deco11111h-
sioning activities during Preparations for Safe Storage is about 23 man-rem
and during Entombment is about 9.4 man-rem.
The average quarterly radiation doses to decommissioning workers for
Immediate Dismantlement, Preparations for Safe Storage, and Entombment are listed
in Table 11.3-4. These quarterly radiation doses are believed to be conservative
and are far below the present 1.25 man-rem/quarter guidelines set by the NRC.
11-15
()
TABLE 11.3-1. Summary of the Estimated External Occupational

Radiation Exposure for Inplant Activities during
Immediate Dismantlement of the Reference Small
MOX Facility
EsUmated Event ~orl
Total Dose a
Description (man-ho11rs) {man-rem)
Flush Wet Process Systems 6,720 6.1
Oecontaminete Rooms 121, 123, 126 510 0.16
Dismantle Rooms 121, 123, 126 900 0.26
Decontaminate Rooms 155, 156 675 0.40
Dismantle Rooms 155, 156 600 0.35
Decontaminate Room 124 1,875 2.0
Dismantle Room 124 1,890 1.1
Deconteminate Room 805 1,485 1.9
Dismantle Room BOS 7,380 3.0
Decontaminate Room 116 135 0.0081
Dismantle Room 1T6 360 0.022
Decontaminate Rooms 129-143 1,170 0.081
Dismantle Room 129-143 2,745 0.18
Dismantle Wall Storage Tanks 8,070 6.2
Dismant 1e Room 802 1,440 0.89
Dismantle Rooms 201, 202 1,665 0.84
Decontaminate Sewage lagoon 1,620 0.097
Dismantle Cold Chemical Preparation Room 420 0.025
Dfsmantl e Rooms 108-111, 117 1,230 0.077
Set Up Electropolishing, Incineration, Packaging 855 0.48
Operate Electropolishing Station Z6,940 14
Dismantle Electropolisher and Final Decontamination 121, 123, 126 1,080 0.37
Operate Packaging and Shipping 21,060 10
Operate Scrap Recovery and Waste Treatment 8,940 7.0
Package and Ship ContaminatP.d Rubble _ill 0.027
TOTALS 117,795 70
(a) Values are rounded to two significant figures.
11-16
' ----~

Radiation Exposure During Preparations for Safe
Storage
Estimated Event ToJal
Total Dose a
Desert ption (man-hours) (man-rem}
flush Wet Process Systems 4,86C 4.2
Decontaminate Rooms 121, 123, 126 505 0.15
Deactivate Rooms 121, 123, 126 220 0.063
Decontaminate Rooms 155, 156 660 0.39
Deactivate Rooms 155, 156 320 0.18
Decontamf nate Room 124 1,505 1.5
Deactivate Room 124 625 0.48
Deactivate Room 805 1,060 0.38
Deactivate Room 128 1,060 0.81
Decontaminate Rooms 129-143 1,205 0.082
Deactivate Rooms 129-143 645 0.04Z
Deactivate Wall Storage Tanks 860 0.63
Deactivate Room B02 320 0.20
Deactivate Cold Chemical Preparation Room 295 0.018
Oeactfvate Room 117 1,050 0.064
Deactivate MMfscellaneous Unnecessary Systems 330 0.20
Check Safe~ Systems, Install Alarms, etc. 1,815 1.1
Ffnal Checkout of Safe~. Securi~. Operating Systems 930 0.54
Operate Scrap Recovery and Neste Treatment 7,375- .2L.
TOTALS 33,435 23
(e) Values ore rounded to two significant ffgures.
11-17
Radiation Exposure for Inplant Activities of
Entombment of the Reference Small MOX Facility
Estimate Event (oJal
Total Dose a
Event Descri~tion (man-hoursl Men-Ra.JL_
Decontaminate Rooms 121. 123 510 0.16
Decontaminate Room 116 135 8.1 X 1Q•3
Decontaminate Rooms 130-133. 135-143 774 5.3 X 10·2
Decontaminate Room 129 375 2.8 X 10• 2
Dtsmantie Rooms 121. 123 580 0.17
Dismantle Room 116 Glove Box 360 2.2 X 1Q•2
Dismantle Room 229 Glove Boxes and Hoods 540 3.5 X 10·2
Dismantle Room 201. Remove Exhaust Ducts 1.665 0.84
SprlY Paint Rooms 121. 123. 126 1.470 0.42
Spray Paint Room 155 221 0.13
Spray Paint Room B05 295 0.36
SprlY Paint Room 128 808 0.72
SprlY Paint Room 127 514 0.37
Spray Paint Room 156 147 8.4 X 10· 2
SprlY Paint Room 116 368 2.2 X 10•2
Spray Paint Rooms 130-133. 135-143 588 4.0 X 10· 2
Spray Paint Room BOl 588 0.48
Spray Paint Room B02 662 0.47
Spray Paint Room 129 588 6.8 X 10·2
Cut New and Plug Old Accessways to
Mechanical Tunnel 270 1.6 lQ-2
X
Excavate Floor Drain 900 5.5 10- 2
X
Modify Air Exhaust Systems 870 0.87
Provide Access to Entombment Areas 270 5.4 X 10·2
Plug First-Floor Exits 240 9.6 X 1Q•2
Drill Pour Holes 184 7.3 X 10• 2
Concrete Pour Rooms BOl and B02 1.160 0.95
Concrete Pour Room B05. Basement Portion 199 0.24
Concrete Pour Room: 155 and 156.
First 8 Lifts 111 6.4 X 10·2
COncrete Pour Room 124. First 8 Lifts 246 0.25
Concrete Pour Room 128. First 8 Lifts 254 0.23
Concrete Pour Room 127. First 8 Lifts 139 9.9 X 10· 2
concrete Pour Rooms 155 and 156.
Last 6 Lifts 83 4.9 X 10· 3
concrete Pour Room 124. Last 16 Lifts 497 4.9 X 1Q•2
COncrete Pour Room 128. Last 16 Lifts 511 4.6 X 1Q•2
COncrete Pour Room 127. Last 16 Lifts 279 3.5 x 1o-2
COncrete Pour Room 126. Last 23 Lifts 295 1.8 X 10•2
COncrete Pour North-South Corridor
24 Lifts 314 1.3 X 10•2
Package and Ship Contaminated Materials .......R!!. 3.0 X 10· 2
Totals 21.500 9.40
(a) Values are rounded to two significant figures
------------··---·- --··
v
\_ __
.
TABLE 11.3-4. Estimated Average Quarterly Occypotional Radiation Dose

frpm Decommissioning Activ1tieslaJ
Estimated Average
Total for all Decommis-
Man-rem Decommissioning Technicfans(b) stoning Staff
Mode Per Mode Aan-Yr ~verage DOse ~emZguarter Aan-9r RimZguarter
Immediate Dismantlement 70 74(c) 0.24 no<c>. 0.16
Preparations for Safe Storage 23 21(d) 0.27 45(d) 0.13
Entombment 9.4 7.6(e) 0.19 28(e) 0.084

(b) All personnel are assumed to be trained radiation zone workers.
(c) Based on Table 10.1-3.
(d) Based on Table 10.2-3.
(e) Based on Table 10.5-3.
The surveillance and maintenance staff are exposed to residual radiation

levels present in the decommission&d reference facility during the Interim
Care period. During this period, the radiation levels will increase slightly
due to the ingrowth of 241 Am. This increase in radiation levels is not
expected to significantly increase the overall radiation doses received by
the Interim Care staff. Thus, the radiation dose received by workers in the
retired facility for any time in the foreseeable future will remain virtually
constant. Table 11.3-5 l'lsts a summary of the man-hours of labor and man-rem
of occupational dose accumulated by the Interim Care staff for periods of 10
and 30 years after facility shutdown.
TABLE 11.3-5. Summary of the Estimated External Occupational Radiation

Exposure Dur1ng Interim Care Following Preparations for
Safe Storage(a}
Radiation Zone Workers Total Interim Care Staff

Tfme After Reference Estimated COllective Estimated Collective
Facility Final Total( ) Radiation Dose Total Radiation Oose
ShutdQ!n(b) (Years) Man-Hours c (man-rem) Man-Hours (man-rem){d)
10 1.1 X 105 51 2.4 X 105 64
30 3.6 X 105 165 7.8 X 105 206

(b) Time after facility shutdown includes one year of Preparations for Safe
Storage. Thus 10 years after shutdown is equivalent to 9 years of Interim
Care.
(c) Six hours of worker rad1atton exposure per eight-hour working day.
(d) Office workers received 0.6 mrem/hr for 8·hour working day.
11-19
..:', ·.:··
'
,. : . .
\'.· ..
.
:~.<
·.
~
~·
.....
·~.-
The estimated external occupational radiation doses for decommissioning
the reference MOX facility are summarized in Table 11.3-6. The total occupa-
tional dose is given for Immediate Dismantlement and Entombment, and a break-
down of Custodial Safe Storage activities into Preparations for Safe Storage,
Interim Care, and Deferred Dismantlement is presented. Occupational radiation
doses for Deferred Dismantlement are considered to be the same as for Immediate
Dismantlement, although some additional work steps, such as change-out of
HEPA filters, are likely to increase the accumulative occupational radiation
dose levels for Deferred Dismantlement to levels slightly above those for
Immediate Dismantlement. For times beyond three years, the Interim Care period
contributes more worker radiation dose to the Safe Storage mode than does the·
preparations period. It takes only seven years for the total occupational
dose from Preparations for Safe Storage plus Interim Care to equal those for
Immediate Dismantlement.
TABLE 11.3-6. Summary of the Estimated Collective Occupational Radiation

Doses for Onsite Decommissioning Activities of the Refer.ence
Small MOX Fuel Fabrication Facility
Time After Estimated
Facility Shutdown Dose
Decommissioning Mode (Years) {man-rem)
Immediate Dismantlement 0 70
Entombment 0 9.4
Custodial Safe Storage
Preparations for Safe Storage 0 23
Interim Care 10 64
30 206
Defe~red Dismantlement 0-30 70
Total for Custodial Saf~ Storage 10 157
with Defe:·red Dismantlement 30 299
..
.....
11-20
. ------------ --~
The estimates for the occupational radiation dose are sensitive to mana-
gement philosophy and to the decommissioning methods utilized. Administrative
controls are assumed to be in place that keep radiation records for each
individual and assure that no one worker exceeds recommended limits. Esti-
mates contained in Table 11.3-6 are based on decommissioning methods that
utilize technicians who are highly trained in effective radiation work pro-
cedures. Different basic assumptions, decommissioning procedures, or increased
manpower may change the occupational radiation dose estimates significantly.
11.3.2 Safety Evaluation of Construction or Industrial Accidents
As a result of decommissioning activities, the potential exists for worker
injuries and fatalities. As with any industrial operation, proper management
and industrial safety practices will minimize the potential for worker acci-
dents. The following estimates of worker injuries and fatalities are based
on data.provided by the U.S. AEC for the period 1943 to 1970.( 2) Table 11.3-7
lists the estimates of worker injuries and fatalities for heavy construction,
light construction, and operational activities that are conducted aurin~
IJJIIIedi!ate Dismantlement, Preparations for Safe Storage, and Entombment. 3 )
As shown in the table, about 1.0 lost-time injury and 0.007 fatalities are
expected during the dismantlement. During Preparations for Safe Storage,
about 0.32 injuries and 0.002 fatalities are expected during the 12 months of
decommissioning activities. For Entombment, about 0.22 injuries and·
0.002 fatalities are expected during the 35 weeks of decommissioning activities •.
Estimates of the number of injuries and fatalities that could occur to
the surveillance and maintenance staff from industrial-related accidents for
Interim Care activities are given in Table 11.3-8. As shown in this table,
about 0.63 lost-time injuries and 5.9 x 10- 3 fatalities can be expected for the
Interim Care staff for a period of 10 years after facility shutdown.
11.4 TRANSPORTATION SAFETY EVALUATION FOR DECOMMISSIONING THE REFERENCE

SMALL MOX FACII.ITY
During decommi5sioning of the reference MOX facility, radioactive waste

materials are packaged and shipped offsite for burial. The~e wastes inc1u~e
11-21
TABLE 11.3-7. Estimated Occupational Lost-Tim~ Jnjuries and Fatalities
from Decommissioning Act1v1t1es(a)
r~,..,1'1-Havr l..cllfate ar Dlft'rrtd Dts.ntl-mt
AcctdtftJL P...,.retfons for Sift Stor1p En~t
Lolt.. f w Lo.t•«• LOst=Tf• Liit-ft•
_,Ac"'-t:..;.lrl""tr.____ lnJuriOI(b) fltolltln 11111-IIOIIrol<)
11\lUtln ratot"las llan-lloursl<) lnJuriH ~ llln-Hou,.(<) lnJurln !!_tolltlos
Han1 c.nstrucu..,Cdl to.o 4.2 • to" 2 3.3 a to4 o.u t.c a 1o· 3 3.2 a to1 3.2 a to· 2 1.3 a to·• 6.7. 103 6.7 • 10" 2 2.e • 1o· 4
Lftllt CGnstructiOft 5.4 3.0 a 10" 2 1.5 • 104 0.46 2.1a to" 3 2.9 a to4 0.11 1.1 a to·• t.c a 10' 7.6 • 10" 2 c.z • 10" 4
!!,!! ~
OpanU0111t :;.pport
TOTAL
t.t 2.3 a 10" 2 1.2 • 105
1.0 ~
6.1 • 10"
6.1 • 104
-- D.t3
0.32
1.4 • to·l
~
2.4 a 10"
J.S a 104
·-----
7.6 a to· 2
0.22
8.3 a 10·4
~
1.5 a 10"
TABLE 11.3-8. Estimated Occupational Lost-Time Injuries and Fatalities

from Interim Care Activities Following Preparations for
Safe Storage(a)
htl110te of the N111ber of OCcupational Safety
Ace I de~~:~~~t~n-Hours Accidents etr
lnterl10 Cora rerj!lll
10 Years 30 Years
~~j~;t!~b)
£Hiftllted Lost·TIIIt LaU·Tfme
~tlvlll Mtn· '.oursLYr Fatalities InJuries Fatalities InJuries Fatalities
Survet llance and Opera- 2.3. to4 2.t 2.3 • 10" 2 0.43 c.a. ro· 3 1.4 1.5 • ro· 2
t ional Support
Ma1ntenance 4.2 r. ro3 5.4 3.0 • 10" 2 0.20 l.t • 10" 3 0.66 3.7. 10·3
Act~lated Tot1l
0.63 5.9 x ro· 3 2.1 ~
(a) lsttmates of 1njur1es and fata1tt1es have been rounded to two stgntf1unt figures.
tb) Lost·tll• tnjurtes are defined in Reference 3.
transuranic contaminated (TRU) wastes(a) that are shipped to a federal

repository (deep geologic disposal) assumed to be located about 2,400 ~
(1,500 mi) from the plant site, and non-TRU wastes(a) that are shipped to a
commercial shallow land burial facility assumed to be located about 800 km
(500 mi) from the site. All wastes are assumed to be shipped by truck. To
minimize the risk that radioactive shipments pose to the public and to trans-
portation workers, federal and state regulations prescribe the containers,
contents, packaging, handling, and burial requirements. The procedures and
standards ·for the packaging and transport of radioactive materials are discus-
sed in Section 5 and Appendix F, and are summarized here.
(a) TRll wastes are assumed to be those contaminated with alpha radioactivity
from transuranic materials at a level of 10 nCi/g o·f waste or greater.
'
:'! Non-TRU wastes are assumed to have transuranic alpha radioactivity less
than 10 nCi/g of waste.
11-22
. ··-:.-.
11.4.1 Radiological Safety Evaluation of Routine Transportation Activities

Shipments of radioactive wastes from decommissioning activities will be
made in exclusive-use vehicles. Department of Transportation regulations< 4>
set the following limits on radiation levels assoc.iated with radioactive
material shipments:
• 1000 mR/hr at 0.91 m (3 ft) from the external surface of tf.::. package
(provided the package is transported in a closed vehicle)
• 200 mR/hr at the external surface of the vehicle
• 10 mR/hr at any point 1.8 m (6ft) from the vehicle
• 2 mR/hr at any norma1ly occupied position in the vehicle.
DOT regulationi( 4) further require that no significant amount of remov-
able radioactive conta~ination is present on the external accessible surfaces
of packages when they are shipped. Levels of removable contamination on the
surfaces are determined by a wipe test. The regulations in 49 CFR Part 173.397
state that removable (non~ftxed) radioactive contamination is considered
significant if the level of contamination, when averaged over any area of
300 cm2 of any part of the package surface. exceeds 10~ 9 Ci/cm2 for beta-
gamma radiation from natural or depleted uranium or natural thorium.
lO~lO Ci/cm2 for alpha radiaiton from natural or depleted uranium or natural
°
thorium. lo- 1 Ci/cl· for all other beta-ganma emitt'ing radionuclides, or
lo- 11 Ci/cm2 for all other alpha emitting radionuclides.< 4>
The method used to estimate routine radiation doses from truck transport
of radioactive material is based on the method given in WASH~~238.(S) In
addition. the following assumptions are made:
1) During an 800 km (500 mile) trip, two truck drivers are assumed to spend
no more than 12 hr inside the cab and 1 hr outside the cab at an average
distance of about 2 m (6 ft) from the truck. The exposure times for a
2400 km trip are taken to be three times these values.
2) Normal truck servicing enroute would require that two garagemen spend
no more than 10 min at about a 2 m (6 ft) distance from a shipment. for
an 800 km trip.
l. ·
;.
11-23
(;f
·.' .. :~ _.;:.
3) Onlookers from the general public might b~ exposed to radiation when a
truck stops for fuel or· for the drivers to eat. The onlooker dose for
an 800-km trip is calculated on the basis that 10 people spend an average
of 3 min each at a distance of about Z m (6 ft) from a shipment.
4) The collective dose to the general public from truck shipments is based
on an average collective dose of 1.2 x 10-5 man-rem per km traveled.(S)
5) Doses for a 2400 km (1500 mi) trip are assumed to be three times those
for an 800 km (500 mi) trip.
The estimated routine radiation doses from truck transport of radioactive
wastes from Immediate Dismantlement, Preparations for Safe Storage, and
Entombment are listed in Table 11.4-1. These radiatiop dose estimates are
based on the maximum allowable dose rates for each shipment in exclusive-use
trucks, and are thus grossly overestimated for the reference radionuclide
mixture in the MOX facility. Table 11.4-l is further based on the number of
TABLE 11.4-1. Esti"~ted Collective Radiation Dose from Truck Transport

of Radioactive Wastes
Radiation Dose J!!r Shl~nt~man-rem)
_ _G!:!!J!P.___ to shall~ o ep Total Radiation Dose
Mode Land Burial • 1 Geologic Disposal (b) Per Mode !man-rem)
lnmedlate Dlsmantllllllnt(tl Truck DrIvers 0.07 0.2 6.1
Garagemen 0.003 0.01 0.29
6.4 Total Worker Dose
Onlookers 0.005 0.02 0.57
Genal'a 1 Publt c 0.01 0.03 lli..
1.5 Total Public Dose
Pl'eparattons for Safe Storage(c) Truck Drivers 0.2 1.6
Garagemen 0.01 .!U
1. 7 Total llorker Dose
Onlookers 0.02 0.16
General Publ lc 0.03 0.24
0.4 Tota 1 Public Dose
Entomblllent Truck Drivers 0.2 D-60
Garag-n 0.01 !!.J2!
,.
0.63 Total llal'ker Dose
;;; Onlookers 0.02 0.06
Gentrel Pub11 c 0.03 g_J!!
0.15 Total Public Dose
•~ Ntllllber based on 800 .. (500 111) to slllllow land burfal site

Jcb Nlllllblr based on 2.400 lall (1.500 11t) to dttp geologic dfs sal site
Total shfJIIIInts: for 1.-:dtate Dt ...ntl-.nt. 18 to slllt;ow land burfal and 24 to dHp geologic ctlsposal;
for Preparations for Safe Storage. 8 to deep geo1ogtc dospos11; for EntOIIbllent 3 to dHp geologic disposal.
11-24
truck shipments and shipping distances listed in Section 10 and in
Appendices G and H. The external dose for routine transportation operations
for all truck shipments from Immediate Dismantlement is conservatively esti-
mated to be less than 6.4 man-rem to transport workers and 1.5 man-rem to the
general public. For Preparations for Safe Storage, the radiation dose is
conservatively estimated to be about three times smaller, or 1.7 man-rem to
workers and 0.4 man-rem to the public. For Entombment, the radiation dose
is conservatively estimated to be about three times smaller than for Prepara-
tions for Safe Storage, or 0.63 man-rem to workers and 0.15 man-rem to the
public. The shipping of sludge from the sewage lagoon to shallow land burial
is assumed t(J result in no dose to either transportation workers or to the
public, and is therefore not considered in the assessment of radiological
consequences of transportation.
11.4.2 Radiological Safety Evaluation of Postulated Transportation Accidents
Transportation accidents have a wide range of severities. Most accidents
occur at low vehicle speeds and have relatively minor consequences. In general,
as speed increases, accident severity also increases. However, accident
severity is not a function of vehicle speed only. Other factors, such as the
type of accident, the kind of equipment involved, and the accident location
can have an important bearing on accident severity.
The probabilities of truck accidents in this study are based on accident
data supplied by the U.S. Department of Transportation. ( 5) Accidents are
classified by severity into five categories as functions of vehicle speed and
fire duration. The five categories and their associated probabilities for
truck accidents are shown in Table 11.4-2.
Estimated accident frequencies, release amounts and radiation doses to
the maximum-exposed individual for selected accidents involving truck trans-
port of radioactive waste materials are shown in Table 11.4-3. These frequen-
cies are calculated by multiplying the total kilometers of radioactive material
transport for each decommissioning mode times the total probability of accident
per unit distance traveled for each accident severity class shown in
Table 11.4-2.
11-25
TABLE 11.4-2. Transportation Accident Severity Categories
Vehicle Fire Proba bi1 f ty

Spe?d Duration Per Truck
Severity ml!h a) _!I!__ Mile
Minor 0-JD < 1/2 6 10-9

X
0-30 0 4 10"7
X
30-50 0 9 X 10" 7
Total 1.3 X 10-6
l'fodHrate 0-30 1/Z-1 5 X 10" 11
30-50 <1/2 1 X 10"8
'i0-70 < 1/2 5 X 10" 9
50-70 0 3 X 10" 7
Total 3.1 X 10" 7
Seven 0-30 >1 -' 5 X 10-12
30-50 >I 1 X 10-11
30-50 1/2-1 6 X
10-12
50-70 112-1 6 X lo-12
>70 <1/2 1 X 10-JO
>70 0 X 10-10
Total 8.2 X 10-9
Extra Severe 50-70 >1 6 X 10-lJ
>70 1/2-1 2 X 10" 13
Total •8 X 10-13
Extreme >70 1 zX 10-14
Total 2 X
10-14.
(a) 1 mph is approximately 1.67 km/hr.
TABLE 11 . 4-3. Estimated Frequencies and Radioactivity Releases for

Selected Transportation Accidents
Ac:t:=:~f') 0:er Ac~;:~:~f~l 0 :0r Rtlea!>e(c,d) Ftrst 'fear Dose

fifty Ye1r DOse
Con~~fbnlnt
Acctdent Descrtetton D1Sinlntlement Saf1 Storagt ~ ~~~~
Minor Accident W1lh Cloud van 7.4 • 10- 2 2.5 Jl lo- 2 No Release J•l
Moderate Accident With Closed _,
Von ).8 X 10· 2 6.0 • 10-l 1 ... 10- 4 6.8 x 1o:~
4.4 k 10
6.4
2.6
X
Jl
10::
10
2.4 J( tO:~
8.9 • 10 n: :g-2
Se\'ere Acddent W1th Closed
Von 4.7x10' 4 1.6 II 10• 4 1 .. 10- 2 6.8 • 10-~ 6.4 • 10- 1 24 6.~ • 10-l
4.4 • 10- 2.6 8.9 6.~
'· ~-
a) Muhtuft•·exposed lndhfdvel ts alSIJIIed at 100 meters from. tM s1te or tht accident.

bl Bued on acddent probability gtvtn tn Rtferenct S. and shown tn Table 11.4-2 for varfous 1cctdent severtty cluses.
1re
~ ::~::,:"f~=c~~=~n~:~1..!!p~~b~! =~.~~~~~~ f~~~=~!~te and uve" accidents assl.lfttd to be 10-6 1nd to·• respectiVely.
e A dnh tndicetes no calculation ws Dlde.
f The ftrst value for eacb uctdent dtscrfptton Is ass~~ntng the releastd radfoactfvtty fs 111 soluble~ the
second value ts Ul\llling 111 releutd radlo1cthtty ts Insoluble.
11-26
. ;;
The maximum-exposed individual is assumed to be located approximately

100 m from the point of a transportation accident. The calculated dose values
shown in Table 11.4-3 are for the first-year dose and 50-year dose commitment
to the bone and lung.
The average rad1onuclide inventory per truck shipment is conservatively
assumed to be 100 Ci of dispersible radioactive material, with shipping
distances of about 800 km (500 mi) to the shallow land burial site, and
2400 km (1500 mi) to the deep geologic disposal site. The waste inventory
is assumed to be characterized by the radionuclide inventory listed in
Table C.2-l of Volume 2.
11.4.3 Nonradiological Transportation Safety Evaluation
;he number of truck shipments for transporting chemicals during Dismantle-
ment is estimated to be no more than one. This is minute compared to the
total truck shipments. Thus, the impact of truck accidents involving ship-
ments of chemical effluents is believed to be negligible for Dismantlement
and for the other decommissioning modes as well.
As with any transport activity, a certain potential exists for injury or
death from decommissioning transport operations. (S) Table 11.4-4 lists
estimates for injuries and fatalities for transportation activities associated
with Immediate Dismantlement, Preparations for Safe Storage, and Entombment.
The numbers of injuries and fatalities for each decommissioning mode are
calculated by multiplying the round-trip distance traveled times the proba-
bility of accidents per vehicle kilometer times the injuries or fatalities
expected per accident.
As shown in Table 11.4-4, there are about 0.57 injuries and 0.034 fatali-
ties estimated to occur for Immediate Dismantlement during the 1.1 million km
of truck travel to and from the waste disposal sites. Since Preparations
for Safe Storage and Entombment require only a fraction of the transport
postulated for Immediate Dismantlement, the injuries and fatalities are sub-
stantially less.
11-27
. ~···~.-~·'>;"'-~:·--:
.. ...:~;;>
. . .'-~;::;?b~~
~~t31f;~1i~~-~'.''(+:~~~. ·-~~~:-
TABLE 11.4-4. Estimated Injuries and Fatalities from Decommissioning Transportation Accidents(a)
Estimated Nonrad1olog1cal
Probabi1 ity Impacts Transpor~-
Transportation (Accidents per Injuries Fatalities km/Operation(b) tion Accidents c
Operation Vehicle, km) Per Accident Per Accident ~Round-Tril!s} lnJurtes Fata1hies
Immediate Dismantldment 1.0 X 10·6 0.51 0.03 1.1 X 106 0.57 0.034
Preparations for Safe Storage 1.0 X 10• 6 0.51 0.03 .].8 X 104 0.02 0.0012
Entombment 1.0 X 10•6 0.51 0.03 1.4 X 104 0.0073 0.00043
(a) Accident frequencies are from Appendix C, Table 1 of Reference 5.

(b) Assuming truck transport of 1600 km (1000 mi) round trip to shallow land burial site, and 4800 km (3000 mi) to
deep geologic disposal site. Immediate Dismantlement requires 630 trips to shallow land burial site and
24 trips to deep geologic disposal site; Preparations for Safe Storage requires 8 trips to deep geologic
disposal site; Entombment requires 3 trips to deep geologic disposal site.
(c) Estimates of injuries and fatalities are rounded to two significant figures •
....
.....
I
N
C»
REFERENCES
1. United Nations Scientific Conrnittee on the Effects of Atomic Radiation,

Ionizing Radiation: Levels and Effects. Vol. 1, United Nations,
pp. 29-63, 1972.
2. Operational Accidents and Radiation Exposures Experienced Within the
~SAEC 1943-1970. WASH-1192, 1971.
3. American National Standards Institute, Method of Recording and Measuring

Work Injury Experience. ANSI 216.1, 1967.
4. U.S. _fode of· Federal Regulations. Title 49, Parts 170-189, "Transportation."
Superintendent of Documents, GPO, Washington, DC, 20555. January 1977.
5. Directorate of Regulatory Standards, Environmental Safety of Transportation
of Radioactive Materials to and From Nuclear Power Plants. WASH-1238, U.S.
Atomic Energy Commission, Washington, DC, 1972.
11-29
,-------
\
\
'
12.0 DISCUSSION OF RESULTS
This section discusses the results of this study and provides comparisons,
where possible, with other known related studies.
Only one other study on the decommissioning of a plutonium fuel fabri-
cation facility 1s known to appear in the current open literature. This is
a study done in 1975 by the staff at Argonne National Laboratory.(l) The
Argonne study discusses, in summary form, the decommissioning methods used to
dismantle one-half of their plutonium fabrication facility.
Five other studies that have possible relationships to the decommissioning
of a MOX fuel fabrication facility exist ir the literature. The earliest ·
of these (September 1974) by the Argonne National Laboratory for the U.S.
Atomic Energy Commission analyzes decontamination techniques and methods for
plutonium-contaminated glove boxes.< 2>
The third reference study (December 1974) is a more in-depth analysis
by the Atlantic Richfield Hanford Company in Richland, Washington for the
U.S. Atomic Energy Commission on the decontamination and dismantlement of a
government-owned plutonium criticality laboratory (called the P-11 facility).( 3 )
The fourth reference study (December 1976) by Mound Laboratory of Monsanto
Research Corporation for the U.S. Energy Research and Development Administra-
tion is a detailed analysis of the decontamination and dismantlement of a
238 Pu contaminated glove box line that was used for fabrication of 238 Pu
isotopic heat sources.< 4 >
The fifth study (June 1977) by Atlantic Richfield Hanford for ERDA is an
analysis of the decommissioning of the plutonium weapons fabrication and
inspection glove box lines in the 234-SZ Building located on the Hanford
Atomic Site.< 5>
The sixth reference study (March 1978) is an analysis by Du Pont de Nemours
'I
and Company at the Savannah River Laboratory for the U.S. Department of
Energy.< 6 > Decontamination experiments in obsolete TRU-contaminated glove
boxes were conducted in this analysis, with the goal of developing guides and
12-1
effective decontamination techniques that would allow large reductions in
the inventories of retrievably stored TRU-contaminated materials.
Another study, an internal su~ary report {1976) by the Eurochemic
Company, documents their decommissioning of a demonstration fuel reprocessing
facility at Mol, Belgium into the Custodial Safe Storage Mode.< 7> Details
about decommissioning their plutonium dioxide plant, however, were insufficient
to allow comparisons with this study.
These studies were undertaken with a variety of motives in mind, and
the conclusions reported tend to reflect the particular interests of the
study sponsor and the purpose for which the study was intended to be used.
The studies are discussed briefly in the following subsections, and the
motivations are indicated, where known. Some discussion of results from
these studies and some comparisons with results from this study are given.
12.1 REFERENCE 1: 1975 ANL STUDY

B. J. Koprowski, L. R. Kelman, D. R. Schmitt and S. Parker, 11 Dis-
mantling a Plutonium Fabrications FaciHty, .. Proceedin¥s of the 23rd
Conference on Remote Systems Technology, pp. 263-269, 975.
The published abstract of this paper follows:
11 The Plutonium Fabrication Facility (PFF) is being dismantled as
part of a plan for consolidating and upgrading plutonium facilities

at Argonne National Laboratory (ANL). The facility consists of fabrica-
tion equipment enclosed within a glove-box system interconnected by a
conveyor. The glove-box system is being dismantled in sections and
the sections are either being reinstalled or converted to scrap ...
This reporL is a brief summary of decommissioning methods used to
dismantle one-half of a plutonium fuel fabrication glove box line. The
principal motive for dismantling the facility was to reduce the needs for
security, safety and safeguards requirements at the laboratory site. The
contents of the report are generally philosophical in approach rather than
technical. The intent of the report is to demonstrate the ability to safely
....;;:
:~:
!::ts> f
~:
; ;:
·;'.. r~·
M~
~~)
'
,.1 ~
12-2
. 2£...··--------~-
dismantle a glove box line and its associated equ1pment, and to convert
salvageable equipment and the cleaned-out building to other uses.
The study examines various alternative techniques for the dismantlement
and removal of the glove box system and discusse~ the rationale used f~r
selecting the mode chosen. Decontamination methods, dismantling equipment
and techniques, transport, salvage, and storage of radioactively contaminated
materials are only briefly discussed. Economics anti safety are not add1·essed.
The evacuated portion of the building was later reoccupied by the New Brunswick
Laborat~ry (DOE). Comparisons between the Argonne study and this MOX study
\'lould be highly desirable. Unfortunately, sufficient information on the
Argonne study, for comparison with this study, is currently unavailable.
tl
12.Z REFERENCE 2: 1974 ANL-8124 STUDY
A. G. Januska, W. J. Tyrrell and G. A. Bennett, "Decontc.mination of
Plutonium Contaminated Glove Boxes," ANL-8124, Argonne National
Laboratory, Argonne, IL, September 1974.
"In connection with the Argonne National Laboratory efforts to
reduce potential hazards in the event a plutonium use facility is
hit by a tornado, a decontamination experiment was carried out to
establish the lowest practicable limits of loose contamination
in an operating glove box, and to determine the relative merits of
solvent wiping and vacuum cleaning as methods of decontamination.
The results showed that a single wiping of the heavily contaminated
test glove box with Calgon Hel-Cat, Myco Tiara, or Pennwalt 2187
solvent for a short period of time removes >95% of the loose
contamination originally present, with a resultant contamination
level of 106 - 107 dpm/100 cm2. Subsequent wipings had little
effect on removing the remaining (< 5%) contamination. Vacuum
cleaning was ineffective as the sole decontamination method;
however, this cleaning method is recommended for removing loose
plutonium in crevices and other hard-to-wipe areas. These results,
although limited by the narrow scope of the experiment, offer the
possibility of decreased decontamination costs for glove boxes
compared to the standard technique, which requires successive
wipings untn the smears are essentially clean."
This study is part of an on-going program at ANL to reduce potential
hazards and p1utonium inventory and to comply with increased security, safety
12-3
r
:'·
:: .•:
.
.
·.
.
.
and safeguards requirements for special nuclear materials. The paper is

similar in intent and purpose to that of Reference 1.
This paper summarizes plutonium decontamination techniques and practices
and details some experiments conducted at ANL to support the decontamination
of pl~tonium-contaminated glove boxes. The effective decontamination techniques
show~ in this ANL study are similar to thos~ used in this MOX study. Economics
and safety di'.t.a are not given.
12.3 REFEREN~~ 3: 1974 ARH-ST-106 STUDY

M. N. Raile, "P-11 Facility Cleanup ~ SuRJDary Report, .. ARH-ST-106,
Atlantic Richfield Hanford Company, Ricnland, WA, December 1974.
11 This document describes methods, techniques, and equipment employed
at Hanford for the cleanup, dismantling, and decommissioning of plutonium-

contaminated facilities. 11
This paper summarizes the methods and techniques employed to cleanup and
dismantle a plutonium criticality laboratory that had been involved in a fire.
The purpose of this decommissioning work was to restore the site to a natural
state that would eliminate any potential environmental hazards to people or
animc.,ls and allow alternative uses of the land area. The report documents the
knowledge gained in plutonium contamination control, dismantling and demolition
methods and special work techniques for the facility being decommissioned. Time
schedYles, work plans and procedures, staff organization, auxiliary equipment
needs and descriptions, radiation monitoring system, necessary building services,
transportation, waste handling and packaging, and demolition techniques are
discussed. A cost summary is provided. The study states that no major injuries
or contamination of workers or environs occurred during the decommissioning.
12.4 REFERENCE 4: 1976 MLM-2381 STUDY

w. R. Harris, B. R. Kokgenge and G. C. Marsh, 11Terminat1on of the Special
Metallurgical {SM) Building at Mound Laboratory - A Final Report,''
MLM-238, Monsanto Research Corp., Mound Laboratory, December 1976.
12-4
-
The author's abstract of this paper follows:

"Highlights of the techniques and procedures. used to decommission
and decontaminate the Special Metallurigcal Building (SM) at the Mound
Laboratory are given. Pertinent health physics information, such as
personnel exposure, final wipe levels of 238pu in the retfred facility,
and ass:~ys of the structure are presented. Recommendations on design
of future plutonium and radioactive material handling facilities
are made."
This is a su11111ary paper highlighting the important factors associated
with decontaminating and decommissioning a building that was used to fabricate
238 Pu isotopic heat sources. Decommissioning work was done to remove
radiological hazards associated with the terminated isotopic heat source
production line. The report provides a written record of the more important
techniques and procedures used for this facility and for similar decommissioning
efforts.
The paper briefly describes the decommissioning staff organization,
decommissioning procedures and techniques, special equipment and facilities,
radiation monitoring systems and techniques, contamination control techniques,
worker radiation exposure data, health physics monitoring data. waste hand.ling,
packaging, shipping and burial data, and recommendations for design of new
238 Pu handling facilities. Cost and public safety data are not provided.
12.5 REFERENCE 5: 1977 ARH-ST-141 STUDY

M. N. t.•ile, "Decommissioning of Divhion of Military Application
(DMA) Equipment at Hanford-Summary Report," ARH-ST-141, Atlantic
Richfield Han\ord Company, Richland, WA, June 1977.
"This report describes the successful decommissioning of plutonium-
contaminated e~ui~ment used for weapon component fabrication and inspec-
tion at the U.S. Energy Research and Developm~nt Administration Hanford
Plant in Washington state. Special materials, techniques, and equipment
were employed during the course of the decommissioning program. Most
significant was the development and design of large, double-wall fiber-
glassed plywood boxes for long-term (20-years, minimum) retrievable stor-
age of the contaminated equipment in underground transuranic waste
trenches."
12-5
This report summarizes the results of a program to decontaminate,
dismantle and remove plutonium-contaminated equipment from a government weapons
production line, to dispose of the equipment by onsite 20-year retrievable
storage or, alternatively, to salvage it for reuse by onsite contractors, and
to restore the cleaned out building areas to other uses.
This decommissioning work was done to eliminate the increasing cost of
continued surveillance, maintenance, and monitoring services for the gradually
deteriorating produ:ction equipment and facilities. The report summarizes
decontamination, di~mantling, waste-handling techniques specifir.ally developed
for decommissioning\the weapons production line. It briefly discusses in a
general manner work P,lans and procedures, staff organization, contamination
control designs, materials and special equipment, dismantling and removal of
equipment, ·records and reports, transuranic waste handling and storage, and
quarterly costs of the entire program.
12.6 REFERENCE 6: 1978 DP-1473 STUDY

J. H. Crawford, "Decontamination of TRU-Glove Boxes," DP-1473,
E. I. DuPont de Nemours and Co., Savannah River Laboratory,
Aiken, SC, March 1978.
"Two glove boxes that had been used for work with transuranic
nuclides (TRU) for about 12 years were decontaminated in a test
program to collect data for developing a decontamination facility
for large equipment highly contaminated with alpha emitters. A
simple chemical technique consisting of a cycle of water flushes
and alkaline permanganate a.nd oxalic acid washes was used for both
boxes. The test showed that·. glove boxes and similar equipment that
are grossly contaminated with transuranic nuclides can be decontami-
nated to the current DOE nonretrievable disposal guide of <10 nCi
TRU/g with a moderate amount of decontamination solution and man-
power. Decontamination of the first box from an estimated 1.3 Ci
to about 5 mCi (6 nCi/g) required 1.3 gallons of decontamination
solution and 0.03 man-hour of work for each square foot of surface
area. The second box was decontaminated from an estimated 3.4 Ci
to about 2.8 mCi (4.2 nCi/g using 0.9 gallon of decontamination
solution and 0.02 man-hour for each square foot of surface area.
Further reductions in contamination were achieved by repetitive
decontamination cycles, but the effectiveness of the technique
decreased sharply after the initial cycle."
12-6
... ·.,:
This work was done to develop and demonstrate cost-effective decontami-

nation techniques for reducing the number and volume of TRU-contaminated
glove boxes, cell liners, and other bulky containers being sent to retrievable
storage. The collected decontamination data serves as a basis for a general
cleaning process and as a basis for the design of a disassembly and decontaminat1~n
facility. The paper highlights the decontamination techniques utilized and .; :·
supplies data that relates decontamination waste volumes and manpower
requirements to the effectiveness of various decontamination methods. It also
discusses contamination controls, decontamination techniques and methods,
and radiation monitoring techniques. Tables are presented that show the
effectiveness of successive decontamination flushes, the volume of waste
solution generated, and the man-hours involved. Costs of these decontamination
efforts are not given.
12.7 DISCUSSION OF STUDY RESULTS

The first point that becomes apparent is that there are no commercial
MOX fuel fabrication facilities for which decommissioning is reported in th~
open literature, and for which direct comparisons can be made with the
results of this study. All but one of the decommissioning experiences
reported in the literature deal with decontamination and dismantling of the
TRU-contaminated glove boxes and glove box systems at laboratories located
within the United States. Where costs are reported, generally they are not
given in sufficient detail to allow the various cost segments to be examined
on a common basis.
Cost information that is available for each of the studies is given in
Table 12.7-1. The only comparable cost data, per 1000 m2 of floor area for
the Reference 3 facility (P-11 criticality laboratory), compares reasonably
well with costs from this study, considering the number of differences between
the two facilities.
Table. 12.7-2 lists average radiation dose per quarter for workers decom-
missioning plutonium-contaminated facilities. The occupational radiation
12-7
·~·" , ....
. :(~,·~ .....
~,,
TABLE 12.7-1. Actual or Estimated Costs for Immediate Dismantlement

of TRU-Contaminated Facilities
Floor Area 1978 Cost Per Unft

Approxi~~~ate Oecontami nated Total 1978 Cost Floor Area Without Burial
Reference Reported Cost, Year of Escalatloy Costs IMil"lions and Oismaotled, ~er Unit Floor A~a, ana fransport Coszs•
No. Study Millions S Estimate Factor a 19 78 Do ll!!!:!L 1000 nZ Mi 11 ions/1000 m Hillions/1000 m
(b)
ANL-NRC - 1975 1.29
2 ANL-AEC - 1974 1.38
3 ARHCO-~EC 0.265 1974-75 1.34 0.36 0.125 2~8
4 NRC-ERDA
ARHCO·EROA
-
2.134
1976 1.11
5 1975-76 1.20 2.56
6 DuPont-DOE - 1978 1.0
Thh Study,
PNL-NRC 7.7 1978 1.0 7.7 2.464 3.1 2.6
(a) Escalation factor to convert to 1978 dollars.

(b) A dash indicates data are not available •
.....
N
I
()0
TABLE 12.7-2. Comparison of Average Worker Radiation
Dose for Immediate Dismantlement of
TRU-Contaminated Facilities
Reference Total Average Man-Rem

No. Study Man-Rem Per Qua~~er of Year
1 ANL-NRC
2 ANL-AEC
3 ARHCO-AEC <0. 1
4 NRC-ERDA 127 0.2(a)
5 ARHCO-ERDA
6 DuPont-DOE
This Study,
PNL-NRC 70 0.22
(a) The range of values here is 0 to 1.
dose estimates in this study compare favorably wUh those of the actual
decommissioning experiences.
Several general conclusions can be drawn from these studies. The
first conclusion is that no major technical impediments exist to the
successful decommissioning of plutonium-contaminated facilities. The
job can be done, using currently available technology, within the
framework of present regulations, with virtually no impact on the safety
of the general public.
The second conclusion is that the decontamination of TRU-contaminated
facilities is a labor intensive, hands-on effort. Thus, labor is the major
fraction of the total decommissioning costs. Efforts to devel_op facility
and equipment designs, and decontamination systems and techniques that can
minimize labor will significantly reduce overall decommissioning costs for
TRU-handling facilities.
The third major conclusion is that the cost of handling, packaging, trans-
portating and disposing of radioactive materials is a significant fraction of
the total decommissioning cost. Again, efforts to develop facility designs
12-9
and decontamination techniques that minimize the quantities of contaminated
material that must be disposed of as radioactive waste will reduce overall
decommissioning costs and the waste management burden.
The final conclusion is that development of realistic nuclear facility
decommissioning cost estimates hinges on the necessity of performing
dl~tailed analysis on the specific plant under consideration. Design
differences among plants can have a significant impact on the types and amount
of work involved in accomplishing decommissioning. Until such time as
facility designs are standardized, application of data from one facility can
only be used as an order-of-magnitude estimatP for another facility. Plant-
specific analyses wil.l likely be necessary.
f'
12-10
REFERENCES
1. B. R. Koprowski, L. R. Kelman, D. R. Schmitt and S. Parker, 11 Dis-

mantling a Plutonium Fabrications Facility, .. Proceedinys of the 23rd
Conference on Remote Systems Technology, pp. 263-269, 975.
2. A. G. Januska, W. J. Tyrrell and G. A. Bennett, Decontamination of
11
Plutonium-Contaminated Glove Boxes, .. ANL-8124, Argonne National

Laboratory, Argonne, IL, September 1974.
3. M. N. Raile, "P-11 Facility Cleanup- Sunmary Report, .. ARH-ST-106,
Atlantic Richfield Hanford Company, Richland, WA, December 1974.
4. W.R. Harris, B. R. Kokgenge and G. C. Marsh, 11 Termination of the
Special Metallurigical (SM) Building at Mound Laboratory - A Final Report, ..
MLM-238, Monsanto Research Corp., Mound Laboratory, December 1976.
5. M. N. Raile, .. Decommissioning of Division of Military Application
(DMA) Equipment at Hanford-Summary Report, .. ·ARH-ST-141, Atlantic
Richfield Hanford Company, Richland, WA, June 1977.
6. J. W. Crawford, "Decontamination of TRU-Glove Boxes," DP-1473,
E. 1. Du Pont de Nemours and Co., Savannah River Laboratory, Aiken, SC,
March 1978.
7. E. J. Detilleux, "Status of the Deconmissioning Programme of the
Eurochemic Reprocessing p·iant," CONF-76-0701, International Symposium
on the Management of Wastes from the LWR Fuel Cycle, Denver, CO, July 1976.
12-11
13.0 DESIGN CONSIDERATIONS FOR THE FACILITA'fiON OF DECOMMISSIONING
The present study on Inwnediate Dismantlement and Safe Storage of a small

MOX plant describes activities that can be used to conceptually decommission
a reference facility. With this study as a basis, insights have been gained
as to plant design characteristics that could simplify the task of decommis-
sioning. This section summarizes some of these potential plant and equipment
design features. Although not aimed at other types of nuclear fuel fabrication
plants (such as for uranium or thorium fuels, or large MOX plants), some of the
general considerations presented here may also be applicable to some of those
faci Hties.
It is recognized that some of the considerations intended to enhance
decommissioning may not always be compatible with those plant characteristics
that are desirable for normal production operations. Some of the characteris-
tics may also be prohibitively expensive. However, the aim of this discussion
is to point out design characteristics that would expedite and simplify the
decommissioning task. These findings regarding desirable features for decom-
missioning are presented with no attempt to rank their relative importance, or
to determine impacts on the rest of the plant designs, on plant production
ope1·ations, or plant process performance. These insights are aimed only at
areas that present obvious complexity or difficulty to decommissioning a
small MOX plant; they are not all inclusive, and do not consider details, side
effects, or variations of the alternatives. Such an analysis would require an
in-depth study beyond the scope of this report.
Title 10 Code of Federal Regulations, Part 50, Appendix F.4 describes the
Nuclear Regulatory Commission•s position regarding facilitation of decommis-
sioning of fuel reprocessing plants: A design objective sha·ll be to facili-
11
tate decontamination and removal of all significant radioactive wastes at the

time the facility is permanently decommissioned ... Application of this NRC
objective to other fuel cycle facilities is a logical extension of the inten-
tion of this regulation. Additionally, NRC Regulatory Guide 8.8, Information
Relevant to Ensuring that Occupational Radia.tion Exposures at Nuclear Power
Stations be as low as is Reasonably Achievable (ALARA), explicitly points
f
r
i
\
13-1
I
I
out that "design concepts and station features should reflect consideration
of the activities of station personnel (including decontamination and decommis-
sioning) that might be anticipated."
l'he general criteria used in selecting design features for consideration
are based on the effect they might be expected to have on decreasing decom-
missioning cost, improving occupational or public safety, reducing total
decommissioning time, creating less radioactive waste, and the general ease
of perfonning the deconmissiorting. In evaluating new design features for
future decommissioning application, appropriate balance must be maintained
between designs that meet these criteria and potential negative effects on
plant construction and operating costs and operating characteristics. For
the considerations offered below, qualitative comments are made about the
possible effects a given design feature might have in satisfying the selection
criteria.
1) Pre-polished Metal Surfaces
Pre-po 1i shi ng the surfaces of meta 1 process eq,Ji pment would be advan-
tageous to decommissioning. This action at the time of p"lant construc-
tion will tend to reduce the holdup of radioactive materials on the
equipment. It wi-11 make the equipment more corrosion-resistant, and it
will render the equipment easier to decontaminate.
2) Minimizing Crevices in Process Areas
Minimizing the crevices in process equipment, glove boxes, and hoods
will ease decommissioning. An example of this technique is to fabricate
glove boxes with all corners rounded. Minimizing crevices will reduce
hold up of radioactive materials and will afford easier decontamination.
3) Disassemblable Glove Boxes
The capability to disassemble glove boxes without cutting would bene-
ficially affect decommissioning. Removal of conventional glove boxes
requires cutting to smaller sizes for eventual treatment or waste
disposal, and cutting requires time and more care to manage the added
fumes and particulates generated from the cutting.
13-2
4) Provide Flushing Capability \
The capability to readily provide liquid flushes, especially to glove

boxes and hoods, would be advantageous to decommissioning. This feature
could be incorporated by such techniques as providing the capability to
accept spray systems and providing drains or sumps to collect the liquids
(especially in dry processing areas). These kinds of provisions would
minimize time-consuming manual cleaning techniques and manual systems
for handling the cleaning liquids. Other related improvements, such as
providing more flexible capability for heating or storing liquid flushes,
would provide similar benefits.
5) Waste Volume Reduction Systems
Reduction of volumes of liquid and solid wastes is highly desirable in
decommissioning to reduce waste handling and waste management costs.
These systems could include evaporation for liquids and incineration for
combustible solids. This capability does not necessarily need to be
installed within the facility for decommissioning, but the facility should
have provisions to readily accept the capability, either built-in or
from portable units.
6) Readily Changeable HEPA Filters
The second stage of HEPA filters in the reference facility are difficult
to change. These could be located and designed for more ready change-
ability. This feature would reduce decommissioning efforts and potentially
improve occupational and public safety.
7} CapabiHty of Glove Box HEPA Filters to Withstand Moisture
Decommissioning typically involves decontamination by spraying liquids.
Conventional HEPA filters at the ventilation exhaust of glove boxes or
hoods are subject to plugging by mists from spraying. Use of filters
that can withstand mists would provide improved safety, flexibility and
shorter times for decontamination techniques, and potentially fewer filter
changes that affect decommissioning costs.
13-3
8) Removal of Equipment Without Destructive Disassembly
./1~ the reference facility, much process equipment within glove boxes
must be cut up in-place to enable its removal. The capability to remove
equipment without cutting it up in-place would reduce decommissioning
activities and the associated safety and cost concerns.
9) Wider Spacing of Piping
Much of the piping and tubing in the facility is spaced relatively close
together, thus making it difficult to use tools for removal of the piping.
With larger spaces between such pipes (and in some places more accessible
piping), a wider variety of tools may be used that would permit more
rapid pipe removal.
10) Separation Between Piping And Wiring
In some places of the reference facility, piping and electrical wiring
are run through the same general areas or raceway, thus causing inter-
ference by one when the other is being removed. Keeping the two services
separated would improve safety and decrease the time required for their
removal.
11) Capability to Handle Large Volumes of Fumes From Cleaning
The plasma arc cutting technique used in this conceptual decommissioning
stu~y generates relatively large volumes of aerosol-containing gases that
must be treated before release to the atmosphere. To allow plasma arc

cutting, portable systems are assumed to be used to handle these fumes,
but many of the reference plant systems are not readily amenable to such
temporary installations. Improved capability to accept these portable
fume-handling systems would reduce the time and cost of decommissioning.
The same consideration applies to some areas where greenhouses are used
for decommissioning but where the effective u:~ of the greenhouses is
t•educed by the layout, because of space limitations or complExity of
the associated equ;pment.
12} Improved Design For Major Maintenance
Many process areas in the reference facility are not amenable to ease
in major maintenance, such as provided by accessibility to equipment
13-4
'
and ready capability to move major equipment to the maintenance area
or to other areas within the building. Improvement in this capability
would allow for safer and faster, and less expensive, decommissioning.
13} Jmproved Removal of Particulates From Glove Box Exhaust
Significant quantities {i.e., kilograms) of plutonium are held up in the
ventilation exhaust ducts from the glove boxes, thereby complicating
decommissioning. Improved retention of these particulates would reduce
the amount of plutonium in these ducts and in1prove safety and reduce
decontamination efforts. The same benefits would be derived by an
improved particulate retention system in the dusty dry process areas.
This might be accomplished by additional vent exhaust systems at the
points of dust generation.
14) Improved Access to Furnace Internals
In the reference facility, the sinterins furnaces hold up major quanti-
ties (i.e., kilograms} of plutonium, primarily because of the porous
nature of the fire brick and the number of crevices. This holdup is
almost impossible to remove wit!1out destroying the furnace. Modified
furnace designs, to minimize dust holdup and to allow access for non-
destructive cleaning during operation, would allow for more streamlined
decon~missioning activities and improved safety.
15) Use of More Corrosion-Resistant Material~
In some areas of the reference MOX facility, such as gaskets, seals and
some metal equipment, leaks occur during operations or operational clean-
outs due to the corrosivity of the process media. These leaks contribute
to the contamination levels within process enclosures. Reducing these
leaks would reduce decontamination efforts.
16) Minimize Contaminated Concrete
To minimize contamination of concrete, the reference facility has most of
the concrete protected by metals or paints. However, few areas,
such as floor drains and liquid storage tanks set within concrete walls.
13-5
are designed in such a manner as to allow contamination of concrete.
Decowmissioning efforts, potential spread of cont~mination, waste
volumes, and costs could be greatly reduced by improved design of
piping cast in concrete. Improvements that would allow piping to
be easily removed, along with associated contamination, would be
highly desirable.
17) Eliminate Contaminated Settling Ponds
The sludge from contaminated settling ponds requires major effort to
remove and is costly for disposal. Installat·ion of a waste management
system that eliminates the use of these ponds would significantly reduce
decommissioning efforts and costs.
13-6
14.0 GLOSSARY
Abbreviations, terms, definitions, and symbols directly related to

decommissioning work and related technology are defined and explained in this
section. It is divided into two parts, with the first part containing
abbreviations, symbols, and a conversion table to International System of
Units {SI), and the second part containing terms and definitions (including
those used in a special sense for this work). Common terms covered adequately
in standard dictionaries are not included.
14.1 ABBREVI~JIONS, SYMBOLS AND SI UNITS

Abbreviations
AEC Atomic Energy Commission
ALARA As Low As is Reasonably Achievable(a}
ATMX Army Transport Mobile for Explosives(a)
CFR Code of Federal Regulations(a)
Ci Curie(a}
OF Dect:mtaminatioll Factor(a)
DOT Department of Transportation
DPM Disintegrations per Minute(a)
EDTA Ethylenediamine tetraacetic acid
FSAR Final Safety Analysis Report
GB Glove Box
HEPA High Efficiency Particulate Air (Filters)
HP Health Physicist(a)
HVAC Heating, Ventilation and Air Conditioning
LWR Light Water Reactor
MOX Mixed Oxide
mR Milliroentgen{a)
mrad Mi 11 i rad {a)
mrem Millirem, see rem also
MT Metric Ton(a)
{a) See Section 14.2 for additional information or explanation.
14-1
MTHM Metric Ton of Heavy Metal
MWd/MTU Thermal Megayatt-day per Metric Ton of Uranium,
the Burnup{
NRC Nuclear Regulatory Commission
PWR PressurizP.d Water Reactor
Q.A. Quality Assurance(a)
Q.C. Quality Control(a)
R Roentgen(a)
rad Radiation Absorbed Dose(a)
rem Roentgen Equivalent Man(a)
SNM Special Nuclear Material(a)
ss Stainless Steel
sx Solvent Extraction
Tl/2,TR Half Life, Radiological(a)
UF Urea-formaldehyde
Symbols
a Alpha Radiation(a)
6 Beta Radiation(a)
y Gamma Radiation(a)
X Chi, Concentration, pCi/m
3
Q Released Quantity of Radioactive Material, Ci
Ql Release Rate of Radioactive Material, Ci/sec
x/Q· Chi-bar/Q prime, normalized annual aver~9e air concentration (pCi/m 3 )
per Ci/sec released, also written sec/m ). Also called the
annual average atmospheric dilution factor.
Sl Units
Sl units for use with radioactivity and ionizing radiations are as
follows:
Old Special
New Named Unit In Other Unit and Relationship
guantitl and Slmbol Sl Units S.l!!!bol New to Old Units
Exposure coulomb/kg (C/kg) roentgen (R) 1 C/kg "'3876 R

Absorbed dose gray (Gy) joule/kg (J/kg) rad (rad) 1 Gy = 100 rad
Dose equivalent sievert (Sv) J/kg rem (rem) 1 Sv = 100 rem
Activity becquerel (Bq) seconds·! (s -1) curte (Ct) 1 Bq ... 2.10 x 1o· 11 ct
(a) See Section 14.2 for additional information or explanation.
14-2
~
l ....
14.2 GLOSSARY DEFINITIONS

Actinides: A series of heavy radioactive metallic elements
of increasin9 atomic number (Z) beginning with
actinium (89) or thorium (90) through element
hahnium of atomic number 105.
Activity: See Radioactivity.
Airborne Radioactive Radioactive particulates, mists, fumes, and/or
Material: gases in air.
ALARA: A philosophy to maintain exposure to radiation
As how As is Reasonably Achievable.
Alpha Decay: Radioactive decay in which an alpha particle
is emitted. This transformation lowers the
atomic number of the nucleus by two and its mass
number by four.
Alpha Particle: A positively charged particle emitted by certain
radioactive materials. It is made up of two
neutrons and two protons, hence it is identical
with the nucleus of a helium atom. It is the
least penetrating of the three common types of
radiation (alpha, beta and gamma) emitted by
radioactive material.
Alpha Emitter: A radionuclide that undergoes transformation by
emission of alpha particles.
ATMX: Railcars that are used in transporting large
quantities of low-level waste at government
facilities. Th~ cars are specially reinforced.
They have interior dimensions of 2.74 m (9ft)
x 2.74 m (9ft) x 15.24 m (50ft) and a useful
load of 45,800 kg {101,000 lb). The Army Trans-
port Mobile Explosives units were originally used
by the U.S. Army for the transport of conventional
explosives. The cars used for transporting nuclear
materials are modified versions of the standard
car.
Atomic Number (Z): The number of protons in the nucleus of an atom;
also its positive charge. Each chemical elemP.nt
has its characteristic atomic number, and the
14-3
atomic numbers of the known elements form a
complete series from 1 (hydrogen) through 105
(hahnium).
Background: That level of radioactivity from sources existing
without the presence of a nuclear plant, including
nonplant-related sources, such as might result
from atmospheric weapons testing.
Bag Out: Term used to describe the techniques for transferring
objects into and/or out of glove boxes without loss
of confinement, utilizing various types of contain-
ers, sealing and packaging techniques.
Beta Decay: Radioactive decay in which a beta particle is emitted
or in which an orbital electron capture occurs.
Beta Particle: An electron, of either positive or negative charge,
which has been emitted by an atomic nucleus in a
nuclear transformation.
Burial Grounds: Areas designated for storage of packaged radioactive
wastes in soils just below the surface.
Burnup, Specific: -lhe total energy released per unit mass of a nuclear
fuel. It is commonly expressed in megawatt-days per
metric ton of fuel material. (Also called fuel
irradiation level.)
Byproduct Material: Any radioactive material (except special nuclear
material) yielded in or made radioactive by exposure
to the radiation incident to the process of producing
or utilizing special nuclear material.
Calcine: To heat a substance to a high temperature, but below
its melting point, causing loss of volatile
constituents such as moisture. Material produced by
this process is also called Calcine.
Cask: A heavily shielded shipping container for radioactive
materials. Some casks weigh as much as 100 metric
tons.
Chemical Limits: Maximum concentrations or quantities imposed upon
chemical releases to the environment in gaseous
or liquid effluents discharged from a facility, and
consistent with known air or water quality standards.
Code of Federal The Code of Feder~l R~gulations is a documentation
Regulations (CFR): of the general rules by the Executive departments
14-4
and agencies of the Federal Government. The Code
is divided into 50 titles that represent broad
areas subject to Federal regulation. Each title
is divided into Chapters that usually bear the
name of the issuing agency. Each Chapter is
further subdivided into Parts covering specific
regulatory areas.
Contact Maintenance: "Hands-on", or maintenance performed by direct
contact of personnel with the equipment. It
includes maintenance with protective equipment
or clothing, such as through gloves in glove
boxes. Most nonradioactive maintenance is
contact maintainance.
Contamination: Undesired materials that have been deposited on
the surfaces, or are internally ingrained into
structures or equipment, or that have been mixed
with another material.
Continuing Care Period: The surveillance and maintenance period of
decommissioning to the Safe Storage state, with
the facility secured against intrusion. Also
called Interim Care period.
CrHical: A condition wherein a medium is capable of
sustaining a nuclear chain reaction.
Prompt critical is being capable of sustaining
a chain reaction without the aid of neutrons
whose velocity has been slowed down.
Critical Mass: The mass of fissionable material that will
support a self-sustaining nuclear chain reaction.
Curie: A special unit ~b radioactivity. One curie
equals 3.7 x 10 nuclear transformations per
second. (Abbreviated Ci.) Several fractions
of the curie are in common usage:
• Millicurie. One-thousandth of a curie. Abbre-
viated mCi (3.7 x 107 d/s).
• Microcurie. One-millionth of a curie. Abbre-
viated ~Ci (3.7 x 104 d/s).
• Nanocurie. One-billionth of a curie. Abbre-
viated nCi (37 d/s).
• Picocurie. One-millionth of a microcurie.
Abbreviated pCi; replaces the term ~~Ci
(0.037 d/s).
14-5
I --------~----'---~-.........---------
Custodial Safe Storage: A minimum cleanup and decont1m·ination effort is
made initially, followed by a period of interim
care with the active protection systems (i.e.,
ventilation, utilities, fire) kept in service.
The site is secured by physical barriers and by
guards against intrusion. Use of the facility
and site is limited to nuclear activities.
Decay, Radioactive: A spontaneous nuclear transformation in which
a particle, gamma radiation, or x-ray radiation
are emitted.
Decommissioning: Preparations taken for retirement from active
service of nuclear facilities, accompanied by
the execution of a program to reduce or stabilize
radioactive contamination. Actions are taken
to minimize potential health and safety impacts
of the retired nuclear facility on the public.
Decontamination: Those activities employed to reduce the levels
of contamination in or on structures, equipment
and materials.
Decontamination Those chemical materials used to effect decon-
Agents: tamination.
Decontamination The ratio of the initial concentration of an
Factor (OF): undesired material to the final concentration
resulting from a treatment process. The term
may also be used as a ratio of quantities.
De minimus Level: That level of contamination that is acceptable
for unrestricted public use or access.
Design Basis A postulated accident believed to have the most
Accident: severe expected impacts on a facility. It is
used as the basis for safety and structural
design.
Discount Rate: The rate of return on capital that could have
been realized in alternative investments, if
the money were not corrmi.tted to the plan being
evaluated, i.e., the opportunity costs of
alternative investments. This cost is equiva-
lent to the weighted average cost of capital.
Disintegration, The transformation of the nucleus of an atom from
:·1 Nuclear: one element to another, characterized by a definite
half-life and the emission of particles or
radiation.
14-6
Disintegration The rate at which disintegrations occur,
Rate: characterized in units of inverse time; i.e.,
disintegrations per minute (dpm), etc.
Dismantlement: Those actions required to disassemble and remove
sufficient radioactive or contaminated materials
from the facility and site, to permit release of
the property for unrestricted use.
Dispersion: A process of mixing one material within a
larger quantity of another. For example,
the mixing of material released to the atmos-
phere with air causes a reduction in concentration
.
with distance from the source •
Disposal: The disposition of materials with the intent
that the materials will not enter man's
environment in sufficient amounts to cause
a health hazard.
Dose, Absorbed: The mean energy imparted to matter by ionizing radia-
tion per unit mass of irradiated material at the
place of interest. The unit of absorbed dose is
the rad. One rad equals 0.01 joules/kilogram in
any medium (100 ergs per gram).
Dose, Equivalent: Expresses the amount of radiation that is effective
in the human body, expressed in rems. Modifying
factors associated with human tissue and body are
considered. Equivalent dose is the product of
absorbed dose multiplied by a quality factor multi-
plied by a distribution factor. Referred to as
Dose in this report.
Dose, Occupational: The exposure of an individual to radiation as a
result of his employment, expressed in rems.
Dose Rate: The radiation dose delivered per unit time and
measured, for instance, in rems per hour.
Dosimeter: A device, such as a film badge or ionization
chamber, that measures radiation dose.
Enrichment: The ratio (usually expressed as a percentage)
of fissile isotope to the 3total amount of the
element (e.g., the% of~ 5u in uranium.)
Entombinent: The encasement of radioactive materials in con-
crete or other strucural materials sufficiently
strong and durable to assure ~etention of th~
14-7
radioactivity until it has decayed to levels
that permit unconditional release of the site.
Exposure: A measure of the ionization produced in air by
x or gamma radiation. It is the sum of the
electrical charges on all ions of one sign
produced in air when all electrons liberated by
photons in a volume element of air are completely
stopped in air, divided by the mass of air in
the volume element. The special unit of exposure
is the roentgen. (See Roentgen.)
Facility: The physical complex of buildings and equipment
within a site.
Fission: The splitting of a heavy atomic nucleus into two
lighter parts (atomic nuclides of lighter ele-
ments), accompanied by the release of a relatively
large amount of energy and generally one or
more neutrons. Fission can occur spontaneously
but usually it is caused by nuclear absorption
of gamma rays, neutrons, or other particles.
Fission Products: The lighter atomic nuclides {fission fragments)
formed by the fission of heavy atoms. It also
refers to the nuclides formed by the fission
fragments• radioactive decay.
Food Chain: The pathways by which any material {such as
radioactive material from fallout) passes through
man's environment through edible plants and/or
animals to man.
Fuel Assembly: A grouping of fuel elements (hollow rods filled
with nuclear fuel for LWRs) that supolv the
nuclear heat in a nuclear reactor. A fuel ele-
ment or rod is the smallest structurally discrete
part of a reactor or fuel assembly that has
nuclear fue:l as its principal constituent.
Fuel Cycle: The series of steps involved in supplying fuel
for nuclear power reactors, handling the spent
fuel and the radioactive waste, including trans-
portation.
Head end: Mining, milling, conversion, enrich-
ment, and fabrication of fuel.
Back end: Includes reactors, spent fuel storage,
spent fuel reprocessing, mixed-oxide fuel
fabrication and waste management.
14-8
Fuel Element: A rod, tube, or other form into which nuclear
fuel is fabricated to use in a reactor.
Gamma Rays: Short-wavelength electromagnetic radiation.
Gamma radiation frequently accompanies alpha
and beta emissions and always accompanies
fission. Gamma rays are best stopped or
shielded against by dense materials such as
lead or uranium. These rays usually originate
from within the nucleus of the atom.
Gaseous: Material in the vapor or gaseous state, but can
include entrained liquids and solids. A gas will
completely fill its container regardless of
container shape or size.
Glove Box: A box, usually made of stainless steel and large
panes of glass or transparent rigid plastic,
in which workers using gloves attached to, sealed,
and passing through, openings in the box can safely
handle radioactive materials from the outside
by inserting their hands into the gloves and
manually performing manipulations.
Greenhouse: In nuclear terms, a temporary structure, fre-
quently constructed of wood and plastic film, used
to provide a confinement barrier between a radio-
active work area and a nonradioactive area.
Guard: An individual whose primary duty is the guarding
and protection of material against theft and/or
the protection of the facility against vandalism
or undesired intruders.
Half-life, The time required for a biological system,
Biological: such as a man or animal, to eliminate by
natural processes, half the amount of a sub-
stance that has been absorbed by it.
Half-Life, The time required for a radionuclide contained
Effective: in a biological system, such as a man or animal,
to reduce its radioactivity by half as a combined
result of radioactivity decay and biological
elimination.
Half-life The time in which half the atoms of a particular
Radioactive: radioactive substance disintegrate to another
nuclear form. Each radionuclide has a unique
half-life. Measured half-lives vary from
millionths of a second to billions of years.
14-9 ~
.'.~
'..1
...:
~
. ·,
I
...
Health Phys1cist: A person trained to perform radiation surveys,

oversee radiation monitoring, estimate the
degree of radiation hazard, and advise on
operating procedures for minimizing radiation
exposures.
Health Physics: The science concerned with recognition,
evaluation, and control of health hazards from
radiation.
Heavy Metal: Jargon used in reference to metals with atomic
numbers 90 and greater. It usually refers to
nuclear fissile or fertile fuels such as thorium,
uranium and plutonium.
Hood: Vented containment space, enclosed on 5 sides,
with the sixth side covered by a movable glass
window to allow access and to maintain suffi-
cient in-flow of air and splash control to
protect the worker from the hazardous materials
handled inside.
Hot Spots: Areas of radioactive contamination higher than
average.
Inunobilization: Treatment and/or emplacement of materials {e.g.,
radioactive contamination) so as to impede its
movement.
Interim Care Period: A period of time starting after the initial
decommissioning activities cease and wherein
surveillance and maintenance takes place. The
duration of time can vary from a few years to
more than 100 years; also called the continuing
care period.
Interim Storage: Storage operations for which a) monitoring and
hum~n control are provided and b) subsequent
action in which final disposition is expected.
Concepts for interim storage include bulk or
compartmented storage of solid, liquid and
gaseous wastes or other materials.
Intrusion Alarm: A means of detecting intrusion of individuals
into a protected area utilizing an electro-
mechanical, electro-optical, electronic,
mechanical or similar device with a visible
or aud·ible alarm signal.
14-10
Ion Exchange: A chemical process involving the selective
absorption or desorption of various chemical
ions in a solution onto a solid material, usually
a plastic or resin. The process is used to
separate and purify chemicals, such as fission
products from plutonium or "hardness" from water
{i.e., water softening).
Layaway: See Custodial Safe Storage.
Licensed Material: Nuclear source material, special nuclear material,
or nuclear by-product material received, possessed,
used, or transferred under a license issued by the
Nuclear Regulatory Commission.
Long-Lived Nuclides: For this study, radioactive isotopes with long
half-lives typically taken to be greater than
about ten years. Most nuclides of interest
to waste management have half-lives on the
order of one year to millions of years.
Management (Waste): The planning, execution, and surveillance of
essential functions related to radioactive waste,
including treatment, solidification, packaging,
interim or long-tenm storage, transportation and
disposal.
Man-rem: A measure of radiation dose. To calculate radiation
dose to the population, the dose equivalent in rem
received by each person in the population is
summed.
Mass Numbers: The number of nucleons {protons and neutrons)
in the nucleus of an atom. {Symbol: A).
Maximum-Exposed Individual: The hypothetical member of the pu.bl ic who receives
the maximum radiation dose to an organ of reference.
For the common case where exposures from airborne
radionuclides result in the highest radiation
exposure, this individual resides at the location
of the highest airborne radionuclide concentration
and eats food grown at that location.
Megawatt-day: A unit for expressing the energy generated in a
reactor; specifically, the number of millions of
watt-days of heat output per metric ton of fuel
in the reactor. Also, the net electrical output
in millions of watts of electrical energy averaged
over one day.
14-11
Megawatts per Metric Ton Amount of thermal megawatts produced per metric
of Uranium: ton of uranium.
Megawatt Days per Metric Amount of thermal megawatt-days produced per
Ton of Uranium: metric ton of uranium; also called burnup. (See
also specific power.)
Metric Ton: 1000 kilograms (See Tonne.)
Mixed O~ide: Amixture of uranium dioxide and plutonium dioxide.
Monitoring: Taking measurements or-observations for recog-
nizing the status or adequacy, or significant
changes in conditions or performance of a facility
or area.
Mothball: A decommissioning mode encompassing custodial
safe storage and protective safe storage.
Normal Operating Operation (including startup, shutdown, and
Conditions: maintenance) of systems within the normal range
of applicable parameters of an operating facility.
Nuclear Reaction: A reaction involving a change in an atomic
nucleus, such as fission, fusion, particle
capture, or radioactive decay.
Offsite: Beyond the boundary line marking the limits
of plant property.
On site: Within the boundary line marking the limits
of plant property.
Operable: Capable of performing the required function.
Overpack: Secondary (or additional) external containment or
cushioning for packaged materials.
Package: The packaging plus the contents of radioactive
materhls.
Packaging: The assembly of radioactive material in one
or more containers and other components necessary
to assure compliance with prescribed regulations.
Passive Safe Storage: A decommissioning mode in which partial clean-up
and decontamination is performed, sufficient
to permit deactivation of the active protection
systems (i.e., ventilation, utilities} during the
interim care period. The structures are secured
"14-12
by rigid physical barriers and continuous remote
monitoring. The plant is limited to nuclear use
on1y, while the site may have non-nuclear uses.
Plant: The physical complex of buildings a~~ equipment,
including the site.
Possession-only A license issued to a nuclear facility owner
License: by the NRC entitling the licensee to own a
facility containing nuclear materials but not
to operate it.
PrP.sent Value of Money: The present value of a future stream of costs
or payments is the present investment necessary
to secure or yield the future stream of payments
with compound interest at a given discount or
interest rate.
Primary Wastes: Wastes that are generated as a part of the
principal operation of a facility. Secondary
wastes are generated from supporting operations,
such as waste treatment.
Process Cells: Shielded rooms housing (radioactive) processing
systems.
Proc~ss Equipment: The functional equipment items or systems
associated directly with the operation of a
chemical or mechanical operation.
Protective Clothing: Special clothing worn by a person in a radio-
actively contaminated area to minimize the
potential for contamination of his body or
personal clothing.
Protective Storage: See Passive Safe Storage.
Protective Survey: An evaluation of the radiation and its hazards
incidental to the production, use or existence
of radioactive materials. It normally includes
a physical survey of the arrangement and use
of equipment and measurements of the radiation
dose rates under expected conditions of use.
Also called protection survey.
Quality Assurance: The systematic actions necessary to provide
adequate confidence that a material, component,
system, process, or facility performs satis-
factorily, or as planned, in service.
14-13
Quality Control: The quality assurance actions that control the
attributes of the material, process, component,
system, or facility in accordance with pre-
determined quality requirements.
Rad: A unit of absorbed dose. The energy imparted
tJ matter by ionizing radiation per unit mass of
irradiated material at the place of interest.
One rad equals 0.01 joule/kilogram of absorbing
material.
Radiation: (l) The emission and propagation of radiant
energy: for instance, the emission and propa-
gation of electromagnetic waves, or of sound
and elastic waves. (2) The energy propagated
through space or through a mater;al medium. for
example, energy in the form of alpha, beta, and
ga11111a emissior•s from radioactive nuclei.
Radiation Area: Any area, accessible to personnel, in which
there exists radiation at such levels that a
major portion of the body could receive in any
one hour a dose in excess of 5 millirem, or
in any 5 consecutive days a dose in excess of
100 millirems. (10 CFR 20.202)
Radiation Background: See background.
Radiation, All radiation coming from a source housing
Leakage (Direct):. except the useful beam.
Radioactive Any material or combination of materials which
Materia 1: spontaneously emit ionizing radiation and
which has a specific radioactivity in excess of
0.002 microcuries per gram of material.
(49 CFR 173.389 (e)).
Radioactive A succession of nuclides, each of which
Series: transforms b.v radioactive disintegration into
the next until a stable nonradioactive nuclide
results. The first member is called the parent,
11 11
the intermediate members are called daughters,

11 11
and the final stable member is called the

enct product ...
11
Radioactivity: The number of nuclear transformations-occurring

in a given quantity of material per unit time
with the emission of particles, gamna radiation,
or x-ray radiation. Often shortened to acti vity. ''
11
Radioactivity, The property of radioactivity exhibited by

Natural: more than fifty natura 11 y occurring radi onuc 1ides.
14-14
1. ·--------...................... _......................,.________ -----------------

.....
Radiological Protection against the effects of internal and
Protection: external exposure to radiation and to radio-
active materials.
Regulatory Regulatory Guides are issued by the NRC, to
Guides: describe and make available to the public,
methods acceptable to the NRC staff, for
implementing specific parts of the NRc•s regu-
lations, to delineate techniques used by
the staff in evaluating specific problems or
postulated accidents, or to provide other
guidance to applicants for nuclear operations.
Guides are not substitutes for regulations and
compliance with them is not explicitly required.
Methods and solutions different from those set
out in the guides may be acceptable if they provide
a basis for the findings requisite to the
issuance or continuance of a permit or license
by the NRC.
Rem: A unit of radiation dose equivalence. The radia-
tion dose equivalence in rems is numerically equal
to the absorbed dose in rads multiplied by the
quality factor, the distribution factor, and
any other necessary modifying factors.
Remote Maintenance: Maintenance by remote means, i.e., the operator
is separated by a shielding wall from the item
being maintained.
Reporting Levels: Those levels or parameters called out in the
Environmental Technical Specifications, the
Decommissioning Order, and/or the Possession-
Only License that do not limit decommissioning
activities, but which may indicate a measurable
impact on the environment.
Repository (Federal): A site owned and operated by the Federal Govern-
ment for long-term storage or disposal of
radioactive materials.
Restricte~ Area: Any area to which acr.ess is controlled for
protection of individuals from exposure to
I Roentgen:
radiation and radioactive materials.
A unit of e :posure to ionizing radiation. It
is that amount of gamma or x-rays required to
produce ions carrying one electrostatic unit
of electrical charge (either positive or negative)
in one cubic centimeter of dry_ air under standard
14-15
conditions. One roentgen equals 2.58 x 10- 4
coulombs per kilogram of air. (See also Exposure.)
Safe Storage: Those actions required to place and maintain
a nuclear facility in a condition that
future risk from the facility to public safety
is within acceptable bounds so that the facility
can be safely stored for the time desired.
Safety-Related: Structures, systems, and components, whose
functions tend to prevent or mitigate the
exceeding of safety limits, as defined in
Regulatory Guide 3.6, and set forth in
Technical Specifications that are part of
the Operating License for a nuclear power
plant.
Scarfing: A technique used to mechanically decontaminate
concrete by chipping, cutting, jackhanmering~
or blasting the surface layer(s) away.
Secondary Wastes: Forms and quantities of all waste~ that result
from treatment of primary wastes or effluents.
Security Officer: A guard or watchman whose primary duty is the
protection of material and property.
Shield: A body of material used to reduce the passage
of particles or electromagnetic radiation. A
shield may be designated according to what it is
intended to ab~orb (as a gamma ray shield or neutron
shield), or according to the kind of protection
it is intended to give (as a background, or
thermal shield).
It may be required for the safety of personnel
or to reduce radiation enough to allow use of
counting instruments for research or for locating
contamination or airborne radioactivity.
Short-Lived For this study, those radioactive isotopes with
Radionuclides: half-lives less than about 10 years.
Shutdown: The time during which a facility is not in product-
ive operation.
Site: The geographic area upon which the facility
is located that is subject to controlled public
access by the facility licensee (includes the
restricted area as designated in the NRC
license).
14-16
-----·······-·- .. ····--·---~--···---
Solid Radioactive Material that is essentially solid and dry but
Waste: may contain sorbed radioactive fluids in
sufficiently small amounts as to be immobile.
Sol idUication: Conversion of radioactive wastes (gases or
liquids) to dry, stable solids.
S~ecial Nuclear Plutonium, uranium enriched in the isotopes
Material: 233 or 235, and any other material as defined
in 10 CFR 51 by the NRC.
Specific Power (of Commonly expressed in units of thermal mega-
Fuel Assemblies}: watts per metric ton of uranium (~1/MTU). It
represents the rate at which thermal energy
is extracted from the fuel; burnup, commonly
expressed in thermal me~awatt-days per metric
ton of uranium (MWd/MTU), represents the total
integrated energy extracted. For MOX fuel,
the unit of fuel is a metric ton of heavy metal
(MTHM); i.e., a metric ton of (U + Pu).
Surface Contamination: The result of the deposition and attachment of
foreign materials to a surface.
Surveillance: Those activities necessary to assure that the
site remains in a safe condition (including
inspection and monitoring of the sit~, maintenance
of barriers to access to radioactive materials
left on the site, and prevention of activities
on the site that might impair these barriers}.
Survey: An evaluation of the radiation hazards incident
to the production, use, release, disposal or
presence of radioactive materials or other
sources of radiation under a specific set of
conditions.
Technical Requirements and limits that encompass nuclear
Speci fi catio.-.:i: safety but are simplified to facilitate use by
plant operation and maintenance personnel. They
are prepared in accordance with the requirement
of 10 CFR 50.36, and are incorporated by
reference into the Operating and/or Possession-
only license issued by the NRC.
Tonne: A metric ton, or 1000 kg, or 2204.6 lb.
Transuranic Elements: Elements with atomic number (Z number) greater
than 92.
14-17
Transuranic Waste: Any waste material measured or assumed to contain
more than a specified concentration (i.e.,
proposed as 10 nanocuries of alpha emitters per
gram of waste, or more preseotl.Y proposed as
100 nanocuries/cm3 of waste Z39u) of transuranic
elements.
Underground Solid Waste Area within an exclusion area where radioactive
Storage Area: solid waste is stored by burial.
Wastes, Radioactive: Equipment and materials (from nuclear operations)
that are radioactive and for which there is no
further known use.
Wastes, Low-Level: Wastes containing types and concentrations of
radioactivity such that little or no shielding
to minimize personnel exposure is required.
Wastes, High-Level: Wastes resulting from th~ operation of the
first cycle solvent extraction system, or
equivalent, in a facility for reprocessing
irradiated reactor fuels (10 CFR 50, App. F.2}.
It is also applied generally to radioactive
wastes of other origins, where the rate of
heat evolution becomes of concern in waste
disposal or the external radiation dose rates
are extremely high.
Wastes, Intermediate-Level: All other radioactive wastes.
X-ray: A penetrating form of electromagnetic radiation
emitted either when the inner orbital electrons
of an excited atom return to their normal state
(characteristic x-rays) or when a metal target
is bombarded with high speed electrons. X-rays
are always non-nuclear in origin; i.e., they
originate external to the nucleus of the atom.
14-18
GENERAL REFERENCES
American National Standard Glossary of Terms In Nuclear Science and Technology.

American Nuclear Society, Hinsdale, IL, 1976.
McGraw-Hill Dictionary of Scientific and Technical Terms. McGraw-Hill, Inc.,
1976.
Radiological Health Handbook. Public Health Service Publication No. 2016,
U.S. Government Print;ng Office, Washington, DC, Revised Edition, January
1970. \
Glossary of Nuclear Industry Terms. Standards and Specifications, Atomic
Power Equipment Department, General Electric Company, San Jose, CA, September
1969.
14-19
.:.:.
NRC Fon11.• 335 I. llLf'()lll NUMOEH (AUignt!dhv DDCI

17·77t U.S. NUCLEAR REGULATORY COMMISSION
BIBLIOGRAPHIC DATA SHEET UREG/CR-0129, Vol. 1
4. TITLE ANO SUBTITLE IAdd Volum11 No., if 11pproprt11t#l "J. (l.t•Mr lll.rn~J
--
"Technology, Safety and Costs of Decommissioning a Referen ~f RECif'lfNT'S ACCESSION NO.
Small Mixed Oxide Fuel Fabrication Plant."
~D) • ] - Maio Bepatt• ~Dl 2 - Appendices
7. AUTHORISI 5. OAT[ RH'Oil r COMPLF. TEO
C. E. Jenkins, E.S. Murphy, K.J. Schneider and others MON111 I
Ylf.ll
December 1978
il. Pi"RFORMING ORGANIZATION NAME ANO MAILING ADDRESS (Inc/uri~ Z•p Code} DATE REPORT ISSUED
MONlll I y [J\FI
Battelle, Pacific Northwest Laboratory Januarv 1979
Battelle Boulevard 6. (Leo1111? hl11nkJ
Richland, Washington 99352
8. (Leatltt blank/
-12. Si'ONSORING ORGANIZATION NAME AND MAILING ADDRESS {lnclud~ Zip Codf!}
10. PROJECT/TASK/WORK UNIT NO.
Fuel Process Systems Branch
Division of Engineering Standards 11. CONTRACT NO.
Washington, D. C. 20555
-13. TYPE OF REPORT IPERIOD COVE RE 0 (lnclusitlf! dares/
Technical, Final Oct. 1977 - Dec. 19.78

-15. SU!>PLEMENTARV NOTES 14. (Leave blank}
16. ABSTRACT (200 words or lttssl

-
Detailed technology, safety and cost information are presented for the
conceptual decommissioning of a reference small mixed oxide fuel fabrication plant.
Alternate methods of decommissioning are described including immediate
dismantlement, safe s.torage for a period of time followed by dismantlement and
entombment. Safety analyses, both occupational and public, and cost evaluations
were conducted for each mode.
17. KEY WORDS AND DOCUMENT ANALYSIS 17a. DESCRIPTORS
•J
,,,;..:~::~.
~'. 1-
17!1. ID!:NTIFIERS/OPEN-ENDEO TERMS
-
;\··:···.
t:.'::··l ~
if,.
~.....18. AVAILABILITY STATEMENT 19. SECUfUTV CLASS IThi; roptut} 21. NO. OF PAGES
bt None
~1
Unlimited 20. SECURITY CLASS (Thisp.t::"!l 22.PRICE
- s
.' '·IIC FORM 33!i (7·171
--~----------=·=·~c:=···=----=-·=-=-...__ _ _ _ _ _ _ _ _ _ _..........-.....
---=·=·--=--=·-·=···-=··:...:..·.

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TECHNOLOGY, SAFETY AND COSTS OF

C.E. Jenkins, t:.S. Murphy

Pac;fic f'tlorthwest labora'i:ory

TECHNOLOGY, SAFETY AND COSTS OF

C.E. Jenkins, E.S. Mur,hy

Manuscript Submitted: January 1979

Pacific Northwest Laboratory

Division f"f Engineering Standards

B!:gu1atory Considerations ~omparison with Other Studies

fa~ility Description G. H. Winsor

(a) Associated with Columbia Engineers, Inc.

The NRC staff is in the process of reappraisir1g its regulatory position

I {1) Plan for Reevaluation of NRC Polic,¥ on Decommissioning of Nuclear

to cost $16.2 million and $28.2 million, respectively, in nondiscounted 1978

Comparison of the cost estimates shows that Entombment is the least

STUDY CONTRIBUTORS. "iii

2.0 SUMMARY. 2-l

2.1 REVIEW OF DECOMMISSIONING EXPERIENCE 2-2

2.7.1 Dismantlement Procedures . 2-9

2.7.3 Entombment Procedures 2-10

2.11 OVERALL COMPf\RISON OF DECOMMISSIONING ALTERNATIVES. 2-1 5

3.0 REVIEW OF DECOMMISSIONING EXPERIENCE . 3-1

3.1.2 [lecorrmissioning of the Special Metallurgical (SM)

3.2 LESSONS LEARNED FROM DECOMMISSIONING EXPERIENCE. 3-8

4.0 DECOMMISSIONING ALTERNATIVES AND STUDY APPROACH 4-1

4.1.3 Definition of and Rationale for Dismantlement 4··9

5.1.1.2 License Termination . 5-·l 0

5.1.2 State and Local Jurisdiction. 5-12

5.1.3 Safeguards Considerations. 5-14

5.1.4 Regulation of Effluents . 5-20

6.1 NEED FOR ASSURANCE OF DECOMMISSIONING FUNDS . 6-1

6.3.2 Higher Initial Sinking Fund Charges . 6-12

7.3. 1 Facility Description • 7-15

7.4 RESIDUAL RADIOACTIVITY ESTIMATES. 7-19

8.1.2 Disposition Criteria . 8-5

9.1.1.1 Planning and Preparation. 9

9. 1. 1.2 Final Processin9 Inventory Cleanout 9-5

9.1.1.4 Disassembly and Transport 9-7

9.1 .2 Quality Assurance Program. 9-13

9.1.4 Essential Systems a11d Services 9-15

9.1.5 Security 9-17

9.2 DECOMMISSIONING BY CUSTODIAL SAFE STORAGE. 9-17

9.3.1 Surveillance and Maintenance Activities . 9-3?

9.3.2 Environmental Surveillance Program. 9-33

9.3.3 Security 9-33

9.3.5 Essential Systems and Services . ~.

10.1.2 Material and Equipment Requirements and Cost:. for

10.3.3 Miscellaneous Owner Expenses During Interim Care. 10-33

10.4.2 Material and Equipment Requirements and Costs

10.5.1 .1 Manpower Requirements 10-43

11.1 TECHNICAL APPROACH . 11-2

11.2.1 Radiological Safety Evaluation of Routine

11.2.2 Radiological Safety Eva·luation of Postulated

11.2.3 Nonradiological Safety Evaluation. 11-14

11.4.1 Radiological Safety Evaluation of Routine

12.0 DISCUSSION OF RESULTS. 12-1

12. 1 REFERENCE 1 : 1975 ANL STUDY. 12-2

14.0 GLOSSARY • 14-1

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