International Isotopes Fluorine Products, Inc. (IIFP) 

A Wholly Owned Subsidiary of 

International Isotopes, Inc. (INIS) 

Fluorine Extraction Process & Depleted 

Uranium De-conversion 

 (FEP/DUP) Plant 

License Application 

Chapter 10 

Decommissioning 

Revision B 

November 17, 2011

 

LA-IFP-001 Revision B CHAPTER 10 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-i 

TABLE OF CONTENTS 

LIST OF FIGURES ................................................................................................................................ 10-ii

LIST OF TABLES.................................................................................................................................. 10-ii

ACRONYMS and ABBREVIATIONS (Provided In License Application Chapter 1 Revision B)

10 DECOMMISSIONING ................................................................................................................... 10-1 

10.1 DECOMMISSIONING STRATEGY .................................................................................. 10-1 

10.1.1 IIFP Facility Description ......................................................................................... 10-1

10.1.2 Decommissioning Design Features ......................................................................... 10-2

 10.1.2.1 Overview .............................................................................................. 10-2

10.1.2.2 Radioactive Contamination Control .................................................... 10-2

 10.1.2.3 Worker Exposure and Waste Volume Control ..................................... 10-3 

 10.1.2.4 Management Organization ................................................................... 10-4

 10.1.2.5 Health and Safety ................................................................................. 10-4 

10.1.2.6 Waste Management .............................................................................. 10-4

10.1.2.7 Security/Material Control ..................................................................... 10-4

10.1.2.8 Recordkeeping ...................................................................................... 10-5 

10.1.3 Decommissioning Process ....................................................................................... 10-5

 10.1.3.1 Overview .............................................................................................. 10-5

10.1.3.2 Size Reduction and Packaging Facility Outfitting .............................. 10-7

 10.1.3.3 System Preparation ............................................................................... 10-7 

 10.1.3.4 Dismantling .......................................................................................... 10-7

 10.1.3.5 Decontamination/Size Reduction ......................................................... 10-8 

10.1.3.6 Salvage of Equipment and Materials .................................................... 10-8

10.1.3.7 Disposal ................................................................................................ 10-8

 10.1.3.8 Final Radiation Survey ......................................................................... 10-8

10.1.3.9 Decommissioning Impact on Integrated Safety Analysis .................... 10-9 

10.1.4 Decontamination/Size Reduction Process ............................................................. 10-9 

 10.1.4.1       Overview .............................................................................................. 10-9 

 10.1.4.2 Methodology ...................................................................................... 10-10

 10.1.4.3 Size Reduction and Packaging Facilities Description ........................ 10-10 

10.1.4.4 Procedures .......................................................................................... 10-11

10.1.4.5 Results ................................................................................................ 10-11 

10.2 SITE-SPECIFIC COST ESTIMATE ................................................................................. 10-11 

10.2.1 Cost Estimate Structure ......................................................................................... 10-12 

10.2.2 Decommissioning Cost Estimate ........................................................................... 10-12 

 10.2.2.1 Summary of Costs .............................................................................. 10-12

 10.2.2.2 Major Assumptions ............................................................................ 10-12 

10.3 FINANCIAL ASSURANCE ............................................................................................. 10-12 

10.3.1 Decommissioning Funding Mechanism ................................................................ 10-13 

10.3.2 Adjusting Decommissioning Costs and Funding .................................................. 10-13 

10.3.3 Recordkeeping Plans Related to Decommissioning Funding ................................ 10-14 

REFERENCES ............................................................................................................................... 10-39 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-ii 

LIST OF FIGURES 

Figure 10-1 Estimated Decommissioning Schedule ......................................................................... 10-15

LIST OF TABLES 

Table 10-1 DUF4 Process and DUF6 Autoclave Building Components ........................................ 10-16

Table 10-2 Decontamination Building and Laboratory Components .............................................. 10-19 

Table 10-3 FEP Buildings - Components for SiF4 Process ............................................................ 10-20

Table 10-4 FEP Buildings - Components for BF3 Process .............................................................. 10-22 

Table 10-5 EPP Facility Components ............................................................................................ 10-24

Table 10-6 Facility Components - Ventilation................................................................................. 10-26 

Table 10-7 Planning and Preparing (Labor Hours) ........................................................................ 10-27

Table 10-8 Facility Characterization ................................................................................................ 10-28 

Table 10-9 Dismantling and Decontamination ................................................................................ 10-29 

Table 10-10 Restoration of Contaminated Areas on Facility Grounds (Labor Hours) .................... 10-30

Table 10-11 Final Radiation Survey (Labor Hours) .......................................................................... 10-31 

Table 10-12 Site Stabilation and Long Term Surveillance (Labor Hours) ........................................ 10-32 

Table 10-13 Total Work Days by Labor Category (Labor Days) .................................................... 10-33

Table 10-14 Worker Unit Cost Schedule ........................................................................................... 10-34 

Table 10-15 Total Labor by Major Decommissioning Task ............................................................ 10-35

Table 10-16 Packaging, Shipping and Disposal of Radioactive Wastes ............................................ 10-36 

Table 10-17 Total Administrative Supplies by Major Decommissioning Task ................................. 10-37 

Table 10-18 Total Decommissioning Cost ...................................................................................... 10-38
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-1 

10 DECOMMISSIONING 

Chapter 10 of the International Isotopes Fluorine Products, Inc. (IIFP), License Application (LA) presents 

the Decommissioning Funding Plan (DFP) for its initial IIFP Facility that is also referred to as the 

Fluorine Extraction Process and Uranium De-conversion (FEP/DUP) Plant. This Decommissioning 

Funding Plan has been developed following the guidance provided in NUREG-1757, U.S. Nuclear 

Regulatory Commission (NRC), 2006. The DFP is only for the current IIFP License Application and 

licensing activities. Any future facility expansions of licensing actions will require an amended or 

separate DFP.

IIFP, Inc. commits to decontaminate and decommission the facility at the end of its operation so that the 

facility and grounds can be released for unrestricted use. Prior to facility decommissioning, a 

Decommissioning Implementation Plan will be prepared in accordance with 10 Code of Federal 

Regulations (CFR) 40.42 (CFR, 2008a) and submitted to the NRC for approval.

This chapter fulfills the applicable provisions of NUREG-1757 (NRC, 2006) through the submittal of 

information in tabular form (Tables 10-1 through 10-18) in a format as suggested by the NUREG. 

10.1 DECOMMISSIONING STRATEGY

The overall strategy for decommissioning is to decontaminate or remove all materials from the IIFP Site 

in order to release the facility and the site for unrestricted use. This approach avoids long-term storage 

and monitoring of wastes on the site. The types and volumes of wastes produced at the IIFP Facility do 

not warrant delays in waste removal normally associated with a deferred dismantlement option.

At the end of useful plant life, the IIFP Facility will be decommissioned such that the site and remaining 

facilities may be released for unrestricted use as defined in 10 CFR 20.1402 (CFR, 2008b). IIFP will use 

guidance provided in NUREG-1505, NUREG-1575 and NUREG-1757 in developing initial and final site 

survey plans sufficient to provide background and post- decontamination site condition to enable the free 

release of the IIFP Site.

All remaining facilities will be decontaminated where needed to acceptable levels for unrestricted use. 

Hazardous wastes will be treated or disposed of in licensed hazardous waste facilities. Disposal of 

radioactive or hazardous material will not occur at the plant site but at licensed facilities located 

elsewhere. Following decommissioning, the facilities and site will be available for reuse.

Financial arrangements are made to cover costs required for returning the IIFP Facility to unrestricted use. 

Updates on cost and funding will be provided as described below in Section 10.3.2 “Adjusting 

Decommissioning Costs and Funds.”

The following describes decommissioning plans and funding arrangements. This information was 

developed in support of the decommissioning cost estimate. Specific elements of decommissioning may 

change with the submittal of a Decommissioning Implementation Plan required at the time of license 

termination.

10.1.1 IIFP Facility Description 

The IIFP Facility and Site are described in the IIFP LA, Revision B. Information relating to the following 

topics can be found in the referenced LA chapters listed below:
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-2 

• A general description of the facility and plant processes is presented in the IIFP LA, Revision B 

Chapter 1 “General Information.” 

• A detailed description of the Plant Site and Facility and the safety aspects of the plant processes 

are presented in the IIFP Revision B Integrated Safety Analysis (ISA) Summary.

• A description of the specific quantities and types of licensed materials used at the facility is 

provided in LA, Revision B Chapter 1 Section 1.3 “Type, Quantity and Form of Licensed 

Material.”

• A general description of how licensed materials are used at the facility is provided in LA, 

Revision B Chapter 1.

10.1.2 Decommissioning Design Features 

The following sections describe the IIFP decommissioning design features. 

10.1.2.1 Overview 

Decommissioning planning begins with ensuring design features are incorporated into the plant’s initial 

design that will simplify eventual dismantling and decontamination. The plans are implemented through 

proper management and health and safety programs. Decommissioning policies address radioactive waste 

management, radioactive contamination control, physical security and material control. 

Major features incorporated into the facility design to facilitate decontamination and decommissioning are 

described in the following sections. 

10.1.2.2 Radioactive Contamination Control 

The following features primarily serve to prevent the spread of radioactive contamination during 

operation thereby simplifying eventual facility decommissioning. As a result, worker exposure to 

radiation and radioactive waste volumes is minimized as well.

• Building areas where uranium is processed and handled are separated physically from other 

buildings, rooms and areas where there is no need to have uranium present. These areas have 

separate ventilation and filtration systems to preclude the spread of contamination. Boundary 

control stations and hand/foot and portable monitors are used at applicable locations to verify that 

personnel and items exiting uranium process areas do not spread radiological materials into nonuranium areas. The Depleted Uranium Tetrafluoride (DUF4) Process Building, Fluorine 

Extraction Process (FEP) Oxide Staging Building, the plant operations Decontamination 

Building, DUF4 Container Storage Building, DUF4 Container Staging Building and the FEP 

Process Building are subject to these specific design features.

• All areas of the plant are sectioned into Unrestricted, Controlled and Restricted Areas as 

described in the LA, Revision B Chapter 1 Section 1.1.2. Restricted Areas limit access for the 

purpose of protecting individuals against undue risks from exposure to radiation and radioactive 

materials. Radiation areas and potential airborne contamination areas have additional controls in 

place to inform workers of the potential hazard in the area and to help prevent the spread of 

contamination. All procedures for these areas fall under the Radiation Protection Program (RPP) 

and serve to minimize the spread of contamination and simplify the eventual decommissioning.
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-3 

• Routine radiological surveys will be conducted throughout the operating lifetime of the facility 

that will minimize the likelihood that radioactive contamination goes undetected and will provide 

a historical record which will simplify the site characterization process. The historical 

Radiological Environmental Monitoring Program (REMP) will also be used to provide guidance 

for the final site survey. Samples will be collected to verify the historical data collected via the 

REMP. Additional samples will be collected if areas of contamination are found.

• The location of process equipment and systems not used in processing licensed materials is 

minimized in areas subject to potential contamination. This limits both the size of the Restricted 

Areas and the activities occurring inside these areas.

• Containment equipment with hoods that exhaust through dust collectors that are designed with 

high removal efficiencies are used where uranium materials are being packaged or withdrawn 

from process systems.

• The hazardous material processes include designs for purge and evacuation (P&E) systems and 

dust-collection equipment as means to provide effective clean out of residual chemicals or dust 

from equipment or piping prior to opening systems for maintenance. The P&E and dust collector 

systems use multiple collection equipment in series (defense-in-depth) to ensure removal and 

treatment efficiency, redundancy, effectiveness and reliability.

• Storm water runoff via the plant storm sewer system flows to a retention basin for evaporation or 

tree farm watering or approved discharge. It is not likely that collected storm water would exceed 

acceptable or regulated levels, but routine sampling for reuse or discharge is conducted for 

further assurance. Domestic sanitary waste water is tertiary treated to meet all discharge 

standards and is either evaporated or used as harvested water for the facility tree farm, . The 

facility is designed for no chemical process water discharges. Engineered systems are used to 

provide for regeneration of scrubbing solutions and recycle within the process systems.

10.1.2.3 Worker Exposure and Waste Volume Control 

The following features serve primarily to minimize worker exposure to radiation and minimize 

radioactive waste volumes during decontamination activities. As a result, the spread of contamination is 

minimized as well. 

• During construction, a washable coating is applied to designated floors and walls in the 

Restricted Areas that have higher potential to become radioactively contaminated during 

operation. The coating will serve to lower waste volumes during decontamination and simplify 

the decontamination process. 

• Sealed nonporous pipe insulation is used in areas with higher potential to become contaminated. 

This will facilitate cleaning in the event of a spill and will reduce waste volume during 

decommissioning.

• Ample access is provided for efficient equipment dismantling and removal of equipment that 

may be contaminated. This minimizes the time of worker exposure.

• Process tanks have access for entry and decontamination. Design provisions are also made to 

allow complete draining of the wastes contained in the tanks.
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-4 

• Process system connections provided for required operation and maintenance allow for thorough 

purging at plant shutdown. This will remove a significant portion of radioactive contamination 

prior to disassembly.

• Design drawings produced for all areas of the plant will be used to simplify the planning and 

implementing of decontamination procedures. This will help reduce worker exposure. 

• Worker access to contaminated areas is controlled to assure that workers wear proper protective 

equipment and limit their time in these areas.

10.1.2.4 Management Organization 

An appropriate organizational structure will be developed to support the decommissioning strategy. This 

organization will ensure that adequate numbers of experienced and knowledgeable personnel are available 

to perform the technical and administrative tasks required to decommission the facility.

IIFP intends to be the prime Decommissioning Operations Contractor (DOC) responsible for 

decommissioning. In this capacity, IIFP will have direct experience with the plant operations and have 

control and oversight over all decommissioning activities. IIFP also plans to secure contract services to 

supplement its capabilities, as necessary. However, for the purposes of estimating costs for the DFP, it is 

assumed that a third-party contractor will be used as the DOC. Management of the Decommissioning 

Implementation Plan will make certain that proper training and procedures are implemented to assure 

worker health and safety. Programs and procedures will focus heavily on minimizing waste volumes and 

worker exposure to hazardous and radioactive materials. Qualified contractors assisting with 

decommissioning will likewise be subject to facility training requirements and procedural controls.

10.1.2.5 Health and Safety 

As with normal site operations, the policy during decommissioning shall be to keep individual and 

collective occupational radiation exposure as low as reasonably achievable (ALARA). A Health Physics 

Program will identify and control sources of radiation, establish worker protection requirements and 

direct the use of survey and monitoring instruments.

10.1.2.6 Waste Management 

Radioactive and hazardous wastes produced during decommissioning will be collected, handled and 

disposed of in accordance with all regulations applicable to the facility at the time of decommissioning. 

Generally, procedures will be similar to those described for wastes produced during normal operation. 

These wastes will ultimately be shipped to licensed radioactive or hazardous waste disposal facilities. 

Non-hazardous and non-radioactive wastes will be disposed of in a manner consistent with good 

industrial practice and in accordance with applicable regulations.

10.1.2.7 Security/Material Control 

Requirements for physical security and for Material Control and Accountability (MC&A) will be 

maintained as required during decommissioning in a manner similar to the programs in force during 

operation. The IIFP Decommissioning Implementation Plan submitted just prior to decommissioning will 

provide a description of any necessary revisions to these programs.
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-5 

10.1.2.8 Recordkeeping 

Records important for safe and effective decommissioning of the facility will be stored in the IIFP 

Records Management System until the IIFP Site is released for Unrestricted Use. Information maintained 

in these records is described below:

1. Records are maintained of spills or other unusual occurrences involving the spread of 

contamination and subsequent cleanup around the facility, equipment or site. These records will 

include any known information on identification of involved radionuclides, quantities, forms, 

concentrations and survey results after cleanup of any spill area.

2. Routine radiological survey records of Restricted and Unrestricted Areas will be retained 

 indefinitely to support historical site assessment and facility characterization at the time of 

 decommissioning. 

3. As-built drawings and modifications of structures and equipment are maintained for areas where 

radioactive materials are used and/or stored. Required drawings will be referenced as necessary, 

although each relevant document will not be indexed individually. If drawings are not available, 

appropriate records of available information concerning these areas will be substituted.

4. The following will be contained in a single records document which will be updated every two 

(2) years except for areas containing only sealed sources:

a. All areas designated and formerly designated as Restricted Areas as defined under 10 

CFR 20.1003, (CFR, 2008c)

b. All areas outside of Restricted Areas that require documentation specified in item 1 

above

c. All areas outside of Restricted Areas where current and previous licensed material wastes 

have been disposed as documented under 10 CFR 20.2108 (CFR, 2008d)

d. All areas outside of Restricted Areas that contain material such that, if the license 

expired, the licensee would be required to either decontaminate the area to meet the 

criteria for decommissioning in 10 CFR 20, subpart E, (CFR, 2008e) or apply for 

approval for disposal under 10 CFR 20.2002, (CFR, 2008f)

5. Records will be maintained of the cost estimate performed for the Decommissioning Funding 

Plan or of the amount certified for decommissioning and the funding method used for assuring 

funds if either a funding plan or certification is used. 

10.1.3 Decommissioning Process 

The following section describes the IIFP decommissioning process. 

10.1.3.1 Overview 

Preparation for decommissioning the facility is expected to begin upon a decision to cease operations 

permanently. This preparation step is estimated to be completed in approximately one (1) year including 

NRC review and approval of the final Decommissioning Implementation Plan.
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-6 

Actual decontamination and decommissioning would follow shortly upon approval of the Plan and the 

award of any subcontracts. The Decommissioning Implementation Plan schedule for the IIFP Facility is 

shown in Figure 10-1. 

The IIFP Facility processes the contents of depleted uranium hexafluoride (DUF6) cylinders routinely 

within a few days of when those are received, inspected and accepted. The IIFP Facility is not a long-term 

storage site for DUF6 tails. However, a relatively small inventory of cylinders (an average of about 25 

cylinders) may be kept during normal operations as a buffer stock for allowing flexibility in operating the 

facility. INIS intends to make disposition of any DUF6 remaining on-site at the end of the useful life of its 

subsidiary IIFP Facility by processing all the residual inventory through the de-conversion and FEP boron 

trifluoride (BF3) processes. In this manner, the DUF6 and remaining in-process inventories of uranium 

feed materials (such as DUF4) will be converted to depleted oxide for disposal at an off-site licensed lowlevel waste (LLW) disposal facility. 

The estimated cost for final DUF6 inventory processing and associated oxide disposal costs have been 

added as an update to the financial assurance decommissioning costs. 

IIFP plans to be the DOC for all the shutdown, cleanout and decommissioning operations. However, for 

the purpose of decommissioning and financial assurance funding levels, an independent third party 

contractor profit and labor costs with fringes and overheads are used in the decommissioning cost 

estimate in the event that IIFP is unable to fulfill this role. Also, the cost estimate for processing and 

disposing of the residual DUF6 (and in-process DUF4) inventory is based on the facility operating costs 

plus the third party contractor costs and profit. No credit is taken in the financial assurance fund for any 

marketable products or assets recovered during the processing of residual materials or decommissioning. 

Table 10-18 of the IIFP License Application provides the total cost for financial assurance funding 

including a 25% contingency. Volumes and costs for LLW disposal, including oxide from the residual 

DUF6 inventory conversion, are provided in Table 10-16. The operating costs for processing of the 

residual DUF6 inventory are shown as a separate line item in Table 10-18.

Prior to beginning decommissioning operations, a radiological survey of the facility will be performed 

and used in conjunction with a historical site assessment to identify areas where contamination may be 

present. The findings of the radiological survey and historical site assessment will be presented in a 

Decommissioning Implementation Plan to be submitted to the NRC. The Plan will be prepared in 

accordance with 10 CFR 40.42 (CFR, 2008a) and the applicable guidance provided in NUREG-1757.

Decommissioning activities will generally include: 1) outfitting of size reduction and packaging areas, 2) 

purging of process systems, 3) dismantling and removal of equipment, 4) sales of salvaged materials, 5) 

packaging and disposal of wastes and 6) completion of a final radiation survey. Credit is not taken for any 

salvage value that might be realized from the sale of potential assets during or after decommissioning.

Decommissioning, using the IIFP approach, requires residual radioactivity to be reduced below specified 

levels so the facilities can be released for Unrestricted Use. Current Nuclear Material Safety and 

Safeguards guidelines for release serve as the basis for decontamination costs estimated herein. Portions 

of the facility that do not exceed contamination limits may remain as-is without further decontamination 

measures applied. The intent of decommissioning the facility is to remove all uranium process-related 

equipment from the buildings such that only the building shells and site infrastructure remain. Equipment 

to be removed includes all piping and components from systems providing uranium hexafluoride (UF6) or 

uranium tetrafluoride (UF4) containment, uranium oxide containment, systems in direct support of 

uranium processing (such as refrigeration and cooling systems), radioactive and hazardous waste 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-7 

handling systems, contaminated heating, ventilation and air conditioning (HVAC) filtration systems, etc. 

Remaining site infrastructure after decommissioning will include the steam facilities, electrical power 

facilities, water supply systems, sanitary water treatment systems, fire protection systems, HVAC 

systems, cooling water systems and communication systems.

Existing plant buildings, such as the Decontamination Building and Material Warehouse, will be outfitted 

to accommodate handling and packaging of components and materials for disposal. These areas will be 

the primary location for size reduction and packaging activities during the decommissioning process. 

Limited capabilities for decontamination will exist for mildly contaminated items that may be 

decontaminated to free release criteria in a cost effective manner. 

Contaminated portions of the buildings will be decontaminated as required. Potential contamination is 

limited to the structures in the Restricted Areas. Good housekeeping practices during normal operation 

will maintain the other areas of the IIFP Site in a contamination free condition. Routine radiological 

contamination surveys will ensure radioactive contamination will not go undetected or be allowed to 

build-up to levels difficult to control.

When decontamination is complete, all areas and facilities on the Site will be surveyed to verify that 

further decontamination is not required. Decontamination activities will continue until the entire site is 

demonstrated to be suitable for Unrestricted Use.

10.1.3.2 Size Reduction and Packaging Facility Outfitting 

Existing facilities can be adapted to accommodate the size reduction and packaging activities associated 

with decommissioning to avoid the expense of constructing other dedicated facilities to do so. The 

existing Decontamination Building and Material Warehouse are considered suitable for these purposes. 

Estimated time for equipment installation is approximately two (2) months. These newly outfitted 

facilities will be completed in time to support the dismantling of the equipment. These facilities are 

described in Section 10.1.4.3 “Size Reduction and Packaging Facilities Description.”

10.1.3.3 System Preparation 

At the end of the useful life of each process line, the uranium process will be shut down and UF6, UF4 and 

uranium oxides will be removed to the extent practicable by normal process operation. This is to be 

followed by evacuation and purging with nitrogen and the application of a fixative where applicable. The 

shutdown and preparation for decommissioning activities is estimated to take approximately three (3) 

months.

10.1.3.4 Dismantling 

Dismantling requires cutting and disconnecting all components requiring removal. Dismantling 

operations are labor intensive and generally require the use of protective clothing. The work process will 

be optimized, considering the following:

• Minimizing the spread of contamination and protective clothing requirements by application of 

fixative coatings

• Balancing the number of cutting and removal operations with the resultant size reduction and 

disposal requirements

• Optimizing the rate of dismantling with the rate of size reduction 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-8 

• Providing required storage and lay down space as impacted by retrieval, security, etc.

• Balancing the cost of salvage with the cost of disposal

Details of the complex optimization process will necessarily be decided near the end of plant life, taking 

into account specific contamination levels, market conditions and available waste disposal sites. The DFP 

assumes most items that were continuously in contact with uranium hexafluoride, uranium tetrafluoride or 

uranium oxide will be disposed at a LLW disposal facility rather than employing rigorous techniques to 

attempt decontamination. Large contaminated equipment may be disassembled to separate contaminated 

and uncontaminated components. To avoid additional lay down space requirements and accompanying 

contamination issues, dismantling should proceed at a rate consistent with the downstream size reduction 

and packaging processes.

The time to accomplish both dismantling and size reduction during IIFP decommissioning is estimated to 

be approximately eighteen (18) months.

10.1.3.5 Decontamination/Size Reduction 

The decontamination and size reduction process is addressed separately in detail in Section 10.1.4.

10.1.3.6 Salvage of Equipment and Materials 

Items to be removed from the facilities can be categorized as potentially reusable equipment, recoverable 

scrap and wastes. However, based on a 40-year operating lifetime, equipment is assumed to have no reuse 

value. Wastes will also have no salvage value. Some amounts of uncontaminated metals such as steel, 

copper and Monel may be recovered and sold. However, no credit is taken for any salvage value that 

might be realized from the sale of potential assets during or after decommissioning.

10.1.3.7 Disposal 

All wastes produced during decommissioning will be collected, handled and disposed of in a manner 

similar to that described for those wastes produced during normal operation. Wastes will consist of 

normal industrial trash, non-hazardous chemicals and fluids, small amounts of hazardous materials and 

radioactive wastes. The radioactive wastes will consist primarily of piping, tanks, hoppers and 

compactable trash generated during the dismantling process. 

Radioactive wastes will ultimately be disposed in licensed low-level radioactive waste disposal facilities. 

Hazardous wastes will be disposed in hazardous waste disposal facilities. Non-hazardous and nonradioactive wastes will be disposed in a manner consistent with good industrial practice and in accordance 

with all applicable regulations. While current best estimates of the these wastes are provided in this 

Chapter 10, an updated estimate of the wastes and effluent to be produced during decommissioning will 

be provided in the Decommissioning Implementation Plan that will be submitted prior to initiating the 

decommissioning of the facility. 

10.1.3.8 Final Radiation Survey 

A final radiation survey must be performed to verify proper decontamination to allow the site to be 

released for Unrestricted Use. The evaluation of the final radiation survey is based in part on an initial 

radiation survey performed prior to initial operation. The initial survey defines the natural background 

radiation of the area; therefore, it provides a baseline for comparison to final survey measurements that 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-9 

will be used to determine any increase in levels of radioactivity. Since only depleted uranium will be 

processed at the IIFP Facility, the initial and final site surveys required as part of the decommissioning 

process will include isotopic analysis for the U-238, U-235 and U-234 isotopes of uranium.

The final survey will systematically measure radioactivity over the entire site and will be designed to 

detect any unreported spills and any generalized contamination that might accumulate over the period of 

operation of the facility. The intensity of the survey will vary depending on the location (i.e. the 

buildings, their immediate areas and the remainder of the IIFP Site). Throughout the operating life of the 

facility, routine surveys will be conducted of licensed material areas and records will be maintained. 

These survey records will be used in conjunction with the REMP as part of the final survey evaluation 

and may reduce the amount of sampling in some areas where the survey history indicates that no 

contamination has occurred. The survey procedures and results will be documented in a report which will 

include, among other things, a map of the survey site, measurement results and the site’s relationship to 

the surrounding area. The results will be analyzed and shown to be below allowable residual radioactivity 

limits; otherwise, further decontamination will be performed.

For decommissioning funding purposes, the final site survey will consist of samples being taken within 

the 40-acre IIFP Restricted Area as well as at other locations outside the Restricted Area but within the 

640-acre site boundary. Inside the Restricted Area, samples will be taken based on a sampling grid pattern 

of approximately 91 m by 91 m (100 yd by 100 yd). Additional samples will be collected within an area 

extending ten (10) feet from process building walls on the basis of one sample per 100 ft2

 (i.e., one 

sample for every ten (10) feet of building perimeter). It is unlikely that the area outside the Restricted 

Area but within the site boundary will be contaminated. . Therefore, the grid will be expanded for this 

area such that samples will be taken on a grid approximately 610 m by 610 m (667 yd by 667 yd). The 

analysis of the samples will be provided by a third party since, at the time of performance of the final 

radiation survey, no analysis facilities will be available on site. A similar collection of samples will be 

performed for the initial site survey as part of the REMP to provide a background against which the final 

site survey will be compared.

10.1.3.9 Decommissioning Impact on Integrated Safety Analysis 

As was described in Section 10.2.3.1 “Summary of Costs,” the decommissioning of the IIFP Facility will 

be conducted over a period of approximately two and one-half (2- 1/2) years, consisting of one (1) year 

for preparation and planning and an estimated eighteen (18) months for dismantling, decontamination 

and disposition.

Although decommissioning steps are planned to be underway while some activities considered in the ISA 

Summary Revision B continue to occur in the other portions of the plant, the current ISA has not fully 

evaluated these decommissioning risks. An updated ISA will be performed prior to decommissioning to 

evaluate the risks from decommissioning operations on concurrent operations.

10.1.4 Decontamination/Size Reduction Process 

The following sections address the decontamination and size reduction process. 

10.1.4.1 Overview 

The facilities, procedures and expected results of decontamination and size reduction are described in the 

paragraphs below. Reprocessed uranium will not be used as feed in any of the commercial uranium 

enrichment facilities that will supply DUF6 to the IIFP Facility for depleted tails de-conversion. 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-10 

Therefore, no consideration of 232U, transuranic alpha-emitters and fission product residues is necessary 

for the decontamination/size reduction process. Only contamination from 238U, 235U, 234U and their 

daughter products will be considered in the decontamination and size reduction processes. The primary 

contaminants will be in the form of small amounts of UF4, uranyl fluoride (UO2F2), uranium oxides (UO2 

or U3O8).

10.1.4.2 Methodology 

It is assumed that decontamination of components and equipment that have been in direct contact with 

uranium compounds will not achieve levels that would support free release. Therefore, decontamination 

efforts to a level of free release would not be feasible and would likely increase the volume of low-level 

radioactive waste requiring disposal. Instead, the most cost effective approach is to clean equipment and 

components sufficiently to be able to cut and remove them, to fix residual radioactivity in place and to 

size reduce by disassembly or mechanical means. The methodology to be used during IIFP Facility 

decommissioning will employ conventional decontamination, fixative application and size reduction 

techniques. The buildings and components will be characterized with respect to radioactive 

contamination immediately prior to the start of decommissioning. The non-contaminated components 

will be removed, monitored and free released for disposal off-site. Non-uranium handling components 

(e.g. electrical cabinets, cable runs, utility pipe work, etc.) are expected to be free of any contamination. If 

these items are found to be contaminated, simple decontamination techniques using mild cleaning 

solutions may be sufficient to remove residual radioactivity to levels that support free release. 

Components that are known to be contaminated will only be decontaminated to the extent necessary to 

prevent the spread of contamination during removal, size reduction and packaging for disposal. In many 

cases fixing residual radioactivity utilizing a fixative coating or expandable foam would provide adequate 

containment of residual radioactivity to support these activities. 

• Sections of DUF6 piping and uranium oxide vacuum transfer piping may be contained by dry 

cleaning to remove excess loose material and filling with an expandable foam or fixative. This 

piping will then be taken down, transferred to the decontamination/size reduction facility and 

sized and packaged for disposal.

• Some larger equipment and piping will be dismantled into sections suitable for transport to the 

size reduction and packaging facility where the sections will be further dismantled. The 

components will be subject to a disposition evaluation to determine if the item is open to the free 

flow of fixative or cleaning solutions and that monitoring of the component after 

decontamination can be performed should decontamination be attempted. Components failing the 

feasibility review will be consigned to sizing and packaging for shipment to a licensed disposal 

facility. 

• Mildly contaminated items with readily accessible surfaces will be designated for 

decontamination. These items will be decontaminated using a mild cleaning solution. 

10.1.4.3 Size Reduction and Packaging Facilities Description 

Size reduction and packaging facilities will be required to accommodate decommissioning. These 

facilities are needed for optimal handling of equipment to be packaged for disposal. It is assumed that 

existing areas such as the Decontamination Building and the Material Warehouse can be outfitted to serve 

effectively as the size reduction and packaging facilities for decommissioning.
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-11 

The decontamination facilities will have six functional areas that include: 1) a disassembly area, 2) a 

stock staging area, 3) a size reduction area, 4) a decontaminating and clean-up area 5) a scrap storage area 

for cleaned stock and 6) a packaging for disposal area. Barriers and other physical measures will be 

installed and administrative controls implemented, as needed, to prevent the spread of contamination.

The size reduction and packaging facilities will be equipped with the types of equipment listed below as 

determined in the final decommissioning plan. Examples include:

• Transport and manipulation equipment

• Dismantling tables 

• Sawing machines

• Nibblers

• Degreasers

• Contamination monitors

10.1.4.4 Procedures 

Formal procedures for all major decommissioning activities will be developed and approved by 

authorized project management personnel to minimize worker exposure and waste volumes and to assure 

work is carried out in a safe manner.

At the end of plant life, some of the equipment, most of the buildings and all of the outdoor areas should 

be acceptable for release for Unrestricted Use. If they had been accidentally contaminated during normal 

operations, they would have been cleaned up when the contamination was discovered. This limits the 

scope of necessary decontamination at the time of decommissioning.

Contaminated plant components will be processed through the size reduction packaging facilities. 

Potential contamination of site structures is limited to a few areas (for example; the DUF6 to DUF4

Autoclave Building, the DUF4 Process Building, the processing area of the FEP Process Building, and the 

FEP Oxide Staging Building) and these areas will be maintained throughout plant operation by regular 

cleaning. Through the application of special protective coatings to surfaces that might become 

radioactively contaminated during operation and good housekeeping practices, final decontamination of 

these areas is assumed to require minimal removal of surface concrete or other structural material.

10.1.4.5 Results 

Recoverable items will have been decontaminated and made suitable for reuse except for a very small 

amount of intractably contaminated material. The buildings and site will be decontaminated and 

decommissioned to a level such that they can be released for reuse. 

The majority of radioactive wastes requiring disposal as the result of the IIFP Facility decommissioning 

will include tanks, hoppers, process piping and residual materials from the work-in-process inventory that 

are not recovered for reuse or sale and possible residues from the final decontamination equipment and 

process. Items, equipment and scrap that remain contaminated beyond free release levels will have been 

disposed of at approved and licensed disposal sites.

10.2 SITE-SPECIFIC COST ESTIMATE 

The following sections describe the site-specific decommissioning cost estimate. 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-12 

10.2.1 Cost Estimate Structure 

The decommissioning cost estimate includes:

• Major assumptions for the cost estimate

• A summary of the number of major facility components volumes and type of disposal required

• The estimated costs (including labor costs, non-labor costs and contingency)

10.2.2 Decommissioning Cost Estimate 

The following sections address specifics of the decommissioning cost estimate. 

10.2.2.1 Summary of Costs 

The decommissioning cost estimate for the IIFP Facility is approximately $Redacted (2009 dollars). 

This cost estimate and supporting information are presented in Tables 10-1 through 10-18, consistent with 

the applicable provisions of NUREG-1757 Volume 3 “Consolidated NMSS Decommissioning Guidance - 

Financial Assurance, Recordkeeping and Timeliness” (NRC, 2006).

The decommissioning project schedule is presented in Figure 10-1. Depending on market conditions 

related to fluorine products, condition of equipment, availability of DUF6 de-conversion services and 

other uncertainties, the decommissioning strategy may need revision in the future. Whenever the strategy 

is revised, the DFP will be updated, including the cost estimate for decommissioning and will be 

resubmitted for approval.

10.2.2.2 Major Assumptions 

Key assumptions underlying the decommissioning cost estimate are listed below:

• Inventories of materials and wastes at the time of decommissioning will be in amounts that are 

consistent with routine plant operating conditions over time.

• Costs are not included for the removal or disposal of non-radioactive structures and materials 

beyond that necessary to terminate the NRC license. Non-radioactive structures will be available 

for other industrial use following completion of decontamination and decommissioning (D&D).

• Credit is not taken for any salvage value that might be realized from the sale of potential assets 

(e.g., recovered materials or decontaminated equipment) during or after decommissioning.

• Decommissioning activities are performed in accordance with current regulatory requirements.

• The cost estimate is adjusted using the required contingency multiplier factor of 1.25.

• Decommissioning costs are presented in 2009 dollars. 

10.3 FINANCIAL ASSURANCE 

The following sections address the financial assurance mechanisms for decommissioning. 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-13 

10.3.1 Decommissioning Funding Mechanism 

IIFP presently intends to utilize a surety bond and Standby Trust Fund method to provide reasonable 

financial assurance that decommissioning funding will be available at the time of decommissioning the 

facility. At least six (6) months prior to the receipt of licensed material in quantities and form requiring 

decommissioning funding, IIFP will provide NRC the financial assurance instrument that IIFP intends to 

execute. Upon finalization of the specific funding instrument to be used and at least twenty-one (21) days 

prior to the commencement of operations, IIFP will supplement its application to include the signed, 

executed documentation. The licensee shall not obtain radioactive material until the NRC reviews and 

approves the executed financial assurance instrument and certification of financial assurance (See the 

IIFP LA, Revision B Chapter 1 Section 1.5.2 regarding request for exemption from certain provisions of 

10 CFR 40.36). The surety bond will provide assurance that decommissioning costs will be paid in the 

unexpected event IIFP is unable to meet its decommissioning obligations at the time of decommissioning. 

In this case funds drawn from the surety bond will be placed directly into a standby trust fund naming the 

U.S. Nuclear Regulatory Commission as the beneficiary. 

IIFP is committed to provide financial assurance funding for the IIFP Facility. Applying a 25% 

contingency factor to the decommissioning cost estimate, yields a total projected decommissioning cost 

for the IIFP Facility for which financial assurance would be provided, of approximately $Redacted

million (expressed in 2009 U.S. dollars).

10.3.2 Adjusting Decommissioning Costs and Funding 

In accordance with 10 CFR 40.36(d) (CFR, 2008h), IIFP will update the decommissioning cost estimate 

for the IIFP Facility and the associated funding levels over the life of the facility. Updates will take into 

account changes resulting from inflation or site-specific factors, such as changes in facility conditions or 

expected decommissioning procedures. IIFP will provide Decommissioning Funding Plan updates and 

facility decommissioning cost estimates to the NRC as specified below: 

The licensee shall provide an updated DFP and updated facility decommissioning cost estimate to NRC 

for review at least six (6) months prior to the planned date for obtaining licensed material. 

On an annual basis, starting on the anniversary date of obtaining licensed material, the licensee shall 

provide an updated DFP and updated facility decommissioning cost estimate to the NRC for review. 

With each annual update, if the cost estimate exceeds the amount of financial assurance provided, the 

licensee shall provide financial assurance in the amount of the updated cost estimate and an updated 

certification of financial assurance to NRC for review and approval. 

All updates to the DFP, and cost estimate for facility decommissioning and financial assurance 

instruments, shall be updated to current year United States dollars and shall encompass all current cost 

data, taking into account changes in inflation, possession limits, licensed material, labor rates, disposal 

and shipping rates and site and facility factors. All updates to the DFP, and cost estimate for facility 

decommissioning and financial assurance instruments shall also include updated costs for the disposal of 

UF6, UF4 and uranium oxides. IIFP shall include the cost of shipping and disposal of any DUF6 that the 

licensee has financial responsibility for its disposal, including DUF6 that the licensee holds legal title. All 

costs shall be supported by a detailed basis, be based on the costs of a third party contractor or The U.S. 

Department of Energy (DOE) and shall not take credit for any salvage value that might be realized from 

the sale of potential assets during or after decommissioning. The total cost estimate shall include the 

contingency factor of at least 25 percent. 
LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-14 

 A record of the update process and results will be retained for review as discussed in Section 10.3.3, 

below. The NRC will be notified through the update process of any material changes to the 

decommissioning cost estimate and associated funding levels (e.g., significant increases in costs beyond 

anticipated inflation). To the extent the underlying instruments are revised to reflect changes in funding 

levels, the NRC will be notified as appropriate.

10.3.3 Recordkeeping Plans Related to Decommissioning Funding 

In accordance with 10 CFR 40.36(f) (CFR, 2008h), IIFP will retain records until the termination of the 

license of information that could have a material effect on the ultimate costs of decommissioning. These 

records will include information regarding: 1) spills or other contamination that cause contaminants to 

remain following cleanup efforts, 2) as built drawings of structures and equipment and modifications 

thereto where radioactive contamination exists (e.g., from the use or storage of such materials), 3) original 

and modified cost estimates of decommissioning and 4) original and modified decommissioning funding 

instruments and supporting documentation.
 LA-IFP-001 Revision B CHAPTER 10 

Figure 10-1 Estimated Decommissioning Schedule 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-1 DUF4 Process and DUF6 Autoclave Building Components 

Portions Redacted for Security Purposes 

Component 

Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) f

Non-LLW 

Disposal 

EQUIPMENT/MATERIALS Refrigeration System for AHF Condensers 1 240 240 240 20 Ton Bridge Crane Hoist 1 18 18 18 20 Ton Bridge Crane 1 360 360 360 20 Ton Bridge Crane Rails 2 150 150 150 3 Ton Monorail 1 8 8 8 Cylinder Cart 2 300 300 300 Cylinder Scale 1 150 150 150 Steam Piping from Boiler to AC 2 156 156 0 Condensate Return Piping 2 7 7 0 Autoclave Relief Piping 2 75 75 0 Heeling Cold Traps P & E Cold Traps 3 85 85 0 P & E NaF (Sodium Fluoride Packing) Traps 3 32 32 0 P & E Activated Alumina Traps 3 32 32 0 Vacuum Pump 1 18 18 0 Vibrating Screen 1 67 67 0 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-1 DUF4 Process and DUF6 Autoclave Building Components 

Portions Redacted for Security Purposes 

Component 

Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) f

Non-LLW 

Disposal 

Cyclone Filter Rotary Valve 2 29 29 0 Secondary Off Gas Filter with Sintered Filter Elements 1 46 46 0 Backup Filter Rotary Valve 1 14 14 0 Carbon-Bed Traps 6 125 125 0 Reaction Vessel Heaters 8 157 157 157 Surge Tank/Feed Piping Hot Box Electric Heaters 1 11 11 11 Surge Tank/Fee Hot Box 1 79 79 79 Primary Dust Collector 1 2280 912 0 Primary Dust Collector Rotary Valve 1 14 14 0 Secondary Dust Collector 1 588 235 0 Dust Collector Blower 1 216 216 0 Reaction Vessel Cooling Blower 1 36 36 0 Vacuum Cleaning Blower 1 36 36 0 Piping from Screw Conveyor to Dust Collectors 1 56 56 0 Oxide Inventory Pending Shipment After Shutdown 1 2825 2825 0 Carbon & Activated Alumina Residual In Process 1 150 150 0 Ventilation Ducting from Table 10-6: 

DUF6 Autoclave Room HVAC Ducting 1 432 144 0 DUF4 Process Building HVAC Ducting 1 1296 432 0 

AHF as Work-in-Process & Storage Waiting to be Shipped CaF2 as Material-in-Process & Storage Awaiting Shipment 

to Customer 

Approximately 

20,000kg 

Regenerated KOH Solution Residual In Process Approximately 7,000kg 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-1 DUF4 Process and DUF6 Autoclave Building Components 

Portions Redacted for Security Purposes 

Component 

Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) f

Non-LLW 

Disposal 

Storage Tanks Included in Equipment ListStorage Areas Included in BuildingsRadiological Waste Areas Included in BuildingsEquipment Decontamination Areas See Table 10-2 TOTAL NON-LLW DISPOSAL 5,627 TOTAL LLW DISPOSAL 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-2 Decontamination Building and Laboratory Components 

Component 

Number 

 of 

Components 

Total 

Component Vol. 

(ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) for 

Non-LLW 

Disposal 

EQUIPMENT/MATERIALS Fume Cupboards (hoods) 4 80 80 0 Floors (concrete/dike demolition) 1 1000 1000 0 Walls And Ceilings (building demolition) 1 1000 1000 1000 Grit Blast Booth/Equipment 1 1998 666 0 Dust Collector 1 588 235 0 Hold Tank 2 560 187 0 Precipitation Tank 1 279 93 0 Centrifugal Pumps 4 7 7 0 Water Spray Submersible Pump 1 2 2 0 Secondary Dust Collector 1 96 38 0 Drum Fill Station 2 288 288 0 Dust Collector Blower 1 71 71 0 Primary Filters 2 151 151 0 Polishing Filters 4 170 170 0 Ion Exchange Columns 2 141 141 0 Decontamination Building Piping 1 19 19 0 Motors 5 9 9 0 Misc Conduit, Instruments, Control Panel 1 20 20 0 Cleaning Solution Waste 1 1875 1875 0 Hazardous Waste 1 750 750 0 Ventilation Ducting from Table 10-6: 

Decontamination Ducting 1 78 26 0 

Laboratory HVAC Ducting 1 78 26 0 

TOTAL NON-LLW 1,000TOTAL LLW 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-3 FEP Buildings - Components for SiF4 Process 

Portions Redacted for Security Purposes 

Component 

Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) 

Non-LL

Dispos

EQUIPMENT/MATERIALS SiO2 Storage 1 785 0 785Vacuum Secondary Filter, Pump & Discharge Silencer 1 1 1 0 SiO2 Feed Hopper 1 21 21 21 SiO2 Hopper Rotary Valves 1 14 14 14 SiO2 Screw Conveyor 1 1 1 0 Ribbon Blender 1 29 29 0 Vibrating Screen 1 94 94 0 Pre Filter 1 42 42 0 Dust Collector & Blower 1 2280 1026 0 Primary Dust Collector Rotary Valve 1 14 14 0 Secondary Dust Collector & Blower 1 215 86 0 Backup Dust Collector Rotary Valve 1 14 14

0 

Backup Dust Collector Drum Enclosure 1 49 49

0 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-3 FEP Buildings - Components for SiF4 Process 

Portions Redacted for Security Purposes 

Component 

Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) 

Non-LL

Dispos

Primary & Secondary Sintered Metal Filter

4 13 13

0 

Pre-Condenser 2 1 1 1 Product Cold Traps 3 1 1 1 Chiller 1 30 30 30 Separator 1 33 33 33 Heat Exchanger 1 30 30 30 Vacuum Pump 1 18 18 18 Venturi Scrubber Downstream of DUF4 Dust Collector 

Blowers 1 50 50 0 

Venturi Scrubber Downstream of SiF4 Dust Collector 

Blowers 1 50 50 0 

Venturi Scrubber KOH Pumps for SiF4 Dust Collector 

Blowers 1 50 50 0 

Ventilation Ducting from Table 10-6: HVAC Ducting 1 1,728 576 0 Storage Areas Included in Buildings Radiological Waste Areas Included in Buildings Equipment Decontamination Areas See Table 10-2 TOTAL NON-LLW 1,575 TOTAL LLW 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-4 FEP Buildings - Components for BF3 Process 

Portions Redacted for Security Purposes 

Component 

Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) 

Non-LL

Dispos

EQUIPMENT/MATERIALS B2O3 Storage 1 785 785 785 Oxide Hopper 1 306 102 0 Oxide Hopper Rotary Valves 2 29 29 0 Drum Filling Enclosure 2 98 98

0 

Dust Collector Blower 1 220 220 0 Piping from Oxide Hopper to Dust Collector 2 56 56

0 

Piping from Drum Fill Station 2 18 18

0 

P & E Chem Traps 4 42 42 42 P & E Vacuum Pump 2 36 36 36 Pre-Heater Feed Screw 2 4 4 0 Pre-Heater 2 25 25 0 Rotary Calciner Feed Screw 2 4 4 0 Rotary Calciner 1 66 66 0 Cooling Screw Conveyor 1 3 3 0 Cooling Screw Conveyor Water Jacket 1 5 5 5 Vacuum Secondary Filter, Pump & Discharge Silencer 2 3 3 0 B2O3 Feed Hopper 2 42 42 42 B2O3 Hopper Rotary Valves 4 57 57 57B2O3 Screw Conveyor 2 1 1 0 Ribbon Blender 2 59 59 0 Vibrating Screen 2 189 189 0 Dust Collector 1 2280 912 0 EQUIPMENT/MATERIALSPrimary Dust Collector Rotary Valve 1 14 14 0 Backup Secondary Dust Collector 1 215 86 0 Backup Dust Collector Rotary Valve 1 14 14 0 Backup Dust Collector Drum Enclosure 1 49 49 0 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-4 FEP Buildings - Components for BF3 Process 

Portions Redacted for Security Purposes 

Component 

Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3

Non-LL

Dispo

Primary & Secondary Sintered Metal Filters 2 7 7 0 Pre-Condenser 2 1 1 1 Cold Traps 4 1 1 1 Chiller 2 60 60 60 Separator 2 66 66 66 Venturi Scrubber Downstream of DUF4 Dust Collector 

Blower 1 50 50 0 

Venturi Scrubber Downstream of BF3 Dust Collector 

Blower 1 50 50 0 

Ventilation Ducting from Table 10-6: 

HVAC Ducting 1 1728 576

0 

Storage Areas Included in BuildingRadiological Waste Areas Included in BuildingE

qui

pment Decontamination Areas See Table 10-2

TOTAL NON-LLW 4,496TOTAL LLW 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-5 EPP Facility Components 

Component 

Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) for 

Non-LLW 

Disposal 

EQUIPMENT/MATERIALS Venturi Scrubber 2 101 101

0 

Venturi Scrubber Liquid/Gas Separator 2 101 101

0 

Venturi Scrubber Water Pump 2 4 4 0 Packed Tower Scrubber 2 32 32

0 

Tower Scrubber KOH Pump 2 4

4

0 

Coke Box 2 266 266

0 

Coke Box KOH Sump Pump 2 4

4

0

Coke Box Blower 2 43 43

0 

Emergency Scrubber 1 59 59 59Emergency Scrubber KOH Sump Pump 1 8 8 8 Emergency Scrubber KOH Pump 1 2 2 2 Emergency Scrubber Blower 1 21 21 21KOH Makeup Tank 1 127 127 127KOH Makeup Tank Pump 1 2 2 2 Acid Transfer Tank 1 1008 1008 1008Lime Mixer Tanks and Agitators 2 71 71 71Lime Mixer Tanks Pumps 2 4

4

4

Acid Reaction Tank and Agitators 1 996 996 996Acid Reaction Tank Pumps 2 4

4

4

Thickener 1 168 168 168Thickener Pumps 3 5 5 5 Emergency Acid Tank 1 7360 3680 3680Lime Silo and Dust Collector 1 2276 1138 1138Spent KOH Storage Tank 1 384 192 192KOH Mixing Tank and Agitators 1 35 35 35KOH Mixing Tank Pumps 2 4

4

4

KOH Reaction Vessel Pumps 2 4

4 4 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-5 EPP Facility Components 

Component

Number 

 of 

Components

Total 

Component 

Vol. (ft3

)

Total Component 

Vol. (ft3) After 

Reduction

Vol. (ft3) for 

Non-LLW 

Disposal

EQUIPMENT/MATERIALSThickener and Rake 1 127 127 127Rotary Vacuum Filter 1 168 168 168Filtrate Liquor Tanks 2 56 56 56Dryer 1 192 192 192 Dust Collector 1 2253 751 751Clarifier and Rake 1 2202 734 734Clarifier Pumps 3 5 5 5 Polishing Filters 2 4

4

4

Piping 1 156 156 156KOH Regeneration Tank 1 385 385 385 KOH Reactor Tank 1 754 377 377 Lime Silo 1 4620 4620 4620Ventilation Ducting from Table 10-6: 

EPP HVAC Ducting 1 279 93 0 

Lime Storage Area Ducting 1 100 33 33 

Equipment Decontamination Areas See Table 10-2TOTAL NON-LLW 15,136 TOTAL LLW 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-6 Facility Components – Ventilation 

Component Number 

 of 

Components 

Total 

Component 

Vol. (ft3) 

Total Component 

Vol. (ft3) After 

Reduction 

Vol. (ft3) for 

Non-LLW 

Disposal 

VENTILATION AND DUCTWORK Fume Cupboards (hoods) 4 240 80 0 Laboratory 1 78 26

0 

DUF6 Autoclave Area 1 432 144

0 

DUF4 Process Building 1 1296 432 0 Contamination Building 1 78 26

0 

SiF4 Building 1 1728 576

0 

BF3 Building 1 1728 576 0 EPP Building 1 279 93 0 Lime Storage Area 1 100 33 33

Note: LLW and Non-LLW disposal amounts in Table 10-6 are included in each of the building lists in Tables 10-1 through 10-5. 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-7 Planning and Preparing (Labor Hours) 

Decommissioning Task Project Management 

Health Physicist 

 & 

Safety Officer 

Engineer 

Project Plan and Schedule 320 40 160 Site Characterization Plan 400 150 200 Decommissioning Plan 1800 675 900 NRC Review Support 600 225 300 Specification for Services 400 150 200 Project Procedures 720 270 360 TOTAL HOURS 4240 1510 2120 HOURLY RATE $77 $84 $79 TOTAL $326,480 $126,840 $167,480 LABOR $643,432ADMINISTRATIVE SUPPLIES $1,200GRAND TOTAL $644,632
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-8 Facility Characterization 

Area Project Management Health Physicist & Safety Officer Health Physics Technician 

DUF6 Autoclave Room 9 9 73 DUF4 Process Building 19 19 145 Decontamination Building 6 6 48 FEP Process Building 23 23 186 HF Day Tank and Truck Loading Building 6 6 42 Maintenance and Stores 3 3 25EPP Building and Scrubber Systems 6 6 51 Lime Storage Area 1 1 7 Material Warehouse 5 5 42 Utilities Building 3 3 25 Main Switchgear Building 3 3 25 Fire Pump House 0 0 2 Water Treatment Building 1 1 6 Process Offices and Laboratories 3 3 26 Administration Building 5 5 38 Guard house 1 1 5 DUF4 Storage Building 3 3 25 Exterior of Buildings 46 46 372 TOTAL HOURS 143 143 1143 HOURLY RATE $77 $84 $64 LABOR COST $11,011 $12,012 $73,152 TOTAL LABOR COST $100,246ADMINISTRATIVE SUPPLIES $1,900GRAND TOTAL $102,146
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-9 Dismantling and Decontamination 

Area Project Management 

Health 

Physicist 

& 

Safety 

Officer 

Laborer Craftsman Supervisor 

Health 

Physics 

Technician 

DUF6 Autoclave Room 313 626 2502 626 626 275 DUF4 Process Building 322 646 2581 646 646 382 Decontamination Building 638 1276 5104 1276 1276 508 FEP Process Building 502 1004 4016 1004 1004 477 HF Day Tank and Truck Loading Building 11 22 87 22 22 11 EPP Building 298 595 2382 595 595 268 Lime Storage Area 45 89 357 89 89 36 DUF4 Storage Building 5 10 40 10 10 10 TOTAL HOURS 2134 4268 17069 4268 4268 1967 HOURLY RATE $77 $84 $26 $38 $67 $64 LABOR COST $164,318 $358,512 $443,794 $162,184 $285,956 $125,888 TOTAL LABOR COST $1,577,122ADMINISTRATIVE SUPPLIES $256,500GRAND TOTAL $1,833,622
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-10 Restoration of Contaminated Areas on Facility Grounds (Labor Hours) 

Activity Labor Category Labor Category Labor Category Labor Cat

Backfill and Restore Site (Note 1)Note 1: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment areas; 

ALARA radiological controls that will result in a low likelihood of contaminating the facility grounds at levels that would require excavation 

a small spill, the limited area affected will be cleaned, surveyed and de-contaminated, if needed, at the time as part of the required cleanup imsuch spill. 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-11 Final Radiation Survey (Labor Hours) 

Area Project 

Management 

Health Physicist & 

Safety Officer 

Health Physics 

Technician 

DUF6 Autoclave Room 13 13 102 DUF4 Process Building 25 25 197 Decontamination Building 3 3 23FEP Process Building 27 27 215 HF Day Tank and Truck Loading Building 2 2 21 Maintenance and Stores Building 2 2 16 EPP and Plant KOH Scrubbing System Buildings 1 1 8 Lime Storage Area 0 0 1 Material Warehouse Building 3 3 25 Utilities Building 2 2 14 Main Switchgear Building 2 2 14 Fire Pump House 0 0 1 Water Treatment Building 0 0 4 Process Offices and Laboratory Building 5 5 43 Administrative Building 3 3 27 Guard House 1 1 4 DUF4 Storage Building 2 2 14 Building Perimeter Sampling 5 5 68 Grid Sampling 5 5 30 Date Evaluation 70 370 70 Close-Out Radiological Survey Report 90 280 40 LABOR COST $20,097 $63,084 $59,968 TOTAL LABOR COST $148,876ADMINISTRATIVE SUPPLIES $4,680SAMPLE ANALYSIS $32,750GRAND TOTAL $186,306
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-12 Site Stabilization and Long Term Surveillance (Labor Hours) 

Activity Labor 

Category 

Labor Category 

Labor Category 

Labor Category 

Labor Category 

 (Note 2)

Note 2: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment areas; in

radiological ALARA controls that will result in a low likelihood of contaminating the facility grounds at levels that would require excavation oa small spill, the limited area affected will be cleaned, surveyed, and decontaminated, if needed, as part of the required cleanup immediately foTherefore, site stabilization and long-term surveillance will not be required and associated decommissioning costs are not provided. 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-13 Total Work Days by Labor Category (Labor Days) 

Task Project Management 

Health 

Physicist 

& 

Safety 

Officer 

Laborer Craftsman Supervisor 

Health 

Physics 

Technician 

& 

Planning and Preparation 530 189 0 0 0 0 Facility Characterization 18 18 0

0 0 143 

Decontamination & Dismantling 267 534 2134 534 534 246 Restoration of Contaminated Areas (Note 1) Packaging (Note 2) 0 0 1712

0 571 571 

Final Survey 33 94 0

0 0 117 

Site Stabilization & Long Term Surveillance (Note 1) TOTAL WORK DAYS 848 835 3,846 534 1,105 1,077 

Note 1: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment area; in

radiological controls that will result in a low likelihood of contaminating the facility grounds at levels that would require excavation or restorat

spill, the limited area affected will be cleaned, surveyed and decontaminated, if needed, at the time as part of the required cleanup immediately 

Note 2: The days of labor shown in this table for packaging represent 4,564 crew hours or 13,692 hours for the Laborers and 4,564 hours each for the s

and the Transportation Specialist. These values divided by 8 hours/day equal the values shown in the table for these labor categories. 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-14 Worker Unit Cost Schedule 

Project 

Management 

Health 

 Physicist 

 & 

Safety 

 Officer 

Laborer Craftsman Supervisor 

Health 

Physics 

Technician 

Salary & Fringe ($/year) $83,900 $92,243 $28,808 $41,811 $72,832 $70,000 

Fringe at 30% Rate $25,170 $27,673 $8,642 $12,543 $21,850 $21,000 

Overhead at 60% Rate $50,340 $55346 $17,285 $25,087 $43,699 $42,000 

Total Cost per Year $159,410 $175,262 $54,735 $79,441 $138,381 $133,000 

Total Cost per Work Day $613 $674 $211 $306 $532 $512 

Hourly Rate $77 $84 $26 $38 $67 $64 

Note: Based on 2,080 work hours per year and 8 hours per working day.
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-15 Total Labor by Major Decommissioning Task 

Task Project Management 

Health 

Physicist 

& 

Safety 

Officer 

Laborer Craftsman Supervisor 

Health 

Physics 

Technician 

E

T

S

Planning and Preparation $326,480. $126,840. $-0- $-0- $-0- $-0- $Facility Characterization $11,011 $12,012 $-0- $-0- $-0- $73,152 Decontamination & Dismantling $164,318 $358,512 $443,794 $162,184 $285,956 $125,888 $Restoration of Contaminated Areas (Note 1) Packaging 0 0 $355,992

0 $305,788 $292,096 $

Final Survey $20,097 $63,084 $-0- $-0- $-0- $59,968 Site Stabilization & Long Term Surveillance (Note 1)TOTAL COST $521,906 $560,448 $799,786 $162,184 $591,744 $551,104 $

Note 1: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment area; in

radiological controls that will result in a low likelihood of contaminating the facility grounds at levels that would require excavation or restorat

spill, the limited area affected will be cleaned, surveyed and decontaminated, if needed, at the time as part of the required cleanup immediately 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-16 Packaging, Shipping and Disposal of Radioactive Wastes (See Footnote) 

Areas Volume of LLW (Cubic Feet) Packaging Cost LLW Disposal Cost 

DUF6 Autoclave Room/DUF4 Process/HF Day Tank 

Buildings 7,455 $349,344 $Redacted 

Decontamination Building and Laboratory 5,854 $194,976 $Redacted FEP Building 5,199 $446,976 $Redacted EPP Building and Lime Storage Area 648 $137,664 $Redacted Totals for Facility Areas 19,156 $1,128,960 $Redacted Packaging Supplies $257,689 Transportation Supplies LLW Packaging Total Cost $1,386,649 LLW Disposal Total Cost $Redacted LLW Transportation Total Cost GRAND TOTAL COST FOR LLW PACKAGING, DISPOSAL AND TRANSPORTATION $Redacted 

Note: Packaging, Disposal and Transportation costs for Non-LLW wastes are not shown in this Table, but are included in Table 10-18. Also packaging 

inventory down prior to decommissioning are included in processing costs shown in Table 10-18. 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-17 Total Administrative Supplies by Major Decommissioning Task 

Task Equipment Cost 

Planning and Preparation $1,200Facility Characterization $1,900Decontamination and Dismantling $256,500Packaging $300,000Transportation $100,000Final Survey $4,680TOTAL $664,280 
 LA-IFP-001 Revision B CHAPTER 10 

Table 10-18 Total Decommissioning Cost 

Task Estimated Base Cost Cost With 12% Profit Margin For Third Party Contractor 

Planning and Preparation $644,632 $721,988 Facility Characterization $102,146 $114,404 Decontamination and Dismantling $1,833,622 $2,053,657 Restoration of Contaminated Areas (Note 1)Sizing and Packaging $1,614,432 $1,808,164 Transportation and Disposal $Redacted $Redacted Final Survey $186,306 $208,663 Site Stabilization and Long Term Surveillance (Note 2) Convert the Residual DUF6 Inventory to Oxide Prior to Decommissioning $1,102,041 (Note 4) $1,161,480 (Note 5) TOTAL PROJECT COST $Redacted $Redacted 

Note 1: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment area; in

radiological controls that will result in a low likelihood of contaminating the facility grounds at levels that would require excavation or restorat

spill, the limited area affected will be cleaned, surveyed and decontaminated, if needed, at the time as part of the required cleanup immediately 

Note 2: For the reasons given in Note 1, site stabilization and long-term surveillance will not be required and associated decommissioning costs are not 

Note 3: Transportation and Disposal Cost already includes profit which would be realized by the transport and disposal companies and not by a third p

the third party contractor margin was not applied. 

Note 4: Includes Third Party Contractor labor, overheads and fringes. Note 5: 12% profit margin applied to Third Party Contractor direct labor, overheads and fringes. 
 LA-IFP-001 Revision B CHAPTER 10 November 17, 2011 

Page | 10-39 

REFERENCES 

CFR, 2008a Title 10, Code of Federal Regulations, Section 40.36 “Financial Assurance and Recordkeeping for 

 Decommissioning,” 2003.

CFR, 2008b Title 10, Code of Federal Regulations, Section 20.1402, “Radiological Criteria for Unrestricted 

 Use,” 2003.

CFR, 2008c Title 10, Code of Federal Regulations, Part 20.1003, “Definitions,” 2003.

CFR, 2008d Code of Federal Regulations, Title 10, Part 20.2108, “Records of Waste Disposal,” 2003.

CFR, 2008e Title 10, Code of Federal Regulations, Part 20, Subpart E, “Radiological Criteria for License 

 Termination,” 2003.

CFR, 2008f Title 10, Code of Federal Regulations, Part 20.2002, “Method for Obtaining Approval of Proposed 

 Disposal Procedures,” 2003.

CFR, 2008g Title 10, Code of Federal Regulations, Section 40.42, “Expiration and Termination of Licenses 

 and Decommissioning of Sites and Separate Buildings or Outdoor Areas,” 2003.

CFR, 2008h Title 10, Code of Federal Regulations, Part 40, Appendix A, “Criteria Relating to the Operation of 

 Uranium Mills and the Disposition of Tailings or Wastes Produced by the Extraction or 

 Concentration of Source Material From Ores Processed Primarily for Their Source Material 

 Content,” 2003.

CFR, 2008i Title 10, Code of Federal Regulations, Part 20.2003, “Disposal by Release into Sanitary 

 Sewerage,” 2008.

CFR, 2008j Title 10, Code of Federal Regulations, Part 20.2004, “Treatment or Disposal by Incineration,” 

 2008.

CFR, 2008l Title 10, Code of Federal Regulations, Part 61, “Licensing Requirements for Land Disposal of 

 Radioactive Waste,” 2008.

CFR, 2008m Title 10, Code of Federal Regulations, Part 20, Subpart E—“Radiological Criteria for License 

 Termination,” 2008.

NRC, 2002 U.S. Nuclear Regulatory Commission, “Standard Review Plan for the Review of a License 

 Application for a Fuel Cycle Facility,” NUREG-1520, 2002.

NRC, 2002b U.S. Nuclear Regulatory Commission, “Revised Analyses of Decommissioning Reference Non- 

 Fuel-Cycle Facilities,” NUREG/CR-6477, 2002.

NRC, 2003 U.S. Nuclear Regulatory Commission, “Assuring the Availability of Funds for Decommissioning 

 Nuclear Reactors,” Regulatory Guide 1.159, 3, 2003.

NRC, 2005 U.S. Nuclear Regulatory Commission, “Safety Evaluation Report for the National Enrichment 

 Facility, Lea County, New Mexico,” NUREG - 1827, 2005. 

NRC, 2006 U.S. Nuclear Regulatory Commission, “Consolidated NMSS Decommissioning Guidance - 

 Financial Assurance, Recordkeeping and Timeliness,” NUREG-1757, Volume 3, 2006.