ML081020537

Massachusetts Institute of Technology - Request for Additional Information License Renewal Request

ML081020537
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	04/21/2008
From:	Pierce S NRC/NRR/ADRA/DPR/PRTA
To:	Bernard J Massachusetts Institute of Technology (MIT)
PIERCE S, NRR/DPR/PRTA 415-2261
References
TAC MA6084
Download: ML081020537 (4)

Text

April 21, 2008 Dr. John A. Bernard, Director Nuclear Reactor Laboratory Massachusetts Institute of Technology 138 Albany Street Cambridge, MA 02139-4296

SUBJECT:

MASSACHUSETTS INSTITUTE OF TECHNOLOGY - REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL REQUEST (TAC NO. MA6084)

Dear Dr. Bernard:

We are continuing our review of your July 8, 1999 application, response to RAI submissions dated May 8, 2000, January 29, 2004 and February 22, 2008, and associated supplements, for the renewal of the Massachusetts Institute of Technologys (MIT) Research Reactor Amended Facility Operating License No. R-37. During our review of your request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 30 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your application request. NRC staff is conducting this review in accordance with the guidance of NUREG 1537.

Sincerely,

/RA/

Stephen Pierce, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

Enclosure:

As stated Docket No. 50-20 cc w/ enclosure: See next page

Massachusetts Institute of Technology Docket No. 50-20 cc:

City Manager City Hall Cambridge, MA 02139 Department of Environmental Protection One Winter Street Boston, MA 02108 Director Radiation Control Program Department of Public Health 90 Washington Street Dorchester, MA 02121 Nuclear Preparedness Manager Massachusetts Emergency Management Agency 40 Worcester Road Framingham, MA 01702-5399 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML081020537 OFFICE DPR/PRTA:LA DRIP/RPRP DPR/PRTA:BC DPR/PRTA:PM NAME EHylton egh CPittigilo cp DCollins dsc SPierce sp DATE 4/15/08 4/21/08 4/21/08 4/21/08

REQUEST FOR ADDITIONAL INFORMATION MASSACHUSETTS INSTITUTE OF TECHNOLOGY RESEARCH REACTOR DOCKET NO. 50-20 The staff reviewed the MITR licensee renewal financial qualifications submittal. The submittal included Chapter 15, entitled Financial Qualifications which referenced a document developed by General Electric entitled, Conceptual Decommissioning Plan and Estimate. The GE document developed a cost adjustment formula (Cost = (1988 Base cost) (.89L + 0.11B) where L is the cost of labor and B is the waste disposal cost which the former can be obtained Bureau of Labor Statistics (BLS) and later from NURE-1307, and a base cost of $ 9.1 million in 1988 dollars.

For the formula, the staff used L = 2.2 and B = 8.6 for vendor disposal in NUREG-1307, Rev. 12 which resulted in a cost in the range of $26.0 million in 2006 dollars. The staff compared their formula amount to the MITR submittal dated July 5, 2006, entitled Review of Decommissioning Funding Response for MIT Research Reactor. The July 5, 2006 submittal, increased the escrow funds to $23.0 million. This amount appears to be based on a new approach to escalating/estimating the costs for the MITR decommissioning. In addition, as part of the October 11, 2006 email (Divine/Dusaniwskyj), an Executive Summary was provided as an attachment that indicated Duke Engineering Services (Duke) had been under contract to develop this new method for estimating and escalating costs.

As required by 10 CFR 50.75 (d)(2), submit (i) a current cost estimate and the associated basis for decommissioning the MITR facility, and (iii) a description of the means of adjusting the cost estimate and associated funding level periodically over the life of the facility. The basis should include a discussion on the selection of the contingency factor. For example, the American Association of Cost Engineers recommends contingencies in Project and Engineers Handbook for decommissioning.

Duke applied the new method for estimating the MITR decommissioning cost, including a 10 percent contingency that resulted in a cost estimate of $26.0 million in 2006 dollars. However, MIT then made a decision to use the cost of $23.0 million. Please explain the basis for using a lower cost. MIT should update the decommissioning cost to 2008 dollars and discuss the mechanism to update this cost. In addition, MIT should also submit the most recent supporting financial information.

In addition please provide the NRC staff with the most recent available financial statement.

Enclosure