ML081480456
| ML081480456 | |
| Person / Time | |
|---|---|
| Site: | Rensselaer Polytechnic Institute |
| Issue date: | 05/28/2008 |
| From: | Hughes D NRC/NRR/ADRA/DPR/PRTA |
| To: | Winters G Rensselaer Polytechnic Institute |
| Kennedy W, NRR/ADRA/DPR/PRT, 415-2784 | |
| References | |
| TAC MC9032 | |
| Download: ML081480456 (5) | |
Text
May 28, 2008 Mr. Glenn Winters, Director Reactor Critical Facility Nuclear Engineering and Science Building Rensselaer Polytechnic Institute Troy, NY 12181
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING FINANCIAL QUALIFICATIONS AND THE REQUALIFICATION PROGRAM FOR RENEWAL OF FACILITY LICENSE NO. CX-22 FOR THE RENSSELAER POLYTECHNIC INSTITUTE REACTOR CRITICAL FACILITY (TAC NO. MC9032)
Dear Mr. Winters:
We are continuing our review of your license renewal request for Facility License No. CX-22 for the Rensselaer Polytechnic Institute Reactor Critical Facility submitted November 19, 2002.
During our review of your request, questions have arisen for which we require additional information and clarification. As we discussed during our telephone conversation of May 29, 2008, please provide responses to the enclosed requests for additional information no later than June 30, 2008. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of your response, we will continue our review of your request.
If you have any questions regarding this review, please contact William B. Kennedy at 301-415-2784, or me at 301-415-1631.
Sincerely,
/RA/
Daniel E. Hughes, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-225
Enclosure:
As stated cc w/enclosure: See next page
Rensselaer Polytechnic Institute Docket No. 50-225 cc:
Mayor of the City of Schenectady Schenectady, NY 12305 Barbara Youngberg Chief, Radiation Section Division of Hazardous Waste and Radiation Management NY State Dept. of Environmental Conservation 625 Broadway Albany, NY 12233-7255 Peter F. Caracappa, Ph.D, CHP Radiation Safety Officer NES Building, Room 1-10, MANE Department Rensselaer Polytechnic Institute 110 8th St.
Troy, NY 12180-3590 Dr. Jeffery Geuther, RCF Supervisor NES Building, Room 1-10, MANE Department Rensselaer Polytechnic Institute 110 8th St.
Troy, NY 12180 Peter Collopy, Director EH&S Rensselaer Polytechnic Institute 21 Union Street Gurley Building 2nd Floor Troy, NY 12180 John P. Spath, State Liaison Officer Designee Program Manager Radioactive Waste Policy and Nuclear Coordination New York State Energy Research & Development Authority 17 Columbia Circle Albany, NY 12203-6399 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611
May 28, 2008 Mr. Glenn Winters, Director Reactor Critical Facility Nuclear Engineering and Science Building Rensselaer Polytechnic Institute Troy, NY 12181
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING FINANCIAL QUALIFICATIONS AND THE REQUALIFICATION PROGRAM FOR RENEWAL OF FACILITY LICENSE NO. CX-22 FOR THE RENSSELAER POLYTECHNIC INSTITUTE REACTOR CRITICAL FACILITY (TAC NO. MC9032)
Dear Mr. Winters:
We are continuing our review of your license renewal request for Facility License No. CX-22 for the Rensselaer Polytechnic Institute Reactor Critical Facility submitted November 19, 2002.
During our review of your request, questions have arisen for which we require additional information and clarification. As we discussed during our telephone conversation of May 29, 2008, please provide responses to the enclosed requests for additional information no later than June 30, 2008. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of your response, we will continue our review of your request.
If you have any questions regarding this review, please contact William B. Kennedy at 301-415-2784, or me at 301-415-1631.
Sincerely,
/RA/
Daniel E. Hughes, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-225
Enclosure:
As stated cc w/enclosure: See next page DISTRIBUTION:
PUBLIC RidsNrrDprPrta RidsNrrDpr MDusaniwskyj DPR/PRT r/f GHill(2)
ACCESSION NO.: ML081480456 Office PRTA:PM PRTA:PM PRTA:LA PFPB PRTA:BC Name WKennedy wbk DHughes deh EBarnhill egh MDusaniwskyj DCollins dsc Date 5/28/08 5/28/08 5/28/08 d 5/28/08 5/28/08 OFFICIAL RECORD COPY
REQUEST FOR ADDITIONAL INFORMATION RENSSELAER POLYTECHNIC INSTITUTE REACTOR CRITICAL FACILITY DOCKET NO. 50-225 Requalification Plan
- 1. 10 CFR 55.53(h) requires all NRC-licensed reactor operators and senior reactor operators to be enrolled in a requalification program. However, the requalification program submitted with the relicensing report appears to pertain only to senior reactor operators. Explain how the requalification program ensures compliance with the requirements of 10 CFR 55.53(h), or submit a revised requalification plan that pertains to both senior reactor operators and reactor operators.
Financial Qualifications
- 1. Under 10 CFR 50.33(d), Contents of applications; general information, certain information is required by the applicant, Rensselaer Polytechnic Institute (RPI). To comply with the regulation, please update the application to include a statement of the organizational form of RPI (e.g., corporation), the state where it is incorporated or organized and the principal location where RPI does business, and the names, addresses and citizenship of RPIs directors (Board of Trustees) and principal officers. Also, please state whether RPI is owned, controlled, or dominated by an alien, foreign corporation, or foreign government, and if so give details.
- 2. The staff will analyze RPIs financial statements for the current year, which are required by 10 CFR 50.71(b), to determine if the applicant is financially qualified to operate the RPI Reactor Critical Facility (RCF). Since RPIs financial statements are not included with the application, please provide a copy of the latest financial statements for the staffs review.
- 3. Under 10 CFR 50.33(f)(2), the applicant shall submit estimates for total annual operating costs for each of the first five years of operations of the facility. Please provide the projected operating costs of the RCF for each of the years FY2009 to FY2013 (the first five years after the projected license renewal) as well as RPIs source(s) of funding to cover the operating costs for the above fiscal years.
- 4. The November 19, 2002 submittal from RPI to the NRC (the Relicensing Report for the Reactor Critical Facility at Rensselaer Polytechnic Institute) identifies two decommissioning cost estimates that vary depending on the degree of work to be completed. As stated in the application, decommissioning costs are estimated to be about $50,000 if the only objective is to remove all fissionable material (i.e., the fuel) from the facility, or $500,000 for a complete decommissioning including removal of all hazardous waste and asbestos, and clean-up of the facility grounds (presumably contaminated from former ALCO plant operations). Since the application does not clearly state certain details regarding the eventual decommissioning of the RCF, the staff requests the applicant to complete and/or update the 2002 submittal to 2008 by including the following:
(a) To comply with 10 CFR 50.75(d), a current cost estimate in 2008 dollars to meet the NRCs radiological release criteria for decommissioning the facility for unrestricted use, describing the basis on how the cost estimate was developed, showing costs specifically
broken down into the categories of labor, waste disposal, other items (such as energy, equipment, and supplies), and a contingency factor of at least 25%.
(b) A statement of the decommissioning method to be used (e.g., DECON or other method).
(c) To comply with 10 CFR 50.75(d), a description and basis of the means of adjusting the cost estimate (the NRC staff notes that cost escalation factors may be appropriately different for the different categories of decommissioning costs) and associated funding level periodically over the life of the facility. Also, please provide a numerical example showing how the cost estimate will be updated periodically.
- 5. As stated in RPIs 1991 Decommissioning Report, the applicant put assets with a market value of $50,000 into a prepaid custodial account. Since 10 CFR 50.33(f)(2) requires that Applicants to renew or extend the term of an operating license for a nonpower reactor shall include the financial information that is required in an application for an initial license, the applicant needs to provide the following information with respect to the decommissioning financial assurance method to be used for the RCF:
(a) State the method to be used (e.g., an external trust or other prepayment method).
(b) Document that the chosen financial assurance method meets all of the requirements of 10 CFR 50.75(e)(1)(i) if the method used is prepayment, or 50.75(e)(1)(iii) if the method used is a surety method, insurance, or other guarantee method, and is consistent with the applicable guidance in Section 2.2 of NRC Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors.
(c) Provide a copy of the agreement governing any prepaid account used, and any other documentation pertaining to such prepaid account.
(d) State the amount of funds currently in the prepaid account and RPIs plans to adjust the level of funds in the account, if such is to continue, periodically over the life of the facility to meet changes in the decommissioning cost estimate.