ML100760616

Aerotest Radiography and Research Reactor - Response to Request for Additional Information Regarding Proposed Indirect License Transfer, (Redacted Copy)

ML100760616
Person / Time
Site:	Aerotest
Issue date:	03/10/2010
From:	Mary Anderson, Thams S Aerotest, X-Ray Industries
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1887
Download: ML100760616 (41)

Text

Docket No. 50-228 March 10, 2010 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Aerotest Radiography and Research Reactor License No. R-98 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED INDIRECT LICENSE TRANSFER (TAC NO. ME1887)

Financial Qualifications

1. purpose and nature of transaction NRC has requested that Autoliv Inc. (Autoliv) divest its interest in Aerotest Operations Inc. (Aerotest). Pursuant to that request, Autoliv has worked to identify a suitable buyer for the ARRR facility. X-Ray Industries, Inc. (X-Ray) and Autoliv have entered into a Letter of Intent to consummate a transaction whereby X-Ray will acquire Aerotest in a stock transaction. Aerotest, as the operating entity holding the license to operate ARRR will remain unchanged as a result of the transaction.

Aerotest Operations, Inc. will continue in its current legal form.

2. ownership chain X-Ray Industries, Inc., with corporate offices located at 1961 Thunderbird, Troy MI 48084 is a privately held "S" corporation, incorporated in the State of Michigan.

X-Ray has formed a new Michigan, single member LLC, with X-Ray Industries, Inc.

as the sole member. The name of the new LLC is Aerotest Holdings, LLC. The new LLC will, as its sole activity, own all of the stock of Aerotest Operations Inc., a California Corporation. The officers and directors of Aerotest Holdings, LLC will be the same as those of X-Ray Industries, Inc. (see below). Please see the graphic below and included as Attachment I for clarity:

X-Ray Industries, Inc.

I Aerotest Holdings, LLC I

Aerotest Operations Inc.

3. foreign ownership X-Ray Industries, Inc. is privately owned by five members of the family. The five shareholders and their respective interests are as follows:

Page 1

All of the shareholders are US citizens, living in the United States and are actively employed by the company. They are the officers of company with responsibilities as indicated above, and are also the sole directors of the company. The family has oce is - 1970. The address of all of the shareholders

4. X-Ray Industries financial statements Included as Attachment 2

5. financial assurance (a) projected income statement The projected income statement for Aerotest is included as Attachment 3 (b) sources of funds for operations The source of funds to cover operating costs is fees for radiography services rendered at the facility. Aerotest has a long stable history as the single largest source for Neutron Radiography inspection of safety critical flight hardware for both the commercial and military markets, as well as for NASA. DoD has determined that keeping the ARRR facility open is a critical matter, as most of our countries flying military assets have components on them that require ongoing Neutron Radiography provided by Aerotest. Five years of historical financial statements for Aerotest are included as Attachment 3.

(c) projected balance sheet The projected balance sheet of Aerotest is included as Attachment 3.

6. decommissioning funding (a) current decommissioning cost estimate (1) basis for decommissioning estimate A decommissioning cost estimate was prepared by Energy Solutions (www.enerovsolutions.com) for the parties. The full text of the report is included as Attachment 4. The report provides a detailed description of the basis for the decommissioning cost estimate of $2.3 Million including labor, energy and waste cost assumptions. The costs were determined by comparing the Aerotest facility size and complexity against cost estimates for other facilities. The details of the cost estimates for the comparative facilities were taken from public .information on the NRC web site. The referenced facilities (A, B, and C) decommissioning reports are as follows:

I The University of Virginia ReactorDecommissioning Plan, February 2000: Accession No. ML003682690, Document Date: 2000-02-09, Docket No:

05000062.

Page 2

2 Decommissioning Cost Estimate for Ward Center for Nuclear Studies at Cornell University: Accession No. ML032400205, Document Date: 2003-07-31, Docket No:

05000157.

3 Decommissioning Plan Nuclear Research Laboratory University of Illinois at Champaign-Urbana, U.S. Nuclear Regulatory Commission Facility Operating License No. R- 1115, March 2006: Accession No. ML, 062980077, Document Date: 2006-03-28, Docket No: 05000151.

(2) clarification of financial assurance provided The spreadsheet included as Attachment 5 outlines the funding assurance to be provided.

(3) basis for 2% return The real rate of return used in the spreadsheet is 1.95%. This is an imputed tax affected rate of return on 30 year t-bills on average since 2001.

(4) source of initial funding The initial funding amount will be provided by Autoliv Inc. in the form of cash.

These funds will be immediately contributed to the nuclear decommissioning trust.

(5) Source of future funding Future funding will be provided by Aerotest per the schedule included as . These funds will be from fees charged to users of Aerotest Neutron Radiography services. A specific fee for this purpose will be charged to these customers for the first five years of operation under the new ownership. These fees are supported by the ultimate customer of these services, the United States Department of Defense (DoD). It is the intent of DoD to work with Aerotest to assure uninterrupted availability of the services provided by Aerotest by communicating their support for these fees to their supply chain. Aerotest is in most cases the only approved source for the required inspection services.

(6) Guarantees X-Ray Industries Inc. guarantees that all funds collected from customers of Aerotest designated for decommissioning funding (decommissioning fees) will be immediately forwarded to the trustee of the Aerotest Nuclear Decommissioning Trust.

(b) financial assurance method Funding assurance will be provided in the form of cash held in trust as outlined on the schedule included as Attachment 5. Additional support, if needed, is provided by the operating cash on the Aerotest balance sheet included as . Funding assurance assets will be held in a nuclear decommissioning trust in conformance with the examples provided in Appendix B of Regulatory Guide 1.159 ASSURING THE AVAILABILITY OF FUNDS FOR DECOMMISSIONING NUCLEAR REACTORS (the Aerotest Nuclear Decommissioning Trust). Bank of New York will act as custodian and trustee.

Merrill Lynch will act as investment advisor, for the trust. The trustee and advisors will act independently of Aerotest in conformance with the referenced guidance document.

Page 3

(c) decommissioning method The decommissioning method to be used is the DECON method. When decommissioning is commenced the facility may need to be in SAFSTOR until the removal of the fuel can be effected under the terms of a contract between Aerotest and the US Department of Energy (DOE). Per the contract DOE is obligated to take the ARRR fuel, "as expeditiously as practicable".

(d) funding adjustment method The required funding level will be adjusted based on updated decommissioning cost estimates to be prepared by outside experts with specific experience on a bi-annual basis. For the purposes of projecting future costs the schedule included as Attachment 5 uses a cost escalation factor of 3%. This escalation factor is based on an average of the annual inflation rates from 1999 thru 2008 of 2.827% rounded up to the next full percentage. For reference see http://www.inflationdata.com/I nflation/Inflation Rate/Historicallnflation.aspx.

Technical Qualifications

7. proposed modifications to Technical Specification The proposed changes to the ARRR Technical Specification are included as Attachment 6.

8. management and technical personnel It is the intention of both Aerotest Operations, Inc. and X-Ray Industries, Inc. that, if a transaction is completed that transfers ownership of Aerotest to X-Ray Industries, Inc., all management and technical personnel at the Aerotest Radiography and Research Reactor, including those individuals responsible for licensed activities including reactor safety, would be offered employment by X-Ray Industries, Inc. on terms and conditions comparable to those enjoyed by such employees prior to such transfer.

Sincerely, Mike Anderson Secretary Aerotest Operations, Inc.

XRyIdThams

-Isoictdent X-Ray Industries, Inc.

Page 4

Attachments:

1) Ownership Chain for ARRR

2) X-Ray Industries, Inc. 2009 reviewed financial statements

3) Aerotest Operations, Inc. historical and projected financial statement

4) Energy Solutions ARRR decommissioning cost study

5) Financial Assurance Projection

6) Technical Specification modifications CC: NRC, NRR - C. Montgomery Page 5 I

Ownership Chain for ARRR X-Ray Industries, Inc.

I Aerotest Holdings, LLC I

SAerotest Operations Inc.

1 EN ERGYSOLUTIONS July 14, 2009 Mt. Scott Thams, President X-Ray Industries

,1961 Thunderbird Troy, Michigan 48084 Re: Engineeiing Support Services; Decominissioning Cost Estimate and License Triansfer Due Diligence Suppori

Dear Scott:

An onsite review of the Aerotest facility, including decommissioning cost defining parameters such as facility size, research areas, and waste inventories was performed this week. This was followed by a relative assessment of the Aerotest facility against cost estimates for other facilities.

A rough order of magnitude decommissioning cost estimate was prepared for the Aerotest facility in San Ramon, California. This estimate is based on com0nparing the Aerotest facility size and complexity against cost estimates for other facilities. The Aerotest facility is smaller and less complex than any other facility in the comparison. As a consequence, the rough order of estimate for the Aerotest facility must be less than the estimates for any of the other facilities.

The smallest estimate after escalation to 2009 dollars was for the University of Illinois reactor at an estimated current cost of $4,740,369 including a 25% contingency. Table I shows the reactors used for decommissioning comparison before and after cost escalation along with some relevant facility size information. The cost per square foot of Class I floor area (potentially contaminated area) was estimated for each of the referenced reactors. A decommissioning cost estimate of $2,300,723 for the ARRR WaS then generated based on the average cost per square foot to decommission and an estimate of $3,279,345 based on the maximum cost per square foot.

These estimates included the 25% contingency.

1009 Comnmerce Park Drive, Suite 100, Oak Ridge, TN 37830 wwwenergysolution s.com

ENERGYSOLUTIONS Mr. Scott Thains, President July 14, 2009 Page Two A spreadsheet has been forwarded that includes the cost per square foot calculations and the cost escalation methods that were used to escalate the decommissioning costs.

If you have questions or would like additional details don't hesitate to call me at (865) 425-4590.

Sincerely, Paul Ely Senior Radiological Engineer EnergySolutions, LLC cc: Ail Palmer, CHP/PMP 1009 Commerce Park Drive, Suite 100 , Ok Ridge, TN 37830 wwv.C1nergY.'1utions.com

==

t I ENERGYSOLUTIONS Reactor Decommissioning Cost Comparison Site Cost per ft2 of D&D Estimate 2009 D&D Class I Area Class I Floor Reactor Cost Year Cost Area (ft 2) (acre) Area UVA1 .$3,065,000 2000 $5,936,434 7,241 2.6 $819.84 Co~rnell 2 $3,603,086 2003 $5,161,696 18,242 1.0 $282.96 U of Illinois: $4,209,348 2006 $4,740,369 7,612 1.0 $622.75 ARRR 'Ž . _ 4,000 0.9 7* * .

Average: $5,279,499 11,032 $575 ARR Cost based on Unit:ft 2 Cost Average: $2,300,723 ARR Cost based on Unit fte Cost Maximum: $3,279,345 1 The University of Virginia Reactor Decommissioning Plan,.February 2000 2 Decommissioning Plan for Ward Center for Nuclear Studies at Cornell University, May 2003.

3 Decommissioning Plan Nuclear Research Laboratory University of Illinois at Champaign-Urbana, U.S. Nuclear Regulatory Commission Facility Operating License No. R-1115, March 2006.

1009 Comnerce Park Drive. Suite 100I Oak Ridge, TN 37830

%tw%:energysolutions.con

Energy Solutions - ARRR Decommissioning Cost Estimate Support Documentation Page 2 Decommissioning Cost Summary UVA Reactor The adjustment of thetotal decommissioning cost estimate can be expressed by (NUREG-1307, Rev. 13):

Estimated Cost (Year X) = [1986 Cost] [ALx + BEx + CBx]

where-A, B, and C are the fractions of the total 1986 dollar costs that are attributable to labor (0.65), energy (0.13), and burial (0.22),

respectively, and sum to 1.0. The factors Lx, Ex, and Bx are the Labor CostAdjustment, the Energy Cost Adjustment, and the LLW BuriallDisposition Cost Adjustment respectively.

The above equation when adjusted to reference the 2000 UVA estimate can be expressedas follows:

Estimated Cost (2009 Cost):= [UVA 2000 Cost] [ALx + BEx + CBx]

where A, B, and C are the fractions of the total 2003 dollar costs that are attributable to labor, energy, and burial, respectively, and sum to 1.0.

The UVA values for these-fractions are given below:

[UVA 2000 Cost]:= $3,065,000 A (Labor Cost Fraction)= 0.647 B (Energy.Cost Fraction)= 0.020 C (Burial Cost Fraction)= 0.333 For+Information Only, the radioactive waste disposal volume was estimated at 7,850 cubic feet Lx= Labor Cost Adjustment, 2000 to the re-estimate month of Year.X, EX =Energy Cost Adjustment, 2000 to the re-estimate month of Year X, and LLW Burial/Disposition Cost Adjustment, 2000 to the re-estimate month of Year X, (i.e., burialldisposition cost S= in the new estimate month of Year X divided by the burial cost in 2000).

Employment Cost Index Series Id: ECU131021 Not Seasonally Adjusted compensation:: Total compensation.

ownership: Private industry periodicity: Index number group: Northeast region Year Qtrl Qtr2 Qtr3 Qtr4 Annual 2000 f2... -

2001 84 :IR b.1). J l 00. /~

Series Id: CIU20100000002121 (B,J)

Not Seasonally Adjusted compensation: Total compensation sector: Private industry periodicity: Index number Industryocc: Middle Atlantic I-- , - - - cots -or mplyeebenefits.

.B13: : New Includes.

series. Historical

, salaries, dataand are employable available be inn with:D-ecembe ber 2005.

0 LABOR ADJUSTMENT FACTOR CALCULATION Estimate Year (X) Estimate Year ()N (Q4, 2005) 4(Q, 2009)

Labor Index. Labor Index 100.0 109.5 The adjustment factor for energy, Ex, is a weighted average of two components, namely, industrial electric power, P%, and light fuel oil, Fx. For UVA E.-is given by:

Ex (PWR) = 0.58P, + 0.42Fx At UVA the PWR energy fractions were used'because they utilize a-higher faction of-electric power than those for a BWR.

The current values of P, and Fx are calculated form the Producer-Price Indexes (PPI), available in the "PPI Detailed Report",! published by the U3S. Department of Labor, Bureau of Labor Statistics. On the internet select the BLS website at.www.bls.gov- Select the "Subject Areas" tab at the top, then select"Producer Price Indexes" under "Inflation & Prices", then "PPI Databases", then under "Commodity Data" select-the "One Screen Data Search" button.

http://www. bls.qov/

To generate the correct report selectthe following options for the report: .(1):"05 Fuels and Related Products & Power", (2) "0543 Industrial Electric Power" and "0573 "Light Fuel Oils", (3) unclick the "Seasonally Adjusted button. Then click the "Add to Your Selection" button for the above categories, and click the "Get Data" button. The report should resemble: the data presented below once'the report is modified to give annual data only.

Series Id: WPU0543 Series Id: WPU0573 Not Seasonally Adjusted Not Seasonally Adjusted Group: Fuels and related products and power Group: Fuels and related products and power Item: Industrial electric power Item:: Light fuel;oils Base Date: 198200 Base Date: 198200 Year Annual Year -Annual 2000 ' - -1.3I' 2000 ....... .__92-j 2001 f.--:._ 2001 ' ..... 35 2002 ..... 139:9 2002 76.31 2003 145$81 2003 . ."--

2004 .. 7.2, 2004 ..... 124.58 2006: 156.1 200o 20076f 2o 172.8 12oo6 2007_ --

_2YfJ 2007 880--4 20087 - 23-051 2009 " 2009 ENERGY ADJUSTMENT FACTOR CALCULATION Base Year Estimate Year (X) Base Year Year (X)

(2000) (2008) P- (2000) (2008) FX Power Index Power Index (2005) Fuel Index Fuel.Index. (Q3, 2005) 131.5 189.1 1.438 :92.8 317.0 3.416 Ex (PWR) = 0.58Px + 0.42Fý II .Ex (2009) = 2.269 II The adjustment factors for waste burialldisposition B., are taken directly from data on the appropriate LLW locations given in Table 2.1 of.

NUREG-1307. For example; B' = 17.9224(in'2002 dollars) for a PWR directly disposing all decommissioning LLW from a state in the Atlantic Compact at the Barnwell South Carolina burial site.

-At UVA waste will be sent to an (1) offsite-waste processor, (2) the Envirocare of Utah Burial site. The adjustment factor for waste burialldisposition B,, is a weightedaverage of these three components. For the UVA Reactor, B. is given by:

B, (UVA) = D*WPx + E*BARNx + F*ENVx where D, E, and F'are the fractions of the total 2003' waste dollar-costs that are attributable to (1) an offsite waste processor, (2) Barnwell South Carolina burial site, and (3) Envirocare of Utah Buriaglsite respectively, and sum to 1.0.

.D= 0.300 E= 0.000 0.700 The adjustment factor for Waste Processors, WP,, is taken from data given in Table 2.1 of NUREG-1307 for Direct Disposal with Vendors at U.S.

Ecology from a PWR for the estimate year X and divided by the adjustment factor for the Base Year 2000. Waste Processors do not publish rateschedules and rates are negotiated with each waste shipper based on current burial site rates and Waste Processor labor rates. Getting rate quotes from a Waste Processor every estimating year would provide a more accurate adjustment factor for UVA, but it would be up to UVA to obtain the rate quotes.

The adjustment factor for Barnwell'South Carolina burial site, BARNx, is taken from data given in'Table 2.1 of NUREG-1307for Direct Disposal from a Non-Atlantic Compact PWR for the estimate year X and divided by the adjustment factor for the Base Year 2000.

The adjustment factor for Envirocare of Utah, ENVX, is taken from data given in Table 2.1 of NUREG-1307 for Direct Disposal at U.S. Ecology from a PWR for the estimate year X and divided by the adjustment factor for the Base Year 2000. Envirocare of Utah does not publish a rate schedule and rates are negotiatedwith each waste shipper based primarily on waste volumeý The disposal rates for Envirocare of Utah are not included, in NUREG-1307, but the rate structure at U.S. Ecology is similar to the negotiated rate structures at Envirocare of Utah. Getting rate

,quote from Envirocare of Utah every year would provide a-more accurate adjustment factor for UVA, but itwould be up to UVA to obtain the rate quotes.

.An example ofthe waste burial/disposition factors for UVA assuming a base year of 2000 and estimate yearof.2009 are given by:

An exampleof the waste burialldisposition factors for ARRR assuming .a base yearof 2006 and estimate year of 2010 are given by:

WP20= 4.638 WP 2009 = 5.088 BARN 2000 = 17.824 BARN 2009 = 26.824 ENV 2000 = 2.250 ENV 2o09 = 9.000 B2009 (UVA) = 0.7*.(9.012.25) + 0.0*(26.824117.824) + 0.3*(5.08814.638) 3.129 Estimated Cost (Year 2000) = [2000 Cost] [AL 2009 '+ BE2 009 + CB 20091

The adjustment factors above must be adjusted for the correct estimate years. However an example calculation is presented below using the

example adjustment factors presented above as if they were for the year 2009.

2000 COST $3,065,000 A= 0.647 0.020 C= 0.333 L2009 = 1.313 E 2 00 9 ;= 2.269 B 2009 ,= 3.129 FE--- 2009 COST= $5,936.434 iI

Energy Solutions - ARRR Decommissioning Cost Estimate Support Documentation Page 3.

Decommissioning Cost Summary Cornell Ward Laboratory The adjustment of the total decommissioning cost estimate can be expressed by (NUREG-1307, Rev. 13):

EstimatedCost (Year X) = [1986 Cost] [ALx:+ BEx + CBx]

where A, B, and C are the fractions of the total"1986 dollar costs:that are attributableto labor (0.65), energy (0.13), and burial (0.22), respectively, and sum to 1.0.. The factors Lx, Ex, and Bx~are theLabor CostAdjustment, the Energy Cost Adjustment, and the LLW Burial/Disposition Cost Adjustmentrespectively.

The above equation when adjusted to reference the 2003 Cornell estimate can be expressed asfollows:

Estimated Cost(2009 Cost);= [Cornell 2003 Cost] [ALx + BEx.+ CBx]

where A, B, and C are the fractions of the total 2003 dollar costs thatare~attributable to labor,:energy, and burial, respectively, and sum to1.0. The Connell values forthese fractions are given below:

[Cornell 2003 Cost] = $3,603,086 A (Labor Cost Fraction)= 0.545 B (Energy Cost Fraction)= 0.020 C (Burial.Cost Fraction)= 0.435 For Information Only,the radioactive waste disposal volume was estimated at 4,714 cubic feet Lx = Labor Cost Adjustment, 2003 to-the.re-estimatemonth ofYear X, Ex = Energy Cost Adjustment, 2003 to there-estimate month of Year X, and LLW Burial/DispositionCost Adjustment, 2003 to the re-estimate month of Year X,. (i.e., burialldisposition costin the new estimate month of YearXkdivided by the burial cost in 2003).

Employment Cost Index Seriesld: ECU131021 NotSeasonally Adjusted compensation: Totalcompensation ownership: Private industry periodicity: Index number group: Northeast region Year Qtrl Qtr2 Qtr3 . Qtr4 Annual 2003 2004 9T5-.

54.51 s: 9-.4i 9-6-7i 2005 97.7*! 98.6f 99.3' 1001ý Series Id:. CIU20100000002111 (BAJ)

Not Seasonally Adjusted compensation: Total compensation sector:. Private industry periodicity: Index number Industryocc: New England

Year Qtrl Qtr2 _ Qtr3 - Qtr4 Annual 2006 - 0U0.71 1041'4 102.1* f 11 3.

2007 104.81 D6"0_____ fO.5:41 D06T6.1_

2008 f06.7* 107-fi 1O7.8! 109.51 2009 109.91 B: Includes wages, salaries, and employer costs for employee benefits.

New series. Historical data are available beginning with December LABORADJUSTMENT FACTOR CALCULATION Base Year Estimate Year (X) Estimate Year (X) ARRR Z fZ~

(Q4, 2003) .(04, 2005) (a1, 2009)

Labor Index Labor Index Labor Index (Q1, 2009)

.93.2 100.0 [10M ~ 1.179 The adjustment factor for energy, Ex; is a weighted average of two components, namely, industrial electric power, Px, and light fuel oil, Fx. For CornellEx is given by:

Ek (PWR)= 058Px + 0.42F, At Cornell the PWR energy fractions were used because they utilize a higher faction of electric powerthan those for a BWR.

The current~values of P, and F, are calculated form the Producer Price indexes (PPI), availablein the "PPI Detailed Report", published by the U.S. Department of Labor, Bureau of Labor Statistics. On the internet select the BLS websiteat .A-.-.bls.gov. Select the "Subject Areas"tab at the top, then select "Producer Price indexes" under

'Inflation & Prices", then "PPI Databases", then under "Commodity Data" select the"One Screen Data Search" button.:

htto:l/www.bls.oov/

To generate the correct report select the following-options for the report (1) "05 Fuels and Related Products & Power", (2) "0543 Industrial Electric Power" and "0573 "Light Fuel Oils", (3) unclick the "Seasonally Adjusted button. Then click the"Add to Your Selection" button for the above categories, and clickthe '"Get Data" button.

The report should resemblethe data presented below once the report is modified tozgive annual data only.

Series Id: WPU0543 Series Id: WPU0573 Not Seasonally Adjusted Not Seasonally Adjusted Group: Fuels and related products and power Group:. Fuels-and related products and power Item:: Industrial electric power Item: Light fuel Oils Base Date: 198200 Base Date: 198200 Year Annual Year Annual 2000 "3.5 2000 9-2.81 2001 141.1! 2001 83:5 2002 f39T9 2002

2003 ____£1.i 2003 _ _ _ _ _ _

2004 ___ ,:7:i 2004 -12.5T 2005 1:5-6: 2005 _ _1-8"3T'j 2006 8_f7-28 2006 __212.1 2007 2007 ,,

__, "2"3"0--_

2008 f*9.1 2008 13f7 2009 " 2009  !

ENERGY-ADJUSTMENT FACTOR CALCULATION Base Year Estimate Year (X) Base Year Year (X) 2003 (2008) Px -2003 (2008) Fj Power Index Power Index (2005) Fuel Index Fuel Index (Q3, 2005) 145-8 189.1 1.297 :I97.9 317.0 3.238 E, (PWR) 0.58P, + 0.42F1 Ex(2009)= 2.112 1 The adjustment factors forwaste burialldisposition Bx, are taken directly from data on the appropriate LLW locations given in Table 2.1 of NUREG-1307.. For example, B.,

17.922 (in 2002 dollars) for a PWR directly disposing all decommissioning LLW from a state in the Atlantic Compact at the Barnwell South Carolina burial site.

At Cornell waste will be sent to an (1.) offsite waste processor, (2) the Envirocareof Utah Burial site. The adjustment factor for waste burial/disposition Bx, is a weighted average of these three components. For the Cornell Reactor, Bx is given by:

Bx (Cornell) = D*WPx + E*BARNx + F*ENVx where D, E, and F are the fractions. of the total 2003 waste dollarcoststhat are attributable to (1) an offsite waste processor, (2) Barnwell South Carolinas burial site, and (3)

Ehvirocare of Utah Burial.site respectively, and'sum to 1.0.

D= 0.300 E= 0.000 F= 0.700 The adjustment factor for Waste Processors, WPx, is taken from data given:in Table 2.1 of NUREG-1307 forDirect Disposal-with Vendors at U.S. Ecology from a.PWR for the estimate year X and divided by the adjustment factor for the Base Year 2003. Wastet Processors do not publish rate schedules.and rates ýarenegotiated with each waste shipper based on current burial site rates andWaste Processor labor rates. Getting rate quotes from a WasteProcessor every estimating year would provide a more accurate adjustment factor for Cornell, but it would be up to Cornell to obtain the rate quotes-The adjustmentfactor for Barnwell South Carolina burial site, BARNx, is taken fromndata givenin Table 2.1 of NUREG-1307 for Direct Disposal from a Non-Atlantic Compact PWR for the estimate year X and divided by the adjustment factor for the Base Year 2003.

The adjustment factor for Envirocare'of.Utah, ENVx, is taken from data given in Table 2.1 of NUREG-1307 for Direct Disposal at U.S. Ecology from~a PWR for the:estimate year X and divided by the adjustmentfactor for the Base Year2003. Envirocare of Utah does not publish a rate schedule and rates are negotiated with each wasteshipper based primarily on waste volume. Thedisposal rates for Envirocare of Utah are not included in NUREG-1307,:butthe rate structure at:U;S. Ecology is similarto the negotiated rate structures at Envirocare of Utah. Getting rate quote from Envirocare of Utah every year would provide a more accurate adjustment factor for Cornell, but it would be up to Cornell to obtain the rate quotes..

An example of thewaste burialldispositibn factors for Cornell assuming a baseyear of 2003 and estimate year of 2009 are given by:

An example of the waste burialldisposition factors for ARRR assuming a. base year of 2006 and estimate year of 2010 are given by:

WP2003 = 4.788 WP 20 09 = 5.088 BARN2003 = 20.824 BARN 2009 = 26.824 ENV2003 = 4.500 ENV 2009 = 9.000 B2009 (Cornell) = 0.7*(9.014.5) + 0.0*(26.824120.824) + 0.3*(5.08814.788)

B20D9 = 1.719 Estimated Cost (Year 2003) = [2003 Cost] j[AL2009 + BE2009 + CB2009]

The adjustment factors.above-must be adjusted for the correct estimate years. However an-example calculation is presented below using the:example adjustment factors presented above as if they werefor the year 2009.

2003 COST = $3,603,086

Energy Solutions - ARRR Decommissioning Cost Estimate Support Documentation Page 4 Decommissioning Cost Summary University of Illinois Research Reactor The adjustment of the total decommissioning cost estimate can be expressed by (NUREG-1307, Rev. 13):

Estimated Cost (Year X) = [1986 Cost] [ALx + BEx + CBx]

where A, B, and C are the fractions of the total 1986 dollar coststhat are attributable to'labor (0.65), energy (0.13), and burial (0.22),

respectively, and sum to 1.0. The factors Lx, Ex, and Bx are the Labor Cost Adjustment, the Energy Cost Adjustment, and the LLW Burial/Disposition Cost Adjustment respectively.

The above equation when adjusted to reference the 2006 Illinois estimate can: be expressed as follows:

Estimated Cost (2009 Cost)= [lllinois 2006 Cost] [ALx + BEx + CBx]

where A, B, and C are the fractions of the total 2006 dollar costs that are attributable to labor, energy,.and burial, respectively, andisum to 1.0. The Illinois values for these fractions are given below::

[Illinois 2006 Cost] = $4,209,348 A (Labor Cost Fraction)= 0.643 B (Energy Cost Fraction)= 0.020 C (Burial Cost Fraction)= 0.337 For Information Only, the radioactivewaste disposal volume was estimated at.5,638 cubic feet L, = Labor Cost Adjustment, 2006 to the re-estimate. month of Year X, Ex = Energy Cost Adjustment, 2006 to the re-estimate month of Year:X, and LLW Burial/Disposition Cost Adjustment, 2006-to there-estimate month of YearX, (i.e., burial/disposition cost Bx= in the new estimate month of Year X divided by the burial costin 2006).

Employment Cost Index Series Id: CIU20100000002301 (B)

Not Seasonally Adjusted compensation: Total compensation sector: Private industry periodicity: Index number industryocc: Midwest Year 2001 i ... Qtrl .I Qtr2 Qtr3 Qtr4 Annual I

2002 .______

2003 98392..*6 248__93.6___-

2004 _____ 9 .6 2005 2 006 1*TO-6,007 9_____

f"1-0f:7 99T5 99

-Dff 10_(

10097.8i T-8, 2007 1003. 3__i! I 2008 -io7- 107.4 2009 .107.9hI I LABOR ADJUSTMENT FACTOR CALCULATION Base Year Estimate Year (X) Illinois (Q4, 2006) (Q1, 2009) L.

Labor Index Labor Index (QI,.2009) 101.7 107.9 1.061 I The adjustment factor for energy, Ex, is a weighted average of two components, namely, industrial electric power, Px, and light fuel oil, Fx.

For Cornell Ex is given by:.

Ex (PWR)=,0.58PX + 0.42Fx At Illinois the PWR energy fractions were used because they utilize a higher faction of electric power than those for a BWR..

The current values of P, and Fxare calculated form the Producer Price Indexes (PPI), available in the "PPI Detailed Report", published by the U.S. Department of Labor, Bureau of Labor Statistics. On the internet select the BLS website at www.bls.gov. Select the ".Subject Areas" tab at the top, then select "Producer Price Indexes" under "Inflation & Prices", then "PPI Databases", then under "Commodity Data" select the "One Screen Data Search" button.

http://www.bls.gov/

To generate the correct report select the following options for the report: (1) "05 Fuels and Related Products`& Power", (2) "0543 Industrial Electric Power" and "0573 "Light Fuel Oils", (3) unclick the "Seasonally Adjusted button. Then click the "Add to Your Selection" button for the above categories, and click the "Get Data" button. The report should resemble the data presented below once theireport is modified to give annual data only.

Series Id: WPU0543 Series Id: WPU0573 Not Seasonally Adjusted Not Seasonally Adjusted Group:, Fuels and related products and power Group: Fuels and related products and power Item: Industrial electric power Item: Light fuel oils Base Date: 198200 Base Date: 198200

Year Annual Yeari Annual L2000 131.51 2000 ... 8 2001 "f Y-j.1 2001 83.

2002 __ _ _ -_39.9l 2002 73 2003 1 2003 1*_.20049--................ 14-2 2004 _ _124.5j 2005 2006:2 -183 2006 2006 -2 -2.j 200780 2007 - 8637051 2008 81 2008 . 31i 2009 1 2009 L J ENERGY ADJUSTMENT FACTOR CALCULATION Base Year Estimate Year (X) Base Year Year (X) 2006 (2008) Px 2006 (2008) Fx Power Index Power Index -2006 Fuel Index Fuel Index (Q3, 2005) 172.8 189.1 1.094 212.1 317.0 1.495 Ex (PWR)= 0.58Px + 0.42F, IF E(2009) = 1.262 The adjustment factors forwaste burialldisposition BX, are taken directly from edata'on the appropriate LLW locations given in Table 2.1 of NUREG-1307. For example, B, = 17.922 (in 2002 dollars) for a PWR directly disposing all decommissioning LLW from a state in the Atlantic Compact at the Barnwell South Carolina burial site.

At Illinois waste will be sent to an (1) offsite waste processor, (2) the Envirocare of Utah Burial site. The adjustment factor for waste burialldisposition Bx, is a weighted average of these three components. For the Illinois Reactor, Bx is given by:

Bx (Cornell) = D*WPx + E*BARNx + F*ENVx where D, E, and F are the fractions of the total 2003 waste dollar costs that are attributable to (1) an offsite waste processor,-(2) Barnwell South Carolina burial site, and (3) Envirocare of Utah Burial site respectively, and sum to 1.0.

D= a0300 0.000 F= 0.700

The adjustment factor for Waste Processors, WPx,,istaken from data given in Table 2.1 of NUREG-1307 for Direct Disposal with Vendors at U.S. Ecology from a PWR for the estimate year X and divided by the adjustment factor for the Base Year 2003. Waste Processors do not publish rate schedules and rates are negotiated with each waste shipper based on-current burial site rates and Waste Processor labor rates. Getting rate quotes from a Waste Processor every estimating year would provide a more accurate adjustmentfactor for Illinois, but it would be up to Illinois to obtain the rate quotes.

The adjustment factor for Barnwell South Carolina burial site, BARNx, is taken from data: given in Table 2.1 of NUREG-1307 for Direct Disposal from a Non-Atlantic Compact PWR for the estimate year X and divided by the adjustment factor for the Base Year 2006.

The adjustment factorfor Envirocare of Utah, ENVx, is taken from data given in Table 2.1 of NUREG-1307 for Direct Disposal at U.S.

Ecology from a: PWR for the estimate year X and divided by the:adjustment factor for the Base Year 2006. Envirocare of Utah does not publish a rate schedule and rates are negotiated with each waste shipper based primarily on waste volume. The disposal rates for Envirocare of Utah are not included in NUREG-1 307, but the rate structure at U.S. Ecology is similar to the negotiated rate structures at Envirocare of Utah. Getting rate quote from Envirocare of Utah every year would provide a more accurate adjustment factor for Cornell, but it would be up to Cornell to obtain the rate quotes.

An example of the waste burial/disposition factors for ARRR assuming a base year of 2006 and estimate year of 2010 are given by:

WP2006 = 4.938 WP 20 0 9 =

5.088 BARN2006 = 23.824 BARN 200 9 = 26.824 ENV2006 = 6.750 ENV2009 = 9.000 B2009 (ll~inois) = 0.7*(nQnO- n0.Q*Q26.824118.824),+ 0.3"15.n8814.688)

B2009 = 1.242ý Estimated Cost (Year 2006) = [2006 Cost] [AL2009 + BE2009 + CB2009]

The'adjustment factors above must be adjusted for the correct estimate years. However an example calculation is presented below using the example adjustment factors presented above as if they were for the year:2009.

2006 COST = .$4,209,348 A= 0.643 B:= 0.020 C= 0.337 L2009 = 1.061 E200= 1.262 B2009 = 1.242 I 2009 COST = $4,740,369 ]1 I

The values for the base year 2006 are not yet available in NUREG-1307.

Table 2.1 from NUREG-1 307 Revision 11 is provided below along with extrapolated data.

Bx Values for Washington Site Year PWR y=mx+b 1995 2.015 0.75 1996 2.845 -1.5 1997 3.112 1998 3.165 1999 #N/A 2000 2.223 2001 #N/A 2002 3.634 2003 #N/A 2004 5.374 2005 #N/A 2006 6.829 2007 #N/A 2008 8.283 Bx Values for Washington Site (Data fitted to a curve and extrapolated to 20"10)

Year Year PWR 1995 0 -1.500 1996 1 -0.750 1997 2 0.000 1998 3 0.750 1999 4 1.500 2000 5 2.250 2001 6 3.000 2002 7 3.750 2003 8 4.500 2004 9 5.250 2005 10 6.000 2006 11 6.750 2007 12 7.500 2008 13 8.250 2009 14 9.000 2010 15 9.750

Bx Values for Washington Site (Data fitted to a curve and extrapolated to 2010) 10.2 -* -, - o ____ - .  ; .

9.8 9.6 - -- 7, _

9.4 8.2 7.2 -- -----

6.8 "

- 6.6 x 5.8 5.6 - -----

5.2 - ~ Z~ -~

-'~--__-__-_-__-----

-I 4.6 4.4 4.2 4 -- '~ -~F Bx-Values for Washington Site ~ ~ ' -

3.8 3.6 -, -4'-Fitted Curve 3.4 3.2 A~~' __

3 2.8 2.6 2.4 2.2 2

01 0)" 0 0 0 0 0 0 0 0 0 0 T_

0) 0) m 0 0 0 0 0

0) 0) 0) 0) 0) 0 0 0 0 0 0

- 9 -(i Year (N CJ (4 CN Year

Energy Solutions - ARRR Decommissioning Cost Estimate Support Documentation Page 6 The values for the base year 2006 are not yet available in NUREG-1307. Table 2.1 from NUREG-1307 Revision 11 is provided below along with extrapolated data.

Bx Values for Waste Processor-Washington Site Year PWR 1998 4.538 y=mx+b 1999 #N/A 0.05 2000 4.06 4.538 2001 #N/A 2002 5.748 2003 #N/A 2004 3.846 2005 #N/A 2006 3.855 2007 #N/A 2008 5.153 B. Values for Waste Processor-Washington Site (Data fitted to a curve and extrapolated to 2010)

Year Year PWR 1998 0 4.538 1999 1 4.588 2000 .2 4.638 2001 3 4.688 2002 4 4.738 2003 5 4.788 2004 6 4.838 2005 7 4.888 2006 8 4.938 2007 9 4.988 2008 10 5.038 2009 11 5.088 2010 12 5.138

Bx Values for Waste Processor-Washington Site (Data fitted to a curve and extrapolated to 2010) 5.8 5 .7 r-  : _ _ . _ , ..- -.

5.6-5.5 5 . - *- 7 7-.

51 f 5.2 r-4.9 .- ----

.= 4 .8 . . .. . . . . .. . ..... . . - . . .

> 4 .7 -- . . . . . . . -. . . .  : - - - . . . .: - - . . . .. . . . "'

m4.6 '-

4 .5 ----  :'-* -- : , - - * -!'

4.4--J- Bx Values for Waste Processor-Washington Site 4.3

-- Fitted Curve 4.2 4 .1 -----

3.9 c0 C3CDC) 0 - C") C. CO 0C 0

0) 0") 00 00 00 00 0CD 0") 0) 0 00 00 0 ) 00 00 0 c"04 N C, 4 C'.4N N04 N, 04 (N Year

. a Energy Solutions - ARRR Decominissioning Cost Estimate Support Documentation Page 7 The values for the base year 2006 are not yet available in NUREG-1 307.

Table 2.1 from NUREG-1307 Revision 11, Non-Atlantic Compact, is provided below along with extrapolated data.

Bx Values for Barnwell SC Site Year PWR y=mx+b 1995 12.824 nm" 1.0 1996 12.771 b= 12.824 1997 15.852 1998 15.886 1999 #N/A 2000 18.129 2001 #N/A 2002 18.732 2003 #N/A 2004 21.937 2005 #N/A 2006.. 23.03 2007 #N/A 2008 #N/A Bx Values for Barnwell SC Site (Data fitted to a curve and extrapolated to 2010)

Year Year PWR 1995 0 12.824 1996 1 13.824 1997 2 14.824 1998 3 15.824 1999 4 16.824 2000 5 17.824 2001 6 18.824 2002 7 19.824 2003 8 20.824 2004 9 21.824 2005 10 22.824 2006 11 23.824 2007 12 24.824 2008 13 25.824 2009 14 26.824 2010 15 27.824

Bx Values for Barnwell SC Site (Non-Compact)

(Data fitted to a curve and extrapolated to 2010) 29---

28 _____

27 -_.

26 __

24 - ------

23 22 S21k'--

19 r 18 -

17 16 _ ___  :- __,-'- _" - Bx Values for Barn 15 /, 1 4-..Fitted Curve 15 /

13 12 LC) CD r (00 ) 0 . N CO LO 0CD (0 0) 0

0) 0) 0") 0) 0) 0 0 0 0 00 0 0 0 0

0) 0) 0) 0) 0) 0 0 0 0 N4 04 o4 0 04 04 N N N 04 Year

- I ~' )

11.0 Fuel Storgae and Transfer 11.1 The fuel storage pits located in the. floor of the reactor room shall accommodate a maximum of 19 fuel elements (700 gm U-235) in storage racks dry or flooded with water. The fuel storage pits shall be secured with a lock and chain except during fuel transfei operations.

11.2 Additional fuel storage racks may be located in the reactor lank. Each of these storage facilities shall be so designed that for all conditions of moderation k eff shall not exceed a value of 0.8.

11.3 A fuel handling tool shall be used in transferring fuel elements of low radioactivity between the storage pits and the reactor; a shielded fuel transfer of highly radio-active fuel elements. The! fuel handling tool shall remain in a locked cabinet under the cognizance of the Reactor Supervisor when not authorized for use.

11.4 All fuel transfers in the reactor tank shall be conducted by a minimum staff of three men, and shall include a licensed Senior Operator and a licensed Operator.

The staff members shall monitor the operation using appropriate radiation monitoring instrumentation. Fuel transfers outside the reactor tank but within the facility shall be supervised by a licensed Operator.

11.5 Not more than one fuel element shall be allowed in the facility which is not in storage or in the core lattice.

12.0 Administrative Requirements 12.1 OrmaniZation of the Licensee 12.1.1 The Reactor Supervisor shall have responsibility of the reactor facility. In all matters pertaining to reactor operations and to these Technical Specifications, the Reactor Supervisor shall be responsible to the Presiden Aerotest Operations, Inc., a wholly-owned subsidiary of Explosive Technology, Inc.AThe Presiderote erotest of Drecto rthe Bord Operations.

ýl*perationis, hic. includes haac. hicb~ .theto shall report "l'resli ent ot *0EA, Inc. an xplosive TechnoI6gy Ino of he Licensee* tb ie'seeee 2.1.2 The Radiological Safety icer shall review and approve all proce ures and experiments involving radiological safety. He shall enforce rules, regulations and procedures relating to radiological safety, conduct routine radiation surveys and is responsible to the Manager, Aerotest Operations.

12.1.3 The Reactor Safeguards Committee shall be composed of not less than five members, of whom no more than three are members of the operating organization. The committee

11.0 Fuel Storage and Transfer 171.1 The fuel storage pits located in the floor of the reactor room shall accommodate a maximum of 19 fuel elements (700 gmn U-235) in storage racks dry or flooded with water. The fuel storage pits shall be secured with a lock and chain except during fuel transfer operations.

11.2 Additional fuel storage racks may be located in the reactor tank. Each of these storage facilities shall be so designed that for all conditions of moderation k eff shall not exceed a value of 0.8.

11.3 A fuel handling tool shall be used in transferring fuel elements of low radioactivity between the storage pits and the reactor; a shielded fuel transfer of highly radio-active fuel elements. The fuel handling tool shall remain in a locked cabinet under the cognizance of the Reactor Supervisor when not authorized for use.

11.4 All fuel transfers in the reactor tank shall be conducted by a minimum staff of three men, and shall include a licensed Senior Operator and a licensed Operator.

The staff members shall monitor the operation using appropriate radiation monitoring instrumentation. Fuel transfers outside the reactor tank but within the facility shall be supervised by a licensed Operator.

11.5 Not more than one fuel element shall be allowed in the facility which is not in storage or in the core lattice.

12.0 Administrative Requirements 12.1 Organization 12.1.1 The Reactor Supervisor shall have responsibility of the reactor facility. In all matters pertaining to reactor operations and to these Technical Specifications, the Reactor Supervisor shall be responsible to the President of the Licensee. The President of the Licensee shall report to the Board of Directors of Licensee.

12.1.2 The Radiological Safety Officer shall review and approve all procedures and experiments involving radiological safety. He shall enforce rules, regulations and procedures relating to radiological safety, conduct routine radiation surveys and is responsible to the Manager, Aerotest Operations.

12.1.3 The Reactor Safeguards Committee shall be composed of not less than five members, of whom no more than three are members of the operating organization. The committee

1K. ^-IX- Ondus res For all your nondestructive testing needs NONDESTRUCTIVE TESTING X-Ray o Gamma & High Energy Radiography o Digital Radiography Magnetic Particle o Liquid Penetrant Ultrasonic o Eddy Current

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• Metal Finishing March 10, 2010 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 OATH AND AFFIRMATION Re: Aerotest RadiographyandResearch Reactor License No. R-98 Response to Requestfor AdditionalInformation- Docket no. 50-228, 3-10-2010 To Whom It May Concern:

I, SCOTT THAMS, hereby certify that the content of our Response to Request for Additional Information Regarding Proposed Indirect License Transfer (TAC no. ME 1887) submitted by Aerotest Operations, Inc., and X-Ray Industries, Inc. dated March 10, 2010, contains information that is true and correct to the best of my knowledge.

Respectfully submitted, S4kOTTlkIA0M-Pr ient,~

X-Ray ustries, Inc.

JEANNE M. PERRY Notary Public, State of Michigan County of Oakland My Commission Expires Nov. 01, 2012 Acting inthe County of -q/y-4A-&A-Vt '

,' "* . V

.J . -A 1961 Thunderbird, Troy MI 48084 (248) 362-2242, Fax (248) 362-4422

Autoliv March 15, 2010 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 OATH AND AFFIRMATION Re: Aerotest Radiography andResearch Reactor License No. R-98 Response to Requestfor Additional Information - Docket no. 50-228, 3-10-2010 To Whom It May Concern:

I, Michael Anderson, hereby certify that the content of our Repsonse to Request for Additional Information Regarding Proposed Indirect License Transfer (TAC no. ME1887) submitted by Aerotest Operations, Inc., and X-Ray Industries, Inc. dated March 10, 2010, contains information that is true and correct to the best of my knowledge.

Respectfully submitted, MICHAEL ANDERSON Secretary Aerotest Operations, Inc.

CANDACE MIERZWINSKI Notary Pubic, State of Michigan County of Oakland my Commission Expires Ma 26,2013)

Acting inthe Count of Michael S. Anderson Vice President for Legal Affairs and General Counsel Autoliv ASP, Inc.

1320 Pacific Drive Phone +1 (248) 475-0442 Auburn Hills, Ml, USA 48326 Fax +1 (801) 625-7399 mike.anderson@autoliv.com Phone +1 (248) 475-9000

NONDESTRUCTIVE TESTING IN/ V; D

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• Metal Finishing March 10, 2010 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 REQUEST TO WITHHOLD FROM PUBLIC DISCLOSURE Re: Aerotest Radiographyand Research Reactor License No. R-98 Response to RequestforAdditional Information- Docket no. 50-228, 3-10-2010 To Whom It May Concern:

Pursuant to 10 CFR 2.390, Public Exemptions, Request for Withholding, Aerotest Operations Inc.

(Aerotest) and X-Ray Industries, Inc. (X-Ray) hereby request that the information contained in its Response to Request for Additional Information Regarding Proposed Indirect License Transfer (TAC No. ME1887), (the ARRR RAD) both in Draft form and final form dated March 10, 2010 be withheld from public disclosure as such ARRR RAI contains trade secrets, commercial information and financial information which is confidential.

In Support of our request we state the following:

1. The document sought to be withheld from public disclosure is the Additional Information Regarding Proposed Indirect License Transfer (TAC No. ME1887) submitted by Aerotest Operations Inc. and X-Ray Industries, Inc. dated March 10, 2010;

2. The persons making this request under individually executed documents are Dario Brisighella,

• President of Aerotest Operations, Inc. and Scott Thams, President of X-Ray Industries, Inc.;

3. The basis for proposing that the information be withheld from public disclosure is that information contained in the ARRR RAI includes confidential business and financial information of Aerotest and X-Ray, which information has been held in confidence by Aerotest and X-Ray is a type customarily held in confidence by its owner, was transmitted to and received by the commission in confidence, is not available in public sources, and if publicly disclosed would be likely to cause substantial harmn to the competitive position of Aerotest and X-Ray taking into account the value of the information, the amount of effort and money expended by Aerotest and X-Ray in developing the information and the difficulty with which the information could be acquired of duplicated by others;

4. If such information was disclosed to the public, Aerotest and X-Ray believe that competitive harm would result; 1961 Thunderbird, Troy Ml 48084 (248) 362-2242, Fax (248) 362-4422

>>~j X-Ray Inh ustie For all your nondestructive testing ned NONDESTRUCTIVE TESTING X-Ray 9 Gamma & High Energy Radiography e Digital Radiography Magnetic Particle 9 Liquid Penetrant Ultrasonic e Eddy Current

• High Volume Sorting Chemical Processing o Metal Finishing PAGE 2 - ARRR Request to Withhold from Public Disclosure

5. The ARRR RAI has been marked to show the locations of the information sought to be withheld.

Further Affiant Sayeth Not, X-Ray Inc.

Notary: 6 .A*

JEANNE M. PERRY Notary Public, State of Michigan County of Oakland My Commission Acting inthe County Expires of _QjjNov. 01, 2012

• LAJt 1961 Thunderbird, Troy MI 48084 (248) 362-2242, Fax (248) 362-4422

L REQUEST TO WITHHOLD FROM PUBLIC DISCLOSURE Pursuant to 10 CFR 2.3 90, Public Inspections, Exemptions, Requests for Withholding, Aerotest Operations, Inc. ("Aerotest") hereby requests that the information contained in its Responses to Request for Additional Information (the "RAI Response") dated March 15, 2010, and any discussions related to the RAI Response be withheld from public disclosure as such RAI Response and discussions include trade secrets and comnmercial and financial information which is confidential.

In support of Aerotest's request, Aerotest states the following:

1. The information sought to be withheld -from public disclosure is the RAI Response submitted by Aerotest Operations, Inc. and X-Ray Industries, Inc. dated March 15, 2010, and discussions with the NRC staff concerning the RAI Response;

2. The person making this affidavit is Michael S. Anderson, Secretary of Aerotest Operations, Inc.;

3. The basis for proposing that the information be withheld from public disclosure is that information contained in the RAI Response and associated discussions include confidential business and financial information of Aerotest, which information has been held in confidence by Aerotest, is a type customarily held in confidence by its owner, was transmitted to and received by the commission in confidence, is not available in public sources, and, if publicly disclosed, would be likely to cause substantial harm to the competitive position of Aerotest taking into account the value of the information, the amount of effort and money expended by Aerotest in developing the information and the difficulty with which the information could be acquired or duplicated by others;

4. If such information was disclosed to the public, Aerotest believes that competitive would result to Aerotest;

5. The RAI Response has been marked to show the locations of the information sought to be withheld.

Further Affiant Sayeth Not, Michal S. Anderson CANDACE MIERZWINSKI M Notary Public, State of Michigan Secretary, Aerotest Operations, Inc. CountyFExpires MyCmmission of Oakland May. 26, 2013 ActIng inthe Count of (* __J*. ,(, . .

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