ML103410207
| ML103410207 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 02/02/2011 |
| From: | Alexander Adams Research and Test Reactors Licensing Branch |
| To: | Warren S Aerotest |
| montgomery c 415-3398 | |
| References | |
| TAC ME1887 | |
| Download: ML103410207 (5) | |
Text
February 2, 2011 Sandra Warren, General Manager Aerotest Operations, Inc.
3455 Fostoria Way San Ramon, CA 94583
SUBJECT:
AEROTEST OPERATIONS, INC. - DECOMMISSIONING ACTIVITIES AT AEROTEST RADIOGRAPHY AND RESEARCH REACTOR (TAC NO. ME1887)
Dear Ms. Warren:
This letter provides guidance on pre-decommissioning activities which can be performed at the Aerotest Radiography and Research Reactor and the process to decommission a research reactor.
Decommissioning is defined in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.2. Activities considered part of decommissioning are not allowed until after your decommissioning plan has been approved by the U. S. Nuclear Regulatory Commission (NRC).
Any pre-decommissioning activities you perform must not permanently modify or dismantle structures, systems or components. The proposed activities must also meet the requirements of 10 CFR 50.59, AChanges, tests, and experiments.@ The activities should not (1) foreclose release of the site for possible unrestricted use, (2) result in significant environmental impact beyond that previously analyzed and assumed for the Aerotest Radiography and Research Reactor, or (3) result in there no longer being reasonable assurance that adequate funds will be available for decommissioning. Further, you must conduct the activities safely in accordance with all applicable requirements.
You may choose to apply for an amendment to your license to a possession-only status prior to the start of decommissioning. Upon approval of an amendment application, the NRC issues a possession-only license amendment to a research reactor that has ceased reactor operations.
Obtaining a possession-only license amendment provides regulatory relief from those license requirements applicable only to operating research reactors. NRC handles possession-only license amendment applications in the same manner as other license amendment applications.
The regulations state that within two years following permanent cessation of operations, and in no case later than one year prior to expiration of the operating license, you must make an application for license termination. The application for termination of a license must be accompanied or preceded by a proposed decommissioning plan (10 CFR 50.82(b)(1)). However, given the current licensing authority for the reactor based on timely submission of your request for license renewal, the NRC staff would expect you to submit your application on an agreed upon schedule.
Decommissioning projects must be planned and executed in compliance with the dose based release criteria given in 10 CFR Part 20, Subpart E. The basic steps in the decommissioning of research reactors include:
Permanent shut down Inform the NRC, in writing, of your decision to permanently cease reactor operations and decommission your reactor.
Fuel removal Fuel removal is not considered part of decommissioning and is conducted under your reactor license.
Possession-only License Amendment (POA)
The POA removes the authority to operate the reactor. You may also request to amend your technical specifications (TS) to remove those that are no longer applicable to a shutdown reactor. Upon the removal of special nuclear material, you may request an amendment to reduce or eliminate certain provisions of the physical security plan of the license for the Aerotest Radiography and Research Reactor..
Submission of Decommissioning Plan (Supplement to Safety Analysis Report)
See NUREG 1537, Part 1, Chapter 17 for guidance and for more extensive decommissioning guidance, see NUREG 1757.
NRC Review Upon receipt of a proposed decommissioning plan, the NRC, in accordance with 10 CFR 20.1405 and 10 CFR 50.82(b)(5), will publish a notice of proposed action regarding the decommissioning plan in the Federal Register. The NRC will review the proposed decommissioning plan in the same manner that a license amendment application is reviewed.
Decommissioning License Amendment Issuance The NRC will issue a license amendment approving the plan subject to such conditions and limitations that NRC deems appropriate and necessary. The approved decommissioning plan will be a supplement to the safety analysis report or equivalent.
The NRC will place a notice of approval of the decommissioning plan in the Federal Register.
Decommissioning Activities Decommissioning activities are carried out in accordance with the approved plan. The NRC will inspect activities to ensure compliance with the plan.
Final Survey The key to a successful decommissioning project is advance planning of all activities with full consideration of the applicable criteria. The surveys should be based on the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) methodology.
Unless the license is being terminated under restricted conditions (10 CFR 20.1403),
radiological criteria must be derived based on the 25 mrem/yr dose limit specified in 10 CFR 20.1402 for unrestricted release of the site.
Confirmatory Survey The NRC will independently assess whether the terminal radiation survey meets the release criteria.
License Termination The NRC will terminate the license when the decommissioning has been performed in accordance with the approved decommissioning plan and the terminal radiation survey and associated documentation demonstrates that the facility and site are suitable for release in accordance with the criteria for decommissioning in 10 CFR Part 20, Subpart E.
Also, the requirements in 10 CFR 50.82(b)(1)(ii) and (b)(1)(iii) state that decommissioning activities should be completed without significant delay unless prevented by factors beyond the licensee's control, such as the inability to remove fuel from the facility.
Should you have any questions concerning these matters, please do not hesitate to call me at 301-415-1127.
Sincerely,
/LTran for RA/
Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-228 cc: Please see next page
Aerotest Operations, Inc.
Docket No. 50-228 cc:
Sandy Warren, General Manager Aerotest Operations, Inc.
3455 Fostoria Way San Ramon, CA 94583 California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814 Radiologic Health Branch P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611
S. Warren Final Survey The key to a successful decommissioning project is advance planning of all activities with full consideration of the applicable criteria. The surveys should be based on the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) methodology.
Unless the license is being terminated under restricted conditions (10 CFR 20.1403),
radiological criteria must be derived based on the 25 mrem/yr dose limit specified in 10 CFR 20.1402 for unrestricted release of the site.
Confirmatory Survey The NRC will independently assess whether the terminal radiation survey meets the release criteria.
License Termination The NRC will terminate the license when the decommissioning has been performed in accordance with the approved decommissioning plan and the terminal radiation survey and associated documentation demonstrates that the facility and site are suitable for release in accordance with the criteria for decommissioning in 10 CFR 20, Subpart E.
Also, the requirements in 10 CFR 50.82(b)(1)(ii) and (b)(1)(iii) state that decommissioning activities should be completed without significant delay unless prevented by factors beyond the licensee's control, such as the inability to remove fuel from the facility.
Should you have any questions concerning these matters, please do not hesitate to call me at 301-415-1127.
Sincerely,
/LTran for RA/
Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-228 cc: Please see next page DISTRIBUTION:
PUBLIC PRLB r/f RidsOgcRp RidsNrrDpr RidsNrrDprPrta GLappert RidsNrrDprPrtb AAdams CMontgomery RidsFsmeOd JHickman ADAMS ACCESSION NO.: ML103410207 TEMPLATE NO.: NRR-106 OFFICE PRLB:PM PRLB:PM PRLB:LA OGC PRLB:BC PRLB:PM NAME CMontgomery AAdams GLappert SUttal JQuichocho AAdams DATE 12/27/2010 12/27/10 12/27/2010 1/31/11 2/1/11 2/2/11 OFFICIAL RECORD COPY