ML103550284
| ML103550284 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 12/30/2010 |
| From: | Ryder C NRC/NMSS/FCSS/FCLD/FMB |
| To: | Peter Habighorst NRC/NMSS/FCSS/FCLD/FMB |
| Chris Ryder NMSS/FCSS/FMB 301-492-3189 | |
| References | |
| Download: ML103550284 (5) | |
Text
December 30, 2010 MEMORANDUM TO:
Peter J. Habighorst, Chief Fuel Manufacturing Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards FROM:
Christopher Ryder, Project Manager /RA/
Fuel Manufacturing Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards
SUBJECT:
DECEMBER 6, 2010, CONFERENCE CALL
SUMMARY
GENERAL ELECTRIC HITACHI VALLECITOS NUCLEAR CENTER A conference call was held on December 6, 2010, to discuss the details of two letters about deficiencies in the September 30, 2010, renewal application and the July 2, 2009, decommissioning funding plan and cost estimate.
A summary of the conversation is enclosed. The summary contains no proprietary or classified information.
Docket No.70-754 License No. SNM-960
Enclosure:
Conference Call Summary CONTACT: Christopher Ryder, NMSS/FCSS 301-492-3189
MEMORANDUM TO:
Peter J. Habighorst, Chief Fuel Manufacturing Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards FROM:
Christopher Ryder, Project Manager /RA/
Fuel Manufacturing Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards
SUBJECT:
DECEMBER 6, 2010, CONFERENCE CALL
SUMMARY
GENERAL ELECTRIC HITACHI VALLECITOS NUCLEAR CENTER A conference call was held on December 6, 2010, to discuss the details of two letters about deficiencies in the September 30, 2010, renewal application and the July 2, 2009, decommissioning funding plan and cost estimate.
A summary of the conversation is enclosed. The summary contains no proprietary or classified information.
Docket No.70-754 License No. SNM-960
Enclosure:
Conference Call Summary CONTACT: Christopher Ryder, NMSS/FCSS 301-492-3189 DISTRIBUTION:
FMB r/f ML103550284 OFFICE FMB FMB FMB NAME CRyder LAllen PHabighorst DATE 12/21/10 12/21/10 12/30/10 OFFICIAL RECORD COPY
CONFERENCE CALL
SUMMARY
GE HITACHI DEFICIENCIES IN LICENSE RENEWAL APPLICATION AND DECOMMISSIONING FUNDING PLAN AND COST ESTIMATE Date and Time: December 6, 2010, at 1:00 P.M. (Eastern Time)
Participants from the U.S. Nuclear Regulatory Commission (NRC):
Alan Frasier, Acting Branch Chief, Uranium Enrichment Branch, Division of Fuel Cycle Safety, and Safeguards (FCSS), Office of Nuclear Material Safety and Safeguards (NMSS)
Christopher Ryder, Licensing Project Manager, NMSS/FCSS/FFLD Alex Murray, Sr. Chemical Processing Engineer, NMSS/FCSS/FFLD Tyrone Naquin, Health Physicist, NMSS/FCSS/FFLD Roman Przygodzki, Office of Federal and State Materials and Environmental Management Programs, Division of Waste Management and Environmental Protection, Decommissioning and Uranium Recovery Licensing Directorate Participants From General Electric Hitachi (GEH):
Scott Murray, Licensing and Liabilities COE Patricia Campbell, Vice President, Washington Regulatory Affairs James Ross, Nuclear Licensing, GEH Nuclear David Turner, Manager, Vallecitos Nuclear Center Donald Krauss, Regulatory Compliance and EHS, Vallecitos Nuclear Center Robert Lillge, ES&H Project Manager Earl Saito, Acting Senior Vice President, Advanced Fuel Programs Charles Vaughan, Consultant Discussion:
The purpose of the conference call was to discuss details of two letters (References 1 and 2) sent to the licensee where deficiencies in the renewal application (Reference 3) and the decommissioning funding plan and cost estimate (Reference 4) were outlined.
The staff reviewed the information requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 70. Requirements for the contents of an application In §70.22(a)(7) and (8) are stated. The staff emphasized the words application and describe. Describe was defined as a discourse intended to give an image of something. §70.22(a)(7) and (8) give examples of the information that is required; the staff emphasized the word examples and that the list was not all inclusive. The information in the application must be sufficient to allow the staff to meet
§70.23(a)(3) and (4), which states that the proposed equipment, facility, and procedures are adequate to protect health and minimize danger to life and property.
The staff made general comments about the September 30 submittal (Reference 3). The submittal lacks information to perform a technical review. The application is general, with a paucity of specific information. The application has insufficient information both to develop
2 Requests for Additional Information (RAIs) in a single round, as is typically practiced, and then make a safety determination.
The staff stated that they need a basis for making licensing decisions and that the basis must be kept current. As stated in previous discussions with GEH, changes can be addressed in several ways, such as by making bounding statements (e.g., no more than, at least), and with a change process similar to that in §70.72. GEH stated that the licensing basis is kept current through the NRC inspection process.
GEH suggested that details be addressed through RAIs; the answers to the RAIs would be used to write the Safety Evaluation Report, but not be incorporated into the license application. The staff stated that RAIs are to clarify submitted information and address minor deficiencies, not to provide basic information that is missing from an application.
GEH participates believe that many of the questions stem from a lack of appreciation about the facility. GEH inquired about the reviewers visiting the site during the acceptance review. Many of their questions may be answered by seeing the facility. The staff said that the process is to have a site visit during the technical review to reduce the number of RAIs.
Similar to the license renewal application, the decommissioning fund plan and cost estimate (Reference 4) also lacks detail to evaluate the cost estimates. Guidance for the staff to do so is given In Reference 5. Key assumptions are not evident, such as the cost being based on the use of an independent third-party contractor. Methods for decontamination and decommis-sioning are not described. Labors costs are not broken down by tasks. The means to adjust the cost estimates for inflation are not specified. GEH asked if the NUREG-1557 method is the only acceptable method. The staff replied that the guidance specifies the information needed to assess the cost estimate.
References:
- 1. Letter to D. W. Turner, Manager, Vallecitos Nuclear Center, from B. W. Smith, Acting Deputy Director, Fuel Facility Licensing Directorate, Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards, NRC, to September 30, 2010, Renewal Application For Special Nuclear Materials License SNM-960 (TAC NO. L33042), ADAMS Accession Number ML10313000540.
- 2. Letter to S. Murray, GE Hitachi, from B. Smith, NRC, Updated Decommissioning Closure Plan And Cost Estimate: GE Hitachi Vallecitos Facility, November 18, 2010. ADAMS Accession Number ML103080149.
- 3. Letter from David W. Turner, Manager, Vallecitos Nuclear Center, to Director, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Renewal of Materials License SNM-960, September 30, 2010. ADAMS Accession Number ML1027402791.
3
- 4. Letter From S. Murray, GE-Hitachi, to M. Baker, NRC, and M. Mendonca, NRC, Updated Decommissioning Closure Plan and Cost Estimate - GE Vallecitos Facility, July 2, 2009.
ADAMS Accession Number ML091870358.
- 5. U.S. NRC, Consolidated NMSS Decommissioning Guidance: Financial Assurance, Recordkeeping, and Timeliness, NUREG-1757, Vol. 3, September 2003. ADAMS Accession Number ML032471471.