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Category:Letter
MONTHYEARIR 05000264/20232012023-08-0101 August 2023 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2023201 - Cover Letter and Enclosure ML23062A1132023-02-28028 February 2023 Dow Chemical Co., Submittal of Annual Report for 2022 ML22284A0472022-10-0606 October 2022 Closure of Level 1 Finding for the Quad Cities Generating Station ML22062B6492022-05-24024 May 2022 Supplemental Information Needed for Acceptance of Proposed Alternative to Use ASME Code Case N-921 IR 05000264/20222012022-04-15015 April 2022 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Inspection Report 05000264/2022201 ML22080A0722022-03-11011 March 2022 Dow Chemical Company - Management Change ML22055A5772022-02-0404 February 2022 Dow Chemical Co., Submittal of Annual Report for 2021 ML21271A0952021-10-0404 October 2021 Dow Chemical Company Change of Facility Project Manager IR 05000264/20212022021-08-10010 August 2021 Dow Chemical Company U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2021202 IR 05000264/20212012021-05-27027 May 2021 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2021201 ML21153A1642021-05-26026 May 2021 Dow Chemical Company - Management Change Update ML21063A2492021-02-16016 February 2021 Dow Triga Research Reactor Annual Report - 2020 ML20295A4242020-11-16016 November 2020 Notification of Mailing Address Change Regarding Submittal of Fingerprint Cards ML20247J3712020-09-0303 September 2020 Examination Confirmation Letter No. 50-264/OL-21-01, Dow Chemical Company Reactor ML20062A1872020-02-24024 February 2020 Dow Chemical Co., Submittal of Annual Report ML19339F8002020-02-0606 February 2020 Dow Chemical Co., Notice of Consideration of Approval of Indirect License Transfer and Conforming Amendment and Opportunity for a Hearing and Petition for Leave to Intervene ML19330E2442019-11-22022 November 2019 Dow Chemical Co., Transmittal of Consent for an Indirect License Transfer IR 05000264/20192022019-10-30030 October 2019 Cover Letter - Dow Chemical Company - U.S. Nuclear Regulatory Commission Security Inspection Report No. 05000264/2019202 IR 05000264/20192012019-10-30030 October 2019 Dow Chemical Company Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2019201 ML19063A4972019-02-22022 February 2019 Annual Report for the Dow Triga Research Nuclear Reactor, Docket No. 50-264 ML18365A3552019-01-0808 January 2019 Dow Chemical Company - Change of Facility Back-Up Project Manager IR 05000264/20182012018-10-19019 October 2018 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Safety Inspection Report No. 05000264/2018201 ML18060A0792018-02-22022 February 2018 2017 Annual Report for the Dow Triga Research Reactor IR 05000264/20172012017-11-0808 November 2017 Dow Chemical Co., NRC Routine Inspection Report 05000264/2017201 ML17067A2792017-03-23023 March 2017 Dow Chemical Company - Non-Power Reactor Closeout of Generic Letter 2016-01, "Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools," for the Dow TRIGA Research Reactor, Docket No. 50-264 (CAC No. A11010) ML17061A5102017-02-24024 February 2017 Annual Report for the Dow Triga Research Nuclear Reactor IR 05000264/20162022016-09-16016 September 2016 Dow Chemical Company, NRC Security Related Inspection Report 05000264/2016202 IR 05000264/20162012016-09-14014 September 2016 Dow Chemical Company - NRC Routine Inspection Report 05000264/2016201, July 19-21, 2016 ML16166A4152016-06-13013 June 2016 the Dow Triga Research Reactor, Response to NRC Generic Letter 2016-01: Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools ML16068A1772016-02-29029 February 2016 Dow Triga Research Nuclear Reactor - Transmittal of Annual Report for 2015 ML15364A3732016-01-19019 January 2016 Dow Chemical Company TRIGA Research Reactor - Closure of Confirmatory Action Letter No. NRR-04-009 on Site-Specific Compensatory Measures Implementation Plan ML14290A4862015-06-0303 June 2015 Y020140127 - Withdrawal of Order EA-05-007, Order Imposing Additional Security Measures ML15051A3672015-02-17017 February 2015 Annual Report 2014 for the Dow Triga Research Nuclear Reactor IR 05000264/20142012014-09-15015 September 2014 IR 05000264/2014201 on August 26-28, 2014 at Dow Chemical Company -NRC Routine Inspection Report No. 50-264/2014-201 ML14202A3282014-07-23023 July 2014 Dow Chemical Company Review of the Surety Bond Increase Rider and Updated Standby Trust Agreement (TAC No. M79548) ML14129A2742014-05-27027 May 2014 Dow Chemical Company - Change of Facility Backup Project Manager ML14100A3492014-04-0909 April 2014 the Dow Chemical Co., Submittal of Responses to RAI Letter Dated 03/06/2014 and Dtrr Revised Technical Specifications ML14070A1792014-03-0707 March 2014 Dow Triga Research Reactor - Annual Report - 2013 ML14133A0182014-03-0707 March 2014 Dow Chemical Company Surety Bond Increase Rider and Updated Standby Trust Agreement Schedules (TAC M79548) ML14058B1342014-03-0606 March 2014 Dow Chemical Company Request for Additional Information Regarding Renewal of Facility Operating License No. R-108 for Dow Chemical Triga Research Reactor IR 05000264/20132012013-09-27027 September 2013 IR 05000264-13-201 on August 26-29, 2013 at Dow Chemical Company - NRC Routine Inspection Report ML13261A0262013-09-16016 September 2013 Letter from Dow Chemical Company Regarding Transmittal of Documents in Support of License Renewal ML13226A0702013-08-12012 August 2013 Rescission of Certain Security Orders Concerning Spent Nuclear Fuel in Transit ML13196A2992013-07-11011 July 2013 Dow Chemical Company Response to RAI Letter Dated June 26, 2013 and Dtrr Revised Technical Specifications ML13157A4122013-06-26026 June 2013 Dow Chemical Company - Request for Additional Information Regarding the Renewal of Facility Operating License No. R-108 for the Dow Chemical Triga Research Reactor ML13113A0012013-05-0606 May 2013 Dow Chemical Company - Letter to Licensee Notification of Supplemental Federal Register for Environmental Assessment Waste Confidence Rule ML13059A4592013-02-27027 February 2013 Dow Triga Research Reactor Annual Report - 2012 ML12226A4012012-08-10010 August 2012 the Dow Chemical Company - Amended Page 46 of the Revised Technical Specifications Dated June 11, 2012, in Support of License Renewal ML1208000322012-07-10010 July 2012 Dow Chemical Company - Letter to Licensee Availability of Environmental Assessment Federal Register Notice (Tac ME1595) ML12164A7842012-06-11011 June 2012 the Dow Chemical Company, Dtrr Revised Technical Specifications and Supplemental Information to the Dtrr Revised Response to RAI 41, Dated November 10, 2011, in Support of the License Renewal 2023-08-01
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-Aý The Dow Chemical Company Midland, Michigan 48667 Mr. Geoffrey Wertz Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
Subject:
Dow Chemical Company- Response to the Request for Additional Information for the renewed license of the TRIGA research reactor. License No. R-108; Docket No. 50-264 Enclosed is the response to phone conference Jan 28, 2011.
Should you have any questions or need additional information, please contact the undersigned at 989-638-6932.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 4, 2011 Melinda Krahenbuhl, Ph.D.
Director Dow TRIGA Research Reactor Subscribed and sworn to before me this day of April, 2011 Notary Pub i-c Notary P~b~ounty, Michigan SStaq L, McKeon My Commission Expires: NTARYK UaI.C, B'cCOUNT'Y, MICHIGAN AC *Nl,4ID.. .j- y, MICHIGAN LIVOMYMiS,, %'*JUNE 28, 2011 cc: Sandeep S. Dhingra, R&D Director - Analytical Sciences A u -
Response to the questions posed in the phone conference Jan. 28, 2011.
- 1. Provide a Chain of Command from Reactor to the CEO.
- a. Organization Chart all US Citizens with the exception of Andrew Liveris
,L I
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- 2. Provide Management Level at which budgetary decision is made and level of dollars.
Global Core R&D 2009 budget was 1.6 billion dollars.
0 Analytical Sciences 2009 budget was 50 million dollars. All budgetary decisions for the reactor are made at the Global Director, R&D level.
Reactor Facility budget projected for 2012 is $810,000.
- 3. Provide support information for decommissioning estimates.
A. Information from facilities used as a guide to estimate cost of decommissioning the DTRR in 2007. DTRR original estimate is bracketed by 1
other reactors of higher power and more diverse function. The DTRR is conservative for the function and size of the reactor.
Power Footprint/Usage Estimated cost Georgia 5 MW 3 stories $7,140,000 Tech Above ground (2001)
Concrete/steel/BORAL and lead shielding 8,000,000 Heavy water moderator and cooled actual cost Graphite thermal column University of 1.5 MW Prepared for shut down prior to $4,200,000 Illinois decommissioning (2007)
University of 2 MW + 2 reactors on site above ground $6,400,000 Virginia CAVILlER (2003)
University of 2 MW 3 stories $9,800,000 Michigan Above ground (2006)
Concrete/steel/BORAL and lead shielding Graphite thermal column DTRR 300kW Below ground installation no shielding, $5,000,000 no thermal column, no beam ports (2007)
B. Square footage, Power and Usage of the current facilities used for "benchmarking". Our current estimate is above the estimate on a $Slicensed power, indicating our estimate does not need to be adjusted.
Licensed power Estimated cost Purdue 1 kW Converted HEU $623,000 to LEU Penn State 2 MW Beam ports/ $12,000,000 above ground/
MURR 10MW Beam ports/ $49,000,000 above ground/
will use SAFE I Storage DTRR 300kW 1 $5,467,000 2
Decommissioning estimate vs Licensed power 50 30 + Research reactor 40
"*I m0[ DTRR 20 E
E 10 oU0- Linear (Research 0 reactor) 0 5000 10000 15000 Licensed power (kW)
C. Mathematical example will be changed for decommissioning estimate instead of surety bond.
As stated in the Response dated Dec. 7, 2010, "The cost estimate for decommissioning the DTRR will continue to be adjusted annually using the inflation factor as calculated in 4(d) of this response."
The inflation factor is based on the Implicit Price Deflators for Gross National Product (FINAL) which are published in July of each year. Since the decommission cost estimate was calculated prior to the annual GNP being published, the previous 2 and 3 year annual GNP figures published as of July in the previous year were used.
2007 Annual GNP Implicit Price Deflator is 106.215 and 2008 Annual GNP Implicit Price Deflator is 108.486 (as of July 31, 2009) - source is the Bureau of Economic Analysis, National Income and Product Accounts Table - Table 1.1.9. Implicit Price Deflators for Gross Domestic Product.
2010- 108.49 + 106.21 = 1.021 2011- 109.609 108.626 = 1.009 This inflation factor was used to inflate the decommission
$5,354,600 x 1.021 = $5,467,000
$5,467,000 x 1.009 = $5,516,000.
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