ML120200203
| ML120200203 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 01/20/2012 |
| From: | Traiforos S Research and Test Reactors Licensing Branch |
| To: | Jessie Quichocho Research and Test Reactors Licensing Branch |
| Traiforos S, 301-415-3965 | |
| References | |
| NRR-2011-001 | |
| Download: ML120200203 (7) | |
Text
January 20, 2012 MEMORANDUM TO:
Jessie Quichocho Branch Chief, RTR Licensing Branch Office of Nuclear Reactor Regulation FROM:
Spyros Traiforos
/RA/
Project Manager, RTR Licensing branch Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JANUARY 18, 2012, PUBLIC MEETING WITH AEROTEST OPERATIONS, INC., TO DISCUSS THE STATUS OF THE ITEMS IN THE CONFIRMATORY ACTION LETTER NO.
NRR-2011-001 On January 18, 2012, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Aerotest Operations, Inc., the licensee for the Aerotest Radiography and Research Reactor (ARRR), at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. A number of the attendees participated via conference call. The purpose of the meeting was to discuss the status of the items in the confirmatory action letter (CAL) No. NRR-2011-001.
The NRC staff discussed the communications which transpired between the NRC staff and the licensee since the CAL was issued on February 26, 2011. The NRC staff reviewed its understanding of the current commitments, as they were agreed upon by both the NRC staff and the licensee. Additionally, the NRC staff reviewed the applicable regulatory requirements for decommissioning activities as applicable to nonpower reactors.
Aerotest discussed the status of their divesture efforts which is part of the CAL. They stated that they have two offers from prospective buyers and a third offer is pending. They also stated that they expect to make a decision on the sale of the ARRR no later than the end of March 2012. They anticipate that an application for a license transfer would be submitted by the end of May 2012. Finally, they stated that in case they do not find a suitable buyer, then they will pursue decommissioning with on site storage by submitting to the NRC a decommissioning plan and possession only license amendment by May 2012. Aerotest did not provide any presentation material.
The licensee did not submit a decommissioning plan, a decommissioning funding plan, a fuel management plan, and a possession-only license amendment in conjunction with the decommissioning plan to the NRC on December 12, 2011, as had been agreed to in the CAL.
During the meeting, Aerotest requested guidance from the NRC before submitting the decommissioning plan. They received various decommissioning options from their contractor and wanted to determine which of those options, were agreeable to the NRC in meeting NRC policy, guidance, and requirements. The NRC staff discussed actions other nonpower facilities have taken to meet the regulatory requirements of 10 CFR 50.82(b). Specifically, the NRC staff discussed under certain circumstances the NRC regulations allows fuel to be stored onsite during certain portions of decommissioning using the safe storage (SAFSTOR) option at the site for a period of time before dismantlement activities are initiated. Aerotest acknowledged this was an option that their contractor had proposed.
Aerotest and the NRC staff discussed experience with storing fuel on site, and the possibility of other licensees accepting the Aerotest fuel for potential use or storage. The NRC staff provided answers to all of the licensees questions concerning decommissioning and fuel storage.
At the conclusion of the meeting Aerotest agreed to provide the NRC with their future plans to include milestones and deliverables as part of a CAL status report due on January 24, 2012.
Also NRC staff and Aerotest agreed to communicate further on a decommissioning plan as needed.
A list of attendees is provided as Enclosure 1. The NRC staff presentation to Aerotest and the public is provided in Enclosure 2.
Members of the public were in attendance. Public Meeting Feedback forms were provided but no feedback was received.
Please direct any inquiries to me at 301-415-3965, or spyros.traiforos@nrc.gov.
Docket No.: 50-228
Enclosures:
- 1. List of Attendees
- 2. Meeting Handouts Aerotest and the NRC staff discussed experience with storing fuel on site, and the possibility of other licensees accepting the Aerotest fuel for potential use or storage. The NRC staff provided answers to all of the licensees questions concerning decommissioning and fuel storage.
At the conclusion of the meeting Aerotest agreed to provide the NRC with their future plans to include milestones and deliverables as part of a CAL status report due on January 24, 2012.
Also NRC staff and Aerotest agreed to communicate further on a decommissioning plan as needed.
A list of attendees is provided as Enclosure 1. The NRC staff presentation to Aerotest and the public is provided in Enclosure 2.
Members of the public were in attendance. Public Meeting Feedback forms were provided but no feedback was received.
Please direct any inquiries to me at 301-415-3965, or spyros.traiforos@nrc.gov.
Docket No 50-228
Enclosures:
- 1. List of Attendees
- 2. Meeting Handouts DISTRIBUTION:
PUBLIC GLappert, NRR JQuichocho, NRR RTR r/f STraiforos, NRR RidsOgcRp Resource AAdams, NRR PMNS Resource JHickman, FSME RidsNrrDprPrta CSafford, OGC RidsNrrDprPrtb RNelson, NRR RidsNrrDpr Resource TMcGinty, NRR Accession Number: ML120200203 OFFICE NRR/PRLB NRR/PRLB NRR/PRLB NRR/PRLB NAME STraiforos GLappert CMH for JQuichocho STraiforos DATE 1/20/2012 1/20/2012 1/20/2012 1/20/2012 OFFICIAL RECORD COPY
ENCLOSURE 1 LIST OF ATTENDEES JANUARY 18, 2012, MEETING WITH AEROTEST OPERATIONS, INC.
TO DISCUSS THE STATUS OF THE ITEMS IN THE CONFIRMATORY ACTION LETTER NO. NRR-2011-01 Name Organization J. Quichocho U.S. NRC R. Nelson U.S. NRC J. Hickman U.S. NRC R.B. Haemer Pillsbury Winthrop Shaw Pittman D. Brisighella Aerotest/Autoliv J. Silberg Pillsbury M. Anderson Aerotest/Autoliv J. Ross GE Hitachi J. Lising U.S. NRC C. Montgomery U.S. NRC E. Britan Alston and Bird L. Tran U.S. NRC T. Fredrichs U.S. NRC D. Hardesty U.S. NRC S. Uttal U.S. NRC F. Naseer U.S. NRC A. Adams U.S. NRC J. Simpson U.S. NRC X. Yin U.S. NRC S. Traiforos U.S. NRC Participated by phone:
C. Safford U.S. NRC P. Torres U.S. NRC G. Wertz U.S. NRC
ENCLOSURE 2 Timeline of NRC - Aerotest Communications 2005: Licence renewal application.
October 15, 2010: Aerotest ceased operations except for operation needed for license compliance.
January 7, 2011: Letter from Aerotest on actions it has taken or will take.
February 26, 2011: NRC Confirmatory Action Letter (CAL) on actions from Aerotest letter dated January 7, 2011.
March 23, 2011: Aerotest response to NRC CAL providing clarifications, changes, deviations and completed actions.
May 24, 2011: NRC response to Aerotest letter dated March 23, 2011. Some changes to commitments were acceptable to the NRC, some were not.
June 14, 2011: Aerotest letter providing acceptable response to the NRC letter dated May 24, 2011, letter.
June to December 2011: Aerotest submitted biweekly letter reports.
November 29, 2011: Aerotest letter requesting guidance from the NRC before submitting the decommissioning plan. Aerotest stated that they expect a delay in submitting the decommissioning plan.
December 9, 2011: Conference call was initiated by the NRC, based also on the interest expressed by the licensee, to discuss above letter.
December 12, 2011: Aerotest letter. According to the licensee, based on the December 9, 2011, conference call, the decommissioning plan and the December 12, 2011, estimate for submitting the decommissioning plan needs to be revised.
December 27, 2011: NRC letter requesting a meeting with Aerotest to address the status of the commitments in the CAL.
NRCs Understanding of Aerotests Commitments The Aerotest commitments were formulated in the NRC Confirmatory Acton letter (CAL) of February 26, 2011. Aerotest proposed some changes to the commitments in their letter of March 23, 2011. The NRC agreed with some of the changes as stated in the NRC letter of May 24, 2011. Additional clarification was provided by Aerotest in their letter of June 14, 2011.
NRCs understanding of Aerotests commitments is as follows:
Cease operations as of October 15, 2010, except for testing, sampling, and fuel observations necessary to comply with the current reactor license.
Maintain staffing levels at the facility in accordance with current technical specifications.
Aerotest continues to negotiate with potential buyers of the Aerotest Radiography and Research Reactor (ARRR). Aerotest should submit at 14-day intervals to the NRC updates of these nagotiations.
Aerotest to submit a decommissioning plan no later than December 12, 2011, but the estimate may be revised in the future to reflect additional input from their contractor.
Develop a decommissioning funding plan in parallel with preparing the decommissioning plan.
Develop a fuel management plan and provide funding for the management of the fuel.
Aerotest will submit an application for a possession-only license amendment either in conjunction with submitting the decommissioning plan or within 30 days of when discussions with current potential buyers end, whichever occurs first.
Aerotest has no plans to commence research or N-ray work at ARRR.
Excerpts from 10 CFR 50.82(b) - Termination of License (b) For non-power reactor licensees--
(2) For decommissioning plans in which the major dismantlement activities are delayed by first placing the facility in storage, planning for these delayed activities may be less detailed.
Updated detailed plans must be submitted and approved prior to the start of these activities.
(3) For decommissioning plans that delay completion of decommissioning by including a period of storage or surveillance, the licensee shall provide that--
(i) Funds needed to complete decommissioning be placed into an account segregated from the licensee's assets and outside the licensee's administrative control during the storage or surveillance period, or a surety method or fund statement of intent be maintained in accordance with the criteria of § 50.75(e); and (ii) Means be included for adjusting cost estimates and associated funding levels over the storage or surveillance period.
(4) The proposed decommissioning plan must include--
(i) The choice of the alternative for decommissioning with a description of activities involved. An alternative is acceptable if it provides for completion of decommissioning without significant delay. Consideration will be given to an alternative which provides for delayed completion of decommissioning only when necessary to protect the public health and safety. Factors to be considered in evaluating an alternative which provides for delayed completion of decommissioning include unavailability of waste disposal capacity and other site-specific factors affecting the licensee's capability to carry out decommissioning, including the presence of other nuclear facilities at the site.
(v) A description of technical specifications, quality assurance provisions and physical security plan provisions in place during decommissioning.