ML13330B006
| ML13330B006 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 12/05/2013 |
| From: | Geoffrey Wertz Research and Test Reactors Licensing Branch |
| To: | Skoda R Texas A&M Univ |
| Wertz G, 301-415-0893 | |
| References | |
| TAC ME1584 | |
| Download: ML13330B006 (7) | |
Text
December 5, 2013 Dr. Radek Skoda, Director Nuclear Science Center Texas Engineering Experiment Station 1095 Nuclear Science Road MS 3575 College Station, TX 77843
SUBJECT:
TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM - REQUEST FOR ADDITIONAL INFORMATION RE: UPDATED FINANCIAL INFORMATION FOR LICENSE RENEWAL (TAC NO. ME1584)
Dear Dr. Skoda:
The U.S. Nuclear Regulatory Commission is continuing its review of your application for the renewal of Facility Operating License No. R-83, dated February 27, 2003 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102920025), and supplemented, in part, by letters dated August 30, 2010 (ADAMS Accession No. ML102510154), and December 9, 2010 (ADAMS Accession No. ML103470278), for the Texas Engineering Experiment Station/Texas A&M University System, Nuclear Science Center, TRIGA-type research reactor. During the course of our review, some of the information provided by your letters dated August 30, and December 9, 2010, has become outdated and needs to reflect the current financial status of your facility. Please provide responses to the enclosed request for additional information (RAI) within 30 days of the date of this letter.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, Written communications.
Information included in your response that is considered sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Any information related to security should be submitted in accordance with 10 CFR 73.21, Protection of Safeguards Information:
Performance requirements. Following receipt of the additional information, we will continue our evaluation of your renewal request.
R. Skoda If you have any question, please contact me at (301) 415-0893 or by electronic mail at:
Geoffrey.wertz@nrc.gov.
Sincerely,
/RA by Alexander Adams for/
Geoffrey A. Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-128
Enclosure:
RAI cc: See next page
- concurrence via email NRR-088 OFFICE NRR/DPR/PRLB:LRPM*
NRR/DPR/PLB:LA NRR/DIRS/IFIB:BC NRR/DPR/PRLB:BC NRR/DPR/PRLB:LRPM*
NAME GWertz PBlechman AKock AAdams GWertz (AAdams for)
DATE 12/03/2013 12/03/2013 12/05/2013 12/04/2013 12/05/2013
Texas A&M University Docket No. 50-128 cc:
Mayor, City of College Station P.O. Box Drawer 9960 College Station, TX 77840-3575 Governors Budget and Planning Office P.O. Box 13561 Austin, TX 78711 Texas A&M University System ATTN: Dr. Dimitris C. Lagoudas, Interim Facility Director Nuclear Science Center Texas Engineering Experiment Station 1095 Nuclear Science Road MS 3575 College Station, Texas 77843 Radiation Program Officer Bureau of Radiation Control Dept. Of State Health Services Division for Regulatory Services 1100 West 49th Street, MC 2828 Austin, TX 78756-3189 Technical Advisor Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087, MS 122 Austin, TX 78711-3087 Test, Research and Training Reactor Newsletter 202 Nuclear Sciences Center University of Florida Gainesville, FL 32611
Enclosure REQUEST FOR ADDITIONAL INFORMATION REGARDING UPDATED FINANCIAL QUALIFICATIONS FOR THE LICENSE RENEWAL FOR THE TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM NUCLEAR SCIENCE CENTER RESEARCH REACTOR LICENSE NO. R-83; DOCKET NO. 50-128 As required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.33(f)(2),
[a]pplicants to renew or extend the term of an operating license for a nonpower reactor shall include the financial information that is required in an application for an initial license. To comply with this requirement, please provide an update to the supplemental information provided by your letters dated August 30 and December 9, 2010, for the proposed renewal of the facility operating license for the Texas Engineering Experiment Station/Texas A&M University System (TEES/TAMUS), Nuclear Science Center (NSC), TRIGA-type research reactor (NSCR). In some cases, the responses provided in the August 30, and December 9, 2010, letters may not have changed (e.g., RAIs 4.(b), 4.(c) and 4.(d)). In that case, please indicate in your response no change, no additional information is necessary, and the NRC staff will consider your response provided in the August 30, and December 9, 2010, submittals to remain current.
- 1.
The U.S. Nuclear Regulatory Commission (NRC) staff will analyze the financial statements for the current year, which are required under 10 CFR 50.71(b), to determine if the applicant is financially qualified to operate the NSCR. Since TEES/TAMUSs financial statements are now out of date, please provide a copy of the latest financial statements.
- 2.
Pursuant to 10 CFR 50.33(f)(2), the applicant shall submit estimates for total annual operating costs for each of the first five years of operations of the facility. Since the information included in the application is now out of date, please provide the following additional information:
(a)
The estimated operating costs for each for each of the fiscal years (FY) 2015 through FY 2019 (the first five-year period after the projected license renewal date).
(b)
The NSCs primary source(s) of funding to cover the operating costs for the above FY.
- 3.
The application indicates that the cost to decommission the NSCR will be $8,938,000 in 2010 dollars, based on information provided in NUREG-1307, Rev. 13, Report on Waste Burial Charges, NUREG/CR-1756, Technology, Safety, and Costs of Decommissioning Reference Nuclear Research and Test Reactors, and the BLS
Inflation Calculator for 2010. Since certain information is needed regarding the eventual decommissioning of the NSC facility, the NRC staff requests that TEES/TAMUS update the application to include the following information:
(a)
Pursuant to 10 CFR 50.75(d)(2), develop a current cost estimate in 2014 dollars to meet the NRCs radiological release criteria for decommissioning the NSCR for unrestricted use; describe the basis on how the cost estimate was developed; show costs in current dollar amounts, specifically broken down into the categories of labor, waste disposal, other items (such as energy, equipment, and supplies); and a contingency factor of at least 25 percent.
(b)
Provide a statement of the decommissioning method to be used (e.g., DECON, or other method).
(c)
To comply with 10 CFR 50.75(d)(2)(iii), the applicant must provide a description of the means of adjusting the cost estimate and associated funding level periodically over the life of the facility. Since the application does not provide this information, please update the application to include a full description of the method to be used as the means of adjusting the cost estimate and associated funding level periodically over the life of the facility.
(d)
Provide a numerical example showing how the 2014 decommissioning cost estimate will be updated periodically in the future.
- 4.
The application states that TEES/TAMUS is a state agency and will be able to obtain the funding for decommissioning when necessary to decommission the facility. Based on this statement, the NRC staff infers that TEES/TAMUS intends to use a statement of intent (SOI) to provide decommissioning funding assurance. Where the applicant intends to use a SOI as the method to provide decommissioning funding assurance, as provided for by 10 CFR 50.75(e)(1)(iv), the NRC staff must find that the applicant is a Federal, State, or local government licensee. To make this finding, the applicant must state that it is a State government organization and that the decommissioning funding obligations of the applicant are backed by the State government, and also provide corroborating documentation. Further, the applicant must provide documentation verifying that the signator of the SOI is authorized to execute said document that binds the applicant. This document may be a governing body resolution, management directives, or other form that provides an equivalent level of assurance. As the application does not include all of the above information, please submit the following:
(a)
An updated SOI, which includes: the date of submittal of the SOI; the current (2014) cost estimate for decommissioning; a statement that funds for decommissioning will be obtained when necessary; typed name and title of the signator, and original signature of the signator; and the signators oath or affirmation attesting to the information.
(b)
Documentation that corroborates the statement in the application that TEES/TAMUS is a State agency and State of Texas government licensee under 10 CFR 50.75(e)(2)(iv).
(c)
A statement as to whether the decommissioning funding obligations for the NSCR (through TEES/TAMUS) are backed by the State of Texas government.
The application must also present information that corroborates this statement.
For example, the documentation may be a copy of or complete citation to a state statute that expressly provides that the obligations, or at least the decommissioning funding obligations, of the applicant are obligations backed or supported by the full faith and credit of the State of Texas, or an opinion of the applicants General Counsel with citations to statutes, regulations, and/or case law that the obligations, or at least with respect to the decommissioning funding obligations, of the applicant are obligations backed or supported by the full faith and credit of the State of Texas.
(d)
Documentation verifying that the signator of the SOI is authorized to execute such a document that binds the applicant financially. For example, provide a copy of the TEES/TAMUS governing board or equivalent resolution that shows that the signator of the SOI has been authorized by TEES/TAMUS to bind TEES/TAMUS financially, at least with respect to funding the decommissioning of the NSCR, or provide a copy of an official State of Texas delegation of authority showing that the signator of the SOI is authorized to bind TEES/TAMUS financially, at least with respect to funding the decommissioning of the NSCR.