ML14107A320
| ML14107A320 | |
| Person / Time | |
|---|---|
| Site: | Pennsylvania State University, 07000113 |
| Issue date: | 04/22/2014 |
| From: | Chang L NRC/FSME/DWMEP/DURLD/SPB |
| To: | Rachel Johnson NRC/NMSS/FCSS/FCLD/FMB |
| Augustus R | |
| References | |
| Download: ML14107A320 (4) | |
Text
April 22, 2014 MEMORANDUM TO: Robert Johnson, Chief Fuel Manufacturing Branch Fuel Facility Licensing Directorate Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards FROM: Lydia Chang, Chief /RA/
Special Projects Branch Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION INPUT WITH RESPECT TO PENNSYLVANIA STATE UNIVERSITY SELF-GUARANTEE On December 20, 2013, Pennsylvania State University submitted its annual certification of its 2014 self-guarantee for its U.S. Nuclear Regulatory Commission (NRC) licenses, which can be accessed through the Agencywide Document Access and Management Systems Accession No. ML14013A265. On January 16, 2014, a Technical Assistance Request was submitted to the Special Projects Branch (SPB) by the Fuel Manufacturing Branch in the Office of Nuclear Materials Safety and Safeguards. The SPB staff has reviewed the submittal and recommends the following request for additional information as outlined in the enclosure.
Docket Nos.: 050-0005, 070-0113 License Nos.: R-2, SNM-95 CONTACT: Reginald Augustus, FSME/DWMEP (301) 415-0165
MEMORANDUM TO: Robert Johnson, Chief Fuel Manufacturing Branch Fuel Facility Licensing Directorate Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards FROM: Lydia Chang, Chief Special Projects Branch Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION INPUT WITH RESPECT TO PENNSYLVANIA STATE UNIVERSITY SELF-GUARANTEE On December 20, 2013, Pennsylvania State University submitted its annual certification of its 2014 self-guarantee for its U.S. Nuclear Regulatory Commission (NRC) licenses, which can be accessed through the Agencywide Document Access and Management System Accession No. ML14013A265. On January 16, 2014, a Technical Assistance Request was submitted to the Special Projects Branch (SPB) by the Fuel Manufacturing Branch in the Office of Nuclear Materials Safety and Safeguards. The SPB staff has reviewed the submittal and recommends the following request for additional information as outlined in the enclosure.
Docket Nos.: 050-0005, 070-0113 License Nos.: R-2, SNM-95 CONTACT: Reginald Augustus, FSME/DWMEP (301) 415-0165 Distribution: CRyder ML14107A320 OFFICE DWMEP/SPB DWMEP/SPB DWMEP/SPB NAME RAugustus SAchten LChang DATE 4/17/14 4/18/14 4/22/14 OFFICAL RECORD COPY
Request for Additional Information (RAI) Input for Pennsylvania State Universitys Self-Guarantee for its Breazeale Nuclear Reactor and Special Nuclear Material Licenses RAI (1)
Description of Deficiency As currently presented, the self-guarantee (SG) submission does not include a comparison of the data used by the licensee in the financial test with the amounts in the independently audited year-end financial statements, an evaluation of the licensees off-balance sheet transactions by the licensees independent certified public accountant, or bond rating verification by accountant.
Basis for Request 10 CFR Part 30 Appendix E.II.(C)(1) states in part that [t]he licensees independent certified public accountant must compare the data used by the licensee in the financial test, which is derived from the independently audited, year-end financial statements for the latest fiscal year, with the amounts in such financial statement. The accountant must evaluate the licensees off-balance sheet transactions and provide an opinion whether those transactions could materially adversely affect the licensees ability to pay for decommissioning costs. The accountant must verify that a bond rating, if used to demonstrate passage of the financial test, meets the requirements of Section II of this appendix. The SG submission does not include the comparison, evaluation of the off-balance sheet transactions, or bond rating verification.
Formulation of RAI Staff recommends that the licensee provide supplemental documentation to include a statement from the independent certified public accountant of a comparison of the data used in the financial test with the independently audited year-end financial statements, an evaluation by its independent certified public accountant of the off-balance sheet transactions, and verification of the bond rating by its independent certified public accountant.
RAI (2)
Description of Deficiency As currently presented, the self-guarantee agreement does not include the express waivers of notice in paragraphs 17 and 21 of the recommended self-guarantee agreement model language.
Basis for Request NUREG-1757, Vol. 3, Rev. 1, Appendix A.9.12 Model Self-Guarantee Agreement recommends in part, that the model language used by the licensee should include express waivers of notice of acceptance of the self-guarantee by NRC and amendments or modifications of the decommissioning requirements. The submission omits the recommended language in its submission.
Enclosure
2 Formulation of RAI Staff recommends that the licensee revise the self-guarantee agreement to include the express waiver of notice language recommended in NUREG-1757, Vol. 3, Rev. 1, Appendix A.9.12.