ML14121A517
| ML14121A517 | |
| Person / Time | |
|---|---|
| Site: | University of California - Irvine |
| Issue date: | 05/08/2014 |
| From: | Lising A Research and Test Reactors Licensing Branch |
| To: | Geoffrey Miller California State Univ |
| Lising A | |
| References | |
| TAC ME1579 | |
| Download: ML14121A517 (7) | |
Text
May 8, 2014 Dr. George E. Miller Department of Chemistry University of California, Irvine 326 Rowland Hall Irvine, CA 92697-2025
SUBJECT:
UNIVERSITY OF CALIFORNIA, IRVINE - REQUEST FOR ADDITIONAL INFORMATION RE: FINANCIAL UPDATE FOR LICENSE RENEWAL FOR THE UNIVERSITY OF CALIFORNIA, IRVINE NUCLEAR REACTOR FACILITY (TAC NO. ME1579)
Dear Dr. Miller:
The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of the University of California, Irvine (UCI, the licensee) application for the renewal of Facility Operating License No. R-116 for the UCI Nuclear Reactor Facility dated October 18, 1999 (a redacted version of the application is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System Accession No. ML083110112), as supplemented.
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 letter dated August 25, 2010 (ADAMS Accession No. ML102500270). Please provide your response to the enclosed request for additional information within 30 days from 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 license renewal request.
If you have any questions about this review, or if you need additional time to respond to this request; please contact me by telephone at 301-415-3841 or by electronic mail at Jason.Lising@nrc.gov Sincerely,
/RA/
A. Jason Lising, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-326 License No. R-116
Enclosure:
Request for Additional Information cc: See next page
University of California at Irvine Docket No. 50-326 cc:
Dr. Howard Gillman Executive Vice Chancellor and Provost 539 Aldrich Hall University of California, Irvine Irvine, CA 92697-2025 Dr. Reginald M. Penner, Chair Department of Chemistry University of California, Irvine Irvine, CA 92697-2025 Radiological Health Branch California Department of Public Health P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611
ML14121A517 NRR-088 OFFICE DPR/PRLB/PM DPR/PRLB/LA DPR/PRLB/BC DPR/PRLB/PM NAME JLising PBlechman AAdams JLising DATE 05/06/2014 05/06/2014 05/07/2014 05/08/2014 Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING FINANCIAL QUALIFICATIONS FOR THE LICENSE RENEWAL FOR UNIVERSITY OF CALIFORNIA-IRVINE NUCLEAR REACTOR FACILITY LICENSE NO. R-116 DOCKET NO. 50-326 The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of the University of California, Irvine (UCI, the licensee) application for the renewal of Facility Operating License No. R-116 for the UCI Nuclear Reactor Facility dated October 18, 1999 (a redacted version of the application is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System Accession No. ML083110112), as supplemented.
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 letter dated August 25, 2010 (ADAMS Accession No. ML102500270). In some cases, the responses provided in afore-mentioned letters may not have changed (e.g., requests for additional information 4.(b) and 4.(c)). In that case, please indicate in the response no change, no additional information is necessary, and the NRC staff will consider the response provided in the submittals to remain current.
- 1.
The NRC staff will analyze the financial statements for the current year, which are required by 10 CFR 50.71(b), to determine if the applicant is financially qualified to operate the UCI Nuclear Reactor Facility. Since UCIs financial statements included with the application are out of date, please provide a copy of the latest financial statements for the NRC staffs review.
- 2.
Pursuant to 10 CFR 50.33(f)(2), the regulation states that [t]he applicant shall submit estimates for total annual operating costs for each of the first five years of operation of the facility. Since the information included in the application is now out of date, please provide the following additional information:
(a)
Projected operating costs for the UCI Nuclear Reactor Facility for each of the fiscal years (FYs) 2015 thru 2019 (the first five year period after the projected license renewal).
(b)
Confirm that UCIs primary source of funding to cover the operating costs for the afore-mentioned FYs will be funding by an annual appropriation from the State of Californias budget as described in the application.
- 3.
The August 25, 2010, supplement (ADAMS Accession No. ML102500270) to the application, references a decommissioning cost estimate for the UCI Nuclear Reactor Facility of 2 million dollars (2011 dollars). In 10 CFR 50.75(d)(1), it states that
[e]ach non-power reactor applicant for or holder of an operating license for a production or utilization facility shall submit a decommissioning report as required by §50.33(k) of this part. Under 10 CFR 50.75(d)(2) the report must (i) [c]ontain a cost estimate for decommissioning the facility; (ii) [i]ndicate which method or methods described in paragraph (e) of this section as acceptable to the NRC will be used to provide funds for decommissioning; and (iii) [p]rovide a description of the means of adjusting the cost estimate and associated funding level periodically over the life of the facility.
The NRC staff needs the following additional information to complete its review of the UCI Nuclear Reactor Facility license renewal application, please provide the following:
(a)
A current decommissioning cost estimate in 2015 dollars for the UCI Nuclear Reactor Facility to meet the NRCs radiological release criteria for decommissioning the facility for unrestricted use, pursuant to 10 CFR 50.75(d)(2). Accordingly, describe the basis for how the cost estimate was developed, showing costs in current dollars, specifically broken down into the categories of labor, waste disposal, other items (e.g., energy, equipment, and supplies), and a 25 percent contingency factor.
(b)
State the decommissioning method to be used. If SAFSTOR is the proposed method, please state.
(c)
A description of the means of adjusting the cost estimate and associated funding level periodically over the life of the facility, to comply with 10 CFR 50.75(d)(2)(iii). Also, please provide a detailed numerical example showing how the 2015 cost estimate will be adjusted periodically in the future.
- 4.
The application includes a statement of intent (SOI) as the chosen method to provide decommissioning funding assurance for the UCI Nuclear Reactor Facility. If 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 signatory of the SOI is authorized to execute said document that binds UCI. This document may be a governing body resolution, management directives, or other form that provides an equivalent level of assurance.
Since the application does not include all of the above information, please submit the following:
(a)
An updated SOI which includes the current (2015 dollars) cost estimate for decommissioning; a statement that funds for decommissioning will be obtained when necessary; name and title of signatory; and the signatorys oath or affirmation attesting to the information.
(b)
Documentation that corroborates the statement in the application that UCI is a State agency and a State of California government licensee under 10 CFR 50.75(e)(2)(iv).
(c)
A statement as to whether the decommissioning funding obligations for UCI are backed by the State of California government. The application must also present documentation 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 backed or supported by the full faith and credit of the State of California, or an opinion of the applicants General Counsel with citations to statutes, regulations, and/or case law that the obligations, or at least those with respect to the decommissioning funding of the applicant are obligations backed or supported by the full faith and credit of the State of California.
(d)
Documentation verifying that the signatory of the SOI is authorized to execute such a document that binds the applicant financially. For example, provide a copy of UCIs governing board or equivalent resolution that shows that the signatory of the SOI has been authorized by UCI to bind UCI financially, at least with respect to funding the decommissioning of the UCI Nuclear Reactor Facility, or provide a copy of an official UCI delegation of authority showing that the signatory of the SOI is authorized to bind UCI financially, at least with respect to funding the decommissioning of the UCI Nuclear Reactor Facility.