ML18030A800
| ML18030A800 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/19/2018 |
| From: | Framatome |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| TJT:18:010 E10-08-010 | |
| Download: ML18030A800 (6) | |
Text
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 10 Decommissioning E10-08-010 Version 2.1 Page i EHS&L Document SNM-1227 - Chapter 10 Decommissioning Nature of Changes Item Paragraph Description Justification
- 1.
Entire Document Changed AREVA Inc. to Framatome Inc.
Company Name Change
- 2.
- 3.
- 4.
- 5.
- 6.
- 7.
- 8.
- 9.
- 10.
List Below any Documents, including Forms & Operator Aids which must be issued concurrently with this document revision:
This Document contains a total of 6 pages excluding the signature page.
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 10 Decommissioning E10-08-010 Version 2.1 Page ii DOCUMENT REVIEW/APPROVAL/DELETION CHECKLIST All new and/or revised procedures shall be approved by the change author, cognizant manager(s) of areas affected by the changes, and by applicable manager(s) of any function that approved the previous revision of the document unless responsibility for such approval has been transferred to another organization. Also, the procedure shall be approved by manager(s) of functional organizations that provide technical reviews with the exception of the Training Department. Finally, Document Control shall verify that the required approvals have been properly obtained and that any documents that must be issued concurrently are ready to be issued.
Document Reviews Document Approvals Purpose/Function of Review Specify Reviewer(s)
(Optional except for change author)
(Check all that apply)
Title of Approver (Check all that Apply)
Document Control (Automatic)
Document Control (Automatic)
Change Author CD Manning Author Independent Technical Review Operability Review(s)
Mgr, Richland Operations(1)
Conversion Mgr, Uranium Conversion &
Recovery Operations(1)
Recovery Ceramics Mgr, Ceramic Operations(1)
Rods Mgr, Rods & Bundles(1)
Bundles Components Mgr, Component Fabrication(1)
Maintenance Review Mgr, Maintenance(1)
Lab Review Mgr, Production Support(1)
Transportation Mgr, Ops Strategy & Supply Chain EHS&L Review(s)
Mgr, EHS&L(2)
Criticality Mgr, Nuclear Safety(2)
Radiation Protection Safety Mgr, Safety(2)
Security/Emergency Prep.
Mgr, Security & Emergency Preparedness(2)
Fire Safety MC&A Mgr, Licensing & Compliance(2)
Transportation Environmental CD Manning Mechanics Richland Review Mgr, Mechanics Richland Mechanics Lynchburg Review Thermal-Hydraulics Richland Review Mgr, Thermal-Hydraulics Richland Thermal-Mechanics Richland Review Mgr, Materials & Therm-Mechs Project & Reliability Review Mgr, Project & Reliability Eng.
Quality Review Mgr, Richland Site Quality Purchasing Review Mgr, PP&CPC Others:
Mgr, Richland Site/Other Document Control Richland Records Management Training & Employee Dev.: (3)
Training & Employee Dev.
(1)Note: If approvals include 2 or more product center managers, the Operations manager can be substituted for the applicable product center managers.
(2)Note: If approvals include 2 or more EHS&L functional managers, the EHS&L manager can be substituted for the applicable EHS&L functional managers.
(3)Note: Training department review is required for all procedures that require or affect a Learning Plan and if additional training materials or curriculum must be revised before issuing procedure.
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 10 Decommissioning E10-08-010 Version 2.1 Page iii 23371 (Rev. 001, 01/09/2018)
EHS&L CHANGE IMPACT EVALUATION FORM The scope and content of this document have been determined by EHS&L to not impact the safety disciplines checked below. Future revisions do not require review by those EHS&L component(s) unless the scope changes such that a previously excluded safety discipline may be impacted.
Criticality Radiation Protection Safety/Security Emergency Preparedness MC&A Transportation Environmental DOCUMENT VERSION:
EHS&L REVIEW COMPONENT:
EVALUATION DATE:
CHANGE EVALUATOR*:
2 ND PARTY APPROVAL*:
The scope and content of this document have been determined by EHS&L to not directly impact the safe handling of licensed materials (enriched uranium). Future revisions to this document do not require the 10CFR 70.72 change evaluation unless the scope of the document changes such that it directly impacts the handling of licensed materials.
DOCUMENT / ECN NO**:
E10-08-010 EVALUATION DATE:
1/19/18 CHANGE EVALUATOR:
CD Manning Does the change potentially impact Criticality Alarm System (CAS) coverage?
YES NO EVALUATION OF NRC PRE-APPROVAL:
IS NRC PRE-APPROVAL ( LICENSE AMENDMENT ) NEEDED?
Based on YES answer to any of five questions below.
Based on NO answer to all five questions below.
YES NO
- 1.
Does the change create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 (create high or intermediate consequence events) and that have not previously been described in Framatomes ISA Summary?
YES NO
- 2.
Does the change use new processes, technologies, or control systems for which Framatome has no prior experience?
YES NO
- 3.
Does the change remove, without at least an equivalent replacement of the safety function an item relied on for safety (IROFS) that is listed in the ISA Summary?
YES NO
- 4.
Does the change alter any item relied on for safety, listed in the ISA Summary, that is the sole item preventing or mitigating an accident sequence of high or intermediate consequences?
YES NO
- 5.
Does the change qualify as a change specifically prohibited by NRC regulation, order or license condition?
YES NO Evaluation of Actions Required PRIOR TO OR CONCURRENT with Change Implementation:
- 6.
Modification / Addition to CAS system or system coverage documentation YES NO
- 7.
Acquire NRC pre-approval (LICENSE AMENDMENT)
YES NO
- 8.
Conduct/modify ISA YES NO
- 9.
Modify /
update the following:
None Other ISA Database Red-Line Drawings/P&ID NCSA NCSS NCSP PHA RHA FHA ChHA Procedures Evaluation of Actions Required SUBSEQUENT TO Change Implementation:
- 10. Modify /
update the following:
None Other ISA Database AS-Built Drawings/P&ID NCSA NCSS NCSP PHA RHA FHA ChHA Procedures Justification Section for YES preceding Questions 1 - 8 or other for 9, 10: Being prepared as part of a License Amendment, however pre-approval of the amendment prior to issuing is not required.
(*)
Only required if one or more of the boxes to exclude a particular safety discipline review is checked.
(**)
If this form exists as a part of a document, the document number is not required.
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 10 Decommissioning E10-08-010 Version 2.1 Page iv
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 10 Decommissioning E10-08-010 Version 2.1 Page v Table of Contents 10.0 Decommissioning....................................................................................................... 10-1 10.1 Decommissioning Funding Plan (DFP)........................................................... 10-1 10.2 Decommissioning Cost Estimate..................................................................... 10-1 10.3 Decommissioning Financial Assurance........................................................... 10-1
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 10 Decommissioning E10-08-010 Version 2.1 Page 10-1 10.0 Decommissioning Framatome Inc. (Framatome) shall fulfill the requirements of 10 CFR 70.25, Financial Assurance and Recordkeeping for Decommissioning, by submittal of a decommissioning funding plan (DFP) to the U.S. Nuclear Regulatory Commission (NRC) and by the maintenance of records of information important to the decommissioning of the site until such time as the site is released for unrestricted use.
10.1 Decommissioning Funding Plan (DFP)
The DFP submitted to the NRC shall contain the elements called for in 10 CFR 70.25(e),
including a decommissioning cost estimate; a financial assurance mechanism; a means for adjusting the cost estimate and associated funding levels periodically over the life of the facility; and a certification that financial assurance has been provided in an amount that covers the current estimate for decommissioning. The DFP will address the decommissioning of facilities on the Richland, Washington site with potential for contamination with licensed materials.
Framatomes DFP is provided to the NRC as E06-04-007, Version 2.0, dated December 19, 2005, or as subsequently revised.
10.2 Decommissioning Cost Estimate The decommissioning cost estimate shall be presented in the DFP. The estimate shall include a facility description, estimated decommissioning costs (labor, non-labor, and contingency), and key underlying assumptions. Consistent with 10 CFR 70.25(e), the cost estimate will be reviewed and updated at an interval not to exceed three years.
10.3 Decommissioning Financial Assurance Financial assurance for decommissioning will be provided by a methodology authorized in 10 CFR 70.25(f). Framatome will provide the NRC with signed originals of the financial instruments obtained to satisfy the requirements of 10 CFR 70.25(f).