ML20119A872
| ML20119A872 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 05/08/2020 |
| From: | Jacob Zimmerman NRC/NMSS/DFM/FFLB |
| To: | Murray S GE Hitachi Nuclear Energy |
| Siurano-Perez O | |
| References | |
| EPID L-2020-DFA-0002 | |
| Download: ML20119A872 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 8, 2020 Mr. Scott P. Murray Manager, Facility Licensing GE Hitachi Nuclear Energy 3901 Castle Hayne Road P.O. Box780 Wilmington, NC 28402
SUBJECT:
GENERAL ELECTRIC-HITACHI: ACCEPTANCE REVIEW AND REQUEST FOR SUPPLEMENTAL INFORMATION, UPDATED DECOMMISSIONING FUNDING PLAN FOR THE VALLECITOS NUCLEAR CENTER - ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2020-DFA-0002
Dear Mr. Murray:
By letter dated March 6, 2020 (Agencywide Documents Access and Management System
[ADAMS] Number ML20066J977), General Electric-Hitachi (GEH) provided an updated decommissioning funding plan for the Vallecitos Nuclear Center.
The U.S. Nuclear Regulatory Commission (NRC) staff performed an acceptance review of your application to determine if it contains sufficient technical information to allow the NRC staff to conduct further technical review. Based on the acceptance review of your submittal, the NRC staff has determined that additional technical information is needed to proceed with a detailed technical review. As such, the NRC staff is declining to accept the submittal until we receive GEHs responses to the enclosed request for supplemental information (RSI) describing the specific information that is needed to proceed with the detailed technical review.
The response to the RSI should be provided within 30 business days from the date of this letter.
The NRC staff held a teleconference on May 5, 2020 to discuss the RSI and ensure mutual understanding. Your submittal was assigned Enterprise Project Identifier L-2020-DFA-0002.
After we receive a response to the RSIs, we will provide an anticipated completion date and work hours estimate for our formal review.
In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. The ADAMS database is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
S. Murray 2 If you have any questions concerning this letter, please contact Mr. Osiris Siurano-Perez, Project Manager, at 301-415-7827, or via e-mail at Osiris.Siurano-Perez@nrc.gov.
Sincerely, Jacob I. Zimmerman, Branch Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 70-0754 License No. SNM-960
Enclosure:
Request for Supplemental Information
ML20119A872 OFFICE DFM/FFLB/PM DFM/FFLB/LA REFS/FAB/BC DFM/FFLB/BC NAME OSiurano ELee FMiller JIZimmerman DATE 05/05/2020 05/05/2020 05/07/2020 05/08/2020 OFFICIAL RECORD COPY REQUEST FOR SUPPLEMENTAL INFORMATION GENERAL ELECTRIC-HITACHI REVIEW OF VALLECITOS NUCLEAR CENTER DECOMMISSIONING FUNDING PLAN CAC/EPID: 000224/07000754/L-2020-DFA-0002 By letter dated March 6, 2020 (Agencywide Documents Access and Management System (ADAMS) Number ML20066J977), General Electric-Hitachi provided an updated decommissioning funding plan (DFP) for the Vallecitos Nuclear Center. The following information is requested by the U.S. Nuclear Regulatory Commission (NRC) staff to proceed with a detailed technical review.
- 1. Decrease in Cost Estimate Issue:
The 2020 cost estimate reflects a decrease of approximately $7,400,000.00 compared to the 2017 decommissioning costs estimate (DCE) without an explanation.
Regulatory Basis:
Title 10 of the Code of Federal Regulations (10 CFR), Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(ii), requires that, Each decommissioning funding plan must be submitted for review and approval and must contain identification of and justification for using the key assumptions contained in the DCE Request:
Please provide a general discussion on why decommissioning costs are being reduced. If an analysis has been performed to calculate/demonstrate such reductions, please provide a copy of such analysis for NRC staff review.
- 2. Criticality Accident Alarm System (CAAS)
Issue:
During the acceptance review, the staff found that the discussion on the CAAS in Section 4.4 of the updated DFP has been deleted.
Regulatory Basis:
The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(ii), requires that, Each decommissioning funding plan must be submitted for review and approval and must contain.identification of and justification for using the key assumptions contained in the DCE Request:
Please explain why this discussion has been deleted. If the system is no longer needed, please explain why.
Enclosure
- 3. Interim Emergency Response Plan Issue:
The discussion on the interim emergency response plan in Section 4.4 of the updated DFP has been deleted.
Regulatory Basis:
The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(ii), requires that, Each decommissioning funding plan must be submitted for review and approval and must contain.identification of and justification for using the key assumptions contained in the DCE Request:
Please explain why this discussion has been deleted. If the system is no longer needed, please clarify why.
- 4. Wastes Associated with the Wilmington, NC, Facility, the Vallecitos Boiling Water Reactor, and the Morris, IL, Facility Issue:
In Chapter 6 of the updated DFP, GEH has deleted the discussion regarding wastes associated with the Wilmington, NC, facility, the Vallecitos Boiling Water Reactor, and the Morris, IL, facility, and does not provide an explanation on the whereabouts of these wastes, nor how these transfers potentially affect the DCE. This is confusing since it appears that these wastes were considered for determining the total decommissioning costs for the Vallecitos Nuclear Center (VNC) under the previous DFP.
Regulatory Basis:
The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(i), requires that, Each decommissioning funding plan must be submitted for review and approval and must contain.a detailed cost estimate for decommissioning, in an amount reflecting:
(A) The cost of an independent contractor to perform all decommissioning activities; (B) The cost of meeting the 10 CFR 20.1402 criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of 10 CFR 20.1403, the cost estimate may be based on meeting the 10 CFR 20.1403 criteria; (C) The volume of onsite subsurface material containing residual radioactivity that will require remediation; and (D) An adequate contingency factor.
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The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(ii), requires that, Each decommissioning funding plan must be submitted for review and approval and must contain.identification of and justification for using the key assumptions contained in the DCE Request:
Please clarify whether these wastes were previously stored at the VNC. Explain if the VNC disposed of these wastes or moved them back to these other facilities, and if these wastes include waste from the Hillside Storage facility (i.e., the bunker). Please explain how the transfer impact the DCE.
- 5. Material Covered Under the California License vs. Material Covered Under the NRC License Issue:
The submittal does not provide clear information on what material is covered under the State of California (CA) license and what is being covered under the NRC license. When was the last time the financial assurance amount was updated and approved for the activities regulated under the CA license? Also, clarify if there is material not covered by financial assurance either by CA or the NRC.
Regulatory Basis:
The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(ii), requires that, Each decommissioning funding plan must be submitted for review and approval and must contain.identification of and justification for using the key assumptions contained in the DCE Request:
Please identify what material is covered under the CA license and what material is covered under the NRC license.
- 6. Cost Adjustments, Basis of Cost Estimate, and Disposition of Inventory at Time of Decommissioning Issue:
The 2020 DFP does not include: (1) basis of cost adjustments to reflect current dollars, (2) numbers and dimensions of facility components that are the basis of the cost estimate, and (3) how the disposition of inventory at the time of decommissioning is incorporated in the DCE. Similar RAIs came up during the 2017 review and GEH supplemented the 2017 DFP (ML17087A171).
Regulatory Basis:
The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(i)(A), require thatEach decommissioning funding plan must be submitted for review and approval and must containa detailed cost estimate 2
for decommissioning, in an amount reflectingthe cost of an independent contractor to perform all decommissioning activities.
The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(ii), requires that, Each decommissioning funding plan must be submitted for review and approval and must contain.identification of and justification for using the key assumptions contained in the DCE Request:
Please provide the basis of cost adjustments reflecting costs in current dollars, the numbers and dimensions of facility components that constitute the basis of the cost estimate, and how the disposition of inventory at the time of decommissioning is incorporated in the DCE.
- 7. Breakdown of Cost Elements Issue:
The 2020 DFP does not provide an adequate breakdown of the cost elements included under the categories of Equipment and Supplies, Offsite Laboratory Costs, Travel & Per Diem, Utilities, Phone, Shared Services, and NRC Fees, in Table 1.1.,
Decommissioning Costs Estimate Summary. To address a similar RAI in 2014, GEH submitted additional detail about each of these cost elements, including the variables used to calculate each cost element (e.g., number of hours to perform an activity, unit costs associated with activity) and an explanation of the basis for the cost element methodology used to calculate the cost (e.g., data source). With the exception of Travel & Per Diem costs, the costs in these categories have decreased from the 2017 DFP to the 2020 DFP.
Regulatory Basis The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(1)(ii), requires that, Each decommissioning funding plan must be submitted for review and approval and must contain.identification of and justification for using the key assumptions contained in the DCE Request:
In order to assess whether the cost elements have been appropriately updated, GEH needs to provide further detail on the basis of each of these costs (e.g., by providing an updated version of Exhibit 2 from GEHs August 1, 2014, supplemental information (ML14213A276)).
- 8. Sources for Unit Costs Issue:
The 2020 DFP does not include sources for most unit costs (e.g., worker hourly rates, container costs, container loading costs, transportation costs, and burial costs). To address a similar RAI in 2014, GEH submitted in the August 1, 2014, supplemental information, a description of the basis for the unit costs relied on in the DFP (e.g., actual costs of contract personnel).
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Regulatory Basis The regulations in 10 CFR, Section 70.25, Financial assurance and recordkeeping for decommissioning, Paragraph (e)(2), requires that, At the time of license renewal and at intervals not to exceed 3 years, the decommissioning funding plan must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination Request:
In order to assess the acceptability of the unit costs relied on in the 2020 DFP, GEH needs to provide a description of the source of all unit costs used in the 2020 DFP.
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