ML20133J964
| ML20133J964 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 06/03/2020 |
| From: | Jack Parrott Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Murray S GE-Hitachi Nuclear Energy Americas |
| Parrott J | |
| References | |
| Download: ML20133J964 (3) | |
Text
June 3, 2020 Scott P. Murray, Manager Facility Licensing GE Hitachi Nuclear Energy 3901 Castle Hayne Road Wilmington, NC 28402
SUBJECT:
GE HITACHI REQUEST FOR PRIOR APPROVAL OF LOWERING THE DECOMMISSIONING FUNDING PLAN COST ESTIMATE AMOUNT FOR THE GE TEST REACTOR AT THE VALLECITOS NUCLEAR CENTER -
Dear Mr. Murray:
By letter dated March 6, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20066J983), GE Hitachi Nuclear Energy (GEH) submitted an updated site-specific decommissioning cost estimate (DCE) and decommissioning funding plan (DFP), pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.75, for the shutdown GE Test Reactor (GETR) at the GEH Vallecitos Nuclear Center (VNC). The submittal described that the update had resulted in a lower DCE for GETR due primarily to lower waste inventories and disposal costs.
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this updated DCE and DFP. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the submittal has any readily apparent information insufficiencies in its characterization of the regulatory requirements or of the basis for the DCE and DFP.
The submittal requested prior approval by the NRC to allow lowering the financial assurance surety bond amount based on this updated DCE. For Part 50 licensees, there is not a requirement to get approval from the NRC to provide a lower DCE upon which to base the amount of funds in the DFP. However, consistent with Section 50.75(f)(4), the submittal should consider, among other things, an up-to-date assessment of the major factors that could affect planning for decommissioning including information on site-specific factors which could affect decommissioning planning and cost.
The NRC staff has reviewed your submittal and concluded that it did not provide technical information in sufficient detail to enable the staff to complete its detailed review and make an independent assessment regarding the acceptability of the proposed DCE in terms of regulatory requirements. Specifically, the DCE states (in Section 2.1) that the reactor facility consists of a reactor enclosure and its ventilation system, a cooling tower, demineralizer, tank farm, and contaminated piping connecting these components, but that only activation and fission product contamination remains and is contained in the reactor building. Section 5.0 states that with respect to subsurface material containing residual radioactivity, there are no known areas of
confirmed soil or groundwater contamination associated with licensed activities covered by the cost estimate.
However, NRC staff review of the updated site-specific DCE for GETR indicates that the basis for the DCE does not consider all of the potential decommissioning liabilities associated with the GETR. Specifically, the DCE only considers the decommissioning of the GETR reactor building itself but not the associated system, structures and components and site land areas outside the reactor building that supported the operation of GETR and are likely radioactively contaminated such that they will require decontamination and/or disposal as radioactive waste.
The basis upon which NRC staff make this observation is contained in the letter from GEH to NRC dated March 25, 2020 (ADAMS Accession No. ML20086K769), where GEH submitted the annual reports for the deactivated reactors at the VNC including the GETR. The GETR annual report includes a site map entitled GETR Site Map that show an area of elevated dose readings outside of the reactor building but within the licensed foot print of the GETR. This area is known to have buried underground and above ground storage tanks. The DCE for the GETR does not appear to factor the decommissioning of the potential residual contamination in this area into the DCE.
Therefore, NRC is requesting that before the DCE for GETR is lowered, that the updated DCE be supplemented to include an estimate to decommission the areas under the GETR license that are outside of the GETR reactor building, and that the supplemented DCE be submitted to the NRC before sufficiency of the DCE and DFP can be considered.
The information requested and associated time frame in this letter were discussed with Scott Murray of your staff on June 3, 2020.
If you have any questions, please call me at (301) 415-6634 or e-mail at Jack.Parrott@nrc.gov.
Sincerely, Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs, Office of Nuclear Material Safety and Safeguards Docket No. 50-70 License No. TR-1 cc:
GE Hitachi shutdown reactor service list.
- by e-mail OFFICE NMSS/DUWP NMSS/DUWP NMSS/REFS NMSS/DUWP NAME J. Parrott B. Watson*
F. Miller*
J. Parrott DATE 05/12/2020 05/12/2020 05/21/2020 06/03/2020