ML20195B838
| ML20195B838 | |
| Person / Time | |
|---|---|
| Site: | 07003085 |
| Issue date: | 10/13/1998 |
| From: | Rosenthal P AFFILIATION NOT ASSIGNED |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20195B760 | List: |
| References | |
| R98-042, R98-42, NUDOCS 9811160293 | |
| Download: ML20195B838 (3) | |
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,BWX Technologies, Inc.
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Habcock & Wh.ca. a Uc"Jermott comaay rio. Don m 6s t)nchbg VA 245061165 (8041522 6000 October 13,1998 R98 042 j
Mr. John W. N. Hickey, Chief Low Level Waste and Decommissioning SNM-2001 Docket No. 70-3085 Projects Branch Division of Waste Management U. S. Nuclear Regulator 3 Commission Washington, D. C.
20555
Dear Mr. Hickey:
RE: f%RKS SIIALLOW LAND DISPOS AL AREA (SidMJ
Reference:
(a) NRC Letter (J.W.N. Hickey) to BWXT (P.R. Rosenthal), dated August 3,1998.
(b) DWXT letter R98-039 (P.R. Rosenthal) to NRC (D.A. Orlando), dated July 9, 1998.
(t:) NRC letter (J.W.N. Hickey') to BWXT (P.R. Rosenthal), dated May 11,1998.
Dear Mi. Hici:
ey:
This is in re.ponse to your letter of Reference (a) and concerns BWXT's license amendment s
request, Reference (b). The license amendment of Reference (b), wlico appivved, would authorize the submittal of a Decommissioning Plan for the SLDA by December 6,2000. In summary, your letter of Reference (a) requests that BWXT provide justification for submittal of a Decommissioning Plan for thc St.D A heyond the 12 month timeframe required by 10CFR70.38.
On June 16, 1998, representatives of DWXT and ARCO met with the NRC statT to dixuas technical issues associated with developing a Decommissioning Plan for the SLDA, the NRC's License Termination Rule (10C1'R20 Subpart K), and its impact en the decommissioning of the
$LDA. Prior to the submittal of Reference (b), members of the ST.DA Project Management Team (PMT) prepared a milestone schedule for the preparation of the SLDA Decommissioning Plan utilizing guidance provided by the NRC, Reference (c), and information gained during our meeting of June 16, 1998.
The milestone schedule reflects that the time required to prepare a decommissioning plan in the case of the SLDA is significantly impa.c by three elements:
- 1. Performance of an Altemative Analysis
- 2. Development of proposed Institutional Controls
- 3. Performance of a Public Participation Program 9811160293 981110 PDR ADOCK 07003085 C
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The alternative analysis includes evaluation. of the vanous attematnes for tbc Sii.DA. This element of the decommissioning plan will build upon analyses previously submitted to the NRC and will also include an attemative suggested by the NRC. In addition, an analysis will be performed of an
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altemative proposed by the Pennsylvania Department of Environmental Pmtection during our meeting of June 16, 1998. De alternatives analyses report will address the criteria contained in 10CFR20, Subpart E. The PMT cstimates that the alternative analysis will take approximately one year to complete.
b.
The milestone schedule allocates six memhs time to identify and make provisions for institutional controls as described by 10CFR20.1403(b) and (e). Please note that the institutional controls cannot be completely identified until aner the attemativet analysis has been completed and the preferred alternative has been selected.
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As you know the PMT has been providing information to the public and c.
seeking public advice since the start of the project and continues with this course. The PMT has scheduled six months for the public participation program as described by 10CFR20.1403(d). In the case of the SLDA, we believe that six months time to establish and convene a site specific Advisory Board (SSAB), allows the SSAB time to adopt a charter and operating procedures, provide adequate notice and hold public meetings, evaluate public comments, provide advice to BWXT and ARCO, and allow for evaluation /inco poration of the advice received, to be the minimum necessary. Please note that seeking public advice on institutional controls cannot begin until the proposed institutional controls have been developed.
While there are other elements of the decommissioning plan that cannot be properly completed until the attemative analysis has been completed, the elements discussed above present the greatest time constraints.
Since the SLDA presents no immediate thrcut to the health and safety of the public, approval of an attemate schedule for submittal of a decommissioning plan presents no undue risk to the public health and safety. In addition, BWX l and ARCU believe that it would be in the public interest to allow sufficient time to complete the alternatives analysis and other elements of the decommissioning plan as required by 10CFR20.1403.
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In conclusion: BWXT requests that the amendment request of Reference (b) he approved under the i
provisions of 10CFR70.38 (g)(2). It'you need any additional infontation concerning this request.
l.
please contact the undersigned.
Sincerely, B&W SF.RVICES, INC.
G.RL AA e
Philip R. Rosenthal Senior Project Manager l
- Cc: K. B. Schoen - ARCO 4
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