ML20205C322

Amend 1 to License SNM-2001,for Bwx Technologies,Inc, Deleting Condition 14(a) & Replacing Condition with Listed Condition Re Decommissioning Plan

ML20205C322
Person / Time
Site:	07003085
Issue date:	03/22/1999
From:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20205C320	List: ML20205C314 ML20205C322
References
NUDOCS 9904010156
Download: ML20205C322 (2)

Text

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l NRC Form 374A u S. NUCLEAR REGULATORY COMMISSION OF I PAGE PAGES I +84 ue:nu number I

, SNM-2001 I E l MATERIALS LICENSE pocket or Reference number E I ,

SUPPLEMENTARY SHEET 070-3085 B l I

Amendment No.1 l i i i E I N I E

, 11. The licensee shall plan all work activities to keep radiation doses to workers as low as is reasonably y

achievable (ALARA) sufficient to meet the intent of 10 CFR 20.1101(b) through the use of R I administrative procedures or engineering controls to limit exposure and effluents during handling of 8 contaminated materials.

l l l E I 12. The release of equipment or packages from the controlled areas for unrestricted use shall be in E accordance with the criteria in " Guidelines for Decontamination of Facilities and Equipment Prior to l

Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear l

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l Materials" dated April 1993.

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13. The licensee shall institute crit,icality safety controls over materials removed from the waste trenches l y J g to restrict the quantity of plutonium and uranium-235 to a safe quantit9in any area. A safe quantity E I is defined as 350 grams U-235,200 grams plutonium, or any combinatio.n of uranium-235 and F I

l plutonium in accordance with the equation ams U-235 + ams Pu is equal to or less than 1.

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! 14. Schedule for Decom'nIissioning Site $ } )  ? (@; n l A. The licensee shall submit a Site Decommissioning Plan by December'6/2000.

l p g B. The licensee shall submit a Decommis'sio'ning Fu_ndirig Plan (DFP) in accordance with 10 CFR H

1. 70.25(e), including an appropriate financialinstrument in accordance with 70.25(f) and covering E the estimated costs of dedommissioning at"the time the SDP is submitted.

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( 15. A. The licensee shall provide a Letter'of Credit (LOC)ik favor of the NRC by a qualified bank

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R 4 (LOC Bank) in the amount of ten million dollars ($.10,000,000) within 10 days from the issuance l

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of this license. '4 /q g The licensee shall maintain an appropriate financial assurance instrument for y

N gl, 4 decommissioning. This in'strument shall be updated in accoidance with Condition 148 and E l

g maintained thereafter to cover the anticipated remaining cost of decommissioning until completion of decommissioning and termination of this license.

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$ FOR THE U.S. NUCLEAR REGULATORY COMMISSION i ,

4 D:te: March 22, 1999 By: f0RIGINAL SIGNED BY: 1 l l John W. N. Hickey, Chief I q Low-Level Waste and Decommissioning i Projects Branch j Division of Waste Management lq Office of Nuclear Material Safety 4 I

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! I MATERIALS LICENSE Focket or Reference number i 11 1

• SUPPLEMENTARY SHEET 070-3085 >

I E l Amendment No.1 l

I i 11. The licensee shall plan all work activities to keep radiation doses to workers as low as is reasonably >M I achievable (ALARA) sufficient to meet the intent of 10 CFR 20.1101(b) through the use of P I

administrative procedures or engineering controls to limit exposure and effluents during handling of l

g contaminated materials.

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i f 4 12. The release of equipment or packages from the controlled areas for unrestricted use shall be in accordance with the criteria in " Guidelines for Decontamination of Facilities and Equipment Prior to jy l l Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Materials" dated April 1993.

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l g 13.

,, O RIe-The licensee shail institute criticality safety controls over materials removed from the waste trenches l

E I to restrict the quantity of plutoniurh and uranium-235 to a safe' quantity in any area. A safe quantity W is defined as 350 grams U-235,'200 grams plutonium, or any conibination of uranium-235 and l

y plutonium in accordance with the equation ams U-235 + ams Pu is eq0'al to or less than 1. p l l

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14. Schedule for Decommissioning Siteg Ei .

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I The licensee $ shall submit . 'l l a Site .iDecommissioning) 3 " Plan'by[ December e 2 l

l B. The licensee shall submit ~a Decoryimis_si6ning g FUndin}; Plan (DFP) y 1 70.25(e), including an app,ropriale finaqcialir s E I

l the estimated Q ~7% ccIsts t.'-i l/ of decoromissioningl!dt tlme tiie SDP is submitted.

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i 15. A. The licensee shahfprovide a Eetfe.'bf Credlit (LOC)~irifayb[of the is N

I (LOC Bank) in the a' mount of ten million dollars ($10,000,000) wit?.110 days from the h I ,

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issuance of this licerise:h -

The licensee shall maintairi an appropriate financial assura6ce instrument for h g i decommissioning. This instrument shall be updated in accordance with Condition 14B and

^ g l maintained thereafter to cover the' anticipated ren'ainin'g i cost of decommissioning until q completion of decommissioning and termination of this license.

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I I FOR THE U.S. NUCLEAR REGULATORY COMMISSION N

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N Date: March 22. 1999 By .

l l John W. N. Hickey, Chief l q Low-Level Waste and Decom issioning l il Projects Branch l Division of Waste Management g Office of Nuclear Material Safety  ;

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' 07 00 95 TE 13:12 FAI 804 92: M67 BkSI ESH&u d inu o BWX Technoiogies, Inc.

sabcock & wkox. a ucDermou company saw services, Inc.

. P o. Box 11165 July 9,1998 W*}*" '* 2'508 "65 R98-039 SNM-2001 Docket No. 70-3085 Mr. Dominick A. Orlando, Project Manager Low Level Waste and Decommissioning Pro,1ects Branch MC T8F37 Division of Waste Management

• U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Orlando:

RE: Parks Shallow Land Disnosal Area (SLDAl

Reference:

(a) DWXT letter R98-039 (P.R. Rosenthal) to NRC (D.A. Orlando),

dated June 10,1998 It is hereby requested that license SNM-2001 be amended as follows.

1. Delete license condition 14 A in its entirety.

2. Add a new license condition 14.A to read: "The licensee shall submit a Site Decommissioning Plan by December 6,2000.

Please be reminded that this action is not intended to be inconsistent with the licensee's position set furth in the above icfenenced letter in regard to tiv: inapplicability of the license ternunation rule, which position we continue to maintain.

If you have any questions concerning this request please conta:t the undersigned.

Sincerely, f

Dlf htAv Philip R. Ro9enthal Senior Project Manager cc:

K. B. Schoen - ARCO J. R. Lewis W WQ l ? S&

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. '07.09/98 TH1' 13:12 FAI 804 522 6667 BwSI ESil&Q 2002 s

, BWX iachnologies, Inc.

_ Babcock & Wlcox. a W0ermott company B&W services. Inc.

R0. Box 11165 July 9,1998 g g d551165 R98-039 SNM-2001 Docket No. 70-3085 Mr. Dominick A. Orlando, Project Manager Low Level Waste and Decommissioning Projects tiranch MC T8F37 Division of Waste Management U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Orlando:

RE: Parks Shallow Land Disnosal Area (SLDA1

Reference:

(a) DWXT letter R98-039 (P.R. Rosenthal) to NRC (D.A. Orlando),

dated June 10,1998 It is hereby requested that license SNM-2001 be amended as follows.

1. Delete license condition 14.A in its entirety. l

2. Add a new license condition 14.A to read: "The licensee shall subrrdt a Site Decommissioning Plan by December 6,2000.

Please be reminded that this action is not intended to be inconsistent with the licensee's position set furth in the above neferenced letter in regard to the inapplicability of the license termination rule, which position we continue to maintain.

If you have any questions conceming this request please contact the undersigned.

Sincerely, Dlf h1Av

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f so l Philip R. Rosenthal Senior Project Manager cc:

K. B. Schoen- ARCO J. R. Lewis

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P BWX Technologies, Inc. B&W services, Inc.

sbcock & Whos. a voermott company

• r.o. Com 11165 tynchburg. VA 245061165 (804i522 6000 October 13,1998 R98-042 Mr. John W. N. Mickey, Chief Low Level Waste and Decommissioning SNM-2001 Projects Branch Docket No. 70-3085 Division of Waste Management U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Hickey:

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RE: PARKS SIIALLOW i.AND DISPOSAL AREA (SLDA)

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.

(c) NRC letter (J.W.N. Hickey) to BWXT (P.R. Rosenthal), dated May 11,1998.

Dear Mr. Hickey:

This is in response to your letter of Reference (a) and concerns BWXT's license amendment request, Reference (b). The license amendment of Reference (b), wlien uppioved, 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 the St.D A beyond the 12 month timeframe required by 10CFR70.38.

01: June 16,1998, representatives of DWXT and ARCO met with the NRC stalT to discuss technical issues associated with developing a Decommissioning Plan for the SLDA, the NRC's ,

License Termination Rule (10CFR20 Subpart E), and its impact on the decommissioning of the I St.DA. Prior to the submittal of Reference (b), members of the SLDA 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 icformation gained during our meeting of June 16, 1998. The milestone schedule reflects that the time required to prepare a l decommissioning plan in the case of the SLDA is significantly impacted by three elements:

1. Performance of an Altemative Analysit )

2. Development of proposed Institutional Controls

3. Perfvimance of a Public Participation Program f

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a. The altemative analysis includes evaluations of the vanous attematnes for the Si 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 altemative proposed by the Pennsylvania Department of Environmental Protection during our meeting of June 16, 1998. The altematives analyses report will address the criteria contained in 10CFR20, Subpart E. He PMT cstimates that the alternative analysis will take approximately one year to i complete.

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b. The milestone schedule allocates six mondis 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 after the altematives nnalytig has been completed and the preferred altcmative has been selected. I

c. As you know the PMT has been providing information to the public and seeking public advice since the start of the pmject and continues with this course. The PMT has scheduled six months for the public participation program as described by '0CFR20.1403(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 pub!!c meetings, evaluate public comments, provide advice to BWXT and ARCO, and allow for evaluation / incorporation of the advice received, to be the minimum necessary. Please note that seeking public advice on instientional controls cannot begin until the pmposed 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 Itme constraints.

Since the SLD A presents no immediate thrcut to the health and safety of the public, approval of an alternate schedule for submittal of a decommissioning plan presents no undue risk to the public health and safety. In addition, BWX 1 and ARCU believe that it would be in the public interest to allow sufficient time to completc 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 l provisions of 10CFR70.38 (g)(2). If you need any additional information conceming this request.

please contact the undersigned.

Sincerely, B&W SF.RVICES, INC. i G.R b AD- y Philip R. Rosenthal Senior Project Manager l Cc: K. B. Schoen ARCO l

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1 BWX Technologies, Inc.

Babcock & Wdcox. a McDermott company B&W Services. Inc.

P.o. Box 11165 Lynchburg. VA 24506-1165 (804) 522-6000 January 19,1999 R99-044 Mr. Dominick A. Orlando, Project Manager Low Level Waste and Decommissioning SNM-2001 Projects Branch MC T8F37 Docket No. 70-3085 Division of Waste Management U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Orlando:

l RE: Parks Shallow Land Disposal Area (SLDA)

Reference:

(a) BWXT letter R98-039 (P. R. Rosenthal) to NRC (D. A. Orlando),

dated July 9,1998 (b) BWXT letter R98-042 (P. R. Rosenthal) to NRC (J. W. N. Hickey), i dated October 13,1998 I

Dear Mr. Orlando:

During our meeting of December 2,1998 with the staffof the Nuclear Regulatory Commission, BWXT & ARCO agreed to provide the NRC with a schedule for the development of a decommissioning plan for the SLDA which included the critical path. Accordingly, enclosed please find four copies of the " ARCO Parks SLDA - Preliminary Draft Schedule" Prior to the development of the critical path schedule the SLDA Project Management Team (PMT) reviewed the activities necessary to develop the decommissioning plan in an effort to improve upon the .

rubmittal date. While the enclosed schedule may reflect schedule changes for some activities, these changes in total will not effect the date for submittal of the decommissioning plan as requested by References (a) and (b). BWXT & ARCO believe that it would be in the best interest ,

of all parties to submit the plan as early as possible and in that regard the PMT will, during the I course of plan preparation, look for ways to improve upon the submittal date.  ;

Also, during our meeting on December 2,1998 I believe you met Robin Bullock of ARCO Environmental Remediation. Ms. Bullock is ARCO's designated Project Manager to replace Ms. Kathleen Schoen who has left the project. It would be appreciated if you would please add Ms. Bullock to distribution for all correspondence related to the SLDA. Ms. Bullock's address is:

q 0060 O/M

F, Robin J. Bullock Senior Environmertal Manager 307 East Park Avenue Suite 400 Anaconda, Montana 59711 If you have any questions concerning the enclosed schedule, please do not hesitate to contact me.

Sincerely,- ,

24Ly4 auxW .

Philip R. Rosenthal Senior Project Manager.

Enclosure:

ARCO PARKS SLDA, Preliminary Schedule (Decommissioning Plan),

Revised December 17,1998 cc:

T. J. Jackson - NRC Region I w/ encl.

J. J. Matviya - PA DEP w/ enc!.

C. Scaillaba - Cong. Murtha Staff w/ encl.

R. J. Bullock - ARCO wo/ encl.

T. Boston - JEG wo/ encl.

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