ML20236X334
| ML20236X334 | |
| Person / Time | |
|---|---|
| Site: | 07003085 |
| Issue date: | 08/03/1998 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rosenthal P External (Affiliation Not Assigned) |
| References | |
| NUDOCS 9808070302 | |
| Download: ML20236X334 (3) | |
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UNITED STATES l
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NUCLEAR REGULATORY COMMISSION P
WASHINGTON, D.C. 20565-0001
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August 3, 1998 Mr. Philip Rosenthal, Senior Project Manager BWX Technologies, Inc.
P.O. Box 11165 Lynchburg, VA 24506-1165
Dear Mr Rosenthal:
I am writirg in response to your letter dated July 9,1998, requesting that the U.S. Nuclear Regulator) Commission (NRC) amend Special Nuclear Materials license SNM-2001 for BWX Technolog es' (BWXT) Shallow Land Disposal Area (SLDA) in Parks Township, PA.
In responst? to our guidance provided in my letter of May 11,1998, you requested that NRC delete condition 14a of SNM-2001, which requires BWXT to submit a decommissioning plan within six months of the publication of the NRC's Record of Decision (ROD) concerning the Environmental Impact Statement for the SLDA, and replace it with a requirement to submit a decommissioning plan for the SLDA by December 6,2000. In our May 11,1998, letter, NRC requested that BWXT submit this amendment request, because the requirement to submit the decommissioning plan after the ROD has been published is not consistent with the requirements in NRC's License Termination Rule.
As discussed below, NRC staff has reviewed your request and concluded that BWXT has not provided sufficient justification in the request to allow the staff to approve your proposed dates for submitting the decommissioning plan for the facility.
The regulations provide the NRC staff with guidance regarding what constitutes a reasonable time frame for the preparation and submittal of a decommissioning plan. NRC regulations at 10 CFR 70.38 require that licensees submit decommissioning plans for their facilities within 12
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months after cessation of operations. NRC notified BWXT on February 12,1998, and I
May 11,1998, of the need to submit a decommissioning plan, and the need to establish a date vl for submitting a decommissioning plan, for the SLDA. BWXT provided a date for submitting a decommissioning plan on July 9,1998. If BWXT's proposal had set a 12 month timeframe for submitting a decommissioning plan, the staff would have found the date to be acceptable without further justification.
g7 However, since BWXT's proposal is well beyond a 12 month timeframe, some specific justification is needed so that the NRC has a basis for reviewing your request. NRC regulations at 10 CFR 70.38(g)(2) state that NRC may approve alternate schedules for the submittal of a decommissioning plan if NRC determines that the alternate schedules are necessary to the effective conduct of the decommissioning operations, do not present undue risk from radiation to the public health cnd safety, and are otherwise in the public interest. As such, in order for l
NRC to approve a request for submittal of a decommissioning plan beyond a 12 month
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' timeframe, BWXT needs to demonstrate that your requested amendment is consistent with the i
criteria in Section 70.38(g)(2).
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9808070302 980803 PDR ADOCK 07003085 C
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August 3, 1998 P. Rosenthal.
If you have ahy questions concerning this letter, please contact Dominick Orlando of my staff, at 301-415-6749.
Sincerely,
[ original signed by:]
John W. N. Hickey, Chief Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety l
and Safeguards License No.: SNM-2001 Docke No.:
70-3085 cc: SLDA Distribution List DISTRIBUTION:
Central File LLDP r/f DWM r/f NMSS r/f RJohnson PUBLIC SGagner TMadden TJackson,RI MRoberts,RI
- SEE PREVIOUS CONCURRENCE DOCUMENT NAME: S:\\DWM\\LLDP\\DAO\\SLDAPDA.WPD OFC LLDP*
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OGCL LLDP DWM
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i NAME DOrlando JCopeland RNelson HN N e JHic' key MWeber r' ATE 07/16/98 07/16/98 07/16/98 S
Of/22/98 07/ :/98 (7/ 3 /98 OFFICIAL RECORD COPY I
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YES NO X ACNW: YES NO X~-
Delete file after distribution YES /
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