ML20237C232
| ML20237C232 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 08/19/1998 |
| From: | Racquel Powell NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Chancellor D UTAH, STATE OF |
| References | |
| FOIA-98-213 NUDOCS 9808210035 | |
| Download: ML20237C232 (2) | |
Text
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NRC FORM 464 Pitt 1 U.S. NUCLEAR REGULATORY COMMISSION FOIA/PA RESPONSE NUMBER Pg
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[" %op4t 98-213 2
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INFORMATION ACT(FOIA)/ PRIVACY RESPONSE -
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ACT (PA) REQUEST TYPE
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REOuESTER DATE EIG191996 Dem,se Chancellor PART l. - INFORM ATION RELEASED
[ No addttional agency records subject to the request have been located.
[ Requested records are available through another public distribution program. S ee Comments section.
APPENDICES Agency records subject to the request that are identified in the listed appendi ces are already available for public inspection and copying at the NRC Public Document Room.
APPENDICES Agency records subject to the request that are identified in the listed appendi ces are being made available for
!)
public inspection and copying at the NRC Public Document Room.
] Document Room,2120 L Street, NW, Washington, DC.
Enclosed is information on '*ow you may obtain access to and the charges for cop ying records located at the NRC Public FF APPE NDICES NJ Agency records subject to the request are enclosed.
gy
{ referred to that agency (see comments section) for a disclosure determination a nd direct response to Records subject V the request that contain information originated by or of int erest to another Federal agency have been
[ We are continuing to process your request.
[ See Comments.
PART l.A - FEES You will be billed by NRC for the amount listed.
M None. Minimum fee threshold not met.
^WUNT *
] You will receive a refund for the amount listed.] Fees waived.
- ee ents PART l.B -INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE
[ No agency records subject to the request have been located.
Certain information in the requested records is being withheld from disclosure pursuant to the exemptions described in and for the reasons stated in Part II.
[ This determination may be appealed within 30 days by writing to the FOIA/PA Officer, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Clearly state on the envelope and in the letter tha t it is a "FOIA/PA Appeal."
PART l.C COMMENTS (Use attached Comments continuation pace if required) i F24 l
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$ ATUR OHM i AND PRIVACY ACT OFFICER A ssell A.
owelF 9808210035 980819 PDR FOIA CHANCEL 98-213 PDR NRC FORM 464 Part 1 (01998)
PRINTED ON RECYCLED PAPER This form was designed using informs
Re: FOIA-98-213 APPENDIX D RECORDS BEING RELEASED IN THEIR ENTIRETY (if copyrighted identify with *)
NO.
DATE DESCRIPTION /(PAGE COUNT) 1.
10/28/97 Letter from Barbara Meehan to Wesley Patrick, subject:
Program Element Plan for Safety Review of a Topical Safety Analysis Report Submitted by Private Fuel Storage (PFS),
Limited Liability Company for the Private Fuel Storage
)
Facility for the FY98 Operations Plan Under Contract No.
NRC-02-97-009. (5 pages) 2.
12/4/97 Letter from Wesley Patrick to Barbara Meehan, subject:
Center for Nuclear Waste Regulatory Analyses Operations Plan for Technical Assistance to the Spent Fuel Project Office on NWPA-Related Projects-Revisons 1, Change 3. (7 Pages)
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%tadCere May 22,1998 FOIA Officer U.S. Nuclear Regulatory Commission Sent by CERTIFTED MAIL Mail Stop T-6 D8 RETURN RECEIPT REQUEST Washington DC 30555-0001
& emaih foiaenre. gov FOIA Reauest for Contract Documents Relating to Docket No. 72-22 re:
Dear FOIA Officer:
In June 1997, Private Fuel Storage, LLC (PFS) submitted a license application to NRC to construct and operate an independent spent fuel storage installation (ISFSI) on the Skull Valley Reservation in Utah. The Part 72 application was assigned Docket No. 72-22 and the Commission established a Licensing Board to preside over hearing reques:s and further proceedings. 62 Fed. Reg. 41,099 (July 21,1997). The State of Utah has been admitted as a party into the proceeding before the Board.
The NRC Staff must conduct a review of the PFS Part 72 application.1 The Staff's review will culminate in a Safety Evaluation Report (SER) and an Environmental Impact Statement (EIS).2 The NRC has contracted with two contractors to assist NRC in developing its SER and EIS and it is those contracts that are the subject of this FOIA request.
In a prehearing conference on May 19,1998, before the Licensing Board, NRC counsel, Sherwin Turk, informed the Board that the NRC has contracted with Oakridge National Laboratory to assist NRC in preparing an EIS and has contracted with the Center for Nuclear Waste v ;alatory Analysis to assist NRC in evaluating safety issues relating to the PFS license application. In a telephone conversation on May 20, the undersigned requested a copy of both contracts from Mr. Turk. The request was denied with respect to both contracts.
l Pursuant to the Freedom of Information Act,5 USC $ 552(a)(3) and implementing regulations, the State of Utah, acting by and through the undersigned, hereby requests a copy of or acces; to the following records:
1.
Contract documents between the U.S. Nuclear Regulatory Commission and Oakridge National Laboratory for the conduct of work relating the Environment Impact
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I Statement process in Docket No. 72-22.
2.
Contract documents between the U. S. Nuclear Regulatory Commission and Nuclear Waste Regulatory Analysis (or similar named-entity) for the conduct of work relating to the review of any issues in Docket No. 72-22, the PFS Part 72 license application.
The term " contact documents" in 1 and 2 above includes any document that describes the work to be performed by the NRC contractor.
This request is submitted by the State of Utah for the purpose of participating in the EIS process and the Atomic Safety and Licensing Board proceedings. The State asks that fees
. otherwise chargeable for costs incurred in responding to this request be waived on the grounds that furnishing the information sought will primarily benefit the public interest and will not serve any commercial interest of the party making the request.
If you require additional information, please contact me at (801) 366-0286.
Sincerely, Denise Chancellor Assistant Attorney General l
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5
- g Wesley C. Patrick. President
.j;. I ; N Center for Nuclear Waste Regulatory Analyses Post Of fice Drawer 28510 6220 Culebra Road San Antonio Texas 78228-0510
Dear Dr. Patrick:
Subject:
Program Element Plan for Safety Review of a Topical Safety Analysis Report Submitted by Private Fuel Storage (PFS). Limited Liability Company for the Private Fuel Storage Facility for the FY98 Operations Plan Under Contract No. NRC-02-97-009 Enclosed is the Program Element Plan (PEP) for the subject work.
This PEP shall be used as the basis for development of an Operations Plan for fiscal year (FY) 1998.
Milestones and deliverables for the FY 1998 Operations Plan should be developed using this information. indicating whether the deliverable is an intermediate or major milestone.
The NRC staff will provide the CNWRA with comments on the interim reports as outlined in Section 9.0.
All PFS deliverables are predecisional, and should be marked accordingly.
The CNWRA is encouraged to work with NRC counterparts to ensure a thorough understanding of this requirement.
The CNWRA is directed to submit the Operations Plan no later t:.an three weeks after receipt of this letter. A separate task under the Spent Fuel Office Operations Plan should be established for this work.
Mark S. Delliga' ti will be the PEM for this task.
j Should you have any questions regarding this letter. please contact me at 301/415-6730.
SincerelyJ/
Barbara Keehan. Contracting Officer Contract Management Branch No. 3 Division of Contracts and Property Management Office of Administration
Enclosure:
As stated cc:
JLinehan NMSS RNL Issued pursuant to memo dated 10/24/97 from SFortuna.
Distribution:
CMB3 BMeehan. MMace.
SFortuna NMSS.
BStiltenpole NMSS. MDelligatti NMSS l
ADL: DCPM:CMB1 i
ieehan
) 10/28/97 i
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Program Element Plan for Assistance in the Review of a Topical Safety Analysis Report Submitted by Private Fuel Storage, Limited Liability Company for the Private Fuel Storage Facility.
1.0 Introduction This Program Element Plan delineates technical assistance activities to be performed by the Center for Nuclear Waste Regulatory Analyses in support of the Spent Fuel Project Oflice (SFPO) review of the Topical Safety Analysis Report submitted by Private Fuel Storage, Limited Liability Company (PFS), as pan ofits application for license to construct and operate the Private l
Fuel Storage Facility, a nroposed away-from-reactor independent spent fuel storage installation.
l These activities include the preparation of an Safety Evaluation Report (SER) with respect to 10 CFR Pan 72.
2.0 Background
PFS has submitted an application to construct and operate an ISFSI on the Reservation of the Skul! Valley Band of Goshute Indians. The Reservation is surrounded by Toole County, Utah. A consortium of utilities has joined together to create PFS. It is the intention of these utilities to ship spent fuel from their nuclear utilities to the Private Fuel Storage Facility (as the ISFSI is to be known). The application references the applications for certification of two dual-purpose spent fuel cask systems, currently under staff review, which PFS intends to use. Since the casks are thus, not part of this review, it focuses mainly on reviewing compliance with the regulatory requirements associated with siting and facilities.
3.0 Objective The objective of this activity is to assist the staffin the review the TSAR and development of an SER.
4.0 Level of Effort i
The principal investigators represent the technical expertise provided by the contractor and l
provide technical continuity during the entire review process. They should have professional credentials in the technical areas assigned to them that will qualify them as expert witnesses for testifying at public hearings. They should have a clear understanding of the depth of review l
generally required by the NRC and specifically required by the type of activity proposed by the applicant for the disciplines they represent. They should also understand the association between DOE work performed on the CISP and the U.S. geologic repository program.
1 i
ATTACHMENT 1
O, The reviewers will be responsible for technical review of discrete areas within the entire review effort. Reviews can be performed by any qualified staff member but may be performed by a principal investigator or by the project manager. At a minimum, the major disciplines needed include:
1.
Environmental Engineering / Health Physics with experience in accident analysis 2.
Civil / Structural Engineering with experience in seismology 3.
Geology and the Natural Sciences associated with facility siting.
4.
Nuclear Engineering with experience in criticality and shielding design 5.
Nuclear Plant Operations with experience in fuel handling.
6.
The reviewers who perform the actual work shall provide detailed technical records of the methods used to evaluate all aspects of their areas ofresponsibility. Upon completion of an evaluation, the reviewer or responsible principalinvestigator will distiU Otis record to suitable documentation for inclusion in NRC reports. SFPO requires that all reports be provided in both draft and final form.
The level of effort (LOE) for this technical assistance request is estimated to be I stafT-years for fiscal year 1998 and point.2 each in FY99 and FY00. Planned allocation is as follows:
Overalllevel of effort (LOE)
Fiscal Year LQE 1998 1999 1
2000 5.0 Period of Performance The work on the tasks described in this SOW is anticipated to commence on or about December 1,1997, and will continue through December, 2000.
6.0 Task Description Task 1: Safety Evaluation Report for the PFS TSAR CNWRA input for the SER for the TSAR will be completed. The requirements of 10 CFR Part l
72 will dictate the overall scope of the assessment. Specifically, the major areas of review l
include: site characteristics, principal design criteria; operation systems; site generated waste confinement and management; radiation protection; accident analysis; operating controls and limits, and quality assurance. The contractor will use NUREG-1536 and NUREG-1567 as 2
guidance in making findings for several areas of this review. The contractor will identify any difficulties and inconsistencies with using NUREG-1567 and NUREG-1571 as review documents.
The reviewer (s) will be requested to assist in meetings with the applicant with regard to TSAR issues. The reviewer (s) may also be requested to assist in resolving technical comments for NRC's Committee to Review Generic Requirements (CRGR).
Level of Efrort: FY 98:
1 staff-year FY 99
.20 stafT-year FY 00
.20 staff-year 7.0 Meetings and Travel For planning purposes throughout the duration of this task, it is expected that there will be monthly coordination meetings between the contractor and NRC stalTby telephone or video conference. At the NRC's direction the contractor will attend meetings at NRC headquarters in Rockville, MD to plan, coordinate, resolve issues, and discuss the progress and status of the work. NRC will fund only those trips approved by the NRC Contracting Officer in advance and that are directly related to this project description.
8.0 NRC Furnished Materials NRC will provide the contractor, as appropriate, with copies of NRC's current regulations, guidance documents, storage and transportation cask documents, and other documents identified as pertinent to performing the required work.
9.0 Product / Deliverables Schedules The following deliverables will be required from the contractor:
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- 1. Request for AdditionalInf-mation 1
Within 90 days the contractor will provide the NRC staff with a request for additional information (RAI), in the format provided by the NRC staff. This will document additionalinformation needed in order for a determination of compliance with applicable regulatory requirements to be made.
- 2. Requests for AdditionalInformation (rounds 2 and 3,if necessary)
In a schedule determined by the applicants response to the first round RAI, the contractor may be asked to develop additional RAI's if necessary.
3.
Safety Evaluation Report on the TSAR 3
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The contractor will provide its draft input into the SEh ta me MF suff, in the format provided by staff,90 days after the receipt of the response to the final pal AtarTwill review the input and, if necessary, request a final version within 30 days of receipt of the draft. The contractor would l
then have 21 days to provide finalinput.
- 3. Presentation to NRC Peer Review Group on the Assessment Report and the Safety Evaluation Report l
l The contractor will be required to give a presentation ofits work to the NRC peer review group.
The presentation will defend contractor evaluations and conclusions that will be submitted as input into the final SER. As a result of the presentation, the contractor may be required to j
provide additional work. The presentation will be given at least 15 days before submittal of final l.
input.
l 4.
Litigation Support As required by the NRC staff, the CNWRA will support the NRC staff by contributing to oral and written testimony for adjudicatory hearings associated with the Private Fuel Storage app ication.
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4 Center for Nuclear _ Waste Regulatory Analyses Decembe, 4, 1,,,
6220 CULEBRA R0AD
- PO DRAWER 28510
- SAN ANTONIO. TEXAS. U.S A. 78228-0510 Contract No. NRC-02-97-009 (210) 522 5160
- FAX (210) 522 5155 U.S. Nuclear Regulatory Commission Attn: Mrs. Barbara D. Meehan Contract Officer Division of Contracts (DC)
TWFN Mail Stop T7-12 Washington, DC 20555
Subject:
Center for Nuclear Waste Regulatory Analyses Operations Plan for Techraical Assistance to the Spent Fuel Project Office on NWPA-Related Projects-Revision 1 Change 3
References:
1.
Comments on CNWRA FY98 Operations Plan for Technical Assistance to the Spent Fuel Project Office on NWPA-Related Projects-Revision 1 Change 2 Under Contract No. NRC-02-97-009, Meehan to Patrick, November 28, 1997 2.
Verbal Agreement Between Mark S.
Delligatti of NRC and Asad Chowdhury of CNWRA
Dear Mrs. Meehan:
Enc".osed are the change pages for the subject Operations Plan which were prepared in accordance with the references noted above. Preparation of this operations plan revision was coordinated with the Nuclear Regulatory Commission (NRC) Program Element Manager (PEM) Mark S.
Delligatti.
The schedule of deliverables for all tasks and subtasks has been prepared on the basis of your approval, per reference no.1, to start work under task 4 ef fective December 8, 1997. The spending and labor plans for task 1 for FY97 and FY98, for task 2 for FY98 and FY99, and for task 3 for FY98 remain the same as in revision 1, change 2 of this operations plan. The spending and labor plans for task 4 for FY98, FY99, and FYOO have been prepared to reflect the CNWRA estimate of costs associated with preparation and submission of the scheduled deliverables to the NRC.
/
If you have any questions concerning the contents of the subject p
, p _ase contact me at (210) 522-5158 or Dr. Asad Chowdhury at (210) 522-5~151.
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SinoM 'ly yours,
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<avA
-v WesPey C.
at ick President /
WCP/AHC/yl
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Enclosure cc:
See Attached List CNWRA Directors CNWRA Element Managers CNWRA Principal Investigators S. Rowe, SwRI Contracts d3 support \\sfpo\\opsplanufpoops tr6 v ~
Washington 01ce
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OPERATIONS PLAN FOR TECIINICAL ASSISTANCE TO Tile SPENT FUEL PROJECT OFFICE ON NWPA-RELATED PROJECTS Revision 1, Change 3 CONTROL, LED COPIES:
Barbara Meehan, Contracts Barbara Stiltenpole NMSS & (5) Uncontrolled copies Shirley Fortuna, NMSS Mark Delligatti, NMSS UNCONTROLLED COPIES:
DCS i
John Linehan, NMSS (w/o enclosure) l Michael Raddatz, NMSS l
Eric Leeds. NMSS Frederick Sturz, NMSS William Kane, NMSS
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Rev 1 Chg 5 Table 3.3-2. Travel for task 3 Number of Number of Number of StafT-Fiscal Year Destination Travelers Trips Days per Trip 1998 Washington. DC 3
3 3
1 5
1999 Washington, DC 7
2 3
1 3
3.4 REVIEW OF A SAFETY ANALYSIS REPORT FOR A PROPOSED PRIVATE FUEL STORAGE FACILITY 3.4.1 Objectives The objectives of this task are to support the NRC in reviewing the proposed private fuel storage facility (PFSF) safety analysis report (SAR) submitted to NRC by Private Fuel Storage, Limited Liability Company (PFS) and in developing a SER for the PFSF. In FY98. the objective is to conduct a detailed technical review of the PFSF SAR and to prepare final inputs to both first and second round requests for additional information (RAI). The PFS response to the first round RAls will also be evaluated during FY98. The FY99 and FYOO activities will include evaluation of the PFS response to the second round RAls, preparation of subsequent RAls. evaluation of the PFS response to those RAls. and preparation of a draft and fmal SER.
3.4.2 Scope The technical review of the PFSF SAR and the preparation of the SER will be in accordance with the requirements of 10 CFR Part 72 and applicable guidance provided by NRC NUREGs 1536 and 1567. It is expected that the major areas of review will include (i) site characteristics; (ii) principal design criteria: (iii) operation systems; (iv) site generated waste confmement and management; (v) radiation protection; and (vi) operating controls and limits. The quality assurance program for the PFSF SAR will be reviewed by the NRC staff. The accident analysis review is not included within the scope of this task.
3.4.3 Technical Approach The CNWRA will use NRC standard review plans NUREG-1567 and NUREG-1536 to perform the safety review of the PFSF S AR. These standard review plans incorporate the regulatory requirements from 10 CFR Part 72 and 10 CFR Part 20 (for radiation protection) that apply to the PFSF. CNWRA l
staff will also use NRC files and staff experience related to PFSF licensing in applying their technical expertise to this review. CNWRA staff will be assigned to conduct the reviews using the following approaches.
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9 Rev 1 Chg 5 Site Characteristics. Review and evaluate whether the (i) geography and demography; geology; seismicity; meteorology; surface and subsurface hydrology; and nearby industrial, transportation, and military facilities of the site have been acceptably described and (ii) site characteristics affecting the determination of design basis conditions and events and the design of PFSF have been acceptably identified, quantified, and evaluated.
Principal Desien Criteria. Review and evaluate whether (i) the design criteria stated or referenced in the SAR are acceptable for the proposed applications during normal and off-normal operations and design-basis accident conditions; (ii) theJbiting characteristics of spent fuel to be stored are acceptably defined; and (iii) the SAR adequately identifies the structures, systems, and components (SSCs), equipment, and controls important to safety.
Operation Systems. Review and evaluate the acceptability of the operating and maintenance procedures to be used at PFSF.
Site Generated Waste Confinement and Manacement. Review and evaluate whether (i) all the site generated wastes have been identi6ed and characterized and (ii) the treatment and retention of these wastes are consistent with NRC radiation protec'icn standards.
Radiation Protection. Review and evaluate whether (i) the design features of the facility will meet NRC criteria for exposures to direct radiation; (ii) the PFSF facility radiation protection program for occupational exposures to workers is consistent with NRC radiation protection standards; (iii) the radiation doses to the general public will meet regulatory standards during normal, off-normal, and design-basis accident situations; and (iv) doses to workers and members of the public will be ALARA.
Oneratine Controls and Limits. Review and evaluate the acceptability of the operating controls and limits or the technical speci6 cations (including their bases and justi6 cations) that the PFS has established.
During the detailed review of the PFSF SAR, the CNWRA staff will conduct independent analyses to con 6rm the DOE conclusions if only specifically requested by NRC PO. If problems are suspected with a particular aspect of the PFSF design, the independent analyses will be focused more closely in that area.11owever, the scope of independent analyses will be determined in consultation with the NRC PO, taking into consideration the cost and schedule of the project. For any mechanical, structural, or thermal calculations, the CNWRA will use in-house codes including ABAQUS and DYNA 3D. For any radiation and shielding calculations, the CNWRA will utilize in-house codes including ORIGEN, GENil, CAP 88, QAD-CGGP, and ISOSHLD, as appropriate. The CNWRA staff will make use of applicable design codes and standards including those provided by ACI, AISC, and ASME.
The CNWR A staff will contact the appropriate NRC staff to obtain any background information that would assist in preparing the SER. Also, frequent coordination with NRC staff will be necessary as activities under this task progress. As requested, CNWRA staff will also support the NRC in meetings l
with the applicant with regard to SAR issues and in resolving technical comments raised by the Committee to Review Generic Requirements (CRGR).
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Rev 1 Chg 5 Completion of this task will require staff with skills in environmental engineering / health physics, civil / structural engineering (specifically seismology), geology and the natural sciences (specifically facility siting experience), nuclear engineering (specifically radiation protection), and nuclear plant operations (specifically fuel handling experience).
3.4.4 Deliverables and Schedule Figure 3.4-1 depicts the schedule for this task. Table 3.4-1 lists the milestones. Work for this task will commence on or about December 10, 1997, and will continue through September 29,2000.
Note that a summary of CNWRA evaluations and conclusions from reviewing the PFSF SAR will be presented to an NRC peer review group at least 15 days prior to submittal of the final SER. Any required revision to deliverable dates will be coordinated with the NRC PO.
Table 3,4-1. Schedule of deliverables for task 4 Deliverable Milestone Completion Ntunber Type Deliverable Description Date 1405-041-810 IM First Round Request for Additional 03/14/98 Information-Final Letter Report 1405-041-820 IM Second Round Request for Additional 09/25/98 information-Final Letter Report 1405-041-910 IM Third Round RAl/ Draft Safety Evaluation 02/26/99 Report-Draft Letter Report 1405-041-920 IM Safety Evaluation Report-Final Letter 06/04/99 Report 3.4.5 Travel Table 3.4-2 describes the travel for this task. In FY98, one three-day trip by three CNWRA staff is planned to the NRC headquarters in Rockville, MD to plan, coordinate, resolve issues, and discuss progress and status of the work. Also, one four-day trip by three CNWRA staff members is planned to visit the PFSF site, if necessary. During FY99 and FYOO, three CNWRA staff will make one trip to NRC. During the FY99 trip to NRC, which will be scheduled approximately 45 days prior to submittal of the final PFSF SER, the CNWRA staff will provide presentations to the NRC peer review group describing CNWRA evaluations and conclusions from reviewing the PFSF SAR. All travel will be coordinated with the NRC PO.
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Table 3.4-2, Travel for task 4 Number of Number of Number of Staff-Fiscal Year Destination Travelers Trips Days per Trip 1998 Washington, DC 3
1 3
1998 PFS PFSF Site, UT 3
1 4
1999 Washington, DC 3
1 3
1 2000 Washington, DC 3
1 3
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