ML24039A156
| ML24039A156 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 01/22/2024 |
| From: | Jack Parrott Reactor Decommissioning Branch |
| To: | Slaughter M Aerotest |
| References | |
| Download: ML24039A156 (2) | |
Text
From: Jack Parrott Sent: Monday, January 22, 2024 4:05 PM To: Mike Slaughter Cc: Shaun Anderson; Shawn Harwell; Marlayna Doell; Nate Fuguet
Subject:
Draft Aerotest RCI and draft license amendment
Dear Dr. Slaughter,
NRC staff is near to completing our review and evaluation of the decommissioning plan (DP) for the ARRR.
However, in our evaluation of the DP, NRC staff found that the requirement 10 CFR 50.82(b)(3)(ii) was not specifically addressed in your application. The regulation in 10 CFR 50.82(b)(3)(ii) requires that DPs that delay completion of decommissioning include a means for adjusting decommissioning cost estimates and associated funding levels over the storage or surveillance period.
NRC staff notes that this related to a requirement considered in the NRCs review of the indirect license transfer dated February 28, 2017 (ML16333A443). To complete our evaluation of the DP, please confirm that you continue to implement the plan to review and adjust, as necessary, the decommissioning funding levels on a biannual basis, based on updated decommissioning cost estimates developed by outside experts, and by maintaining a $300,000 letter of credit from a Federally insured bank to be used in the event that future updates to the cost estimates or funding levels reveal a shortfall in the fund balance, consistent with 10 CFR 50.75(e)(1)(iii)(A), as stated in your 2017 license transfer application.
We would like to share with you the text of a draft license condition (License Condition 2.F), that will be added to the ARRR license for approval of the DP, for your review. The condition would read as follows:
F. Decommissioning
The licensee shall implement and maintain in effect all provisions of the approved Decommissioning Plan for the Aerotest Radiography and Research Reactor, dated July 20, 2021, as supplemented on January 20, 2022, July 21, 2022, and November 16, 2022 (hereinafter the DP), which authorizes inclusion of the DP as a supplement to the Safety Analysis report pursuant to 10 CFR 50.82(b), and is subject to and amended by the following stipulations:
(1) The licensee may make changes to the DP without prior NRC approval provided the proposed changes do not meet any of the following criteria:
a) Require Commission approval under 10 CFR 50.59, Changes, tests, and experiments.
b) Result in the potential for significant environmental impacts that have not previously been reviewed.
c) Detract or negate the reasonable assurance that adequate funds will be available for decommissioning.
(2) This DP is approved under the regulation in 10 CFR 50.82(b)(2) that allows for a DP, in which the major dismantlement activities are delayed by first placing the facility in storage, to be less detailed. Therefore, an updated detailed DP shall be submitted and approved prior to the start of major dismantlement activities. The updated DP shall contain more detailed information on the remaining site characterization, dismantlement, and remediation activities, as well as the final status survey plan, for NRC review and approval prior to
1 conducting final status surveys for license termination. Approval of this less detailed DP is not binding on the NRCs determination of the specific adequacy of the updated detailed ARRR DP.
In order for NRC staff to complete review of the ARRR DP, please reply to this email confirming that Aerotest Operations, Inc. will continue to review and adjust, as necessary, the decommissioning funding levels as stated above and as required under the license transfer of 2017.
Sincerely,
Jack D. Parrott Senior Project Manager US Nuclear Regulatory Commission 301-415-6634
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