ML24285A088
| ML24285A088 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/30/2024 |
| From: | Stephen Poy NRC/NMSS/DFM/FFLB |
| To: | Kenneth Kline, Lisa Pope NRC/NMSS/DREFS/FAB |
| References | |
| Download: ML24285A088 (1) | |
Text
From: Stephen Poy To: Kenneth Kline; Lisa Pope
Subject:
FW: RE: RE: RE: RE: DFP Update Date: Tuesday, July 30, 2024 6:34:00 PM Attachments: image001.png image002.png image003.jpg
FYI
From: TATE Timothy (Framatome) <timothy.tate@framatome.com>
Sent: Tuesday, July 30, 2024 5:57 PM To: Stephen Poy <Stephen.Poy@nrc.gov>
Cc: HANSON Brandon (Framatome) <brandon.hanson@framatome.com>; MANNING Calvin (Framatome) <calvin.manning@framatome.com>
Subject:
[External_Sender] RE: RE: RE: RE: DFP Update
- Stephen,
Hope this helps, please let me know if you have additional questions.
CAST is an independent trucking company that has the credentials to transport radioactive materials.
We currently use them to transport our product.
Main Home Updated - Trucking Company l Freight Hauling Service l CAST Transportation
The work that CAST will be performing is only transporting radioactive waste to the burial site.
The cost per transport of $1,800 per transport is the combined cost for shipping paper work and actual transportation to US Ecology for each shipment. The break down is what was previously shared with you; $600.00 per shipment (high estimate of hourly rate $115.00 for Cast Transportation local driver) to go from HRR to U.S. Ecology (~15 Miles) and a very conservative estimate of $1,200 for a contracted Transportation Engineer through System One to prepare paper work and oversee the shipment.
From: Stephen Poy < Stephen.Poy@nrc.gov>
Sent: Tuesday, July 30, 2024 1:00 PM To: TATE Timothy (FRA-FL) < timothy.tate@framatome.com>
Cc: HANSON Brandon (FRA-FL) <brandon.hanson@framatome.com>; MANNING Calvin (FRA-FL)
<calvin.manning@framatome.com>
Subject:
RE: RE: RE: RE: DFP Update
Security Notice: Please be aware that this email was sent by an external sender.
Good afternoon,
The finance branch wanted to clarify if CAST was an independent contractor or an in-house organization used in the decommissioning. They wanted a statement to the scope of work they would be performing - are the activities the decommissioning and transport? - and the hourly rate charged by them to perform their activities - Is the rate changed by them $1800.00 per shipment?
- Thanks,
Steve
Stephen Poy, Project Manager U.S. Nuclear Regulatory Commission (NRC)
Office of Nuclear Material Safety and Safeguards (NMSS)
Division of Fuel Management (DFM)
Fuel Facilities Licensing Branch (FFLB)
Phone: 301-415-7135 Email: stephen.poy@nrc.gov
From: TATE Timothy (Framatome) <timothy.tate@framatome.com>
Sent: Wednesday, July 24, 2024 12:22 PM To: Stephen Poy <Stephen.Poy@nrc.gov>
Cc: HANSON Brandon (Framatome) <brandon.hanson@framatome.com>; MANNING Calvin (Framatome) <calvin.manning@framatome.com>
Subject:
[External_Sender] RE: RE: RE: DFP Update
Stephen, per our conversation today, please see the words below and let me know if there are any changes needed. Have a wonderful afternoon.
Transportation costs for LLRW in the DFP have decreased from $5,732 per shipment to $1,800 per shipment by eliminating the very high cost of using a logistics service company and adding the cost of an independent contractor as per 10 CFR 70.25 to perform all decommissioning transportation activities and a local trucking company who has the permits required to transport LLRW.
From: Stephen Poy <Stephen.Poy@nrc.gov>
Sent: Wednesday, July 17, 2024 7:33 AM To: MANNING Calvin (FRA-FL) <calvin.manning@framatome.com>; TATE Timothy (FRA-FL)
<timothy.tate@framatome.com>
Cc: HANSON Brandon (FRA-FL) <brandon.hanson@framatome.com>
Subject:
RE: RE: RE: DFP Update
Security Notice: Please be aware that this email was sent by an external sender.
The Finance Branchs interpretation of 10 CFR 70.25 is
10 CFR 70.25 requires:
(e)(1) Each decommissioning funding plan must be submitted for review and approval and must contain
(i) A detailed cost estimate for decommissioning, in an amount reflecting:
(A) The cost of an independent contractor to perform all decommissioning activities;
Their reading is that an independent contractor must conduct the activities - the Finance Branch requires the DFP include estimates with the 3rd party conducting the activities.
The indicated to me the assumption is that the licensee is bankrupt and cant conduct the decommissioning. That is the reason for the 3rd party estimate. With regard to estimates for preparing the paper work if these are decommissioning costs they need to be conducted by a 3rd party if they are not then they do not need to be.
Let me know if you have any questions.
From: MANNING Calvin (Framatome) < calvin.manning@framatome.com>
Sent: Wednesday, July 17, 2024 8:45 AM To: Stephen Poy < Stephen.Poy@nrc.gov>; TATE Timothy (Framatome)
<timothy.tate@framatome.com>
Cc: HANSON Brandon (Framatome) <brandon.hanson@framatome.com>
Subject:
[External_Sender] RE: RE: DFP Update
Stephen;
My original submital estimated the cost by using Cast to do the transport and using the time estimates for preparing the paper work from our current logistics technician and the charge out rate to hire an individual with these credentials through system one. This cost reduction was significant because Orano over charges for the service. The change in wording was made to address the concerns expressed by the reviewer.
If I can find a contractor e.g. system one that is cheaper than another, e.g. Orano, why is the NRC concerned?
Cal
Sent from Workspace ONE Boxer On July 17, 2024 at 5:04:57AM PDT, Stephen Poy < Stephen.Poy@nrc.gov> wrote:
Security Notice: Please be aware that this email was sent by an external sender.
The Finance Branch came back with the following guidance:
10 CFR 70.25 requires:
(e)(1) Each decommissioning funding plan must be submitted for review and approval and must contain
(i) A detailed cost estimate for decommissioning, in an amount reflecting:
(A) The cost of an independent contractor to perform all decommissioning activities;
Therefore, Framatome cannot eliminate the cost of using an independent contractor to create the required shipping paperwork, and instead performing those tasks in-house at the Framatome HRR facility. The licensee will need to include independent contractor costs to perform these tasks.
I believe the guidance is - even though Framatome is conducting the activities in-house - Framatome needs to provide an independent contractor estimate as per the regulations.
Let me know if you have any questions.
Thanks,
Steve
From: TATE Timothy (Framatome) <timothy.tate@framatome.com>
Sent: Friday, July 12, 2024 12:57 PM To: Stephen Poy <Stephen.Poy@nrc.gov>
Cc: MANNING Calvin (Framatome) <calvin.manning@framatome.com>; HANSON Brandon (Framatome) <brandon.hanson@framatome.com>
Subject:
[External_Sender] RE: DFP Update
Stephen, are these words acceptable? Thanks
"Transportation costs for LLRW in this DFP have decreased from $5,732 per shipment to $1,800 per shipment by eliminating the high cost of using an independent contractor to create the required shipping paperwork, and instead performing those tasks in-house at the Framatome HRR facility. Additional cost was removed by utilizing a local trucking company with permits required to transport LLRW instead of a logistics service company.
From: Stephen Poy <Stephen.Poy@nrc.gov>
Sent: Thursday, June 27, 2024 5:14 PM To: TATE Timothy (FRA-FL) <timothy.tate@framatome.com>
Cc: MANNING Calvin (FRA-FL) <calvin.manning@framatome.com>; HANSON Brandon (FRA-FL) <brandon.hanson@framatome.com>
Subject:
RE: DFP Update
Security Notice: Please be aware that this email was sent by an external sender.
- Tim,
As per our conversation today, the Finance Branch wanted to know (in reference to the statement below) if an actual contract is in place with the said contractor for the amount that Framatome will be adding to the updated DFP.
Please include this in the DFP or as per our conversation, discuss in the DFP how there will be no contractor and how Framatome will be doing this work internally.
Let me know if you have any questions.
- Thanks,
Steve
Stephen Poy, Project Manager U.S. Nuclear Regulatory Commission (NRC)
Office of Nuclear Material Safety and Safeguards (NMSS)
Division of Fuel Management (DFM)
Fuel Facilities Licensing Branch (FFLB)
Phone: 301-415-7135 Email: stephen.poy@nrc.gov
From: TATE Timothy (Framatome) < timothy.tate@framatome.com>
Sent: Wednesday, June 19, 2024 9:30 AM To: Stephen Poy < Stephen.Poy@nrc.gov>
Cc: MANNING Calvin (Framatome) <calvin.manning@framatome.com>; HANSON Brandon (Framatome) <brandon.hanson@framatome.com>
Subject:
[External_Sender] DFP Update
Stephen, we have added the language into the DFP and it is currently routing for approval. Please let us know if you have any questions and have a wonderful day.
Timothy J. Tate Manager, Environmental, Health, Safety and Licensing Framatome Office(509) 375-8550 Mobile (509) 528-0982 2101 Horn Rapids Road Richland, WA 99354 mail to: timothy.tate@framatome.com
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