ML25023A002
| ML25023A002 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 01/22/2025 |
| From: | Paulette Torres NRC/NRR/DANU |
| To: | Hawari A North Carolina State University |
| References | |
| L-2020-NFR-0007 | |
| Download: ML25023A002 (5) | |
Text
From:
Paulette Torres Sent:
Wednesday, January 22, 2025 4:08 PM To:
ayman.hawari@ncsu.edu Cc:
Colby Fleming; Austin Wells; Duane Hardesty (He/Him/His); Holly Cruz (She/Her/Hers); Andrew Miller
Subject:
North Carolina State University LRA-REQUEST FOR ADDITIONAL INFORMATION - Financial Qualifications (EPID L-2020-NFR-0007)
Attachments:
RAI-10478-R1-FINAL.docx Dr. Ayman I. Hawari, Director Nuclear Reactor Program Department of Nuclear Engineering North Carolina State University Campus Box 7909 2500 Stinson Drive Raleigh, NC 27695-7909 Dr. Hawari, The U.S. Nuclear Regulatory Commission (NRC) staff is continuing its review of the North Carolina State University (NCSU) PULSTAR Nuclear Research Reactor license renewal application (LRA) letter, dated February 24, 2017 (Agencywide Documents Access and Management System Accession No. ML17088A819). Included with the NCSU LRA was the Safety Analysis Report (ML17201Q129 - redacted version) and the Financial Qualifications Report (ML17088A828). In reference to the documents submitted by NCSU, pertaining to chapter 15 "FINANCIAL QUALIFICATIONS" and the financial qualifications requirements of 10 CFR 50.33(f) for the facility, the NRC staff has identified the items in the enclosure, which need additional information.
The NRC staff held a phone call with Colby Fleming and Austin Wells on December 17, 2024, discussing the draft RAIs. The final RAIs are enclosed. We request that you provide responses within 60 days from the date of this email. If you have any questions, please contact me at (301) 415-5656, or by email at Paulette.Torres@nrc.gov.
Respectfully, Paulette A. Torres Non-Power Production and Utilization Facility Licensing (UNPL)
Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU)
Office of Nuclear Reactor Regulation (NRR)
(301) 415-5656 paulette.torres@nrc.gov Docket No. 50-297 License No. R-120 EPID: L-2020-NFR-0007 cc: GovDelivery Subscribers
Hearing Identifier:
NRR_DRMA Email Number:
2704 Mail Envelope Properties (SA0PR09MB70367CB814BB2D76049B2DBCFEE12)
Subject:
North Carolina State University LRA-REQUEST FOR ADDITIONAL INFORMATION - Financial Qualifications (EPID L-2020-NFR-0007)
Sent Date:
1/22/2025 4:08:03 PM Received Date:
1/22/2025 4:07:00 PM From:
Paulette Torres Created By:
Paulette.Torres@nrc.gov Recipients:
"Colby Fleming" <ncsorrel@ncsu.edu>
Tracking Status: None "Austin Wells" <ajwells2@ncsu.edu>
Tracking Status: None "Duane Hardesty (He/Him/His)" <Duane.Hardesty@nrc.gov>
Tracking Status: None "Holly Cruz (She/Her/Hers)" <Holly.Cruz@nrc.gov>
Tracking Status: None "Andrew Miller" <Andrew.Miller@nrc.gov>
Tracking Status: None "ayman.hawari@ncsu.edu" <ayman.hawari@ncsu.edu>
Tracking Status: None Post Office:
SA0PR09MB7036.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1824 1/22/2025 4:07:00 PM RAI-10478-R1-FINAL.docx 24902 Options Priority:
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1 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 297-NC STATE LICENSE RENEWAL AND POWER UPRATE NORTH CAROLINA STATE UNIVERSITY AT RALEIGH NORTH CAROLINA STATE UNIVERSITY, UNIT 1 DOCKET NO. 05000297 ISSUE DATE: 01/22/2025
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Background===
The U.S. Nuclear Regulatory Commission (NRC) staff is continuing its review of the North Carolina State University (NCSU) PULSTAR Nuclear Research Reactor license renewal application (LRA) letter, dated February 24, 2017 (Agencywide Documents Access and Management System Accession No. ML17088A819). Included with the NCSU LRA was the Updated Safety Analysis Report (ML17201Q129 - redacted version) and the Financial Qualifications Report (ML17088A828). The NRC staff requires the following additional information to continue its review of the LRA pertaining to chapter 15 "FINANCIAL QUALIFICATIONS" and the financial qualifications requirements of 10 CFR 50.33(f) for the facility.
We request that you provide responses within 60 days from the date of this letter.
These requests for additional information have been developed based on the following requirements and guidance applicable to the NCSU LRA:
- Title 10 of the Code of Federal Regulations (10 CFR).
- Part 20, Standards for Protection against Radiation, of 10 CFR require that radiation doses to workers and members of the public be limited. To support meeting the public dose limits, 10 CFR Part 20, also limits the release of radioactive materials from the licensed facility to the environment (e.g., 10 CFR Part 20, Appendix B, Table 3).
- Section 50.9, Completeness and accuracy of information, of 10 CFR require that information provided to the Commission by a licensee shall be complete and accurate in all material respects.
- NUREG-1537 Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, issued February 1996 (ADAMS Accession No. ML042430055).
- NUREG-1537 Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Standard Review Plan and Acceptance Criteria, issued February 1996 (ADAMS Accession No. ML042430048).
Question 1 By letter dated February 24, 2017 (ML17088A819) and supplements dated March 29, 2017 (ML17201Q129, ML17088A828), August 9, 2019 (ML19221B600) and November 1, 2018 (ML18312A305), May 26, 2020 (ML20149K877), NCSU submitted its projected operating cost for the NCSU PULSTAR reactor for each of the fiscal years (FY) 2018 through FY2022. The regulations in 10 CFR 50.33(f) requires an applicant for a license to provide information on its financial qualifications. Therefore, NCSU must provide information that demonstrates that it possesses or has reasonable assurance of obtaining the funds necessary to cover estimated operating costs for the period of the license. The NCSU must also submit estimates for the total annual operating costs for each of the first five years of facility operations from the expected
2 license renewal date and indicate the source(s) of funds to cover those costs. Provide the projected operating costs for the NCSU PULSTAR reactor for year 2026, 2027, 2028, 2029, and 2030 looking into the five years forward.
Question 2 The regulations in 10 CFR 50.75, Reporting and recordkeeping for decommissioning planning",
(d)(1), states, in part, that each non-power reactor applicant for or holder of an operating license for a production or utilization facility shall submit a decommissioning report. Pursuant to 10 CFR 50.75(d)(2), NCSU provided a decommissioning cost estimate of $16.4M in 2017 dollars. Provide an updated decommissioning cost estimate for the NCSU PULSTAR reactor in 2025 dollars that includes inflation considerations.
Question 3 NCSU has elected to use a statement of intent (SOI) to provide financial assurance, as allowed by 10 CFR 50.75(e)(1)(iv) for a Federal, State or local government licensee. The SOI must contain or reference a cost estimate for decommissioning and indicate that funds for decommissioning will be obtained when necessary. NCSU provided an updated SOI, titled "PULSTAR REACTOR FINANCIAL QUALIFICATIONS REPORT", dated March 29, 2017 (ML17088A828), stating that it is a state government organization and that decommissioning funding obligations are fully backed by the state government of North Carolina. Provide an updated SOI for year 2025.
Question 4 Consistent with section 104c of the Atomic Energy Act of 1954, as amended (AEA), in the case of a utilization facility that is useful in the conduct of research and development activities of the types specified in section 31 of the Act, no more than 75 percent of the annual cost to the licensee of owning and operating the facility can be devoted to the sale of nonenergy services, energy, or a combination of nonenergy services and energy, other than for research and development or education and training, and no more than 50 percent of the annual costs to the licensee of owning and operating the facility are devoted to the sale of energy.
Additionally, 10 CFR 50.22, Class 103 licenses; for commercial and industrial facilities, states, in part, that, in the case of a utilization facility which is useful in the conduct of research and development activities of the types specified in section 31 of the Act, such facility is deemed to be for industrial or commercial purposes if the facility is to be used so that more than 50 percent of the annual cost of owning and operating the facility is devoted to the production of materials, products, or energy for sale or commercial distribution, or to the sale of services, other than research and development or education or training.
By letter dated March 29, 2017 (ML17088A828), NCSU submitted a financial qualification report discussing the commercial activities in relation to the annual cost of owning and operating the NCSU PULSTAR reactor facility. Provide an updated financial qualification report showing the status as of year 2025 that provides a statement that the NCSU PULSTAR reactor facility complies with these requirements and 10 CFR 50.22 to renew licensing as a Class 104 research reactor.
3 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/BC NAME PTorres HCruz DATE 01/22/2025 01/21/2025