ML20195F836

Forwards Addl Info in Support of Application to Amend License TR-2 Re Name Change

ML20195F836
Person / Time
Site:	Waltz Mill
Issue date:	11/17/1998
From:	Nardi A WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RA-98-070, RA-98-70, NUDOCS 9811200101
Download: ML20195F836 (8)

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Westin'g' house Electric Company, Energy Systems Boxass

- a dvision of CBS Corporaton PetughPennsylvania 1523H365 RA-98-070 November 17,1998 l

oyX 30 Document Control Center U. S. Nuclear Regulatory Commission

-Washington, DC 20555-0001 j i

Subject:

Submittal of Additional Information to Support Application for Name Change, USNRC License Number TR-2, Docket No.50-022 l

References:

1. CBS Letter dated September 28,1998 from Louis J. Briskman to Samuel J. Collins, USNRC; Subject " Request for a Name Change Amendment to License Number TR-2, Docket Number 50-022".  !

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Dear Sirs:

By letter dated September 28,1998 (Reference 1), CBS Corporation, acting through its .

Westinghouse Electric Company division ("CBS"), submitted an Application for a name change I amendment to the license for the Westinghouse Test Reactor (License No. TR-2) located at the Waltz Mill Site in Madison, PA. The Application requests that the name of the license.a be changed from "CBS Corporation, acting through its Westinghouse Electric Company division" l to "CBS Corporation" to reflect the fact that the TR-2 license will not be transferred as part of j the sale (with certain exceptions) by CBS of its nuclear and govemment services businesses to f a consortium consisting of Morrison-Knudsen Corporation and BNFL USA Group, Inc. (the

" Purchasers"). In response to discussions held with Mr. Theodore Michaels of your staff, the l attached additional information is being submitted to support that Application.

- The submitted additional information consists of revisions to: (1) Exhibit A submitted with the original Application and (2) an Organization Chart (Figure 2-13) submitted as part of the i approved Decommissioning Plan for the TR-2 license. Exhibit A to the original Application (Reference 1) has been revised in its entirety to clarify the discussion of the contractual

, relationships that will exist between CBS and the company that will be formed by the

! Purchasers to effect the sale of the CBS nuclear assets as discussed in the Application. The attached revision to the Organization Chart reflects the organizational relationships that will j exist between these entities as of the closing date of the sale transaction.

I 9811200101 981117 I i- PDR ADOCK 05000022 o P

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d, If you have any questions conceming this submittal, please contact me at (412) 374-4652.

, Sincerely, l

6 1-A. J ph N rdi, Supe sory Engineer Regulatory Affairs

/sif . -

Attachments:

cc: Mr. Theodore S. Michaels, Senior Project Manager

! Non-Power Reactors & Decommissioning Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 James Yusko, Regional Manager Radiation Protection Commonwealth of Pennsylvania Department of Environmental Protection Field Operations 400 Waterfront Drive Pittsburgh, Pennsylvania 15222-4745 Copies transmitted: 3 notarized and 5 conformed COMMONWEALTH OF PENNSYLVANIA )

) SS:

COUNTY OF ALLEGHENY )

Before me, the undersigned notary public, this day personally appeared A. Joseph Nardi, Supervisory Engineer, Westinghouse Electric Company, a division of CBS Corporation,4350 Northem I Pike, Monroeville PA,15146-2886 to me known, who being duly swom according to law, deposes and says that the statements swom to in this letter and attachment are correct and accurate to the best of his knowledge.

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Sigfature ofpffiant l;~ Subscri and swom to before me this IV day of November,1998

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Notary Public /

1 i Notarial Seal Lorraine Mgica, Notary Public RA-6,111796, Pg. 2 M omn51s ion Ex ec ,t 9 a

sumner Penne uvahnn of Notare:

d EXHIBIT A ANALYSIS OF NO SIGNIFICANT HAZARDS CONSIDERATION FOR NAME CHANGE AMENDMENT OF THE WESTINGHOUSE TEST REACTOR FACILITY LICENSE NUMBER TR-2, DOCKET 50-022 (Revision 1, November 17,1998)

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l ANALYSIS OF l

NO SIGNIFICANT HAZARDS CONSIDERATION FOR NAME CHANGE AMENDMENT OF THE l WESTINGHOUSE TEST REACTOR FACILITY l LICENSE NUMBER TR-2, DOCKET 50-022 l (Revision 1, November 17,1998) i i

l REFERENCE 10 CFR 50.91(a) l l The proposed change that is the subject of the requested amendment has been

!. evaluated against the standards of 10 CFR 50.92(c) and it has been determined to not l involve any significant hazards consideration in that licensed activities in accord with ,

t the proposed amendment:

1) Would not involve a sigmficant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment will change the name of the Licensee for the Westinghouse Test Reactor ("WTR facility") TR-2 license, a possession only license (the "TR-2 License"), from "CBS Corporation, acting throu Westinghouse Electric Company Division" to "CBS . The Corporation"' gh l amendment request is necessary because on June 26,1998, CBS Corporation ]

("CBS")2 announced that it had entered into a contract for the sale (with certain I exceptions) ofits nuclear and government services businesses, which comprise  ;

its Westinghouse Electric Company division. The WTR facility license (TR-2 l

License)is not being transferred to the new company. CBS will retain the WTR facility license and the responsibility to continue the on-going decommissioning and license termination activities in accordance with the  :

"Deconunissioning Plan" that has been submitted to the NRC for review and approval. (See " Westinghouse Test Reacter. TR-2, Final Decommissioning Plan", July 25,1997, as revised.3) The need for the requested name change  ;

amendment to the TR-2 License being retained by CBS is due to the fact that the Purchasers will have the right to continue using the Westinghouse name in connection with the CBS nuclear assets and facilities they will acquire in the sale. The new company to be formed by the Purchasers to hold the nuclear assets and facilities, and associated nuclear licenses, that will be transferred as part of the sale transaction will be Westinghouse Electric Company, LLC, a MK/BNFL Company ("WELCO").

l ' This name change was issued as Amendment No. 7 (July 31,1998) to the license.

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• On December 1,1997, Westinghouse Electric Corporation formally changed its name to CBS l Corporation.

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• This Decommissioning Plan was approved as Amendment No. 8 (September 30,1998) to the

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license.

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,. There will be no change in the financial qualification of CBS to continue to

, hold the TR-2 License as a result of the Application to amend the license. The l implementation of the decommissioning of the WTR facility as described in the Decommissioning Plan will be continued by CBS without interruption.

In order to implement the decommissioning of the WTR facility as described in the Decommissioning Plan, CBS currently has entered into contracts with qualified contractors as described in the Decommissioning Plan. These  !

contracts will be transferred to WELCO upon the closing of the sale '

transaction. In addition, CBS will enter into a new contract with WELCO as of the closing date, by which former CBS remediation and decommissioning personnel transferred to WELCO will manage the decommissioning activities of these qualified contractors as described in the Decommissioning Plan on behalf of CBS. The effect of these actions: a direct contract between CBS and WELCO and WELCO, in turn, holding the existing contracts with the qualified contractors to implement the decommissioning activities, is that there will be no substantive change in the personnel associated with the on-going decommissioning project under the TR-2 License. CBS, as licensee, will continue to retain full responsibility for the project and will continue to maintain an organization, in the form of personnel who will remain CBS employees or are contractor personnel reporting to CBS, to provide overall management oversight of all licensed activities.

Under the provisions of the Decommissioning Plan, personnel at the Waltz Mill Site currently provide certain oversight activities with respect to radiation safety for the WTR facility decommissioning project. These oversight activities primarily involve the review and approval of the implementation of decommissioning activities utilizing the Waltz Mill Radiation Safety Committee that is established under the site's active SNM-770 license. The assets and facilities, including personnel, associated with the SNM-770 license will be transferred to WELCO as part of the sale transaction. It therefore will be necessary for CBS and WELCO to continue to coordinate the activities conducted under the active SNM-770 license that support the TR-2 decommissioning activities. CBS therefore also will enter into a contract with WELCO as of the closing date of the sale to continue the site oversight activities currently provided by the Waltz Mill Site under license SNM-770, as described in the Decommissioning Plan.

In summary, in connection with the requested name changeamendment, there will be no substantive change in the personnel who are responsible for

! implementing the TR-2 License decommissioning effort as described in the Decommissioning Plan. All personnel responsible for decommissioning activities under the TR-2 License will continue to be technically qualified to carry out licensed activities. CBS has already established or will establish the i

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necessary contractual relationships to assure the continued involvement of all

,. organizations described in the Decommissioning Plan. The primary new contractual relationship that will be established will be between CBS and WELCO to continue the licensed activities by current Waltz Mill site personnel and qualified third party contractors, subject to CBS oversight, i.e., existing decommissioning personnel will act as contractors and subcontractors to CBS rather than as licensee personnel and contractors. Thus, the requested amendment does not involve any substantive changes in the conduct of licensed activities, which will continue in their current form without interruptions of any kind.

The proposed amendment also does not require any physical change to the WTR facility or changes to the Technical Specifications or procedures under the TR-2 License. The proposed change does not increase the probability of an accident previously evaluated because it does not affect any initiators in any_of the previously evaluated accidents. The proposed change does not increase the consequence of any accident previously evaluated because it does not affect any of the items on which the consequence depend.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Would not create the possibility of a new or dyferent kind of accidentfrom any accident previously evaluated.

The proposed amendment does not modify the WTR facility configuration or licensed activities. Thus no new accident initiators are introduced.

Therefore, the proposed amendment does not create the possibility of a new or different accident from any accident previously evaluated.

3) Would not involve a significant reduction in a margin ofsafety.

This amendment is necessary because of the announced sale (with certain exceptions) of the nuclear businesses of CBS. CBS will continue to be financially qualified to hold the WTR facility TR-2 License.

Furthermore, the CBS personnel responsible for decommissioning activities under the TR-2 License, both CBS employees and contractor personnel reporting to CBS, will continue to be technically qualified to carry out licensed activities. In connection with the name change, there will be no effective change in the personnel who are responsible to implement the TR-2 License decommissioning effort as described in the Decommissioning Plan, although

• there will be new contractual relationships established between CBS and WELCO, as described above in item 1), to continue this effort; i.e., WELCO

Waltz Mill Site personnel and qualified contractors will act as contractors and

,. ,. ' subcontractors to CBS rather than as licensee personnel and contractors. Thus, the requested amendment does not involve any changes in the conduct of licensed activities, which will continue in their current form without interruptions of any kind.

The proposed amendment does not alter any margin of safety because it does not involve any changes in the WTR facility or licensed activities under the TR-2 License which will continue in the current form without interruptions of - -

any kind resulting from the name change. .

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety. -

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• FIGURE 2-13 SNM-770 Remediation and TR-2 Decommissioning Organizational Structure 1

. Westinghouse Electric Co. CBS Corporation WELCO Environmental Remediation Nuclear Service Division V.P. General Manager (2)  !

- Quality and ,

- Environmental Radiation Safety.

ystems Waltz Mill Site Committee . CBS Project j Manager i Office i Radiation Safety

-l Officer (Note 1)

2)  ;

j Manager WELCO Remediation & .

WM Industrial Hygiene, DecommissioningTeam l Safety and Program Manager Environmental.

Compliance Project Technical Lead

. Radiation Safety Officer (Note 1) i Quality GTS Duratek MK l Assurance Health Physics Operations  !

Manager Manager

, Notes:

(1) The WM Radiation Safety Officer reports to the Industrial Hygiene, Safety and Environmental Compliance Manager and is also the Secretary of the Radiation Safety Committee

' (2) Denotes a Contractual Relationship

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