ML21293A252

Amended Safety Evaluation Report

ML21293A252
Person / Time
Site:	Framatome ANP Richland
Issue date:	10/19/2021
From:	NRC/NMSS/DFM/FFLB
To:	Framatome
O S-PEREZ NRC/NMSS/DFM/FFLB 3014157827
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ML21293A251	List: ML21293A252 ML21293A253
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Download: ML21293A252 (4)

Text

OFFICIAL USE ONLY - PROPRIETARY INFORMATION

AMENDED SAFETY EVALUATION REPORT

DOCKET NUMBER: 70-1257

LICENSE NUMBER: SNM-1227

LICENSEE: Framatome, Inc.

SUBJECT:

FRAMATOME, INC., AMENDMENT 16 - TRIENNIAL UPDATE TO DECOMMISSIONING FUNDING PLAN

1.0 BACKGROUND

Nuclear facilities licensed under Title 10 of the Code of Federal Regulations (10 CFR), Part 70, are required to provide adequate financial assurance for decomm issioning, decontamination and reclamation pursuant to 10 CFR Section 70.25, Financial as surance and recordkeeping for decommissioning. Framatome, Inc. (Framatome or the licensee) is the holder of Special Nuclear Material License Number SNM-1227. Pursuant to 10 CFR P aragraph 70.25(e)(2),

Framatome is required to submit an updated decommissioning fund ing plan (DFP) and financial assurance at least every 3 years for U.S. Nuclear Regulatory Co mmissions (NRC) review and approval.

By letter dated January 28, 2021 (Agencywide Documents Access M anagement System

[ADAMS] Accession Number ML21028A753), Framatome submitted an u pdated decommissioning cost estimate (DCE) for its Richland Facility. The NRC staff accepted Framatomes submittal by letter dated March 17, 2021 (ADAMS Acc ession Number ML21074A022) and proceeded to conduct its detailed review. By letter dated April 30, 2021 (ADAMS Accession Number ML21116A141), the NRC staff issued a re quest for additional information requesting Framatome to provide information that wa s necessary before final action could be taken. By letter dated June 8, 2021 (ADAMS Accession Number ML21159A159),

Framatome provided its response to the NRC staffs request.

2.0 REGULATORY REQUIREMENTS

As required by 10 CFR 70.25(e)(2), Framatome must continue to s ubmit an updated cost estimate for decommissioning for NRCs review at intervals not to exceed 3 years. After resolution of any NRC staff comments on the estimate, Framatome must submit a signed original of the financial instrument reflecting an amount suffi cient to cover the approved cost estimate. Framatome remains responsible for the current status and future decommissioning of the licensed site and facility, and for abiding by all commitme nts and representations previously made to the NRC. Framatome must abide by all constraints, cond itions, requirements, representations, and commitments identified in the license.

3.0 REGULATORY GUIDANCE

The NRC staff utilizes NUREG-1757, Vol. 3, Rev. 1, Consolidate d NMSS Decommissioning Guidance - Financial Assurance, Recordkeeping, and Timeliness as guidance to evaluate the decommissioning funding plans submitted by 10 CFR 70 licensees.

Enclosure 1

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4.0 NRC STAFF EVALUATION

The NRC staff approved Framatomes previous DCE by letter dated July 9, 2018 (ADAMS Accession Number ML18186A236) in the amount of $66,425,800. Fr amatomes 2021 DCE is in the amount of $81,580,462, which is a $15,154,200 increase over its previously approved cost estimate.

In its submittal, Framatome stated that the DFP and associated decommissioning cost estimate had been prepared in accordance with the requirements of 10 CFR 70.25 and the guidance provided in NUREG-1757, Vol. 3, Rev. 1, Consolidated NMSS Decommissioning Guidance - Financial Assurance, Recordkeeping, and Timeliness.

The NRC staff noted that, in Section 2 of the updated DFP, Fram atome provided justification for the key assumptions used in the preparation of the DFP and cost estimate for the decommissioning of their Richland Facility. In addition, the N RC staff noted that in Table 7 of its 2021 DCE, Framatome provided the cost to perform decommissionin g activities based on the billing rates (wages, benefits, overheads, and profits) from th e State of Washington-based third-party contractors. Framatome also based its DCE on unres tricted use and used a contingency factor to estimate the total decommissioning costs. The NRC staff also noted that, in accordance with the requirements in 10 CFR 70.25(e)(2), Fram atome considered the effect of the following events on its decommissioning costs:

1. Spills of radioactive material

Framatome stated that, No spills that will impact decommission ing costs have occurred.

The few very minor unplanned contamination events since the las t update have been cleaned up to release limits and any contaminated soil or aspha lt was packaged into waste drums.

2. Waste inventory increases

Framatome has updated Table 26 in the DCE to reflect current wa ste inventory.

3. Waste disposal costs increases

Framatome has updated its disposal costs since the last DCE upd ate to reflect recent quotes. The estimated disposal costs are primarily due to incr eased disposal and labor costs. The waste volume estimates for decommissioning is uncha nged.

4. Facility modifications

Framatome stated that since the last DFP update, the Scrap Uran ium Recovery Facility (SURF) Building was constructed to house a replacement of the G adolinia Scrap Uranium Recovery Facility (fuel scrap dissolution and solvent extractio n activities) that was previously located in the ELO Building. Due to the addition of the SURF b uilding, the volume of contaminated piping, duct work and other equipment has changed. In addition, some equipment stored that had not been previously accounted for, in cluding two rod scanners, have been included. The additional costs for decommissioning t he SURF and the new equipment increased the DCE, and have been included in the curr ent DFP update.

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5. Changes in authorized possession limits

Framatome stated that there have not been any changes in the au thorized possession limits since the last update.

6. Actual remediation costs that exceed the previous cost estim ate

Framatome stated that no actual remediation costs have occurred since the last update.

7. Onsite disposal

Framatome stated that no onsite disposal has occurred.

8. Use of a settling pond

Framatome stated no use of settling ponds has occurred since th e last update. In addition, Framatome stated that the most significant area of known soil c ontamination at their site, the legacy surface impoundment system, has been removed and its ass ociated radiological and non-radiological soil contamination has been remediated to meet Washington State Department of Ecology soil cleanup levels for uranium and regulated chemical constituents.

Framatome also stated that additional soil remediation to meet NRC radiological decommissioning criteria is not anticipated to be necessary.

Based on the information discussed above, the NRC staff finds t hat Framatomes updated DFP meets the regulatory requirements in 10 CFR 70.25(e). Specific ally, Framatome submitted a detailed cost estimate for decommissioning within 3 years of it s last approved estimate. In addition, the NRC staff finds that Framatomes DCE provides jus tification for key assumptions, reflects the cost of an independent contractor to perform decom missioning activities, is based on unrestricted use, and includes an adequate contingency facto r. As such, the NRC staff finds Framatomes triennial DFP update acceptable and should be appro ved.

5.0 ENVIRONMENTAL REVIEW

This action involves a change to surety requirements. Pursuant to 10 CFR 51.22(c)(10), this is a category of action that does not individually or cumulatively have a significant effect on the human environment. Therefore, nei ther an environmental assessm ent nor an environmental impact statement is required for this action.

6.0 CONCLUSION

Based on the review of its January 28, 2021, submittal, and sup plemental letter dated June 8, 2021, the NRC staff finds that Framatomes DCE is based on reas onable, documented, and justified key assumptions, and that it reasonably estimates the current costs to decommission the facility. The NRC staff also found that the DCE adequately reflects the cost of an independent contractor to perform decommissioning activities, i s based on unrestricted use, and includes an adequate contingency factor. Accordingly, the NRC staff finds that Framatomes 2021 DCE satisfies the requirements of 10 CFR 70.25(e) and is c onsistent with the guidance in NUREG-1757, Volume 3, Rev. 1. Therefore, the NRC staff conclud es that Framatomes 2021 DCE of $81,580,462 is reasonable and, as such, is acceptable.

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Framatome must appropriately revise its financial assurance mec hanisms and Certification of Financial Assurance and submit them for NRC staff review within 30 days from the staffs approval date of the 2021 DCE.

7.0 PRINCIPAL CONTRIBUTOR Kenneth Kline, NMSS/REFS

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