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This letter provides the fourteenth response to U.S. Nuclear Regulatory Commission
This letter provides the fourteenth response to U.S. Nuclear Regulatory Commission
("NRC") letters dated February 26, 2011 and May 24, 2011 in the above docket. This letter forwards an affidavit executed by Dario Brisighella on December 13, 2011, updating the previous responses.
("NRC") letters dated February 26, 2011 and May 24, 2011 in the above docket. This letter forwards an affidavit executed by Dario Brisighella on December 13, 2011, updating the previous responses.
Three potential buyers have each signed a Non-Disclosure Agreement.
Three potential buyers have each signed a Non-Disclosure Agreement. Aerotest has received two written offers outlining the terms for acquisition of the Aerotest Radiography and Research Reactor ("ARRR"). One entity continues due diligence reviews and is expected to submit a written offer by the middle of January. On that schedule, Aerotest estimates that negotiations with current potential buyers will end by the end of February 2012. Based on these dates, Aerotest, by the end of March 2012, will submit to the NRC either (1) a request for a possession only license ("POL") or (2) a schedule for submitting a license transfer application.
Aerotest has received two written offers outlining the terms for acquisition of the Aerotest Radiography and Research Reactor ("ARRR").
In addition, the attached affidavit states Aerotest expects that the NRC will hold a public meeting where additional guidance on decommissioning ARRR with fuel on site would be discussed.               Therefore,. Aerotest currently plans to delay submitting the decommissioning plan until some time after that public meeting.
One entity continues due diligence reviews and is expected to submit a written offer by the middle of January. On that schedule, Aerotest estimates that negotiations with current potential buyers will end by the end of February 2012. Based on these dates, Aerotest, by the end of March 2012, will submit to the NRC either (1) a request for a possession only license ("POL") or (2) a schedule for submitting a license transfer application.
Aerotest will provide its next update by December 27, 2011.
In addition, the attached affidavit states Aerotest expects that the NRC will hold a public meeting where additional guidance on decommissioning ARRR with fuel on site would be discussed.
The undersigned affirms the accuracy of the contents of this letter to best of his 40ý I'D
Therefore,.
 
Aerotest currently plans to delay submitting the decommissioning plan until some time after that public meeting.Aerotest will provide its next update by December 27, 2011.The undersigned affirms the accuracy of the contents of this letter to best of his 40ý I'D pillsbur1 Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW I Washington, DC 20037-1122 I tel 202.663.8000 I fax 202.663.8007 knowledge and belief. If you have any questions regarding this submittal, please contact the undersigned at (202) 663-9086 (robert.haemerbpillsburylaw.com) or Michael S.Anderson, Secretary of Aerotest at (248) 475-0442 (mike.anderson ,autoliv.com).
pillsbur1 Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW I Washington, DC 20037-1122 I tel 202.663.8000 I fax 202.663.8007 knowledge and belief. If you have any questions regarding this submittal, please contact the undersigned at (202) 663-9086 (robert.haemerbpillsburylaw.com) or Michael S.
Sincerely, Robert. B. Haemer Counsel for Aerotest Operations, Inc.cc: U.S. NRC Office of Nuclear Reactor Regulation/NRLPO U.S. NRC Region IV, Regional Administrator NRC, NRR (S. Traiforos)
Anderson, Secretary of Aerotest at (248) 475-0442 (mike.anderson ,autoliv.com).
Sincerely, Robert. B. Haemer Counsel for Aerotest Operations, Inc.
cc:       U.S. NRC Office of Nuclear Reactor Regulation/NRLPO U.S. NRC Region IV, Regional Administrator NRC, NRR (S. Traiforos)
NRC, OGC (S. Uttal)
NRC, OGC (S. Uttal)
AFFIDAVIT OF DARIO BRISIGHELLA STATE OF UTAH ))ss))COUNTY OF WEBER )I, Dario Brisighella, President Aerotest Operations, Inc., do hereby affirm and state: 1. I am authorized to execute this affidavit on behalf of Aerotest Operations, Inc.(hereinafter referred to as "Aerotest").
 
: 2. I provide this affidavit pursuant to the actions described in the NRC letter to Aerotest of February 26, 2011, also known as a Confirmatory Action Letter. This affidavit also responds to the request for additional information in NRC letter of May 24, 2011.3. Three potential buyers have signed Non-Disclosure Agreements
AFFIDAVIT OF DARIO BRISIGHELLA STATE OF UTAH                       )
("NDA").Aerotest has received two written offers outlining the terms for acquisition of the Aerotest Radiography and Research Reactor ("ARRR").
                                    )ss
One entity continues due diligence reviews and is expected to submit a written offer by the middle of January.Based on that schedule, Aerotest estimates that negotiations with current buyers will end by the end of February 2012. Based on these dates, Aerotest, by the end of March 2012, will submit to the NRC either (1) a request for a possession only license ("POL")within thirty days after negotiations with current potential buyers cease or (2) a schedule for submitting a license transfer application.
                                    )
: 4. Current operations and status of the ARRR remain as described in paragraph 1 of Aerotest letter of January 7, 2011.5. Current staffing of the ARRR remain as described in paragraph 2 of Aerotest letter of January 7, 2011.6. After reviewing proposals from two decommissioning contractors, EnergySolutions, Inc. ("EnergySolutions")
                                    )
was selected as the decommissioning contractor in January 2011. A contract with EnergySolutions was signed in late February 2011.7. EnergySolutions has submitted a draft decommissioning plan to Aerotest and associated supporting documents to Aerotest for review. The draft decommissioning plan assumes spent fuel has been removed from the site. Reflecting a September 2010 change to the Aerotest contract with the U.S. Department of Energy ("DOE") for spent fuel acceptance under which the DOE would not agree to remove the fuel from the ARRR site until 2055 or later, EnergySolutions proposes that Aerotest not plan to submit the decommissioning plan to the NRC until 18 months after spent fuel is removed from the ARRR site.8. The NRC guidance in the Guidelines for Preparing and Receiving Applications for the Licensing of Non-Power Reactors (NUREG-1537), Part 1, § 17.1.5, is based on a project promptly commencing spent fuel removal and decontamination.
COUNTY OF WEBER                     )
If the project cannot meet these conditions, the guidance states that the licensee should contact the appropriate NRC project manager. Aerotest and the NRC project manager have had several discussions starting on November 21, 2011 relating to the guidance in § 17.1.5.Aerotest expects the NRC will schedule a public meeting to discuss additional guidance for preparing a decommissioning plan with spent fuel on site at ARRR.9. Aerotest has commenced drafting an application for a POL, but that work is complicated by needing to address retaining fuel on site. Fuel management options continue to be studied; and these options impact the details of any revisions to the technical specifications that would accompany a POL request.10. Aerotest is developing a decommissioning funding plan and a fuel management funding plan in parallel with the EnergySolutions finalizing the decommissioning plan cost estimate.11. Aerotest has no plans to commence research or N-ray work at the ARRR.Aerotest is not aware of any regulatory approvals required prior to resuming such work.Dario Brisighella, being duly sworn, states that I am President of Aerotest, that I am authorized on the part of said Company to sign and file with the U. S. Nuclear Regulatory Commission this affidavit, and that all the matter and facts set forth herein are true and correct to the best of my knowledge.
I, Dario Brisighella, President Aerotest Operations, Inc., do hereby affirm and state:
Dario Brisighella President, Aerotest Operations, Inc.Subscribed and sworn to before me, a Notary Public, in and for the county and state above named, thisLa day of December, 2011.C otary u bicina ndfo r State of Utah TERRI SCOVILL My Commission Expires: "Notary Public, State of Utah My Commission E 'PJlnb,} Commission  
: 1.     I am authorized to execute this affidavit on behalf of Aerotest Operations, Inc.
# 575822 MyCommiasion Expires otobr2l)0, 2012 2}}
(hereinafter referred to as "Aerotest").
: 2.     I provide this affidavit pursuant to the actions described in the NRC letter to Aerotest of February 26, 2011, also known as a Confirmatory Action Letter. This affidavit also responds to the request for additional information in NRC letter of May 24, 2011.
: 3.     Three potential buyers have signed Non-Disclosure Agreements ("NDA").
Aerotest has received two written offers outlining the terms for acquisition of the Aerotest Radiography and Research Reactor ("ARRR"). One entity continues due diligence reviews and is expected to submit a written offer by the middle of January.
Based on that schedule, Aerotest estimates that negotiations with current buyers will end by the end of February 2012. Based on these dates, Aerotest, by the end of March 2012, will submit to the NRC either (1) a request for a possession only license ("POL")
within thirty days after negotiations with current potential buyers cease or (2) a schedule for submitting a license transfer application.
: 4.     Current operations and status of the ARRR remain as described in paragraph 1 of Aerotest letter of January 7, 2011.
: 5.     Current staffing of the ARRR remain as described in paragraph 2 of Aerotest letter of January 7, 2011.
: 6.     After   reviewing   proposals     from   two     decommissioning     contractors, EnergySolutions, Inc. ("EnergySolutions") was selected as the decommissioning contractor in January 2011. A contract with EnergySolutions was signed in late February 2011.
: 7.     EnergySolutions has submitted a draft decommissioning plan to Aerotest and associated supporting documents to Aerotest for review. The draft decommissioning plan assumes spent fuel has been removed from the site. Reflecting a September 2010 change to the Aerotest contract with the U.S. Department of Energy ("DOE") for spent fuel acceptance under which the DOE would not agree to remove the fuel from the ARRR site until 2055 or later, EnergySolutions proposes that Aerotest not plan to
 
submit the decommissioning plan to the NRC until 18 months after spent fuel is removed from the ARRR site.
: 8. The NRC guidance in the Guidelines for Preparing and Receiving Applications for the Licensing of Non-Power Reactors (NUREG-1537), Part 1, § 17.1.5, is based on a project promptly commencing spent fuel removal and decontamination. Ifthe project cannot meet these conditions, the guidance states that the licensee should contact the appropriate NRC project manager. Aerotest and the NRC project manager have had several discussions starting on November 21, 2011 relating to the guidance in § 17.1.5.
Aerotest expects the NRC will schedule a public meeting to discuss additional guidance for preparing a decommissioning plan with spent fuel on site at ARRR.
: 9. Aerotest has commenced drafting an application for a POL, but that work is complicated by needing to address retaining fuel on site. Fuel management options continue to be studied; and these options impact the details of any revisions to the technical specifications that would accompany a POL request.
: 10. Aerotest is developing a decommissioning funding plan and a fuel management funding plan in parallel with the EnergySolutions finalizing the decommissioning plan cost estimate.
: 11. Aerotest has no plans to commence research or N-ray work at the ARRR.
Aerotest is not aware of any regulatory approvals required prior to resuming such work.
Dario Brisighella, being duly sworn, states that I am President of Aerotest, that I am authorized on the part of said Company to sign and file with the U. S. Nuclear Regulatory Commission this affidavit, and that all the matter and facts set forth herein are true and correct to the best of my knowledge.
Dario Brisighella President, Aerotest Operations, Inc.
Subscribed and sworn to before me, a Notary Public, in and for the county and state above named, thisLa day of December, 2011.
C         otary u bicina ndfo r     State of Utah TERRI SCOVILL My Commission Expires:                     "Notary My Commission E   'PJlnb,}       Public, State of Utah Commission # 575822 MyCommiasion Expires otobr2l)0, 2012 2}}

Latest revision as of 11:39, 12 November 2019

Aerotest Radiography and Research Reactor - Fourteenth Response to NRC Letters of February 26, 2011 and May 24, 2011
ML11354A096
Person / Time
Site: Aerotest
Issue date: 12/13/2011
From: Haemer R
Aerotest, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11354A096 (4)
v • d • e


Text

pillsburq Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW I Washington, DC 20037-1122 I tel 202.663.8000 1 fax 202.663.8007 Robert B. Haemer tel 202.663.9086 robert.haemer@pillsburylaw.com License No. R-98 December 13, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike Rockville MD 20852 via courier Aerotest Radiography and Research Reactor Docket No. 50-228 Fourteenth Response to NRC Letters of February 26, 2011 and May 24, 2011 Ladies and Gentlemen:

This letter provides the fourteenth response to U.S. Nuclear Regulatory Commission

("NRC") letters dated February 26, 2011 and May 24, 2011 in the above docket. This letter forwards an affidavit executed by Dario Brisighella on December 13, 2011, updating the previous responses.

Three potential buyers have each signed a Non-Disclosure Agreement. Aerotest has received two written offers outlining the terms for acquisition of the Aerotest Radiography and Research Reactor ("ARRR"). One entity continues due diligence reviews and is expected to submit a written offer by the middle of January. On that schedule, Aerotest estimates that negotiations with current potential buyers will end by the end of February 2012. Based on these dates, Aerotest, by the end of March 2012, will submit to the NRC either (1) a request for a possession only license ("POL") or (2) a schedule for submitting a license transfer application.

In addition, the attached affidavit states Aerotest expects that the NRC will hold a public meeting where additional guidance on decommissioning ARRR with fuel on site would be discussed. Therefore,. Aerotest currently plans to delay submitting the decommissioning plan until some time after that public meeting.

Aerotest will provide its next update by December 27, 2011.

The undersigned affirms the accuracy of the contents of this letter to best of his 40ý I'D

pillsbur1 Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW I Washington, DC 20037-1122 I tel 202.663.8000 I fax 202.663.8007 knowledge and belief. If you have any questions regarding this submittal, please contact the undersigned at (202) 663-9086 (robert.haemerbpillsburylaw.com) or Michael S.

Anderson, Secretary of Aerotest at (248) 475-0442 (mike.anderson ,autoliv.com).

Sincerely, Robert. B. Haemer Counsel for Aerotest Operations, Inc.

cc: U.S. NRC Office of Nuclear Reactor Regulation/NRLPO U.S. NRC Region IV, Regional Administrator NRC, NRR (S. Traiforos)

NRC, OGC (S. Uttal)

AFFIDAVIT OF DARIO BRISIGHELLA STATE OF UTAH )

)ss

)

)

COUNTY OF WEBER )

I, Dario Brisighella, President Aerotest Operations, Inc., do hereby affirm and state:

1. I am authorized to execute this affidavit on behalf of Aerotest Operations, Inc.

(hereinafter referred to as "Aerotest").

2. I provide this affidavit pursuant to the actions described in the NRC letter to Aerotest of February 26, 2011, also known as a Confirmatory Action Letter. This affidavit also responds to the request for additional information in NRC letter of May 24, 2011.
3. Three potential buyers have signed Non-Disclosure Agreements ("NDA").

Aerotest has received two written offers outlining the terms for acquisition of the Aerotest Radiography and Research Reactor ("ARRR"). One entity continues due diligence reviews and is expected to submit a written offer by the middle of January.

Based on that schedule, Aerotest estimates that negotiations with current buyers will end by the end of February 2012. Based on these dates, Aerotest, by the end of March 2012, will submit to the NRC either (1) a request for a possession only license ("POL")

within thirty days after negotiations with current potential buyers cease or (2) a schedule for submitting a license transfer application.

4. Current operations and status of the ARRR remain as described in paragraph 1 of Aerotest letter of January 7, 2011.
5. Current staffing of the ARRR remain as described in paragraph 2 of Aerotest letter of January 7, 2011.
6. After reviewing proposals from two decommissioning contractors, EnergySolutions, Inc. ("EnergySolutions") was selected as the decommissioning contractor in January 2011. A contract with EnergySolutions was signed in late February 2011.
7. EnergySolutions has submitted a draft decommissioning plan to Aerotest and associated supporting documents to Aerotest for review. The draft decommissioning plan assumes spent fuel has been removed from the site. Reflecting a September 2010 change to the Aerotest contract with the U.S. Department of Energy ("DOE") for spent fuel acceptance under which the DOE would not agree to remove the fuel from the ARRR site until 2055 or later, EnergySolutions proposes that Aerotest not plan to

submit the decommissioning plan to the NRC until 18 months after spent fuel is removed from the ARRR site.

8. The NRC guidance in the Guidelines for Preparing and Receiving Applications for the Licensing of Non-Power Reactors (NUREG-1537), Part 1, § 17.1.5, is based on a project promptly commencing spent fuel removal and decontamination. Ifthe project cannot meet these conditions, the guidance states that the licensee should contact the appropriate NRC project manager. Aerotest and the NRC project manager have had several discussions starting on November 21, 2011 relating to the guidance in § 17.1.5.

Aerotest expects the NRC will schedule a public meeting to discuss additional guidance for preparing a decommissioning plan with spent fuel on site at ARRR.

9. Aerotest has commenced drafting an application for a POL, but that work is complicated by needing to address retaining fuel on site. Fuel management options continue to be studied; and these options impact the details of any revisions to the technical specifications that would accompany a POL request.
10. Aerotest is developing a decommissioning funding plan and a fuel management funding plan in parallel with the EnergySolutions finalizing the decommissioning plan cost estimate.
11. Aerotest has no plans to commence research or N-ray work at the ARRR.

Aerotest is not aware of any regulatory approvals required prior to resuming such work.

Dario Brisighella, being duly sworn, states that I am President of Aerotest, that I am authorized on the part of said Company to sign and file with the U. S. Nuclear Regulatory Commission this affidavit, and that all the matter and facts set forth herein are true and correct to the best of my knowledge.

Dario Brisighella President, Aerotest Operations, Inc.

Subscribed and sworn to before me, a Notary Public, in and for the county and state above named, thisLa day of December, 2011.

C otary u bicina ndfo r State of Utah TERRI SCOVILL My Commission Expires: "Notary My Commission E 'PJlnb,} Public, State of Utah Commission # 575822 MyCommiasion Expires otobr2l)0, 2012 2

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