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MONTHYEARML0928000542009-11-17017 November 2009 Aerotest Operations, Inc., NRC Response to November 2, 2009 Extension of Time to Request Hearing on Proposed Denial of License Renewal (Tac ME1887) Project stage: Other ML1001204182010-02-0202 February 2010 Aerotest Operations, Inc. - U. S. Nuclear Regulatory Commission Response to Request for Extension of Time to Request Hearing on Proposed Denial of License Renewal for Facility Operating License No. R-98 Project stage: Other ML1005004042010-02-23023 February 2010 Request for Additional Information Regarding the Proposed Indirect License Transfer of the Aerotest Radiography and Research Reactor for Facility Operating License No. R-98 Project stage: RAI ML1007606162010-03-10010 March 2010 Aerotest Radiography and Research Reactor - Response to Request for Additional Information Regarding Proposed Indirect License Transfer, (Redacted Copy) Project stage: Response to RAI ML1007606182010-03-12012 March 2010 Aerotest Radiography and Research Reactor - Response to Request for Additional Information Regarding Proposed Indirect License Transfer, (Redacted Copy) Project stage: Response to RAI ML1009801532010-04-0101 April 2010 Aerotest Radiography & Research Reactor Response to Request for Additional Information Re Proposed Indirect License Transfer Project stage: Response to RAI ML1034102072011-02-0202 February 2011 Decommissioning Activities at Aerotest Operations Inc., Aerotest Radiography and Research Reactor Project stage: Other 2010-03-10
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Category:Letter
MONTHYEARIR 05000228/20230012024-02-0505 February 2024 NRC Inspection Report 050-00228/2023-001, Disputed Cited Violation and Minor Violation Revised, EA-23-118 ML23279A1062023-10-0202 October 2023 Response to Violation 05000228/2023001-001B ML23255A0342023-09-0909 September 2023 Response to Violation 050-00228/2023-001-00lA ML23255A0362023-09-0909 September 2023 Response to Inspection Report 050-00228/2023-001 ML23219A1882023-08-24024 August 2023 NRC Inspection Report 05000228/2023001, and Notice of Violation ML23187A0562023-07-0101 July 2023 Radiation Safety Officer Change Update ML23187A0582023-07-0101 July 2023 July 1, 2022 Thru June 30, 2023 Summary of Changes, Tests, and Experiments ML23157A0662023-05-24024 May 2023 Letter from David Slaughter, Aerotest Operations, Inc. Inadequate Oversight of Non-Power Reactor OIG Case No. 21-012 and Requested Payment for Damages Caused by the Nrc'S Inadequate Oversight ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML22340A0062022-11-16016 November 2022 Reference Documents from Decommissioning Plan ML22215A1522022-07-21021 July 2022 Aerotest Radiography and Research Reactor - AO RAI Responses for Decommissioning Plan ML22187A0852022-07-0101 July 2022 Inc - July 1, 2021 Thru June 30, 2022 Summary of Changes, Tests, and Experiments ML22152A2522022-06-28028 June 2022 Request for Additional Information on Review of Request for Amendment to Approve Decommissioning Plan, Arrr (License No. R-98, Docket No. 50-228) ML22060A2602022-03-21021 March 2022 Change in NRC Staff Project Management Responsibility for the Aerotest Radiography and Research Reactor ML22040A1992022-03-0909 March 2022 Examination Confirmation Letter No. 50-288/OL-22-03, Reed College ML22025A2002022-01-20020 January 2022 Amendment to AO Decommissioning Plan Submittal Letter Dated July 20, 2021, Agencywide Documents Access, and Management System (ADAMS) Accession No. ML21230A304 ML21307A3242022-01-12012 January 2022 Request for Supplemental Information for Decommissioning Plan, Arrr (License R-98, Docket 50-228) ML21344A0332022-01-0303 January 2022 Aerotest Letter from the Chief Financial Officer Regarding Additional Information for the Fees Assessed Under to Aerotest Operations, Inc. (Aerotest) within Invoice Number Lfb 22-0346 ML21361A0472021-12-21021 December 2021 Response to December 6, 2021 NRC Pol Issuance; the Licensee and Its Reactor Safeguard Committee Request a Reasonable Opportunity to Review and Address Short Comings of the Draft Licensee and Technical Specifications Along with the Draft Sa ML21242A4632021-12-0606 December 2021 Issuance of License Amendment No. 6 to Facility Operating License No. R-98 for the Aerotest Radiography and Research Reactor with Partial Denial of Amendment Request ML21307A1252021-10-28028 October 2021 Letter Regarding Charges Billed ML21209A5192021-07-20020 July 2021 Aerotest Radiography and Research Reactor, Response to NRC Letter Dated July 12, 2021 (ML21188A391) ML21230A3042021-07-20020 July 2021 Decommissioning Plan Submittal (Redacted) ML21147A3732021-07-19019 July 2021 Correction of Letters Regarding Closure of Confirmatory Action Letter No. NRR-04-003 and Review of Physical Security Plan ML21188A3912021-07-12012 July 2021 Inc. - Revised Completion Date Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License ML21188A2162021-07-0101 July 2021 July 1, 2020 Through June 30, 2021 Summary of Changes, Tests, and Experiments ML21193A0892021-07-0101 July 2021 Emergency Plan (Redacted) ML21181A1232021-06-22022 June 2021 License and TS Amendments ML21147A0602021-05-19019 May 2021 Response to RAI 28 and 29 ML21056A3172021-04-30030 April 2021 CFO Response to Aerotest November 11 2020 Letter ML21126A1502021-04-28028 April 2021 License and TS Amendments ML21098A1572021-03-31031 March 2021 Response to RAI CFH Training and Requalification Program- 3/30/21 ML21118A0252021-03-30030 March 2021 Confirmatory Order ML21047A4682021-03-30030 March 2021 Request for Additional Information Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98 ML21034A6262021-03-12012 March 2021 Request for Additional Information Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License No. R-098 ML21048A1392021-03-0505 March 2021 Acknowledgement of Letter Regarding Decommissioning Plan and Exercise of Enforcement Discretion ML21004A0792021-01-0707 January 2021 Review of Physical Security Plan in Support of Possession-Only License Amendment Request License No. R-98 ML20345A0312020-12-28028 December 2020 CFO Response to Aerotest November 2020 Letter Re Lfb 20-1849 IR 05000228/20202022020-12-10010 December 2020 U.S. Nuclear Regulatory Commission Security Inspection Report No. 05000228/2020202 and Notice of Violation - Non-OUO-SRI (Cover Letter) ML20332A0322020-11-18018 November 2020 Unable to Submit Decommissioning Plan by December 5, 2020 Due to COVID-19 ML20295A4242020-11-16016 November 2020 Notification of Mailing Address Change Regarding Submittal of Fingerprint Cards ML20325A1762020-11-11011 November 2020 Response to NRC CFO, Letter Dated April 18, 2019 Re Reimbursement Request for Activities Associated with the Fees That Were Not Performed in a Satisfactory Manner ML20325A1342020-11-10010 November 2020 Letter Disputing to Make Payment for Services That Are Not or Poorly Rendered ML20289A4772020-10-23023 October 2020 Aerotest Response Letter from D. Slaughter Dated September 14, 2020 Docket 50-228 ML20304A1532020-10-21021 October 2020 Response to Notice of Violation IR 05000228/20202012020-10-15015 October 2020 U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000228/2020201 and Notice of Violation ML20276A2472020-09-28028 September 2020 Aerotest Radiography and Research Reactor - Updated Arrr Security Plan ML20234A6312020-09-17017 September 2020 Request for Clarification Physical Security Plan Review - Cover Letter - (Public Version) ML20248H4602020-08-28028 August 2020 Inc - List of Explanations, Changes, and Justifications for Raj CFH Training and Requalification Program ML20177A2032020-07-27027 July 2020 Request for Additional Information Possession-Only License Amendment Request to Use Certified Fuel Handlers for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98 2024-02-05
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML22152A2522022-06-28028 June 2022 Request for Additional Information on Review of Request for Amendment to Approve Decommissioning Plan, Arrr (License No. R-98, Docket No. 50-228) ML21201A3622021-06-0303 June 2021 (External Sender) E-mail NRC RAI follow-up Letter Opportunity to Review the Draft Enclosure 6.3.21 ML21201A3642021-06-0303 June 2021 Request for Additional Information Regarding Amendment for Possession-Only License Facility Operating License No. R-98 ML21047A4682021-03-30030 March 2021 Request for Additional Information Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98 ML21034A6262021-03-12012 March 2021 Request for Additional Information Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License No. R-098 ML20234A6312020-09-17017 September 2020 Request for Clarification Physical Security Plan Review - Cover Letter - (Public Version) ML20177A2032020-07-27027 July 2020 Request for Additional Information Possession-Only License Amendment Request to Use Certified Fuel Handlers for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98 ML20112F4892020-04-30030 April 2020 Request for Clarification Amendment Request for Possession Only License for the Aerotest Radiography and Research Reactor Facility Operating License No . R-98 ML20034G4452020-02-13013 February 2020 Request for Additional Information Amendment Request for Possession Only License for the Aerotest Radiography and Research Reactor Operating License No. R-98 ML18277A2962018-10-15015 October 2018 Request for Additional Information Regarding the Operator Requalification Program for the Aerotest Radiography and Research Reactor ML18186A5782018-07-16016 July 2018 Request for Supplemental Information Regarding Request for 10 CFR 170.11 and 171.11 Fee Exemptions ML18088A7012018-04-24024 April 2018 Request for Additional Information Regarding the Renewal of Facility Operating License No. R-98 ML18088A7552018-03-29029 March 2018 Aerotest Operations, Inc.: Draft Aerotest License Renewal Request for Additional Information ML17277B2612017-10-24024 October 2017 Aerotest Radiography and Research Reactor, Request for Additional Information Regarding the Renewal of Facility Operating License No. R-98 ML16182A3972016-07-20020 July 2016 Aerotest Operations Inc. and Nuclear Labyrinth LLC - Request for Additional Information Re: Supplemented 2012 Application for Approval of Indirect Transfer of Control of License of Aerotest Radiography and Research Reactor Pursuant To 10 CFR 50.80 ML15335A4532016-01-20020 January 2016 Request for Additional Information Regarding Aerotest Operations, Inc's Application for a Change in Method of Providing Financial Protection ML12242A4792012-09-14014 September 2012 Inc., and Nuclear Labyrinth LLC - Enclosure 2 NON-PROP Request for Additional Information Application for Approval of Indirect Transfer of Control of License of Aerotest Radiography and Research Reactor ML1217403432012-07-0505 July 2012 Labyrinth LLC Request for Supplemental Information ML1005004042010-02-23023 February 2010 Request for Additional Information Regarding the Proposed Indirect License Transfer of the Aerotest Radiography and Research Reactor for Facility Operating License No. R-98 ML0903000682009-02-0404 February 2009 Aerotest Operations Inc- Request for Additional Information Regarding License Renewal Request Application and Financial Qualifications ML0526902742005-10-0707 October 2005 RAI Letter - Security Measures - Tsukimura 2022-06-28
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Text
February 23, 2010
Mr. Dario Brisighella, President
Aerotest Operations, Inc.
3350 Airport Road Ogden, UT 84405
SUBJECT:
AEROTEST OPERATIONS, INC. - REQUEST FOR ADDITIONAL INFORMATION REGARDINGTHE PROPOSED INDIRECT LICENSE TRANSFER OF THE AEROTEST RADIOGRAPHY AND RESEARCH REACTOR (TAC NO. ME1887)
Dear Mr. Brisighella:
The U.S. Nuclear Regulatory Commission is reviewing your January 7, 2010 application for consent to transfer Facility Operating License No. R-98 for the Aerotest Radiography and Research Reactor (ARRR). During our review, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information no later than March 26, 2010. In accordance with Title 10 of the
Code of Federal Regulations Part 50.30(b), your response must be executed in a signed original under oath or affirmation.
If you have any questions regarding this review, please contact me at 301-415-3398 or by electronic mail to Cindy.Montgomery@nrc.gov. Sincerely, /RA/ Cindy K. Montgomery, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
Docket No. 50-228
License No. R-98
Enclosure:
As stated
cc w/encl: See next page
ML100500404 NRR-088 OFFICE PRLB: PM PRLB: LA PFPB:PM PRLB: BC PRLB: PM NAME CMontgomery GLappert JSimpson KBrock CMontgomery DATE 2/19/2010 2/22/2010 2/22/2010 2/23/10 2/23/10 Aerotest Operations, Inc.
Docket No. 50-228 cc:
Michael S. Anderson Vice President for Legal Affairs and General Counsel Autoliv ASP, Inc.
1320 Pacific Drive Auburn Hills, MI 48326
Robert B. Haemer Pillsbury Winthrop Shaw Pittman LLP
2300 N Street, NW Washington, DC 20037-1122 OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING THE INDIRECT LICENSE TRANSFER AEROTEST RADIOGRAPHY AND RESEARCH REACTOR FACILITY OPERATING LICENSE NO. R-98 DOCKET NO. 50-288 Financial Qualifications
As required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.80(b)(1)(i), "[A]n application for transfer of a license shall include] for a construction permit or operating license under this part, as much of the information described in §50.33 and 50.34 of this part with respect to the identity and technical and financial qualifications of the proposed transferee as would be required by those sections if the application were for an initial license." To comply with this requirement, please provide the following additional information to the January 7, 2010, amended on February 2, 2010, indirect license transfer application (the application) of Aerotest
Operations, Inc., (Aerotest) from OEA Aerospace, Inc., and OEA, Inc., subsidiaries of Autoliv ASP, Inc., (Autoliv, seller applicant) to X-Ray Industries, Inc., (X-Ray Industries, buyer
applicant).
- 1. Pursuant to 10 CFR 50.80(b)(2), provide a statement of the purposes for which the transfer of the license is requested, and the nature of the transaction necessitating or making desirable the transfer of the license.
- 2. As described in 10 CFR 50.33(a)-(d), provide all of the general information for X-Ray Industries, OEA Aerospace, Inc., OEA, Inc., and any X-Ray Industries-owned entities in the ownership chain of the prospective licensee, including, but not limited to names, addresses and citizenship of the principal officers. Describe the relationship of OEA Aerospace, Inc., and OEA, Inc., and ownership interest as it relates to the proposed license transfer.
- 3. Please state whether X-Ray Industries is owned, controlled, or dominated by an alien, a foreign corporation, or foreign government, and, if so, give details.
- 4. Pursuant to 10 CFR 50.80(b)(1)(i), please provide a copy of X-Ray Industries latest annual financial statements since they were not included in the license transfer application.
- 5. Pursuant to 10 CFR 50.33(f)(2), "-the applicant shall submit information that demonstrates the applicant possesses or has reasonable assurance of obtaining the funds necessary to cover estimated operation costs for the period of the license." In order for the U. S. Nuclear Regulatory Commission (NRC) staff to complete its review of
the application, please provide the following additional information to complete its
review: (a) A projected income statement for the first five years of operations of Aerotest which includes, at a minimum, the following six line items: total revenue; total operating expense (O&M); net operating income; other income, expenses, and taxes; decommissioning funding, and net income after tax.
(b) The source(s) of funds to cover the operating costs pursuant to 10 CFR 50.33(b)(1)(c).
(c) A projected balance sheet, which recognizes decommissioning costs as a liability, as allowed by 10 CFR 50.33(f)(5).
- 6. Pursuant to 10 CFR 50.75(d)(1), "[e]ach non-power reactor applicant for or holder of an operating license for a production or utilization facility shall submit a decommissioning report as required by §50.33(k) of this part." Under 50.75(d)(2) the report must "(i) Contain a cost estimate for decommissioning the facility; (ii) Indicate which method or methods described in paragraph (e) of this section as acceptable to the NRC will be used to provide funds for decommissioning; and (iii) Provide a description of the means of adjusting the cost estimate and associated level periodically over the life of the facility."
In order for the NRC staff to complete its review, provide the basis for the decommissioning cost estimate in Attachment 1: "Decommissioning Funding Analysis for Aerotest Radiography and
Research Reactor." The NRC staff notes that the previous decommissioning cost estimate, stated in the April 28, 2009 teleconference, was $4.7 million, but the new estimate in the January 7, 2010 license transfer application was $2.3 million. Please provide:
(a) Clarification of the actual current cost to decommission the ARRR to meet the NRC's radiological release criteria for decommissioning the facility for unrestricted use to comply with 10 CFR 50.75(d)(2), including but not limited to the following information:
(1) A description of the basis on how the decommissioning cost estimate was developed, including, but not limited to:
I. labor, energy, and waste disposal cost assumptions for the Aerotest facility;
II. A description of Sites A, B, and C, which were used to develop the square foot cost estimate, including the dates of these estimates;
III. For Sites A, B, and C, provide the size of the reactor; the amount of radioactive waste; the unit disposal costs of radioactive waste;
the extent of contamination; labor-hours; and time to complete decommissioning. Compare the values of Sites A, B, and C to the values of the Aerotest facility. Provide supporting documentation for all calculations, including square footage calculations.
(2) Clarification of the total amount of decommissioning financial assurance to be provided. The NRC staff notes that the application states that the amount needed to provide decommissioning funding assurance (Attachment 1) is $1,150,000 based on a net present value calculation.
Since Aerotest does not qualify to use an external sinking fund, the full amount of the decommissioning cost estimate must be covered using one or more of the acceptable funding mechanisms noted in 10 CFR 50.75(e);
such as prepayment or a letter of credit.
(3) Provide the basis for including a 2% real rate of return calculation through 2045. (4) Provide the source of the $2 million in funding listed as "Amount available initially."
(5) Provide the source of the $1.25 million in additional funding listed as "Amount available in 2015."
(6) What guarantee(s) can X-Ray Industries provide to demonstrate that required decommissioning funds will be obtained and deposited into the
trust fund?
(b) Clarification of the decommissioning financial assurance method or methods to be used to provide financial assurance per NRC regulations. The Buyer's Commitment letter (Attachment 2) dated January 6, 2010, is not an acceptable decommissioning financial assurance mechanism. The NRC staff notes that an acceptable decommissioning financial assurance mechanism will clearly state the party responsible to provide decommissioning funding.
(c) A statement of the decommissioning method to be used (e.g., DECON, SAFSTOR, or other method) and the estimated length of time required to decommission the facility.
(d) A description of the means of adjusting the cost estimate and associated funding level periodically over the life of the facility, to comply with 10 CFR 50.75(d)(2)(ii).
Since the application does not provide this information, please update the application to include a full description of the method to be used as the means of adjusting the cost estimate and associated funding level periodically over the life of the facility.
Technical Qualifications
- 7. Pursuant to 10 CFR 2.1315(b) "Where administrative license amendments are necessary to reflect an approved transfer, such amendments will be included in the order that approves the transfer-" Please provide proposed modifications to the Technical Specifications for the proposed indirect transfer of ownership from Autoliv ASP, Inc., to X-Ray Industries to conform the license to reflect the transfers of control (e.g. changes to the name of the licensee). Please provide a markup of the current Technical Specifications and a copy of the proposed Technical Specifications incorporating the changes.
- 8. Pursuant to 10 CFR 50.80 (b)(1)(i) "An application for transfer of a license shall include:
-as much of the information described in §§ 50.33 and 50.34 of this part with respect to the identity and technical and financial qualifications of the proposed transferee as would be required by those sections if the application were for an initial license-" Furthermore, pursuant to 10 CFR 50.33(f) "The Commission may request-information regarding a licensee's ability to continue the conduct of the activities authorized by the license and to decommission the facility."
Your January 7, 2010 license transfer application states that "The Parties are aware of no changes in personnel or duties related to the licensed programs. The Buyer intends to retain the current management team at the facility, except Scott W. Thams
[President, X-Ray Industries, Inc.] will replace Dario Brisighella [President, Aerotest
Operations, Inc.]" In order for the NRC staff to complete its review, please confirm that the management and technical personnel at the Aerotest Radiography and Research Reactor located in San Ramone, California who are responsible for licensed activities including reactor safety and nuclear safety will become employees of X-Ray Industries and will not change due to the license transfer.