ML18222A219

NRC Solar Letter

ML18222A219
Person / Time
Site:	West Valley Demonstration Project
Issue date:	06/19/2018
From:	Bembia P State of NY, Energy Research & Development Authority
To:	Stephen Koenick Division of Decommissioning, Uranium Recovery and Waste Programs
A SNYDER NMSS DUWP
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ML18222A216	List: ML18222A218 ML18222A219
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Download: ML18222A219 (20)

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4 WYORK TEO F OR T UNI T Y NYSERDA ANDREW M. CUOMO Governor Mr. Stephen Koenick, Chief Materials Decommissioning Branch RICHARD L KAUFFMAN Chair June 19, 2018 ALICIA BARTON President and CEO Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11545 Rockville Pike Rockville, MD 20852 st ep hen.koenick

@nrc.g ov

Dear Mr. Koenick:

As we recently discussed, the New York State Energy Research and Development Authority (NYSERDA) has had several discussions with staff of the U.S. Nuclear Regulatory Commission (NRC) over the last two years regarding a proposal by the Town of Ashford to establish a community-shared solar photovoltaic electric generation project on property of the Western New York Nuclear Service Center (WNYNSC).

As described by the town, this project would be in keeping with the town's goals of: 1) identifying reuse options for WNYNSC property that would benefit the town and its residents; and 2) becoming a regional leader in the deployment of renewable energy technologies on a local level. Although the WNYNSC property is currently regulated under an NRC Part 50 license, most of the significant site facilities and the vast majority of the Part SO-regulated material is under the control of the U.S. Department of Energy (DOE) to conduct the West Valley Demonstration Project (WVDP). Given the unique nature of the site and the respective responsibilities of DOE and NYSERDA, NYSERDA staff have had several discussions with NRC on the concept of establishing the solar project. NRC staff indicated that, in order to evaluate the project, NRC would need to see a project description, documentation to show that the proposed facility would be located on nonimpacted property, an evaluation under 10 CFR 50.59 to determine whether a license amendment would be needed, and information from the DOE with regard to whether the proposed solar facility would, in DOE's judgment, inhibit or prevent DOE from taking action under the Atomic Energy Act or the West Valley Demonstration Project Act.1 Con v ersations on the concept of locating a solar facility on WNYNSC property were held in late-20 16 with Michael Nora to, Chief , Materials Decommissioning Branch, Division of Decommissioning, Uranium Recovery and Waste Programs; and in February 2017 with Theodore Smith, Acting Branch Chief, Materials Decommissioning Branch, Division of Decommissioning, Uranium Recovery and Waste Programs. In March 2017 , Amy Snyder , Senior Project Manager. Materials Decommissioning Branch, Division of Decommissioning, U ranium Recovery , and Waste Programs , identified the information NRC would need in order to evaluate a proposed solar facility on the WNYNSC property. PJB/18amd014.pjb New Y or k State Energy Research and D e v e lopment Authority Albany Buffalo 17 Columbia Circle, Albany. NY 12203 6399 726 Exchange Street (P) 1-866 NYSERDA I (F} 518*862-1091 Suite 821 nyserda.ny.gov I info@nyserda.ny.gov Buffalo, NY 14210-1484 (P)716*842-1522 (F)716*842*0156 New York City 1359 Broadway 19th Floor New York. NY 10018-7842 (P) 212-971-5342 (F) 518-862-1091 West Valley Site Management Program 9030-B Route 219 West Valley, NY 14171-9500

{Pl 716-942-9960

{F) 716*942*9961 Mr. Stephen l<oenick Page 2 June 19, 2018 As you and I discussed, the NRC does not normally review 50.59 evaluations prepared by l i censees because the 50.59 process is structured to enable licensees to make changes without prior NRC approval.

Given the unique nature of the West Valley facility, however, we asked that NRC conduct a "screen" of the information and provide NYSERDA with any comments or questions related to the proposed solar project. You indicated that if NYSERDA submitted the information package in the near term, NRC would be able to complete its screen of that information within a two* to three-month period. To address the NRC staffs need s with regard to the solar facility, NYSERDA has prepared the attached "Evaluation of the Installation and Subsequent Operation, Maintenance and Removal of a Solar Photovoltaic facility on a Non* Impacted Area of the WNYNSC" (Evaluation).

The Evaluation describes the project and its proposed location on a non-impacted portion of the WNYNSC Retained Premises; contains a 10 CFR 50.59 evaluation using the guidance in Reg Guide DG-1334 and NE196-07, Revision 1; and includes a letter from DOE that expresses DOE's view on the proposed solar project. The conclusion of NYSERDA's Evaluation is that the solar facility "screens out" under 10 CFR 50.59, and will not require a license amendment or other approval. In addition, DOE has determined that the project will not have an impact on the WVDP and DOE does not object to the development of the solar facility.

NYSERDA prov i des this Evaluation now in accordance with the NRC staffs request for the i nformation noted above. Please contact me at (716) 942-9960 ext. 4900 if you have questions or wish to discuss the solar facility directly.

Sincerely, PJB/amd Attachment

VALLEY SITE MANAGEMENT PROGRAM 1. NYSERDA's Evaluation of the Installation and Subsequent Operation, Maintenance and Removal of a Solar Photovoftaic Facility on a Non-Impacted Area of the WNYNSC, Rev. 0, dated June 2018. ec: Amy Snyder, amy.snyder@nrc.gov , w/att. Charles Davis, Supervisor, Town of Ashford, toasupervisor@yahoo.com , w/att. Bryan Bower, Director, DOE-WVDP, bryan.bower@emcbc.doe.gov , w/att. Stephen Gavitt, NYSDOH, Stephen.gav i tt@health.ny.gov , w/att. Timothy Rice, NYSDEC, Timothy.Rice@dec

.ny.gov , w/att. Noah Shaw, NYSERDA General Counsel, Noah.Shaw@nyserda.ny.gov , w/att. Janice Dean, NYSERDA Deputy Counsel, Janice.Dean@nyserda.ny.gov , w/att. PJB/18amd014.pjb