ML22215A152
| ML22215A152 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 07/21/2022 |
| From: | Slaughter D Aerotest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML22215A152 (6) | |
Text
The Enclosures to this letter are identified as containing a CD with reference documents containing Safeguards Information. However, this letter is decontrolled when separated from the CD which contains the Safeguards Information. Therefore, this document by itself can be declared publicly available when separated from the Enclosures.
AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212
- FAX (925) 866-1716 July 21 , 2022 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.
ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 11545 Rockville Pike Rockville, MD 20852-2746
Subject:
AO RAJ Responses for Decommissioning Plan Ladies and Gentlemen:
The attached document provides additional information associated with the Decommissioning Plan for the Aerotest Radiography and Research Reactor as requested in NRC communication ML#22152A252 dated June 28, 2022. This submission contains RAJ responses and requested documents referenced in the decommissioning plan. The reference documents are transmitted under the label "safeguard material -
modified handing." The detail information in the reference documents, in their entirety, can weaken our security circumstances.
Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (80 I) 631 5919 or dmsraven@gmail.com.
I declare under penalty of perjury that the forgoing is correct and truthful.
Sit
. Slaughter, Ph.D.
President, Reactor Administrator, Manager Aerotest Operations, Inc.
Enclosures:
AO Responses to NRC- RAls Associated with ARRR Decommissioning Plan CD Reference Materials-Safeguards Material -Modified Handing
This Enclosure, when separated from the CD identified in the cover letter as containing Safeguards Material, is decontrolled.
Therefore, this document by itself can be declared publicly available.
AO Responses to NRC- RAis Associated with ARRR Decommissioning Plan The information below are the responses to NRC- RAis associated with the ARRR Decommissioning Plan. The NRC-RAis accompanied the NRC letter dated June 28, 2022 *
(ML#22152A252).
RAI 1. Please identify if Aerotest believes this request requires an environmental assessment or qualifies for an exception under the regulations cited above, and if so, please provide the basis for that determination.
In the July 20, 2021, Decommissioning plan submitted by Aerotest Operations, Inc., the .
Environmental Report was included in Appendix A. The study was performed and the report prepared by Energy Solutions CS-HP-PR-005 Revision 0, 'dated 8/11/11. A copy is provided on the accompanying CD.
On page 5 of 54, of submitted Appendix A entitled Environmental Report Aerotest Radiography and Research Reactor, it states "After fuel removal ....... As with other facilities of this nature, the ARRR Facility is contaminated with varying small amounts of radioactive material and small amounts of hazardous waste. This result is before the radioactive waste shipment in April 2017.
The information and findings have not significantly altered. Also; the reactor has not been operated since 2010.
The report was submitted in its entirety in lieu ofrequesting for an exception "l O CFR 51.22 (C)
(20) Decommissioning of sites where licensed operations have been limited to the use of- (i)
Small quantities of short-lived radioactive materials."
RAI 2. Are the Reactor Safeguard(s) Committee, the Radiation Safety Committee, and the Reactor Safety Committee one and the same? Yes, they are the same.
RAI 3. If they are the same committee, please clarify the name of the committee?
The Reactor Safeguards Committee per TS 12.1.6 12.1.6 The Reactor Safeguards Committee shal I be composed of not less than five members, of whom no more than three are members of Aerotest Operations, Inc. The committee shall meet on call of the chairman and they shall meet at least annually. The committee shall be responsible for, but not limited to the following:
12.1.6.1 Reviewing and approving* nuclear safety standards associated with the use of the facility; 12.1.6.2 Reviewing ARRR facility's procedures and modifications; 12.1.6.3 determining whether proposed changes to the facility or procedures are allowed without prior authorization by the NRC, as detaped in 10 CFR 50. 59;
This Enclosure, when separated from the CD identified in the cover letter as containing Safeguards Material, is decontrolled.
Therefore, this document by itself can be declared publicly available.
12.1.6.4 Conducting periodic audits of procedures, maintenance, equipment performance, and records; 12.1.6.5 Reviewing all reported violations of these Technical Specifications, evaluating the causes of such events and the corrective action taken and recommending measures to prevent reoccurrence and; 12.1.6.6 Reporting their findings and recommendations concerning the above to the President, Aerotest Operations, Inc.
RAI 4. Please provide the required technical qualifications of the Radiation Safety Officer and the Reactor Administrator, or reference where that information is contained in the licensee's Possession-only License or Technical Specifications.
TS 12.1.2 The Reactor Administrator (Level 2) shall have the responsibilities of ensuring security and safety of the Aerotest facility. He/she shall enforce, review and amend procedures associated with security and safety programs. The reactor administrator shall be responsible to the President, Aerotest Operations, Inc. The Reactor Administrator shall have a minimum of 5 years of experience in reactor operations, 2 years of exper:ience with personnel and environmental/occupational radiation monitoring programs, and 2 years of experience with complying with government regulations. Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.
- TS 12.1.4 The Radiation Safety Officer (Level 3) shall review and approve all procedures involving radiological safety. He/she shall enforce rules, regulations and procedures relating to radiological safety, conduct routine radiation surveys and is responsible to the President, Aerotest Operations, Inc. The Radiation Safety Officer shall have a minimum of 2 years of experience in personnel and environmental/occupational radiation monitoring programs.
Successfully completed college level work in the nuclear and radi~tion related fields of study may be considered in lieu of the experience requirement.
RAI 5. Does the Radiation Safety Officer or radiation safety organization have independent authority to stop work? Yes, they both do.
RAI 6. Please reconcile the differences in the ARRR Decommissioning Organization presented in Figure 4-3 of the DP with the Figure l of the ARRR Technical Specifications entitled, "ARRR ANSI/ ANS-15.1 Organization" iri Attachment 2 to Facility Operating License No. R-98.
Amendment No. 6. dated January 6. 2021 (ML21242A463).
Both figures are basically the same. Figure 4-3; ARRR decommissioning organization needs Reactor Safety Committee changed to Reactor Safeguards Committee (see RAl3)-and a communications line from Reactor Safeguards Committee to Reactor Administration. Once the fuel is removed and we start decommissioning we don't need the Certified Fuel Handler Supervisor or Certified Fuel Handler shown on Figure 1 ...:. ARRR ANSI/ANS 15..1 Organization.
This Enclosure, when separated from the CD identified in the cover letter as containing Safeguards Material, is decontrolled.
Therefore, this document by itself can be declared publicly available.
- RAI 7. For NRC to folly evaluate the planned final radiation survey in accordance with 10 CFR 50.82(b)(4)(iii), please provide a copy of Ref 4-1, CS-HP-PR-004, Historical Site Assessment of
- the Aerotest Radiography and Research Reactor, San Ramon, California, Revision 0, July 2011.
The requested reference CS-HP-PR-004 is provided (on CD) in its entirety. The reference remains relevant but does contain a few dated descriptions including '
building and room conditions, radioactive waste inventory, etc. These and other changes have occurred since 2011 historical site studies and are represented in the 2021 decommissioning plan .
. RAI 8. For NRC to fully evaluate the planned final radiation survey in accordance with 10 CFR
. 50.82(b)(4)(iii), p_lease provide a copy of Ref 4-2, CSHP-PR-007, Characterization Report/or the Aerotest Radiography & Research Reactor, San Ramon, California, Revision 0, August 20 I I:.
The requested references CS-HP-PR-008 (corrected number) is provided in its entirety. They co~tain dated descriptions including building and room conditions, radioactive waste inventory, etc. Radioactivated parts stored in various were location such as the mezzanine area were consolidated in an inventoried shielded storage. In house radiation surveys have been performed and a 22,565 lbs. ( I ,920 FT3) low-level radioactive waste shipment to Energy Solutions occurred in April 2017. These and other changes have occurred since 20 I I characterization studies and are represented in the 2021 decommissioning plan.
RAJ 9. _For NRC to fully evaluate the factors delaying the completion of decommissioning (I 0 CFR 50.82(b)(4)(i)) please provide a description of fuel management plans, plans for fuel removal, and plans for ultimate disposition of fuel to the extent they are known at this time (see NUREG-153 7, Part 2, Chapter I 7, Appendix 17 .1, Section 3 .2.1, "Fuel Removal")
A Trust Fund meeting 10 CFR 50 requirements provides funds for the storage and surveillances required before the pickup of the spent fuel as well as a signed .fixed cost agreement between the DOE and Aerotest Operation, Inc. (DE-CR0I-83NE44484) to receive at the fence line and dispose of the fuel at Idaho National Laboratory (INL) The Trust document has be,enavailable for inspection since July 2017. The language of the trust w~s reviewed by *all parties including the NRC staff and determined it acceptable before the indirect iransfer of the reactor license.
Being a small business, estimating schedules and their impacting costs when agreed upon tasks that are delayed is frustrating. Especially when the delays are directly related to government parties. I have limited resources to waste and therefore cannot afford the devastating disagreements between government agencies that negatively impact the timely transfer of_ spent fuel. In this case the State of Idaho and the DOE are in a dispute. The State of Idaho in a punitive action against the DOE blocked the receipt of TRI GA spent fuel until the DOE can comply with terms in a contractual agreement with the State of Idaho. The DOE's noncompliance is unrelated to spent fuel transfer or storage. (I will also state that the past practice of prioritizing the acceptance of foreign over domestic owned spent TRI GA fuel impacts timing as well.) As a US individual and corporate taxpayer, this delaying circumstance is unacceptable. The funds in the Trust Fund cover the current needs however, it is not clear in the future given the uncertainty of a timely resolution of the disputing parties. I am working with California and Wyoming US senatorial offi~es to provide some assistance in getting this fuel removed.
This Enclosure, when separated from the CD identified in the cover letter as containing Safeguards Material, is decontrolled.
Therefore, this document by itself can be declared publicly available.
RAJ 10. Provide information on all funding currently available for ARRR decommissioning.
Include a comparison of available funding to the amount estimated to be needed for SAFSTOR and decommissioning of ARRR, a means for adjusting funding over the SAFSTOR period, and a plan for assuring the availability of funds for completion of decommissioning.
The Trust Fund meeting 10 CFR 50 requirements represents the legal document that describes the administrative and financial controls and protections to ensure funds are available for decommissioning activities.
Two cost estimates are presented below. The estimated costs are included in 2019 estimate generated from a decommissioning study containing several possible decommissioning paths.
Also included is a 2021 the cost estimate for the specific chosen decommissioning path. The final financial is the current content of the trust instrument associated with the decommissioning activities. The current funds in the Trust Fund currently exceeds the cost estimates in the 2019 and 2021 documents.
RAI 11. Provide a copy of CSHP-PR-006, "Decommissioning Cost Estimate for the Aerotest Radiography and Research Reactor, San Ramon," Revision 6, January 2019, prepared by Energy Solutions. Include a current estimated cost in 2022 dollars and means for adjusting the cost estimate during the storage and active decommissioning periods.
CS-HP-PR-006 R5 authored by Energy Solutions is provided for your records. The red text is the upgraded information and budget (generated by Energy Solutions). Radioactive waste disposal and non-radioactive cleanup provided in 2017 required the need for reevaluating the decommissioning cost for the number of possible decommissioning paths as presented in the 2011 decommissioning study. In the decommissioning choices immediate decommissioning in 2011 was also taken into consideration with it typically higher costs i.e., higher radiation exposure and disposal costs.
In the chosen decommissioning path, as described in the 2021 decommissioning plan, only cost items that are relevant are included. The 2011 and 2019 estimates are from a study which .
included multiple decommissioning paths and did not utilize the inhouse expertise and processes.
While the CS-HP-PR-006 R5 (2019) is the basis for some cost elements of the decommission activities, there are portions of the report that are no longer relevant. To name a few relevant changes caused by the choice of direction, the low-level radioactive material, non-radioactive debris, and labor are smaller, the uncontaminated and nonactivated security shielding blocks are being repurposed not disposed of at a low-level waste site. Contractors will be task oriented and
. may be sought from inside and out-of-state where appropriate. (The 2011 and 2019 estimates assumed that all contractor personnel are out of state thus requiring travel and living budgets).
No duplication of administrative and safety responsibilities. The administrative streamlining assures that safety concerns to be acted upon. The President of Aerotest operations Inc. is responsible of the actions.of all personnel (AO and contractors); His AO Radiation Safety Officer and AO Reactor Administrator must have real time information to act ensuring*the protection of the workers and the J?Ublic.
This Enclosure, when separated from the CD identified in the cover letter as containing Safeguards Material, is decontrolled.
Therefore, this document by itself can be declared publicly available.
RAI 12. To support the updated decommissioning cost estimate, please provide the estimated volumes (if not provided in the above reference requests) oflow-level radioactive waste by waste classification that will require offsite disposal The other documents provide \estimated low level radioactive waste volume and disposal but do not accurately assess the smaller amount to be generated and the current 2022 pricing for disposal at Clive, Utah. The cost of the waste will be updated based on our decommissioned generated inventory. This will remain an open item until a disposal cost estimate is received from Energy Solutions.