ML18155A603

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Response to Third Request for Extension of Time to Respond to Letter Regarding Irrevocable Standby Letter of Credit for the Aerotest Radiography and Research Reactor
ML18155A603
Person / Time
Site: Aerotest
Issue date: 06/07/2018
From: Edward Helvenston
Research and Test Reactors Licensing Projects Branch
To: Slaughter D
Aerotest
Helvenston E, NRR/DLP, 415-3151
References
EPID L-2017-PMP-0014
Download: ML18155A603 (3)


Text

June 7, 2018 Dr. David M. Slaughter, President and Reactor Administrator Aerotest Operations, Inc.

3455 Fostoria Way San Ramon, CA 94583

SUBJECT:

AEROTEST OPERATIONS, INC. - RESPONSE TO THIRD REQUEST FOR EXTENSION OF TIME TO RESPOND TO LETTER REGARDING IRREVOCABLE STANDBY LETTER OF CREDIT FOR THE AEROTEST RADIOGRAPHY AND RESEARCH REACTOR (EPID L-2017-PMP-0014)

Dear Dr. Slaughter:

By letter dated March 8, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18054A077), the U.S. Nuclear Regulatory Commission (NRC) staff sent Aerotest Operations, Inc. (Aerotest) a request that Aerotest respond within 30 days of its receipt of that letter to explain how it complies, or plans on complying, with the license transfer condition that its irrevocable standby letter of credit conforms to the guidance provided in NRC Regulatory Guide (RG) 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors. The current version of RG 1.159, Revision 2, dated October 2011, may be found at ADAMS Accession No. ML112160012.

By letter dated March 27, 2018 (ADAMS Accession No. ML18092A087), Aerotest requested an additional 30 days beyond the deadline in the NRC staffs March 8, 2018, letter to respond to the March 8, 2018, letter. By letter dated April 3, 2018 (ADAMS Accession No. ML18087A340),

the NRC staff accepted Aerotests first extension request dated March 27, 2018. By letter dated May 7, 2018 (ADAMS Accession No. ML18130A578), Aerotest requested that the deadline extension granted by the NRC staffs April 3, 2018, letter be further extended such that the new deadline would be 60 days beyond the original deadline to respond to the NRC staffs March 8, 2018, letter. By letter dated May 16, 2018 (ADAMS Accession No. ML18128A034),

the NRC staff accepted Aerotests second extension request dated May 7, 2018. By letter dated June 1, 2018 (ADAMS Accession No. ML18156A130), Aerotest requested that the deadline to respond to the NRC staffs March 8, 2018, letter be extended again such that the new deadline would be 90 days beyond the original deadline to respond to the NRC staffs March 8, 2018, letter.

Aerotest stated that its June 1, 2018, extension request was necessary because it determined that the revised letter of credit language proposed by Bank of the West (BoW) to address the issue of insolvency notification to the applicant and beneficiary was not adequate. Aerotest stated that it had submitted a follow-up revision, referencing RG 1.159, Appendix B-5, to BoW, and that the follow-up revision is currently under review by BoW. (The NRC staff notes, however, that in RG 1.159, Revision 2, the example wording for an irrevocable standby letter of credit for a nuclear reactor licensee is found in Appendix A-5.)

The NRC staff accepts Aerotests third extension request dated June 1, 2018.

If you have any questions, or need additional time to respond to the NRC staffs original March 8, 2018, request please contact me at 301-415-4067, or by electronic mail at Edward.Helvenston@nrc.gov.

Sincerely,

/RA/

Edward Helvenston, Project Manager Research and Test Reactors Licensing Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-228 License No. R-98 cc: Sandy Warren, General Manager Aerotest Operations, Inc.

3455 Fostoria Way San Ramon, CA 94583 California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814 Radiologic Health Branch P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611

ML18155A603

  • concurred via email OFFICE NRR/DLP/PRLB/PM NRR/DLP/PRLB/LA* NRR/DLP/PRLB/BC NRR/DLP/PRLB/BC NAME EHelvenston NParker AAdams EHelvenston DATE 6/6/2018 6/6/2018 6/6/2018 6/7/2018