ML111300318
| ML111300318 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, 07000754, 07001113, 07002872, 07200001, Vallecitos |
| Issue date: | 06/02/2011 |
| From: | Ryder C NRC/NMSS/FCSS/FCLD/FMB |
| To: | Sherin K General Electric Co |
| Shared Package | |
| ML111300305 | List: |
| References | |
| TAC L33125 | |
| Download: ML111300318 (3) | |
Text
Request for Additional Information Parent Company Guarantee and Annual Financial Test for General Electric Hitachi RAI 1: Clarify the effective date of the Parent Company Guarantee The model Parent Company Guarantee Agreement (the Agreement), provided in Section A.13.10 of Reference 1, recommends that an effective date be stated on the Agreement.
Re-submit the Agreement with the effective date stated.
The information is need per Title 10 of the Code of Federal Regulations (10 CFR) 70.25(e) and recommended per Reference 1 for the NRC staff to complete its review by the Standard Review Plan.
RAI 2: Clarify the corporate relationship between the various licensees stated on the Agreement The Agreement states that Global Nuclear Fuel-Americas, LLC (GNF-A), GE-Hitachi Nuclear Energy Americas, LLC, and GE Reuter Stokes, Inc. are the licensees for which General Electric Company is providing financial assurance for decommissioning. NUREG-1757, Volume 3, Appendix A.13.3 recommends that the licensee provide a letter from its Chief Executive Officer (CEO). The submittal contains a letter from the CEO of GE-Hitachi Nuclear Energy Americas, LLC.
Clarify the corporate relationship of GNF-A, GE Reuter Stokes, Inc. and GE-Hitachi Nuclear Energy Americas, LLC to the General Electric Company.
Discuss whether or not that GNF-A, LLC and GE Reuter Stokes, Inc. should also provide letters from their CEOs.
The information is needed per 10 CFR 70.25 and recommended per Reference 1 for the NRC staff to complete its review by the Standard Review Plan.
RAI 3: Clarify the basis for the increased cost estimates.
It appears that the cost estimates for most of the licenses have increased with respect to the previous Chief Financial Officer letter (CFO) (ML100900076). The exceptions are Special Nuclear Material-1826 (unchanged from the previous year) and DR-10 (decreased from the previous year).
Clarify how the cost estimates for the Part 70 and Part 72 licenses have been adjusted in a manner consistent with the means for adjusting cost estimates and associated funding levels contained in the Decommissioning Funding Plans (DFP).
Clarify how the cost estimates for the Part 50 licenses have been adjusted in a manner consistent with the means of adjusting the cost estimate[s] and associated funding level[s]
contained in the decommissioning report.
Enclosure
Explain the method for updating the cost estimates, and clarify whether the cost estimates are adjusted in a manner consistent with the method for updating the cost estimates.
The information is needed per 10 CFR 50.75(d)(2)(iii), 10 CFR 70.25, and 10 CFR 72.30(b)
RAI 4: Provide a Certification of Financial Assurance.
10 CFR 70.25 states that a decommissioning funding plan must also contain a certification by the licensee that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning. NUREG-1757, Volume 3, Appendix A.2.5 states that
[a] Certification of Financial Assurance must be included with the [Decommissioning Funding Plan] DFP. While the submittal under review is not a decommissioning funding plan, it is unclear that a Certification of Financial Assurance was provided in the past. In addition, because the cost estimates for the Part 70 licenses have changed with respect to the previous letter from the Chief Financial Officer (Ref. 2), the staff requests an updated Certification of Financial Assurance.
The information is requested per 10 CFR 70.25; and recommended by Section Appendix A.2.5 of Reference 1.
References
- 1. USNRC, Consolidated NMSS Decommissioning Guidance: Financial Assurance, Recordkeeping, and Timelines,, NUREG-1757,Volume 3, Appendix A. September 2003.
ADAMS accession number ML032471471.
- 2. Letter from Keith S. Sherin , General Electric Company, to Director, Nuclear Material Safety and Safeguards, NRC, and Director Nuclear Reactor Regulations, NRC, General Electric Company Parent - Guarantee of Funds for Decommissioning: Updated Letter from Chief Financial Officer to Demonstrate Financial Assurance. March 18, 2010. ADAMS Accession Number ML100900076.
2