ML19288A062

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Financial Assurance Instruments to Support the NFS Decommissioning Funding Plan
ML19288A062
Person / Time
Site: Erwin
Issue date: 10/02/2019
From: Freudenberger R
BWXT Nuclear Fuel Services, Nuclear Fuel Services
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
21G-19-0119, ACF-19-0210, EPID L-2018-DFA-0011, GOV-01-55-04
Download: ML19288A062 (3)


Text

Nuclear Fuel Services, Inc.

OFFICIAL USE ONLY Director 21G-19-0119 GOV-01-55-04 ACF-19-0210 October 2, 2019 Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Reference:

1)

Docket No.70-143; SNM License 124

Subject:

2)
3)
4)
5)

Letter from Richard J. Freudenberger to NRC, dated November 30, 2018, (21 G-18-0148), Updated Decommissioning Funding Plan as Required by 10 CFR 70.25(e)(2)

Letter from NRC to Richard J. Freudenberger, dated March 28, 2018, (Enterprise Project Identification Code L-2018-DFA-0011 ), Request for Additional Information Concerning Updated Decommissioning Funding Plan Letter from Richard J. Freudenberger to NRC, dated April 25, 2019 (21 G-19-0044), Response to NRC Request for Additional Information (RAI)

Concerning Updated Decommissioning Funding Plan Letter from NRC to Richard J. Freudenberger, dated June 24, 2019, NFS Interim Approval of Decommissioning Cost Estimate Amount (Enterprise Project Identifier L-2018-DFA-0011)

Final!1lciai Ass1U1raruce instrumell'1lts to Support tlhe NFS Decommissioning F1..mdill'1lg P!an Nuclear Fuel Services, Inc. (NFS), hereby submits the financial assurance documents supporting the Decommissioning Funding Plan (DFP) for the NFS Site. Additionally, per License Condition S-2, minor administrative changes to SNM-124, Chapter 10, "Decommissioning," are being submitted as a result of the DFP update.

The financial assurance instruments contained herein guarantee that sufficient funds will be available when needed for decommissioning the NFS Site. Attachment 1 contains a summary of the methods of financial assurance in use and the corresponding instruments currently in place. Attachments 2, 3, and 4 contain an updated Statement of Intent, Amendment No. 3 of All D /

the Standby Trust Agreement, and an updated Surety Bond. Attachment 5 contains a

,-/ 0 Certification of Financial Assurance that has been prepared in conformance with the Consolidated NMSS Decommissioning Guidance (NUREG-1757, Vol. 3).

JJvf 5>5Zb is a copy of the original document that was submitted directly to NRC by DOE/Naval Reactors under a separate cover letter. Attachments 3, 4, and 5 are copies of OFFICIAL USE ONLY When detached, handle this page as decontrolled. P l

St eop e rang 1205 Banner Hill Rd, Erwin, TN 37650

t. +1.423.743.9141 f* *1.423.743.0140 wwwnucteariuelservices.com

/NNDVATIQN DRIVEN )

OFFICIAL USE ONLY 21 G-19-011 9 GOV-01-55-04 ACF-19-0210 originally-signed documents. To ensure proper handling of the fully executed, originally-signed documents, the original attachments are being provided to the NRC Project Manager for NFS as an enclosure to his copy of this submittal. NFS is requesting that the NRC acknowledge and accept Amendment No. 3 of the Standby Trust Agreement and the Surety Bond by signing the bottom of the two documents as flagged on the originals.

As mentioned above, Attachment 1 contains a summary of the methods of financial assurance in use and the corresponding instruments currently in place. Upon completion of your review, please return the financial assurance documents currently on file that have now been superseded and are no longer required. These documents include DOE Statements of Intent (dated 11/07/2016 and 11/09/2016), a Certification of Financial Assurance (dated 12/14/2016),

and Amendment No. 2 to the Standby Trust Agreement (dated 06/12/2017).

NFS is submitting a revised Chapter 10 for the SNM license as a result of this latest DFP update; it is included in Attachment 6. The revised chapter is included in its entirety, in addition to a revised Chapter Index. Changes are noted by vertical lines in the right margin of affected pages. In accordance with the criteria of License Condition S-2, NFS has determined that the changes are administrative in nature and do not reduce safety or the level of effectiveness of

  • the License Application.

If you or your staff have any questions, require additional information, or wish to discuss this, please contact me, or Mr. Tim Knowles, Licensing Manager, at (423) 735-5061. Please reference our unique document identification number (21 G-19-0119) in any correspondence concerning this letter.

AAM/pj Sincerely, NUClEAR FUEl SERVICES, INC.

~,~

Richard J. Freudenberger, Director Safety and Safeguards OfFlCIAL USE ONl Y When d,etach,ed, handle this page as decont:ro!!ed.

OFFICIAL USE ONl Y :

Summary of NFS D&D Liability and Financial Assurance 21 G-19-0119 GOV-01-55-04 ACF-19-0210 : :

Statement of Intent from DOE/Naval Reactors, dated 08/22/2019 Amendment No. 3 of the Standby Trust Agreement, dated 03/01/2016 (Re-issued 08/30/2019) :

Surety Bond :

Certification of Financial Assurance :

SNM-124, Chapter 10, Update Per License Condition S-2 Copy:

Regional Administrator U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Joel Rivera-Ortiz Senior Fuel Facility Inspector U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Kevin Ramsey (originals)

Senior Project Manager Fuel Manufacturing Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Robert Williams Chief, Projects Branch I Division of Fuel Facility Inspection U.S. NRC, Region 11 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Larry Harris Senior Resident inspector U.S. Nuclear Regulatory Commission OFFICIAL USE ONl Y When detached, handle this page as dlecontrolued.