ML20029D344
| ML20029D344 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 04/28/1994 |
| From: | Lamastra M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Knapp K BABCOCK & WILCOX CO. |
| References | |
| TAC-L21661, NUDOCS 9405050173 | |
| Download: ML20029D344 (3) | |
Text
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APR 2 81994 Docket 70-1201 License SNM-ll68 Ms. K. S. Knapp, Manager Safety and Licensing B&W Fuel Company Commercial Nuclear Fuel Plant P.O. Box 11646 Lynchburg, Virginia 24506-1646
Dear Ms. Knapp:
SUr fCT:
DECOMMISSIONING FUNDING PLAN (TAC NO. L21661)
Thn, reiers to your letters dated August 23, and October 15, 1993 in which you submitted modifications to your Decommissioning Funding Plan (DFP), including an amendment to the Letter of Credit and a new Standby Trust Agreement.
Our review of your submittal has identified additional information that is needed before final action can be taken on your request.
Prior to formalizing responses and prior to initiation of any projects resulting from the questions, you should discuss the questions with NRC through telephone discussions and/or meetings to ensure that the intent of the questions is clear.
Additionally, you are requested to provide written responses to the questions within 30 days of the date of this letter.
Please reference the above TAC No. in future correspondence related to this request.
If you have any questions regarding this matter, please contact me at (301) 504-3416.
Sincerely,
(#@ Pol SWHXi By' Michael A. Lamastra Licensing Branch Licensing Branch 2 Divisicn of Fuel Cycle Safety and Safeguards, NMSS
Enclosure:
As stated DISTRIBUTION: w/enci (Control No. 3505)
Docket 70-1201 PDR NRC File Center Region 11 NMSS r/f FCSS r/f FCLB r/f FCLS2 r/f Madams GTroup, RII
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i Request for Additional Information i
Letters dated August 23, and October 15, 1993 B&W Fuel Company Docket 70-1201 1.
Provide additional information for the 10 percent contingency factor used vs recommended vaiue of 25 percent, We note that you believe that NUREG/CR-1754 is not an appropriate reference source for your facility since your operation is basically a mechanical operation and involves very low contamination levels.
However, the purpose of the 25 percent contingency factor is to help protect against unforeseen decommissioning costs, such as higher levels of contamination then expected at the time of decommissioning, and should not be reduced because foreseeable costs are low. Accordingly, you should revise your contingency factor to 25 percent or provide additional justification for the 10 percent value.
2.
Revise or justify the estimates of waste generated from decontaminating facility components.
In response to our earlier request, you revised the cost estimate to include the cost of disposing of waste generated during decontamination of facility components.
To estimate the amount of decontamination waste, you assumed that I cubic foot of waste would be generated per 1,000 square foot of wall and ceiling and per 1,000 cubic feet of doors, fixtures, and equipment. We note that you chose the 1 cubic foot value over the NUREG/CR-1754 guidance based on your past experience.
However, since the 1 cubic foot value is far less than the estimate presented in NUREG/CR-1754 (less than 1 percent), you should either revise the estimated quantity of waste generated during decontamination of facility components and/or provide further justification for your current estimate (e.g., a description of past decontamination experience and its applicability to the types of areas covered by the current cost estimate).
3.
Submit specimen certificate of resolution to commence decommissioning (Regulatory Guide 3.66, page 4-25). Tho submission lacks a specimen certificate of resolution, which should contain blank spaces for dates and signatures until decommissioning activities are commenced. Although you submitted a specimen certificate of events, which references the certificate of resolution to commence decommissioning, the submission does not include the specimen certificate of resolution.
4.
Submit a letter of acknowledgement with the Standby Trust Agreement (Regulatory Guide 3.66, page 4-27).
The submission does not include a letter of acknowledgement for the new Standby Trust Agreement, as recommended in Regulatory Guide 3.66.
The acknowledgement is needed to verify the execution of the Standby Trust Agreement and to certify the Trustee's signature and authority to enter into the agreement.
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2 5.
Submit evidence indicating that the party signing the Standby Trust Agreement for BWFC is authorized to represent the company (Regulatory Guide 3.66, Page 3-14). The submission does not provide sufficient evidence indicating that the party signing the Standby Trust Agreement is authorized to represent BWFC.
Evidence of authority to represent BWFC is necessary to ensure the validity and enforceability of the t
mechanism. Accordingly, you should submit a copy of the corporate by-laws or other evidence indicating that the party signing the Standby Trust Agreement is an authorized representative, and to have a second party (e.g., the Licensee's corporate secretary) provide an attesting signature on the Standby Trust Agreement in the unsigned space (labeled
" attest") provided for that purpose in the signature block of the submitted Standby Trust Agreement.
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