ML20043B149
| ML20043B149 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 05/21/1990 |
| From: | Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| NUDOCS 9005240284 | |
| Download: ML20043B149 (2) | |
Text
$lE,.g' W
i s
v m, s. 4
..m
,T
..m MAY. 21 1990 Docket ~No._ 70 1257:
L-icense No. SNM-1227-J 1 Advanced Nuclear Fuels Corporation ATTN:. Mr. C. W. Malody, Manager Corporate Licensing l2101 Horn Rapids Road j
(
- Richland,' Washington-99352-0130 i
' Gentlemen:.
LWe have reviewed the draft submittal dated April 13, 1990' regarding financial i
- assurance for decommissioning and have enclosed our comments.
Please note-
-that guidance on= financial assurance mechanisms can be found in the draft regulatory ' guide, " Standard Format and Content of Financial Assurance Mechanisms
- Required:for. Decommissioning'Under 10 CFR Parts 30, 40, 70, and~72," dated ~
(January 1990.
'If 'you have any questions regarding this matter, please contact Mr. Scott
- Pennington of myy staff on (301) 492-0693.
Sincerely, M M BY'
-r Charles J. Haughney, Chief' Fuel Cycle Safety Branch Division of Industrial and Medical: Nuclear Safety, HMSS r
Enclosure:
As stated;
- Distribution w/ encl..
Docketk70-1257' kPDR2M" NRC0 File"tsnief Region V' CHooker, RV, NHSS R/F IMUF R/F IMSB'R/F IMNS Central File VLTharpe(2)'
-SPennington.
GBidinger NHorn RFonner, 0GC 0FC:IMUf:
IMUF d OGC:
____............4.........IMUF: g NAME:WSPennington:mh:.
VLTharpe:
GhBidinger:
CHau ey:
I /'
..................._________.........______..........,.____$er:
.DATE:5/T/90:
5/T /90:
5/c[/90:
5/ /90:
5/g//90
~
OFFICIAL RECORD CCP Y
,([
9005240284 900521 PDR ADOCK 07001257 C-PDC y
i
t q
6:
o l
Comments on Advanced Nuclear Fuel Corporation's (ANF)
Draf t Financial Assurance for Decommissioning l
By telephone on May 2,1990, Mr. Charles Malody of ANF stated that the
=
financial assurance for decommissioning will be submitted in the form of a certification. Therefore, ANF should clearly state that the submittal is a certification of financial assurance for decommissioning.
In addition, the draft submittal makes several references to a decommissioning cost estimate equal to $8,500,000. A decommissioning cost estimate and its basis are required for a decommissioning funding plan. A certification of financial assurance does not require a cost estimate but must be in an amount at least i
equal to $750,000. However, ANF may choose to certify an amount which exceeds
$750,000.
The financial assurance mechanism chosen by ANF is the parcnt company guarantee.
The guarantor is Siemens Corporation, and the trustee in the standby trust agreement is Ch::e Manhattan Bank, N.A.
The submittal should. include a cooy of the corporate bylaws, resolution, or other evidence indicating that the parties signing the financial instrument are authorized to represent the organizations in the transaction.
Although the submittal states that Siemens Corporation is ANF's parent company, the license states that ANF is a wholly-owned subsidiary of Siemens KWU, Inc., a Delaware Corporation, which is a wholly-owned subsidiary of.
t Siemens Capital Corporation, also a Delaware Corporation. The submittal must-correctly identify the parent company.
The submittal-should provide evidence indicating that the corporate parent has majority control of ANF's voting stock.
In the drafts of.the letter from the Chief Financial Officer of Siemens Corporation'and the corporate guarantee, a-bond paper program and bond ratings-are discussed. We are not familiar with this program or the bond ratings.
Furthermore, no issue or maturity dates were provided for the bond (s).
In.the first sentence of the corporate guarantee, the word " affiliate" should be replaced with " subsidiary."
On page 3, paragraph 11, of the guarantee, the draft incorrectly states that the NRC is responsible for determining if the guarantor continues to meet the financial test criteria.
This-is a responsibility of the guarantor.
.The ANF corporate office address given in both the guarantee and the standby 1
trust agreement is different from the address stated in the license.
The draft letter and schedule from Price Waterhouse do not conform to the recommended wording in the draft regulatory guide. Deviations in wording must be justified.
The submittal should include a corporate annual report or financial statements for both the licensee and parent company.
-