ML20043C726
| ML20043C726 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 05/21/1990 |
| From: | Rutherford P ROCKWELL INTERNATIONAL CORP. |
| To: | Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 90RC06305, 90RC6305, NUDOCS 9006060108 | |
| Download: ML20043C726 (4) | |
Text
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-j 4-Rocketdyne Division -
RockweH international Corporation -
- ROCkWell conoo. l."M"Oni.^;"ra international
- Telex: 698478 -
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May 21, 1990 In reply refer to 90RC06305 Mr. Charles J. Haughney,' Chief
' Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety U.S. Nuclear Regulatory Commission Washington, D.C._20555
Subject:
Financial ~ Guarantee for the Decomissioning of the Rockwell-International Hot Lab (Building 20) at the Santa Susana Field '
Laboratory (SSFL)
Ref. 1:
Letter from Anthony J. Adduci -(DOE-SAN) to Philip D. Rutherford -
(Rockwell), " Decontamination and Decomissioning.of Building 20-Hot Cell, Area 'IV, of Santa Susana Field Laboratory,(SSFL)"
Dear Mr. Haughney:
Pursuant to the financial guarantee requirements of 10CFR70.25(f), DOE has acknowledged responsibility for-the D&D of Bldg.- 20,iand has stated that funding has been requested (see attachedLletter from DOE, Reference 1).
DOE has been supplied with a detailed. cost estimate of:the D&D, which formed the basis for the annual cost figures contained -in the decomissioning plan i
submitted to NRC on April 12, 1990.
l Rockwell understands from conversations with Merri Horn of your staff that the-current NRC regulations do not explicitly allow for a DOE commitment as financial guarantee, and that the NRC would have to grant a specific exception for Bldg. 20.
Rockwell believes that' the provisions of 10CFR70.25(f)(4) related to federal licensees (quoted'below) can be interpreted to be applicable to the present, situation, since Bldg. 20 was-contaminated while l
under exclusive contract-to DOE and utilizing DOE nuclear material.
"(4)
In the case of federal,. state and local government licensees, a statement of intent containing'a cost' estimate for decomissioning or an amount based on the table in paragraph (d)-
of this section, and indicating that funds for decommissioning will be obtained when necessary."
e 9006060108 900521 PDR ADOCK 07000025 f
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4i 90RC6305 May 21, 1990 Page 2-Please confirm that this is an acceptable basis upon which to provide financial assurance, and contact the undersigned at:(818)1718-3413 if additional material is required.
Very truly yours, t.
ROCKWELL INTERNATIONAL Rocketdyne Division
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tY.l> -uckftef P. D. Rutherford, Manager Nuclear Safety & Reliability Engineering PDR:dr Enclosure as stated l
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S Mr. Pha.11p D. Rutherford j
Rocketdyne Division Mail'Stop 055-HB07
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6633-Canoga Avenue Canoga-Park, California 4.
91303
SUBJECT:
Decontamination andLDec'ommissioning of' Building 20 Hot Cell' Area:IV of Santa Susana Field Laboratory (SSFL)
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Dear Mr.' Rutherford:
This is in reference ' to _ a letter from Mr.
R.
Lancet-of your organization concerning the ' Decontamination. and : Decommissioning-l (D&D) of Building 20_'at SSFL..
The letter asked if DOE would be-responsible for funding the D&D ef fort ' at Building
- 20.. _ By-4 accepting this financial responsibility, this-would satisfy-the Nuclear Regulatory Commission (NRC) licensing D&D requirements.
Building 20 Hot Cells were contaminated by Atomic International'.
(part of Rockwell -International),in the. performance ' of a DOE-g contract.
DOE has acknowledged - its responsibility ' to - DED - of Building 20.
In accepting the responsibility, DOE has placed in Contract' No. DE--
AC03-89SF16021 in the-Statement of Work the direction to-Rockwell International-to D&D Building ' 20 and has provided funding to perform the D&D effort;-
However, currently Rockwell has asked for a no cost. extension to their contract in order to prepare a cost. estimate'for the cost growth of the D&D ' effort. ' This indicates that.the budget estimates which DOE has made for future years. for. this,D&D - effort will-definitely be needed.
As-to whether.the funds will'be available on time for an orderly D&D activity to take place, is. strictly a function of (1) where. the Department of Energy places this s
particular effort in the priority list with other D&D activities i
and (2) _ how' Congress alloc.ates-funds to the various efforts of the DOE.
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Philip D. Rutherford, RD~
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In summary, DOE is responsible for Building 20 D&D.
DOE has-submitted budget requests for an orderly D&D; but the time-and quantity of. funds which will actually flow to the project, and when all of the D&D will be complete-is at this point not known nor'will DOE commit to a schedule date'to complete.
Sincerely,
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Anthony J. Adduci-Project Manager Nuclear Energy Division.
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