ML20046C102
ML20046C102 | |
Person / Time | |
---|---|
Site: | 07001100 |
Issue date: | 08/02/1993 |
From: | Tokar M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
To: | Kersteen G ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
References | |
TAC-L21635, NUDOCS 9308090203 | |
Download: ML20046C102 (6) | |
Text
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AUG 2 1993 Docket 70-1100 License SNM-1067 Mr. Gary C. Kersteen, Uranium Plant Manager Windsor Nuclear Fuel Manufacturing Combustion Engineering, Inc.
1000 Prospect Hill Road Windsor, Connecticut 06095-0500
Dear Mr. Kersteen:
SUBJECT:
DECOMMISSIONING FUNDING PLAN (TAC N0. L21635)
This refers to.your letter dated July 2,1992, which transmitted your decommissioning funding plan. Our contractor has reviewed your plan and identified additionel information that is needed before final action can be 4en.
This additional information (6 copies), specified in the enclosure,
_;ld he provided within 30 days of the date of this letter.
The NRC's ew was also facsimiled to your Mr. John Conant on July 28, 1993.
r Please include the above TAC NO. in future correspondence related to this subject.
If you have any questions regarding this matter, please contact me at (301) 504-2590 or Mr. Sean Soong at (301) 504-2604.
Sincerely, Uriginal Sgped By-Michael. Tokar, Section Leader Licensing Section 2 Licensing Branch Division of fuel Cycle Safety and Safeguards, NMSS
Enclosure:
As stated cc w/encls:
Mr. J. F. Conant, Manager Nuclear Materials Licensing Distribution: w/encls. (Control No. 2000)
Docket No. 70-1100 PDR
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Review of Decommissioning Funding Plan and Surety Bond Submitted Subj ect:
by Combustion Engineering, Inc.
Combustion Engineerinb Inc. it. Vindsor, Connecticut, submitted a
- decommissioning funding plan (DTP), using an amended surety bcnd, in the a=ount of $2,000,000. The submission assures estimated decommissioning costs of $1.999,980 for license SNM 1067 issued under 10 CFR Fart'70, and modifies a 1
certification of financial assurance previously submitted to NRC.1 Upon review of the submission, ICF recommends that.NRC require the licenses to modify the submission in the following ways:
(1)
Submit additional detail to support the cost estimate (Regulatory Guide 3.66, Appendix F);
(2)
Substantiate the extent of contamination at the facility; (3)
Revise the cost estimate to reflect volume of vaste.and radioactive material routinely stored on site (Regulatory
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Guide 3.66, page 1-10);
(4)
Submit _ justification for the contingency factor used in the cost estimate (NURIG/CR-1754, Addendum 1);
(5)
Submit evidence that the parties signing the surety bond, rider, and standby trust agreement for the licensee are i
authorized to represent the company (Regulatory Guide 3.66, pages 3-14 and 3-17); and (6)
Revise Schedule A of the standby trust agreement to include the certification amount (Regulatory Guide J.66, page 4 26).
These reco=mendations and other issues are discussed below.
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1 ICT revieved the licensee's provious submission and reported several recommendations to NRC in a memorandum dated May 22, 1982.
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2 (1)
Submit Additional Detail to Support the Cost Estimate (Regulatory Culde J.66, Appendix F)
Although the licensee included cost estimating tables in support of its decommissioning cost estimate, the tables used by the licensee are less comprehensive than the cost estimating tables found in Appendix F of Regulatory Calde J.66 " Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72," June 1990. As a result, the DFP does not provide enough detail to justify the cost estimate. The licensee provided little information on the decommissioning activities to be conducted, and no information on the size of the facility (ies) and individual facility components (fume hoods, glove boxes, laboratory benches, ductwork, etc.) that need to be decontaminated. This 4
information is recessary to determine the accuracy of the licensee's cost estimate.
ICF recommends that NRC require the licensee to submit additional detail in support of its cost estimate, and to use or adapt the cost estimating tables in Appendix F of Regulatory Guide J.66 to demonstrate that it has provided reasonable cost estimates for all major decommissioning activities.
The licensee should provide the dimensions of the buildings to be decommissioned, the dimensions of individual facility components, and the waste volumes that will be generated during decommissioning.
The licensee should also indicate whether site stabilization and long-term surveillance activities will be necessary at the facility, and if so, should detail the costs of these activities.
ICF also recommends that the licensee use the tables found in Appendices A and E of NUREG/CR-1754, Addendum 1, to help calculate the decommissioning costs.2 The tables estimate.the number of person-days required, the cost of equipment and supplies, and the quantity of generated in decontaminating individual facility components (e.g.,
waste individual time, cost, and waste generation estimates for decontaminating floors, ceilings, ductwork, etc.).
(2)
Substantiate the Extent of contaminatien at the Facility The licensee has not adequately docu=ented its assumptions regarding the low contamination levels,at certain areas of the facility. The submission states that Ancillary areas and other buildings (other than Buildings 5, 6, and 17] are not anticipated to contain significant amounts of residue since unclad Uranium was not handled in significant amounts. For these areas and buildings, verification surveys will be performed to document that they do not requirs decontamination. As part of the 2 NUREG/CR-1754, Addendum 1. Technolory. Safe ty and Costs of Decommissioning Reference Non-Fuel-Cycle Nuclear Facilities:
Compendium of 1
Current Information, Pacific Northwest Laboratory, October 1989.
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3 Decommissioning Plan a more thorough characterization of contaminated areas will be undertaken.
The submission provides no evidence (e.g., sampling data) or further discussion of the licensee's claim that decontamination activities will not be necessary in ancillary areas and buildings (other than Buildings 5, 6, and 17), even though radioactive materials were handled in tbase areas.
If future
" verification surveys" were to determine that decontamination activities are required, then the licensee's financial assurance, based on the licensee's cost estimate, would not be sufficient to pay for all decommissioning costs.
Therefore, to ensure that the cost estimate addresses decommissioning of all appropriate areas, ICF re:ommends that NRC require additional information (e.g., survey results) about the level of contamination at the ancillary areas and buildings.
(3)
Revise the Cost Estimate to Reflect Volume of Vaste and Radioactive Material Routinely Stored On Site (Regulatory Guide 3.66, page 1-10)
Regulatory Culde 3.66, page 1-10, directs licensees to base cost estimates on " reasonable costs expected under routine facility conditions" (emphasis added). The licensee based its estimate of disposal costs for stored radioactive waste and material on the amount it had on site when the decommissioning cost estimate was prepared.
The DFP does not discuss whether this amount is reasonable given routine facility conditions (e.g., whether the current amount is within the high, medium, or low end of amounts routinely stored on site, or whether the current amount will remain constant until the planned decommissioning in 1993). Unless the cost estimate is sufficient to dispose of the maximum amount of waste routinely stored on site, then the estimate will not be adequate to dispose of all amounts routinely stored on site.
Therefore, to ensure that the cost estimate is reasonable under routine facility conditions, as recommended in Regulacory Culde 3.66, ICF recommends that NRC require the licensee to base its disposal costs on the maximum amount of waste and radioactive material routinely stored on-site, rather than the amount currently stored on-site, (4)
Submit Justification for the Contingency Factor Used in the Cost Estimate (NUREG/CR,-1754, Addendum 1)
The licensee used a contingency factor of 10 percent of its decommissioning costs, but did not justify its use of this percentage.
NUREG/CR-1754 uses a contingency factor of 25 percent in its cost estimates for each of six reference laboratories.3 Increasing the contingency factor to 25 percent would raise the total cost estimate by approximately $273,000.
ICF recom= ends that NRC require the licensee to increase its contingency factor to at least 25 percent of decommissioning costs or to show why use of a lower contingency f5ctor is appropriate.
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3 NUREC/CR 1754, Addendum 1. Technology. Safety and Costs of 1
Decommissioninz Reference Non-Fuel-Cvele Nuclear Facilities:
Compendium of Current Information, Pacific Northwest Laboratory, October 1989.
4 (5)
Submit Evidence that the Parties Signing the surety Bond, Rider, and Standby Trust Agreement for the Licensee are Authorized to Represent the J
co=pany (Regulatory Culde 3.66, pages 3-14 and 3-17)
The submission does not include evidence indicating that the parties signing the financial mechanisms for the licensee are authorized to represent the licensee in the agreements, as recommended in Regulatory Culde 3.66, pages 3-14 and 3-17.
Evidence of authority to represent the licensee is necessary to ensure the validity and enforceability of the mechanism.
ICF recommends that NRC require the licensee to submit a copy of the corporate by-laws or other evidence indicating that the parties signing the surety bond, the rider to the surety bond, and the standby trust agreement for the licensee are authorized to do so.
(6)
Revise Schedule A of the Standby Trust Agreement to Include the Certification Amount (Regulatory Culde 3.66, page 4-26)
Section 2 of the standby trust agreeuent states that "This Agreement pertains to the costs of decom=issioning.
as shown in Schedule A."
The licensee, however, used a copy of its NRC materials license as Schedule A of the standby trust agreement. Consequently, the submitted schedule does not indicate the applicable financial assurance amount for the facilities covered by the mechanism.
Specification in Schedule A of the estimated costs of decommissioning is important to allow the trustee to properly administer the conditions and requirements of the agreement; for example, the amount of the cost estimate can be critical to determining whether a particular withdrawal should be allowed.
ICF recommends that NRC require the licensee to modify Schedule A to include the certification amount, as recommended in Regulatory Guide 3.66, page 4-26.
f Other Issues Apart from editorial rad non-substantive changes to the standard wording provided in Regulatory Culde 3.66, the following points are noteworthy:
(a)
The licensee states in the DTP that it intends "to terminate manuf acturing activities by the end of NRC FY 1993 and to im=ediately begin decommissioning." Because the life of the facility is limited, the DTP does not describe a means for adjusting the decommissioning cost estimate and associated funding level over the life of the facility.
(b)
The surety bond does not indicate a liability limit for the facility as recommended by (Regulatory Culde 3.66, page 4-30). This omission does not detract from the protection provided by the mechanism, however. The penal sua of
$2,000,000 (as specified in the rider to the surety bond) is equal to the liability limit, as noted in the last sentence on page 1 of the bond.
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(c)
The surety bond omits a provision that allows for annual adjustment of the penal sum. Although this provision is included in the recommended wording on page 4-31 of i
Regulatory Guide 3.66, page 3-16 of the Regulatory Guide cites the provision as optional. Without the provision, the penal sum of the bond may not be adjusted, but the licensee could obtain additional financial assurance (if necessary) by obtaining another financial mechanism.
(d)
Section 5 of the standby trust agreement allows withdrawal of up to " ten percent of the outstanding balance of the Fund or 100,000 dollars, whichever is greater, without NRC approval." Although $100,000 corresponds to only five percent of the financial assurance coverage, the agreement correctly requires withdrawals of more than ten percent to be accompanied by written NRC approval.
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(e)
The submitted standby trust agreement does not include section 6(c) of the recommended wording of Regulatory Culde 3.66, page 4-20.
This section authorizes the trustee to hold uninvested cash for up to 60 days without liability for interest. Although the trustee may now be liable for interest on uninvested cash, the earned interest will accrue to the trust. Consequently, the omission (which has been accepted by the trustee) does not diminish the protections afforded NRC.
Finally, the Region should ensure that documents submitted by the are ori inally signed duplicates, as recommended in Regulatory Guide licensee S
3.66.
Unless the documents have been properly signed, NRC cannot be certain that the financial assurance mechanism is enforceable.
Because ICF does not possess the original submissions, we cannot verify compliance with these requirements.
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