ML20056G442
| ML20056G442 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 08/23/1993 |
| From: | Knapp K FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20056G443 | List: |
| References | |
| RTR-NUREG-CR-1754 NUDOCS 9309030125 | |
| Download: ML20056G442 (7) | |
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>B&WFUEL COMPANY N
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) An Amencen Company with Wodo' wide Resources P.O. Box 1164 S Lynchburg. VA 24506-1646 Telephone:B04-522-6000 August 23, 1993 Mr. Robert C.
Pierson Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS United States Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Pierson:
REFERENCE:
SNM License 1168, Docket 71-1201, Decommissioning Funding Plan B&W Fuel Company (BWFC) submitted it's Decommissioning Funding Plan for the Commercial Nuclear Fuel Plant (CNFP) on March 27, 1992.
NRC requested further information regarding our submittal on April 29, 1993.
With the exception of using NUREG/CR-1754, the Plan has been revised to include comments 1-4 from your April correspondence.
NUREG/CR-1754, which you cited as a reference source, reports on a cost study for decommissioning non-fuel cycle nuclear facilities.
We have gained our own experience by decommissioning areas of the plant that was used for pelletizing operations in addition with decontamination efforts that are performed to support day to day operations.
This experience, using current labor rates, was used to determine cost estimates for decommissioning.
In regards to items 5 -
10, the requested changes will be incorporated to the Letter of Credit and the Standby Trust Agreement to meet RegOuide ~3.66.
However, due to the increase in projected decommissioning ' costs, resolutien of the Partnership Board of B&W Fuel Company will be required prior to issuing the Letter of Credit.
This should be finalized by October 15, 1993.
Upon receipt, a copy shall be forwarded to you.
Attachment I addresses each comment separately.
In addition to your comments other changes include:
the costs for decommissioning the wet-weather stream has been significantly reduced due to characterization work that was completed in 1991 -
1993, additional field service equipment was added, and associated costs were changed to reflect current rates.
Six copies of the Decommissioning Funding Plan and revisions made to chapter seven of our license are included.
If you should need any further assistance with this matter, please feel free to I
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contact me at (804) 522-6202.
Sincerely, B&W FUEL COMPANY Commercial Nuclear Fuel Plant
'(chiav d. hypp Kathryn S.
Knapp cc:
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l ATTACHMENT I Please provide the following information:
l 1.
Although the Decommissioning Funding Plan (DFP) outlines the work required to deccmmission the facility, it does not include all the information needed to evaluate the cost i
estimate.
Please provide information needed to evaluate the cost estimate.
Please provide a more detailed description of i
the facility, including the number and dimensions of facility J
components (e.g., floors, ceilings, walls, fume hoods, sinks, drains, hot cells, benches); the extent of contamination at j
the facility; and the specific radionuclides handled.
Based j
on the information provided in the-DFP, you may have 4
underestimated the following cost elements:
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RESPONSE: A more detailed description of the controlled areas in i
the facility and drawings have been added to the Plan.
l (a)
Your estimate of $4.00 per square foot to decontaminate the ceilings and walls may be below NUREG/CR-1754 l
estimates that the activity will cost $10.29 per square foot ($100.00 per square meter).
RESPONSE: You cite NUREG/CR-1754 as a reference source.
This document was developed for non-fuel cycle nuclear
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facilities and BWFC does not feel that it is appropriate for our facility.
We relied on the experience' gained during our own decommissioning of areas of the plant that was used for pelletizing operations for decommissioning cost estimates.
(b)
Your cost estimate does not appear to include disposal I
costs for waste generated during decontamination of facility components.
Decontamination of walls, benches, and equipment will generate contaminated
- wastes, including wastewater, brushes, sponges, paper towels, and i
personal protective equipment.
For example, NUREG/CR-1754 estimates that decontamination of a ceiling will generate 0.2 cubic feet of waste per square foot of 3
2 ceiling (0.05 m /m ) which must than be disposed.
RESPONSE: We agree that these costs should be included.
- However, experience indicates that 1 cubic feet of waste per 1000 4
square feet is a more appropriate figure to use for the
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cost estimate for our facility in place of the guidance I
referenced in NUREG/CR-1754.
(c)
The DFP states it may be necessary to raze the facility but did not estimate the cost of the associated activities (e.g.,
disposal and decontamination costs).
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1 Y
It is recommended that you use or adapt the " cost estimating tables" in Appendix F of Regulatory Guide (RG) 3.66 to demonstrate that you have provided reasonable cost estimates for all major decommissioning activities and facility components.
You should also state explicitly whether site stabilization and/or long term surveillance will be necessary and, if so, estimate the cost of these activities.
RESPONSE: It is not credible that the facility will need to be razed due to contamination.
The decommissioning efforts outlined in this plan should be sufficient in accomplishing regulatory levels without razing the facility.
That paragraph has been removed.
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2.
RG 3.66, page 1-9, recommends that decommissioning estimates include the cost of planning and preparing the facility for decommissioning.
NUREG/CR-1754 estimates that it would require more than 60 person-days for planning and preparing each of the six referenced laboratories.
Although the DFP describes a pre-survey on page 2, it does not clearly include the cost of this pre-survey in the cost estimate nor does it address other activities related to planning and preparation (e.g.,
preparation of documentation for regula*ory agencies, development of detailed work plans).
It is recommended that you revise the estimate to account for the cost of planning and preparing for decommissioning.
RESPONSE: $
18,500 has been included for pre-planning and preparation.
This amount reflects 480 manhours at the current 3.ote for health physics support.
3.
It appears that your cost estimate credit for salvage value may be realized with the sale of potential assets after 4
decommissioning.
Page 3 of the cost estimate states:
" Contaminated equipment may be sold for use at another j
licensed facility.
In such instances, all exterior j
surfaces will be cleaned to levels permissible for restricted area use. The equipment will then be packaged and transported in accordance with DOT and NRC regulations.
The cost estimate does not account for equipment of this type."
RG 3.66 states that cost estimates should not incorporate credit for salvage value because you may not be able to sell the equipment.
Accordingly, you should increase the cost estimate to eliminate all credit for salvage value.
RESPONSE: The mentioned paragraph has been removed.
It was referring to the equipment used for field service activities conducted by SERF-3.
Appropriate costs for 2
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decontaminating and free releasing the material has been added in its place.
i 4.
It does n-; appear that the cost estimate has made any allowance for contingencies.
RG 3.66 recommends that a contingency factor be included in the decommissioning cost estimated.
Incorporating a contingency factor in cost estimates helps ensure coverage for unexpected circumstances that could raise decommissioning costs.
NUREG/CR-1754 uses a contingency factor at 25 percent.
Accordingly, it is recommended that you incorporate a contingency factor of 25 percent into your decommissioning cost estimate.
You may use a lower contingency factor, if you can demonstrate a lower factor is appropriate.
RESPONSE: Once again we feel that NUREG/CR-1754 is not an appropriate reference source for our f acility. Since our facility is basically mechanical operations and involve very low levels of contamination we do not feel that a 25% contingency factor is necessary.
We have included a contingency factor of 10%.
5.
Paragraph 3 of the letter of credit is worded as recommended in RG 3.66, page 4-33, except that it does not include a i
requirement to notify NRC and the B&W Fuel Company by l
" certified mail."
The letter of credit must be revised'to j
include the phrase "by certified mail."
RESPONSE: The Letter of Credit will be revised to include the i
phrase " certified mail."
The Letter of Credit shall be forwarded to you by October 15, 1993.
i 6.
Section 5, paragraph 2, of the standby trust agreement should be modified so that you cannot withdraw more than 10 percent of the outstanding balance of the trust, without NRC approval.
RESPONSE: The standby trust agreement has been modified to incorporate your request.
The standby trust agreement shall be forwarded to you by October 15, 1993.
7.
Section 6 of the standby trust agreement should be modified to require the trustee to invest the fund in the interest of the NRC (RG. 3.66, page 4-20).
l RESPONSE: The standby trust agreement has been modified to incorporate your request.
The standby trust agreement shall be forwarded to you by October 15, 1993.
l 8.
The standby trust agreement does not reference or include Schedules A,
B, and C.
Section 2 of the standby trust agreement does not reference Schedule A,
and the agreement does not include a Schedule A nor does it identify the 3
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i licensed facility beyond the license number.
The purpose of i
Schadule A is to assist the trustee in determining if funds should be distributed for a specific facility and, therefore, shoulu list the most recent decommissioning cost estimate or certification amount, the facility address, the NRC license number (s), and the licensee's name and address.
Section 4 of the agreement does not reference Schedule B, and the agreement does not include a Schedule B listing the property or money initially constituting the fund.
Schedule B is necessary to evaluate whether the trust fund contains enough funds to cover the cost of decommissioning.
The agreement also does not reference Schedule C in Section 11 and does not include a Schedule C.
Schedule C should stat the trustee's compensation for serving as trustee and is also called for by the RG 3.66.
It is recommended that you submit these schedules, as recommended in RG 3.66.
The schedules should include working similar to the samples on page 4-26 of RG 3.66.
Alternatively, you could revise the standby trust agreement to include the information from these schedules.
RESPONSE: The standby trust agreement has been modified to i
incorporate your request.
The standby trust agreement shall be forwarded to you by October 15, 1993.
l 9.
The submission does not include a specimen certificate 'of events or a specimen certificate of resolution with the standby trust agreement.
Section 5 of the standby trust agreement refers to specimen certificate of events, which in turn, refers to an attached certificate of resolution. Without the specimen certificates, we cannot be sure that the trustee will release decommissioning funds only upon receiving appropriate instructions.
In addition, the trustee may not be able to determine the validity of future resolutions authorizing commencement of decommissioning activities and payments from the trust.
Accordingly, please provide the specimen certificated (which should contain blank spaces for dates and signatures until decommissioning activities have commenced) worded similarly to the specimen certificates on pages 4-24 and 4-25 of RG 3.66.
RESPONSE: The specimen certificate has been revised to include your request.
10.
The second paragraph of the standby trust agreement does not include the complete phrase "the Atomic Energy Act of 1954 and the Enerav Reoraanization Act of 1974." While this is a minor omission, we request that the omitted phrase be included in your revised standby trust agreement.
RESPONSE: The standby trust agreement has been revised to include l
the omitted phrase. The standby trust agreemer.t shall be forwarded to you by October 15, 1993.
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B&W FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT USNRC LICENSE SNM-1168', DOCKET 70-1201 l
PART I CHAPTER 7.0 DECOMMISSIONING PLAN l
7.0 Decommissionina Plan The B&W Fuel Company shall fulfill the requirements set forth in 10 CFR 70.25 (e) and (f) through the implementation of the Decommissioning Funding Plan submitted to the Commission on March 27, 1992 and supplemented on August 23, 1993.
The B&W Fuel Company, Commercial Nuclear Fuel Plant will make no changes to the Plan which would decrease its effectiveness without prior approval of the USNRC.
Changes, which do not decrease the effectiveness of the Plan, will be reported to the NRC within six months of the change to the Chief, Fuel i
Cycle Safety Branch, Division of Industrial and Medical
[
Nuclear Safety, NMSS, Washington, D.C.
20555.
If decommissioning efforts are executed prior to plant closure, the affected area may be removed from the Plan.
The Plan shall be reviewed biennially and revised accordingly.
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PAGE:
7-1 LATE:
08-23-93 REV.:
2 SUPERSEDES:
PAGE:
DATE:
03-27-92 REV.:
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