ML20079C797

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Responds to NRC 910529 Request Re Decommissioning Funding Assurance.Creation of Fund Useful as Step Constituting Further Assurance of Decommissioning Funding
ML20079C797
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 06/20/1991
From: Kessel R
LONG ISLAND POWER AUTHORITY
To: Crutchfield D
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9106260118
Download: ML20079C797 (2)


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A utri tv 2200 June 20, 1991

$~0 - fa?N Mr. Dennis Crutchfield Division Director for Advanced Reactors and Special Projects Office of Nuclear Reactor Regulation Document Control Desk U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 Re:

Comments of the Long Island Power Authority Recardino Decommissionino Fundino Assurance

Dear Mr. Crutchfield:

This letter respt.nds to the NRC Staff's May 29, 1991 request that LIPA address the three NRC Staff inquiries concerning decommissio-ing funding posed in your letter to LILCO dated May 22, 1951.

In response, LIPA hereby endorses LILCO's responses but wishes to comment further upon LILCO's Answer 1.

LIPA agrees with LILCO that decommissioning funding is fully assured (1) b1 the mechanism of the Site Cooperation and Reimbursement Agreement, dated January 24, 1990 (" Site Agreement")

and (2) by the ongoing commitment of the New York Public Service Commission ("PSC") to effectuation of the Shoreham Settlement.

Accordingly, LIPA also agrees that creation of a separate $10 million contingency fund was not a necessary ingredient of assuring decommissioning funding.

However, as.noted by LILCO, creation of the fund was useful as a step constituting "further assur2nce" of decommissioning funding.

LIPA is providing these additional comments to put into more appropriate context LILCO's statement in its Answer 1 that, if

" decommissioning activities [were] suspended," $10 million would

-suffice to place Shoreham in a radiologically safe condition pending resumption of decommissioning activities.

LIPA does not dispute LILCO's technical conclusion, but believes that such a scenario is so remote as not to be credible.

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Page 2 First, as noted above, the assurances provided by the Site Agreement and PSC commitments demonstrate that decommissioning funding is amply assured and hence that there will be no interruptions in funding.

The S10 million fund provides a further assurance that decommissioning can continue without interruption.

And LILCO has now committed to yet another level of assurance by dedicating portions of its line of credit to cover decommissioning costs.

(See LILCO Answer 3. )

But assuming hypothetically that the foregoing financial resources were not equal to some unforeseeable and evtreme circuustance, all interested entities in New York State would recognize that the type of temporary decommissioning suspension referred to by LILCO would be wasteful and disruptive and that, if necessary, additional fincncial restorces should be tapped to assure uninterrupted decommissioning.

Please advise if further information from LIPA would be of assistance.

LIPA is, of course, anxious that the NRC's funding conccrns be resolved expeditiously so as to allow f urther progress on the joint LILCO-LIPA application for license transfer.

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