ML20126G938
| ML20126G938 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 12/22/1992 |
| From: | Fauver D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Stauter J KERR-MCGEE CORP. |
| References | |
| NUDOCS 9301050009 | |
| Download: ML20126G938 (4) | |
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UNITED STATES E' -
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NUCLE AR REGULATORY COMMISSION W ASHING T ON, 0. C. 20555 k...../
OEC 2 21992 Docket No. 70-3073 John C. Stauter Kerr-McGee Corporation Technology & Engineering Division P.O. Box 25861 Oklahoma City, OK 73125
Dear Mr. Stauter:
SUBJECl:
REVISED APPLICATION FOR MATERIALS LICENSE FOR CUSHING REFINERY SITE - FINANCIAL ASSURANCE This letter refers to Kerr-McGee's September 25, 1992, revised materials license application for possession of the radioactively contaminated material at the t,ushing, Oklahoma Refinery 3ite. The Nuclear Regulatory Commission staff has completed its review of Attachment 4 to the application, which contains the Decommissioning Funding Plan, the Surety Bond Document, and the Standby Trust Agreement.
The comments on Attachment 4 are enclosed (Enclosure 1). NRC is continuing its review of the remaining parts of the application.
As stated in NRC's July 30, 1991, letter, which provided guidance on the preparation of your license application, the staff uses Regulatory Guide 3.66,
" Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72," as guidance when reviewing financial assurance submittals. A copy of Regulatory Guide 3.66 is enclosed (Enclosure 2).
The comments on the Surety Bond Document and the Standby Trust Agreement were generated by directly comparing the format in Regulatory Guide 3.66 with your submittals. To expedite the approval of ynur license application, please incorporate the comments verbatim into a revired to the Cushing Refinery Site license application and submit the revised attachment to NRC. The comments on your cost estimate are general.
However, Appendix F to Regulatory Guide 3.66 provides an acceptable format for the decommissioning cost estimate.
if you have any questions or concerns regarding the recommended format, please contact me at 301-504-2554.
Sincerely, puuh ~
/
David N. Fauver, Project Manager Decommissioning and Regulatory Issues Branch 0 4 0 0 63.-
Division of tow-tevel waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
Enclosures:
1.
NRC Comments i
2.
Regulatory Guide 3.66 j" 5 * ' " -
m oc;g p e 9301050009 921222
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PDR ADOCK 07003073 pij}g{
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r NRC COMMENTS ON ATTACHMENT 4 TO THE REVISED APPLICATION FOR MATERIALS LICENSE FOR THE CUSHING, OKLAHOMA REFINERY SITE, DATED SEPTEMBER 25, 1992 Qefommissionino fundino Plan In general, the Decommissioning Funding Plan cost estimate does not provide sufficient detail to allow NRC to independently review the acceptability of the cost estimate.
Provide a more detailed breakdown of the estimated decommissioning cosa. Appendix F to Regulatory Guide 3.66 contains an acceptable format foi the cost estimate.
Include such items as the breakdown of crew charges, administrattun charges, and contractor charges, basis for hydrocarbon extraction process costs, projected disposal cell dimensions, etc.
Satety Bond Document l
1.
Page 2, top paragraph, line 7, replace the word "provided" with the word, " provide".
2.
The three paragraphs at the top of page 4-32 of Regulatory Guide 3.66 should be included in the surety bond.
3.
The surety bond also should provide all of the information with regard to signatures, seals, and dollar amounts requested on page 4-32 of Regulatory Guide 3.66.
4.
NRC should have an originally signed duplicate of the surety bond document.
Standby Trust Aareement 1.
Page 1, the upper right hand corner provides the words " Duplicate Original".
NRC should have an originall3 signed duplicate of the Standby Trust Agreement and accompanied scheoules.
2.
Page 3, Section 6(b), line 6, following the words "Baa or", replace the word "high" with the word " higher".
3.
Page 6, top paragraph, line 10, replace the word " writing" with the word
" written".
4.
Page 7, bottom of page, should contain a seal.
5.
A certificate (of events) is required.
Please refer to page 4-24 of Regulatory Guide 3.66.
4 Docket No, 3073
- John C.-Stauter Kerr-McGee Corporation Tech _nology & Engineering Division P.O.. Box 25861 Oklahoma City, OK 73125
Dear F. Stauter,
SUBJECT REVISED APPLICATION FOR MATERIALS LICENSE FOR CUSHING REFINERY SITE - FINANCIAL ASSURANCE This lett r refers to Kerr-McGee's September 25, 1992, revised materials license i
applicatioh for possession of the radioactively contaminated material at the Cushing, Oklahoma Re 'nery Site.
The Nuclear Regulatory Commission staff has completed its review of Attachment to the application, which contains the Decommissioning Funding Plan, the Surety Bond Doc ment, and the Standby Trust Agreement.
The comments on Attachment 4 are enclosed (enclos e 1).
We are continuing our review of the remaining parts of the application.
As stated in NRC's J y 30, 1991, letter, which provided guidance on the preparation of your license applicati n, the staff uses Regulatory Guide 3.66, " Standard Format and Content of Financial As urance Mechanisms Required for Decommissioning Under 10 CFR-Parts 30, 40, 70, and 72," as uidance when reviewing financial assurance submittals.
A copy of Rcgulatory Guide 3.66 is nclosed (enclosure 2). The comments on the Surety Bond Document and the Standby Trust Agre ent were generated by directly comparing the format in Regulatory Guide 3.66 with pur submittals. To expedite the approval of your license application, please incorpord e the comments verbatim into a revised Attachment 4 to the Cushing Refinery Site license pplication and submit the revised attachment to NRC. The comments on your cost estimate re general. However, Appendix F to Regulatory Guide 3.66 provides an acceptable format fo-the decommissioning cost estimate.
I If you have any questions or conce s regarding the recommended format please contact me at 301-530-4527.
Sincerely, David N. Fauve Project Manager FacilitiesSectln Decommissioning a d Regulatory Issues Branch Division of Low-Le el Waste Management and Decommissioni
, NMSS
Enclosures:
- 1. NRC Comments
- 2. Regulatory Guide 3.66 RISTRIBUTION:
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