ML20141F328
| ML20141F328 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies, 07001201, 07000364, 07000824, 07000135 |
| Issue date: | 01/26/1978 |
| From: | Favret L BABCOCK & WILCOX CO. |
| To: | Martin L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 08477, 8477, NUDOCS 8601090221 | |
| Download: ML20141F328 (3) | |
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1725 K Street. N.W., Washington D.C. 20006 Babcock &Wilcox (eg m g,0 m78
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Mr. John B. Martin, Assistant rector
_7 Fuel Cycle Safety and Licensing C
MN26 Division of Fuel Cycle and Material Safety 9-
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D8S Z United States Nuclear Regulatory Commission J
Washington, D. C.
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License Numbers SNM-42, SNM-145, SNM-414, SNM-778 m
o and SNM-ll68 -- Requests for Information Concerning Decommissioning Plans and Financial Arrangements
Dear Mr. Martin:
In response to a number of communications from NRC, including letters dated April 23, 1977, September 8,1977, and October 21, 1977, Babcock & Wilcox (B&W) is hereby submitting a proposal concerning financial qualifications to provide reasonable assurance that the facilities which are subject to the above-referenced licenses will be satisfactorily decommissioned.
Plans describing the methodn, criteria, and estimated costs of decommissioning o$ those facilities will be submitted separately.
Although there are no existing Commission regulations applicable to the above-referenced licenses which require a decom-missioning plan or related financial arrangements, B&W recognizes that, under 10 C.F.R. 570.23(a)(5) the Commission may consider whether an SNM licensee " appears to be financially qualified to engage in the groposed activities ' under the license.
This regulation does not,
)y its terms, require that consideration of financial qualifications encompass the costs of permanently shutting down the facility and maintaining it in a safe condition.
However, B6W is sensitive to the l
importance of maintaining public confidence in its licensed activities and the need to be responsive to the regulatory process.
Accordingly, B&W has given serious consideration to the question of financial qualifications for decommissioning under the above-referenced SNM licenses by drawing analogies to the more stringent regulations applicable to power reactor licenses.
B&W believes that the Commission's regulations applicable to financial qualifications of power reactor licenaces provide meaningful guidance for assessing suitable financial qualifications l
for decommissioning of facilition under SNM licenses.
10 C.F.R. 550.33(f) requires that a power reactor licensco establish that ho possesses or has reasonable assurance of obtaining (or any combina-tion of the two), sufficient financial resources to cover the estimated cost of operating the facility plus the estimated cost i
of permanently shutting down the facility and maintaining it in 1
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Babcock & Wilcox 2-January 26, 1978 Mr. John B'.
Martin a safe condition.
This regulation, which is more stringent than the analogous regulation applicable to special nuclear materials licenses (10 C.F.R. 570.23(a)(5)), does not require that the estimated costs of permanently shutting down the facility and maintaining it in a safe condition be assured by specific, dedicated financial arrangements, such as surety bonds or escrow accounts.
10 C.F.R. Part 50 and Appendix C require that financial qualifications be established solely on the basis of financial statements from the applicant or licensee.
10 C.F.R.
- 550, Appendix C distinguishes established enti ties f rom newly-fonned entities in regard to the quantum of information necessary to show financial qualifications.
In regard to established entities, such as B&W, Appendix C would recognize that current annual reports,
including a summary of prior year operating experience, would constitute sufficient information to establish financial qualifi-cations.
Moreover, the additional requirements in Section III and IV of Appendix C, which establish the licensee's obligation to file financial statements on an annual basis and provide additional information at the request of the Commission, assure that the Commission is continuously apprised of the licensee's financial qualifications.
If required by NRC, B&W will take action to implement now requirements for providing financial assurance with respect to decommissioning under the above-referenced licenses.
Specifi-cally, B&W would provide assurance of financial qualifications for decommissioning in accordance with its plan by filing informa-tion consistent with the existing reactor licensing requirements set forth in 10 C.F.R. 550.33(f) and 10 C.F.R. Part 50, Appendix C.
B&W, as an established entity, believes that impicmenta-tion of the aforementioned new requirements would provide adequate financial assurance for the decommissioning of those B&W facilities which are subject to special nucicar materials licenses.
We would welcome the opportunity to meet with you to answer any questions you may have or to discuss the foregoing proposal.
Respect fully st,1bmitted, l
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Vice Prentdent, Nuclear Divisions The Babcock 6 Uf1cox Company
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