ML20151J782
| ML20151J782 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant, Portsmouth Gaseous Diffusion Plant, 07003089 |
| Issue date: | 08/01/1997 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-62FR23394, FRN-63FR29535, RULE-PR-30, RULE-PR-40, RULE-PR-50, RULE-PR-70, RULE-PR-72 62FR23394-00012, 62FR23394-12, AF64-2-013, AF64-2-13, GDP-97-0137, GDP-97-137, NUDOCS 9708050253 | |
| Download: ML20151J782 (2) | |
Text
FROM UsEc 301-ss4-3210 1997 08-01 17:10 e368 P.02/03 I
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6903 Rockkdge Drive
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Tel: (301) 514-3200 l
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United States 0FFICE OF SECRE TARY Emichment Corporation DOCKETING & SERVICE BRANCH l
DOCKET NUMBER PROPOSED RULE N soson l
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August 1,1997 Q pgggy I2 Secretary SERIAL: GDP 97-0137 US Nuclear Reguletory Commission 4
Washington, D.C. 20555-0001 1
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Attention: Docketing and Service Branch l
Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
AVLIS Uranium Enrichment Plant Docket Nos. 70-700170-7002,70-3089 USEC Comments on NRC's Proposed Rule "Self-Guarantee of Decommissioning Funding by Non-Profit and Non-Bond Issuing Licensees," (62 Fed. Reg. 23395)
Dear Sir:
On behalf of the United States Emichment Corporation (USEC), I am pleased to provide the following comments on the NRC's Proposed Rule, "Self-Guarantee of Decommissioning Fundmg by Non-Profit and Non-Bond Issuing Licensees."
The proposed amendment would extend current authority for licensees to self-guarant e f
decommissioning funding. It is not clear that certificatees. such as USEC, would also be extend d
'f this authority. USEC would also benefit from this opportunity to reduce the costs of complying Q
NRC finmMal assurance requirements. It was recently estimated that the costs ofobtaining Letter j
s of Credit and Surety Bonds for our gaseous diffusion plants is in excess of S100,000 per yea r.
Allowing certificatees to demonstrate compliance with the proposed financial criteda required to self-guarantee would reduce compliance costs while providing adequate confidence to the NRC that funds for decommissioning will be available when needed. It is proposed that the NRC modify th e language of the proposed rule to clarify that it also applies to certificatees.
The term " cash flow" is undefined in Appendix D. USEC understands the term to mean thp
" sum of net income plus depreciation, depletion, and a :,tornzation." It is proposed that the NRC modify the language of the proposed rule to define tF.e term " cash flow."
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9708050253 970801 PDR PR 30 62FR23394 PDR DSIO Officesin Paducah. Kentucky Portsmouth, ohio Washington. Do
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FROM USEC 301-564-3210 1997 08-01 17:11 C368 P.03/03 l'
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U.S. Nuclear Red =+ary Commission Dc 1 ' g and Service Branch August 1,1997 GDP 97-0137, Page 2 t
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Danic you fbr the Wdif to provide our input to the Commianian's evaluation em We would be pleased to discuss these enmments with you. Please contact Ms. T Je==*rie Jarriel at (3 31)
I 564-3247.
l sincerely,
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S. R.
I Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager t
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