ML20151J782

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Comment on Proposed Rules 10CFR30,40,50,70 & 72 Re self- Guarantee of Decommissioning Funding by non-profit & non- Bonding Issuing Licensees.Proposes That NRC Modify Language of Proposed Rule to Clarify Applicability to Certificates
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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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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