ML23089A240
| ML23089A240 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/10/2023 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | Global Nuclear Fuel |
| Shared Package | |
| ML23089A238 | List: |
| References | |
| EPID L-2022-DDP-0002 | |
| Download: ML23089A240 (1) | |
Text
Enclosure REQUEST FOR SUPPLEMENTAL INFORMATION DOCKET NO.:
70-1113 LICENSE NO.: SNM-1097 LICENSEE:
GLOBAL NUCLEAR FUEL - AMERICAS, LLC
SUBJECT:
2022 TRIENNIAL UPDATE TO DECOMMISSIONING FUNDING PLAN By letter dated October 4, 2022 (Agencywide Documents Access and Management System
{ADAMS} Accession Number ML22277A539), in accordance with the requirements in title 10 of the Code of Federal Regulations (10 CFR) 70.25(e)(2), Global Nuclear Fuel-Americas, L.L.C.
(GNF-A), provided its 2022 triennial update to its decommissioning funding plan (DFP) for its facility in Wilmington, NC. The U.S. Nuclear Regulatory Commission (NRC) staff identified the following information that is needed to complete its acceptance review of GNF-As submittal and for proceeding with a detailed technical review.
1.
The decommissioning cost estimate (DCE) is to reflect current facility conditions.
Issue:
With respect to onsite radiological inventory, GNF-As 2022 DFP indicates on page 5.1, Current SNM material is owned by GNF-A customers, is of significant value, and will be utilized as part of normal licensed processes or transferred for use at another facility prior to commencing decommissioning. The GNF-A fuel manufacturing processes can be emptied of SNM inventory in a timely manner and produce a form of material that can be removed from the site under arrangements that fall under principal licensed activities. Operations will continue until inventory quantities of uranium have been removed. Operational waste inventories will be representative of normal operations.
This assumption is inconsistent with NRC requirements and guidance, specifically because it does not (1) reflect an assumption that routine facility conditions exist at the time of decommissioning, (2) adequately demonstrate that the customers will cover the costs for packaging, loading, and transporting the material to another facility which can accept the material (e.g., affirmation that current GNF-A sales contracts contain such provisions), or (3) include the costs for removal of such inventory in the DCE.
Regulatory Basis:
The regulations in 10 CFR 10 CFR 70.25(e)(1)(ii) require, in part, that each licensee to identify and justify the key assumptions used in preparing the DCE. Additionally, the regulations in 10 CFR 70.25(e)(2)(v) require, in part, that each licensee specifically consider changes in authorized possession limits.
Request:
Describe how GNF-A customers are responsible to remove inventory off-site prior to decommissioning (provide an affirmative statement that all inventory remains titled in the customers name and customers are responsible via contract to package, load, and ship
2 inventory from GNF back to customers NRC licensed facility) or increase the DCE amount to cover costs to permanently remove inventory offsite.
2.
Update GNF-As Schedule A to its Standby Trust Agreement.
Issue:
In the 2017 NRC safety evaluation report of GNF-As financial instruments (ML17275A603) it states, General Electric has previously submitted multiple Standby Trust Agreements (STA) that have been approved by NRC staff. The STA Schedule A amounts will need to be updated to reflect all current decommissioning costs identified in GEs latest PCG [Parent Company Guarantee] submission. This Schedule A update for each facility should be submitted with the re-submittal of the next decommissioning funding plan or license renewal, whichever comes first. The Schedule A update was not included with the DFP.
Regulatory Basis:
The regulations in 10 CFR 70.25(e)(1)(v) requires a signed original, or, if permitted, a copy, of the financial instrument obtained to satisfy the requirements of paragraph (f) of this section (unless a previously submitted and accepted financial instrument continues to cover the cost estimate for decommissioning).
Request:
GNF-A is requested to submit the Schedule A update.
ML23089A238; ML23089A240 OFFICE NMSS/DFM/FFLB NSIR/DSO/SOSB NMSS/REFS/FAB NRR NAME JRowley JCurry FMiller SLav DATE Mar 30, 2023 Apr 4, 2023 Apr 5, 2023 Apr 7, 2023 OFFICE NMSS/DFM/FFLB NAME JRowley DATE Apr 10, 2023