ML23116A184

GNF-A Response to NRC Request for Supplemental Information - Decommissioning Funding Plan (DFP)

ML23116A184
Person / Time
Site:	07001113
Issue date:	04/26/2023
From:	Murray S Global Nuclear Fuel - Americas
To:	Rowley J Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
M230059
Download: ML23116A184 (1)

Text

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Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing Global Nuclear Fuel 3901 Castle Hayne Road P.O . Box 780 Wilmington, NC 28402 USA M230059 T (910) 819-5950 scott.murray@ge.com April 26, 2023 Jonathan Rowley, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety & Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk

Subject:

GNF-A Response to NRC Request for Supplemental Information -

Decommissioning Funding Plan (DFP)

References:

1) NRC License SNM-1097, Docket 70-1113

2) GNF*A Decommissioning Funding Plan, Rev. 8, 10/4/22

3) Letter, from Jonathan Rowley (NRC) to S. P. Murray (GNF-A) Request for Supplemental Information Regarding Update to DFP, 4/10/23

Dear Mr. Rowley:

Per your request (Reference 3), the Global Nuclear Fuel-Americas, L.L.C. (GNF-A) facility in Wilmington, North Carolina hereby provides supplemental information regarding the GNF-A Decommissioning Funding Plan, Rev. 8 dated October 4, 2022.

If you have any questions regarding this matter, please contact me at (910) 819-5950.

Sincerely, std~

Facility Licensing ger ( /

Attachment:

GNF-A response to NRC request for supplemental information cc: J. Rivera, USNRC/RII/DFFI SPM 23-016

USNRC M230059 April 26, 2023 Page 1 of 2 GNF-A RESPONSE TO REQUEST FOR SUPPLEMENTAL INFORMATION REGARDING UPDATE TO GNF-A DFP (NRC Request dated 04/10/23)

Global Nuclear Fuels -Americas License Number: SNM-1097 Docket Number: 0700-1113 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-A's 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-A's 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 customer's name and customers are responsible via contract to package, load, and ship

USNRC M230059 April 26, 2023 Page 2 of 2 inventory from GNF back to customer's NRC licensed facility) or increase the DCE amount to cover costs to permanently remove inventory offsite.

GNF-A Response:

Revision 8 of the GNF-A SNM-1097 DFP, Section 5.0, Assumption 2 currently states, in part:

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.

Per NRC's additional request:

Current fuel supply contracts require the customer to remove their uranium supplied inventory upon contract termination. Costs associated with these returns are porne by the customer, except for limited conditions where GNF-A is liable. In the unlikely event that GNF-A becomes responsible for costs associated uranium inventory removal, these costs are operational in nature and are anticipated to be a small percentage of the decommissioning cost estimate.

2. Update GNF-A's Schedule A to its Standby Trust Agreement.

Issue:

In the 2017 NRC safety evaluation report of GNF-A's 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 GE's 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.

GNF-A Response:

The GNF-A standby trust agreement Schedule A will be updated and submitted in a timely manner after NRC approves Revision 8 of the decommissioning funding plan dated October 4, 2022.