ML24340A209
| ML24340A209 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 11/22/2024 |
| From: | Freudenberger R BWXT, BWXT |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| 24-069 | |
| Download: ML24340A209 (1) | |
Text
e WXr OFFICIAL USE ONLY BWX Technologies, Inc.
November 22, 2024 24-069 U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety & Safeguards Attn: Document Control Desk Washington, DC 20555-0001
Reference:
SNM-42, Docket 70-27
Subject:
Request to Amend License SNM-42, Chapter 10, Decommissioning-Update of Decommissioning Cost Estimate
Dear Sir or Madam:
BWXT Nuclear Operations Group, Inc. - Lynchburg (BWXT NOG-L) is submitting the revised Chapter 10 of the SNM-42 License Application in accordance with 10 CFR 70.25(e). This proposed amendment updates the cost estimate required for financial assurance for decommissioning as required by SNM-42, Chapter 10, Section 10.4. The original decommissioning plan, accompanying cost estimate and assurances were prepared in accordance with NUREG 1727 and approved by the NRC. This amendment updates those cost estimates for the approved decommissioning plan as required by the license. NUREG 1757, which incorporates and updates NUREG 1727, has been regarded as appropriate while updating this cost estimate. Amendments to the current Surety Bond, Standby Trust Agreement and Certificate of Financial Assurance will be revised and provided to the NRC following their approval of this update to the Decommissioning Cost Estimate. Additionally, all processes associated with Downblending have been removed from the facility. The Decommissioning plan has been updated to reflect this removal.
The following changes to Chapter 10 are being submitted for approval:
Changes Section 10.2, Plan (pages 10-1 & 10-2): Updates were made to areas listed. Naval reactors previously listed as bay 15A this was moved to Research Test Reactors. Downblending was removed since, this area has been decommissioned and is being repurposed for other operations.
Section 10.2.2.1, Procedure (page 10-3): Downblend removed.
Section 10.3, Table 10.3 (page 10-5): Downblend removed and L TC cost estimate updated.
Section 10.3.4, Stand by Trust Agreement (page 10-6): re numbered section with removal of Downblend section 10.3.4.
Section 10.4, Cost Estimates (pages 10-6 & 10-7): All mentions of Downblend removed. Sections renumbered as needed.
Appendix 10-2 (page 10-13): Updated the title Appendix 10-3 (Decommissioning Cost Estimate for Downblending Areas) removed due to Downblend no longer existing. Subsequent Appendixes renumbered.
New Appendix 10-3, Building B (page 10-17): Labs listed and names of these labs were updated to accurately reflect their current purposes and title.
New Appendix 10-3, Labor Rates (page 10-24): Updates to labor rates.
New Appendix 10-3, Cost Estimate (pages 10-25 & 10-26):
replaced tables with updated numbers.
New Appendix 10-4 (page 10-27): Renumbered previously 10-5 Document transmitted herewith contains Official Use Only Information Justification Editorial. List now accurately reflects plant conditions.
Editorial. Downblend no longer exists.
These changes reflect the updated cost estimates required to be submitted by the licensee every three years.
Editorial. Downblend no longer exists.
Editorial. Downblend no longer exists.
Editorial.
Editorial Downblend no longer exists. All existing equipment was fully removed on June of 2024.
Editorial. Some Labs and areas at L TC have changed requiring title updates and classification.
These changes reflect the updated cost estimates required to be submitted by the licensee every three years.
These changes reflect the updated cost estimates required to be submitted by the licensee everv three years.
Editorial QUO markings not applicable when OUO enclosure(s) is removed.
OFFICIAL USE ONLY INNOVATION DRIVEN >
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OFFICIAL USE ONLY As required, the Enclosure 1 to this letter includes the adjusted Decommissioning Funding Plan, as documented in Chapter 10 of the SNM-42 License Application, accounting for changes in costs and extent of contamination. Enclosure 1 also contains the revised SNM-42, License Application Chapter 10, Decommissioning. Enclosure 2 contains a red-lined version of SNM-42 to identify the changes to the plan. They consist of commercial and financial proprietary information, as well as proprietary contractual information, which is of a type described in 10 CFR 2.390(a)(4) and 10 CFR 9.17(a)(4). The enclosures are designated as Official Use Only.
If you have questions or require additional information, please contact Daniel Ashworth, Manager of Licensing and Safety Analysis, at dlashworth@bwxt.com or 434-522-5472.
Sincerely,
~
l!:=;f, Manager, Environment, Safety, Health & Safeguards BWXT Nuclear Operations Group, Inc., Lynchburg Enclosure cc: NRC, Resident Inspector (Cover Letter Only)
NRC, James Downs, Senior Project Manager (Cover Letter Only)
NRC, Noel Pitoniak, Region II YMN~ bw>o:t com OFFICIAL USE ONLY I'(! lJ pl,, '.,Irr; r1 q INNOVATION DRIVEN >