ML26034C174

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Financial Assurance Instruments to Support the NFS Decommissioning Funding Plan
ML26034C174
Person / Time
Site: Erwin
(SNM-0124)
Issue date: 01/22/2026
From: Rogers D
Nuclear Fuel Services
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
21G-25-0207, GOV-01-55-04, ACF-25-0355
Download: ML26034C174 (0)


Text

'I' Nuclear Fu el Services, Inc.

OFFICIAL USE ONLY Certified Mail Return Receipt Required 21G-25-0207 GOV-01-55-04 ACF-25-0355 January 22, 2026 Director Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Reference:

1)

Docket No.70-143; SNM License 124

Subject:

2)
3)

Letter from Danielle Rogers to NRC, dated November 25, 2024, (21 G 0224 ), Updated Decommissioning Funding Plan as Required by 10 CFR 70.25(e)(2)

Letter from NRC to Danielle Rogers, dated June 10, 2025, NFS Interim Approval of Decommissioning Cost Estimate Amount (Enterprise Project Identifier L-2024-DFA-0021)

Financial Assurance Instruments to Support the NFS Decommissioning Funding Plan Nuclear Fuel Services, Inc. (NFS), hereby submits the financial assurance documents supporting the Decommissioning Funding Plan (DFP) for the NFS Site. Additionally, per License Condition S-2, minor administrative changes to SNM-124, Chapter 10, "Decommissioning," are being submitted as a result of the DFP update.

The financial assurance instruments contained herein guarantee that sufficient funds will be available when needed for decommissioning the NFS Site. Attachment 1 contains a summary of the methods of financial assurance in use and the corresponding instruments currently in place. Enclosures A, B, and C contain an updated Statement of Intent, Amendment No. 5 of the Standby Trust Agreement, and an updated Surety Bond. Attachment 2 contains a Certification of Financial Assurance that has been prepared in conformance with the Consolidated NMSS Decommissioning Guidance (NUREG-1757, Vol. 3).

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t: +1.423.743.9141 I + 1.423 743.0140 www nuclearfuelservices.com

OFFICIAL USE ONLY 21 G-25-0207 GOV-01-55-04 ACF-25-0355 Enclosure A is a copy of the original document that was submitted directly to NRC by DOE/Naval Reactors under a separate cover letter. It should be noted that Enclosure A erroneously states the total financial liability, not the value that is specifically the responsibility of the DOE. NFS sent a request on September 30, that the letters be revised to reflect the corrected value. DOE/NR has responded that the original letter is bounding and a revised letter will be issued at a later date, yet to be determined. Attachment 2 and Enclosures B, and C are copies of originally-signed documents. To ensure proper handling of the fully executed, originally-signed documents, the original attachments are being provided to the NRC Project Manager for NFS as an enclosure to his copy of this submittal. NFS is requesting that the NRC acknowledge and accept Enclosures Band C of the Standby Trust Agreement and the Surety Bond by signing the bottom of the two documents as flagged on the originals.

As mentioned above, Attachment 1 contains a summary of the methods of financial assurance in use and the corresponding instruments currently in place. Upon completion of your review, please return the financial assurance documents currently on file that have now been superseded and are no longer required. These documents include DOE Statements of Intent

( dated 8/31/2022 and 9/1/2022), a Certification of Financial Assurance ( dated 10/4/2022), and Amendment No. 4 to the Standby Trust Agreement (dated 8/1/2022).

NFS is submitting a revised Chapter 1 O for the SNM license as a result of this latest DFP update; it is included in Enclosure D. The revised chapter is included in its entirety, in addition to a revised Chapter Index. Changes are noted by vertical lines in the left margin of the affected pages. In accordance with the criteria of License Condition S-2, NFS has determined that the changes are administrative in nature and do not reduce safety or the level of effectiveness of the License Application.

If you or your staff have any questions, require additional information, or wish to discuss this, please contact me, or Mrs. Ashley Morris, Licensing Manager, at (423) 743-1758. Please reference our unique document identification number (21 G-25-0207) in any correspondence concerning this letter.

ARM/las Sincerely, NUCLEAR FUEL SERVICES, INC.

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Danielle Rogers, Director Safety and Safeguards OFFICIAL USE ONLY When detached, handle this page as decontrolled.

OFFICIAL USE ONLY : Summary of NFS D&D Liability and Financial Assurance : Certification of Financial Assurance 21 G-25-0207 GOV-01-55-04 ACF-25-0355 Enclosure A:

Statement of Intent from DOE/Naval Reactors, dated 09/11/2025 and 09/10/2025 Enclosure B: Amendment No. 5 of the Standby Trust Agreement, dated 03/01/2016 (Re-issued 01/09/2026)

Enclosure C: Surety Bond Enclosure D: SNM-124, Chapter 10, Update Per License Condition S-2 Copy:

Regional Administrator U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. James Downs (originals)

Senior Project Manager Fuel Manufacturing Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Bradley Davis Chief, Projects Branch I Division of Fuel Facility Inspection U. S. NRC, Region 11 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Nicholas Peterka Senior Fuel Facility Inspector U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Richard Skokowski Senior Resident Inspector U.S. Nuclear Regulatory Commission OFFICIAL USE ONLY When detached, handle this page as decontrolled.