NUREG/CR-1754, Requests Listed Info within 120 Days Supporting Decommissioning Funding Plan & Parent Company Guarantee. Forwards Reg Guide 3.66 & NUREG/CR-1754.W/o Encl
| ML20059A808 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 10/21/1993 |
| From: | Lamastra M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Christopher Boyd BABCOCK & WILCOX CO. |
| References | |
| RTR-NUREG-CR-1754, RTR-REGGD-03.066, RTR-REGGD-3.066 TAC-L21624, NUDOCS 9310270132 | |
| Download: ML20059A808 (3) | |
Text
Docket 70-824
. License SNM-778 OCT 211993 Mr. Charlie C. Boyd, Jr.
Licensing & Compliance Officer Babcock & Wilcox Nuclear Environmental Services Division Lynchburg Technology Center P.O. Box 11165 Lynchburg, VA 24506-1165
Dear Mr. Boyd:
SUBJECT:
DECOMMISSIONING FUNDING PLAN AND PARENT COMPANY GUARANTEE r
(TAC NO. L21624)
We have completed our review of the Decommissioning Funding Plan and Parent Company Guarantee provided by your letter dated August 27, 1992. We have concluded that additional information is needed before final action can be taken (see enclosure).
We reviewed your plan against Regulatory Guide 3.66,
" Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72," and NUREG/CR-1754, "lechnoloav. Safety and Costs of Decommissionina Reference Non-Fuel-Cycle Nuclear Facilities." Copies of Regulatory Guide 3.66 and NUREG/CR-1754 are enclosed for your use.
Please submit the requested information (six copies) within 120 days of the date of this letter.
Please reference the above TAC No. in future correspondence related to this request.
If you have any questions, please contact me at (301) 504-3416.
bhlGitMLSIGNED BY Michael A. Lamastna Licensing Section 2 l
Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS
Enclosures:
1.
Comments on Decommissioning Funding Plan and Parent Company Guarantee 2.
NUREG/CR-1754 fl Distribution w/ encl.1 (Control No. 2405)
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a Request for Additional Information i
Application Dated August 27, 1992 i
Babcock & Wilcox (B&W) l Lynchburg Technology Center Docket 70-824 l
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Please provide the following information:
i 1.
The preamble to the decommissioning rule (Federal Reaister, Vol.
l 53, No. 123, June 27, 1988, Pages 24035-24036) states that a parent guarantee is allowed only when the parent company provides "an independent commitment beyond that of the licensee to expend funds." Our review of financial information on the parent, Babcock & Wilcox Investment Company (BWICO), indicates that nearly 1
all of the parent's financial strength derives from the licensee, Babcock & Wilcox Company. Accordingly, an adverse performance by B&W could significantly diminish the financial strength' of BWICO.
l Since our analysis indicates BWICO cannot provide an independent
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commitment of funds (beyond the licensee), BWIC0 appears to be an-l unacceptable parent company for purposes of compliance with 10 CFR Part 30, and you should submit an alternate financial assurance mechanism, or provide further information indicating that BWICO can provide a parent guarantee based on the parent's financial strength independent of licensee-subsidy assets.
2.
While your decommissioning cost estimate generally followed the i
cost estimating tables in Appendix F of Regulatory Guide 3.66, the cost estimate did not include sufficient detail to allow an i
adequate evaluation of cost estimate.
In particular, the i
submission did not include the following information-l Description of the facility, the activities that occur l
a.
at the facility, and the levels of contamination that may be present; b.
The number and dimension of the laboratory or facility components that will need to be decontaminated (such as fume hoods, glove boxes, laboratory benches, or ductwork), as addressed in table 2 of the cost estimate (" Equipment To Be Decontaminated"); and i
c.
The amount of contaminated materials generated during decommissioning and the associated cost of disposing these materials.
Please provide the above additional information.
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