View source for ML22293A425

{{Adams
| number = ML22293A425
| issue date = 10/04/2022
| title = NFS Financial Assurance Instruments 2022 Letter
| author name = Knowles T
| author affiliation = BWXT Nuclear Fuel Services, Inc
| addressee name = 
| addressee affiliation = NRC/NMSS/DFM
| docket = 07000143
| license number = SNM-124
| contact person = JDOWNS NMSS/DFM/FFLB 3014157744
| case reference number = 21G-22-0126, ACF-22-0247, GOV-01-55-04
| package number = ML22293A424
| document type = Letter
| page count = 3
}}

=Text=
{{#Wiki_filter:Nuclear Fuel Services, Inc. OFFICIAL USE ONLY

Certified Mail 21G-22-0126 Return Receipt Required GOV-01-55-04 ACF-22-024 7

October 4, 2022

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
: 2) Letter from Tim Knowles to NRC, dated November 30, 2021, (21G 0091 ), Updated Decommissioning Funding Plan as Required by 10 CFR 70.25(e)(2)
: 3) Letter from NRC to Tim Knowles, dated June 15, 2022, NFS Interim Approval of Decommissioning Cost Estimate Amount (Enterprise Project Identifier L-2021-DFA-0009)

==Subject:==
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, 8, and C contain an updated Statement of Intent, Amendment No. 4 of the Standby Trust Agreement, and an updated Surety Bond. Attachment 2 contains a Certification of Financ ial Assurance that has been prepared in conformance with the Consolidated NMSS Decommissioning Guidance (NUREG-1757, Vol. 3).

Enclosure A is a copy of the original document that was submitted directly to NRC by DOE/Naval Reactors under a separate cover letter. 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.

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120 5 B anner H ill R d, Erwin, TN 3 7650 t: + 1.423.743.9141 f: +1.423.743.0 140 www.nuclearfuelservices.com INNOVATION DRIVEN }
OFFICIAL USE ONLY 21 G-22-0126 GOV-01-55-04 ACF-22-0247

NFS is requesting that the NRC acknowledge and accept Enclosures B and 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 8/22/2019 and 8/13/2019), a Certification of Financial Assurance (dated 10/2/2019), and Amendment No. 3 to the Standby Trust Agreement (dated 8/30/2019).

NFS is submitting a revised Chapter 10 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 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 Mr. Tom Holly, Licensing Manager, at (423) 735-2595. Please reference our unique document identification number (21 G-22-0126) in any correspondence concerning this letter.

Sincerely,

NUCLEAR FUEL SERVICES, INC.
J~I~
Tim Knowles, Director Safety and Safeguards

TCH/las

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OFFICIAL USE ONLY 21 G-22-0126 GOV-01-55-04 ACF-22-0247

Attachment 1: Summary of NFS D&D Liability and Financial Assurance Attachment 2: Certification of Financial Assurance Enclosure A: Statement of Intent from DOE/Naval Reactors, dated 9/1/2022 and 8/31/2022 Enclosure B: Amendment No. 4 of the Standby Trust Agreement, dated 03/01/2016 (Re issued 08/1/2022)
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. Joel Rivera-Ortiz Senior Fuel Facility Inspector 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. Robert Williams Chief, Projects Branch I Division of Fuel Facility Inspection U. S. NRC, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257

Mr. Larry Harris Senior Resident Inspector U.S. Nuclear Regulatory Commission

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