ML20210D510

Responds to Request That General Atomics Update Portions of Current License Renewal Application That Address Requirements for Decommissioning Financial Assurance & Emergency Plans

ML20210D510
Person / Time
Site:	07000734
Issue date:	06/11/1992
From:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
696-1920, NUDOCS 9206160120
Download: ML20210D510 (2)

Text

{{#Wiki_filter:-- i ~. 'cansanLAscancs 1 ~ June 11,1992 696 1920-VM "EDERAL EXPRESS Mr. John W. N. Hickey, Chief Fuel Cycle Safety Branch. Division of Industrial and Medical Safety, NMSS ~U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White' Flint North Rockville, MD 2C852

Subject:

Docket No. 70-734; License No. SNM-696: Request for Schedular Exemption :

References:

Hickey, John W. N., Letter to General Atomics, ATrN: Dr. Keith E. Asmussen,-- dated May 12,1992

Dear Mr. Hickey:

This letter is in response to your recent request.(Ref.) that General' Atomics (GA) l update portions ofits current license renewal application that address the requirements for Decommissioning Financial Assurance (10 CFR 70.25) and Emergency _ Flans (10 CFR 70.22). Clearly,10 CFR ~70.22(a)(9) does indeed ' explicitly require compliance with'10_ j CFR 70.25. However, when referring to holders.of specific licenses issued before July 27, 1990,'such as General l Atomics,10 CFR 70.25(c)(2) states that such licensees "... shall submit, on or before July 27,-1990, a decommissioning funding plan or certification of financial assurance for -_ decommissioning in an amount at least ' equal to-$750,000'in'- accordance with'the criteria set forth in thisisection." lIn compliance with the.-newL regulation, GA submitted certification of financial assurance'for $750,000 by letter dated-July 26,1990. In support of the financial _ assurance provided,LGA submitted revised-financial statements on March 29,1991.. By letter dated April 25,1991,' NRC advised GAL that a review of GA's financial' assurance submittal _ dated July 26,1990_-and the revis'ed - financial statement submitted March 29,1991-identified no deSciencies. i F Consistent with NRC staff, GA viewed, and still views, the rule changes (i.e.,10.CFR 70.22 and 10 CFR 70.25) as' requirements for the next licen e renewal application.that'it ~ . submits after July 20,1990. This_is'alsol consistent with the text of the rules, with thet a background information provided in the Federal Register notice announcing the new final 9206160120 920611 -{DR ADOCK 0700 4' 3550 GENERAL ATOMICS COURT, SAN DIEGQ CA 92171-1194 ~~ PO 80X.86608, SAN DIEGa CA 92186-9784 (619i456-3000 < }k w, ,s # 'i u

Jotyi W. N. Hick y, U.S. NRC June 11,1992 696 1920 Page 2 rule (53 FR 24018, June 27,1988), with the information presented by NRC staff at the NRC Fuel Cycle Licensee Workshop May 3-4,1989, as well as with the guidance provided by NRC in NUREG-1336 Rev.1 " Standard Format and Content Guide for Financial As;urance Mechanisms Required for Decommissioning Under 10 CFR Parts 30,40,70, and 72," dated August 1989. Notwithstanding the above arguments, GA will prepare and submit a decommissioning funding plan in response to your recent request (Ref.). In fact, necessary cost estimates for such a plan are currently being prepared. However, GA will need additional time to complete the cost estimates and establish a proposed mechanism for providing financial assurance in the amount of the cost estimate. Accordingly, GA hereby requests that it be granted a 90 day extension of time, until September 9,1992, to submit its decommission-ing funding plan. 4 With regard to the new requirements for emergency plans (10 CFR 70.22), GA understands that its NRC approved Radiological Contingency Plan needs to be updated to include a certification that GA has met its responsibilities under the Emergency Planning and Community Right to-Know Act of 1986, Title III Pub. L. 99-499. GA is meeting its responsibilities under this law and will add such a certification to its Radiological Comingency Plan. GA proposes to review its entire plan for areas needing updating or revision, to incorporate the just mentioned certification, along with any other needed changes, and submit a revised plan to NRC on the same schedule as requested above for submitting a decommissioning funding plan. Hopeful of your early concurrence with this request, GA is proceeding as discussed above. If you have any questions regarding this matter, or require additional information, please contact me at your earliest convenience at (619) 455 2823. Very truly yours, Y w Keith E. Asmussen, Director Licensing, Safety and Nuclear Compliance KEA:shs cc: Ms. Merri Horn, U.S. NRC Headquarters Mr. John B. Martin, Regional Administrator, U.S. NRC Headquarters}}