ML111950099
| ML111950099 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, 07000754, 07001113, 07002872, 07200001, Vallecitos |
| Issue date: | 07/19/2011 |
| From: | Ryder C P NRC/NMSS/FCSS |
| To: | |
| Chris Ryder | |
| Shared Package | |
| ML112010212 | List: |
| References | |
| Download: ML111950099 (3) | |
Text
Conference Call Summary General Electric Parent Company's Guarantee of Funds for Decommissioning, Dated March 18, 2011 Date and Time: June 17, 2011, 9:30 A.M. (Eastern Time)
Participants from the U.S. Nuclear Regulatory Commission (NRC)
Christopher Ryder, Fuel Manufacturing Branch, Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards (NMSS)
Roman Przygodzki, Special Projects Branch, Division of Waste Management and Environmental Protection (DWMEP), Office of Federal and State Materials and Environmental Management Programs
Participants From General Electric-Hitachi (GEH)
Scott Murray, Manager, Licensing and Liabilities COE Nuclear, GEH Nuclear Energy Bob Lillge, Manager, GEH Liabilities Reduction
Background
In a letter (Reference 1), dated March 18, 2011, General Electric Company (GE) submitted its annual demonstration of passage of the financial test set forth in Title 10 of the Code of Federal Regulations (10 CFR) Part 30, Appendix A, "Criteria Relating to Use of Financial Tests and Parent Company Guarantees for Providing Reasonable Assurance of Funds for Decom-missioning." GE provided a parent company guarantee of decommissioning funding, which covers, in addition to other licenses, Special Nuclear Material License SNM-960. By letter, dated June 2, 2011, the NRC staff sent a letter to GE in Fairfield, CT, transmitting requests for additional information (RAIs). The letter was forwarded to S. Murray at GEH in Wilmington, NC on June 17, 2011. S. Murray asked C. Ryder for a conference call to clarify the RAIs and discuss, in general terms, the content of the answers. S. Murray also asked for an extension to reply. Reference 2 requests a reply within 30 days of the date of the letter. He received the letter on June 16, 2011, leaving insufficient time to provide a response.
Discussion
Request for Additional Information (RAI) 1 asks that GE clarify the effective date of the Parent Company Guarantee. S. Murray stated that every year, GE guarantees the subsidiaries and that Reference 1 is a recertification of that guarantee. S. Murray stated that GE interprets the effective date to be the first line of the guarantee in Attachment 3 of Reference 1. R. Przygodzki stated that Reference 3 has wording that makes a distinction between the effective date and the date of the financial instrument. The wording is in Reference 3, page A-125. S. Murray agreed 2 that the submittal does not have guidance wording. He inquired if there is an alternative way to meet the intent of Reference 3, given that the financial instrument would have to be revised at GE Headquarters. R. Przygodzki agreed to defer the change to the next year, provided that the RAI response clearly states the effective date. S. Murray agreed to state this in the response to RAI 1; then, GE attorneys will have to consider the wording in Reference 1.
RAI 2 asks GE to clarify the corporate relationship between the various licensees stated on the Agreement. S. Murray briefly discussed the relationships. This will be clarified in the response to RAI 2.
RAI 3 asks GE to clarify the basis for changes in the cost estimates. S. Murray and B. Lillge briefly described the reasons for the changes in the costs. R. Przygodzki wanted clarification as to whether the changes to the cost estimates stated in Reference 1 are consistent with the methods for adjusting cost estimates as described in the respective decommissioning funding plan and cost estimate.
RAI 4 asks GE to provide a Certification of Financial Assurance. S. Murray agreed that the document was not provided. He asked if the possession limits need to be provided in the document. Given that GEH has multiple licenses, the possession limits can be given in an attachment. Both an unredacted and redacted version will be necessary. Guidance on the certification is on page A-23 of Reference 3. Also, R. Przygodzki stated that per 10 CFR 70.25(e), the certification is to be done by the licensee. S. Murray asked whether the Chief Executive Officer of GEH could be the licensee's business leader who would sign the Certification of Financial Assurance. R. Przygodzki stated that this would be acceptable for those licenses that identify the licensee as GEH.
Extension to Reply to the RAIs
S. Murray asked for an extension to reply to the RAIs to the end of July 2011. Currently, the date would be July 2, 2011. C. Ryder stated that the request needs to be in writing. The letter should be sent to NRC (to the same address as all other correspondence). C. Ryder suggested that the request ask for an extension on or before mid-August 2011.
References
- 1. Letter to Director, NMSS, NRC, from Keith S. Sherin, GE, "General Electric Company Parent - Guarantee of Funds for Decommissioning: Updated Letter from Chief Financial Officer to Demonstrate Financial Assurance," March 18, 2011. Agencywide Documents Access and Management System (ADAMS) Accession Number ML110900562.
- 2. Letter from C. Ryder, NRC, to Keith S. Sherin, "Request For Additional Information Regarding Parent Company Guarantee And Annual Financial Test For General Electric Hitachi (TAC NO. L33125)," June 2, 2011. ADAMS Accession Number ML111300305.
3 3. NRC, "Consolidated NMSS Decommissioning Guidance - Financial Assurance, Recordkeeping, and Timeliness," NUREG-1757, Volume 3. Final Report. September 2003. ADAMS Accession Number ML032471471.