ML18214A709

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Conversation Record for Dow Agrosciences to License No. 13-26398-01
ML18214A709
Person / Time
Site: 03032714
Issue date: 09/18/2013
From: Bishop J L
NRC/RGN-III
To: Roberts R
Dow AgroSciences
References
300363
Download: ML18214A709 (2)


Text

NRC FORM 699 ,,...-""*-.,., U.S. NUCLEAR REGULATORY COMMISSION (03-2013) f 3 ';,~ ,: \., .l CONVERSATION RECORD .... ..,. NAME OF PERSON(S)

CONTACTED OR IN CONTACT WITH YOU Rohen Roberts E-MAIL ADDRESS reroberts@dow.com ORGANIZATION Radiation Safety Officer LICENSE NUMBER(S) 13-26398-01 SUBJECT Additional Information Requested for Financial Assurance Review

SUMMARY

DOCKET NUMBER(S) 030-32714 CONTROL NUMBER(S) 300363 DATE OF CONTACT 09/18/2013 TELEPHONE NUMBER (317) 337-3435 DATE OF SIGNATURE 09/18/2013 TYPE OF CONVERSATION DE-MAIL 0 TELEPHONE D INCOMING 0 OUTGOING We are currently working to complete reviews of several financial assurance requests and have found that we have not yet received a response from a letter sent to you dated February 13, 2007. This letter was sent a second time, by fax, on May 2, 2008. In order to complete the review of the amendment to your letter of credit, we will need the following information:

1. In letter dated February 13, 2007, we requested a standby trust agreement that is amended to include the new company name and a change in the value of the letter of credit. 2. In letter dated February 13, 2007, we requested a certification of financial assurance be submitted due to the company name change and a change in the value of the letter of credit. A copy of the letter is attached.

Jam also attaching NUREG 1757, Volume 3, Revision 1, Appendix A, Section A.2 for reference on completing the certification of financial assurance.

Continue on Page 2 ACTION REQUIRED (IF ANY) Action Required:

Submit the requested information by referencing control number 300363 to facilitate proper handling in our office. Please periodically contact me with the status of your review. Continue on Page 3 NAME OF PERSON DOCUMENTING CONVERSATION Jennifer L. Bishop SIG~* NRC FORM 699 (03-2013)

Page 1 of UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 2443 WARRENVILLE ROAD, SUITE 210 LISLE, ILLINOIS 60532-4352 FEB 1 3 2007 Roben Neal, RSO Dow Agrosciences, LLC 306 Building E2-1010 9330 Zionsville Rd. Indianapolis, IN 46268-1054

Dear Mr. Neal:

We have completed our evaluation of the revision to your financial assurance that involves an increase from $750,000 to $1,125,000.

Please also revise your standby trust and certificate of financial assurance for the reasons explained below. The regulations of 10 CFR 30.35(e)(2)(ii) require that a licensee that uses a letter of credit to provide financial assurance for decommissioning must provide a trust that is "acceptable to the Commission." NUREG-1757, Vol. 3 provides the standard format of a trust that is acceptable to the Commission.

To be acceptable, the trust must specify the name of the licensee, cover the amount of the decommissioning cost, and provide supporting documents as outlined in NUREG-1757, Vol. 3. Due to the changes in the licensee's name and amount of financial assurance, the standby trust and supporting documents must be revised to reflect the changes. The regulations of 10 CFR 30.35(b) require the licensee to submit a certification that financial assurance has been provided in the amount prescribed by paragraph (d) of that section. Due to an amendment to§ 30.35(d), the amount required of Dow Agrosciences, LLC was increased.

Therefore, the licensee must submit a new certificate that covers the new amount. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). The NRC's document system is accessible from the NRC Web site at http://www.

nrc. gov/reading-rm/adams.

html. If you have any questions, please contact me at (630) 829-9854.

Docket: 03032714 License: 13-26398-01 Sincerely, Kevin G. Null Materials Licensing Branch