ML18267A195
| ML18267A195 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/2018 |
| From: | Dylanne Duvigneaud Programmatic Oversight and Regional Support Branch |
| To: | |
| Duvigneaud D | |
| References | |
| Download: ML18267A195 (7) | |
Text
Update on Interim Staff Guidance Decommissioning Funding Plans Materials Licensees
Interim Staff Guidance
Background
NMSS has been working on a draft ISG (ML18163A087) covering:
Decommissioning Cost Estimate (DCE) reflecting current facility conditions Evaluating events since the last Decommissioning Funding Plan (DFP) approval Updates to financial instruments 2
Interim Staff Guidance DCE reflecting current facility conditions Part 70 licensees covering inventory:
- Licensee owned - contract in place where another party pays for packing, loading and shipping to an end destination
- Customer owned - customer retains legal title to the material and is contractually responsible for packing, loading and shipping to an end destination
- In-process inventory - justify a brief timeframe to process the material through into finished product, and then it will fall into licensee-owned or customer-owned inventory The draft ISG considers NEIs previous letter (ML16229A175) and NRCs response (ML16307A014) regarding DCE reflecting current facility conditions 3
Interim Staff Guidance Evaluating events since last DFP approval Make sure to include the 8 factors required by 30.35(e)(2), 40.36(d)(2) and CFR 70.25(e)(2):
Spills of radioactive material impacting the subsurface Waste inventory that exceeds previous estimate Waste disposal costs that exceed previous cost estimated Facility modifications Changes in possession limits Remediation costs that exceed previous cost estimate Onsite disposal Use of a settling pond To reduce RAIs provide a narrative covering the 8 factors 4
Interim Staff Guidance Financial instruments Send original hard copy financial instruments directly to site PM not NRC Document Control as DC does not maintain original hard-copy documents For approval, NRC staff needs to review all agreements including any side letters to the financial instruments A template sight draft is being provided for staff use Banks typically require a sight draft to draw on the financial instrument Guidance on addressing CPAs opinion of off-balance sheet transactions for guarantees Supporting documents for Statements of Intent Verifying trust operations are regulated and examined by a Federal or State agency 5
Interim Staff Guidance Notices August 1st Federal Register Notice (FRN) published seeking comments on draft ISG requesting comments by September 17, 2018 NEI contacted NMSS and indicated they would be holding a meeting with industry and requested to extend the comment period until after this meeting; therefore, on August 21st an FRN was published extending the comment period to October 5, 2018 6
Interim Staff Guidance Next steps NMSS looks forward to receiving comments on the draft ISG Working towards publishing final ISG at the end of January 2019 7