ML20053B535
| ML20053B535 | |
| Person / Time | |
|---|---|
| Issue date: | 04/07/1982 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Saltzman J NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| REF-WM-5 NUDOCS 8205280540 | |
| Download: ML20053B535 (2) | |
Text
DISTRIBUTION:
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REBrowning MEMORANDUM FOR: Jerome D. Saltzman JBMartin Assistant Director for og State and Licensee Relations I
Office of State Programs o
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Ross A. Scarano, Chief f
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Uranium Recovery Licensing Branch 4 $g Division of Waste Management, NMSS
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SUBJECT:
REQUEST FOR ASSISTANCE IN DEVELOPING A FINANCIAL QUALIFICATIONS TEST AND REVIEWING LICENSEE'S C,
APPLICATION FOR SELF-BONDING 1
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'b As you know, for a number of years it has been a practice of the Uranium Recovery Licensing Branch to require mill licensees to establish financial arrangements to assure that funds will be available for performance of site decommissioning and reclamation. Mill operators have typically satisfied this requirement by obtaining a surety bond.
However, a number of other financial arrangements can be established which will provide the regulatory authority with an appropriate level of assurance. Some of these other arrangements may be more advantageous to the licensee than a surety bond.
In connection with this, the licensing staff is presently working to develop a position paper which will identify a financial qualifications test for licensee consideration and possible use in satisfaction of the surety arrangement. Among the alternatives being considered are financial qualification tests developed by other government agencies.
The Environmental Protection Agency has estabilished similar financial assurance requirements for operators of hazardous waste disposal sites.
The decommissioning and reclamation activities at such sites appear to be similar to the activities required for reclamation of a uranium mill tailings disposal site.
EPA and EPA contractors have expended considerable effort toward the development of a financial qualifications test.
The criteria which they have determined to be appropriate are attached as.
Similarly, under State authority, the Wyoming Department of Environmental Quality permits use of a self-bonding mechanism to assure the performance DIST:
TICKET NO:
8205280540 820407 OFC PDR WASTE WM-5 PDR NAME :
DATE :82/04/06 i
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l of mine land reclamation activities. The State's regulations (which appear to be very general in nature) are attached as Enclosure 2.
Under these regulations, Rocky Mountain Energy's Bear Creek Uranium Company has submitted an applicaton to Wyoming for self_ bonding. This application (attached at
' ) would eventually be submitted to NRC if approved by the State.
In conjunction with our efforts to identify a financial qualifications test which provides an adequate level of assurance, we are also interested in determining what criteria different firms can meet.
Therefore, we are requesting your assistance in reviewing the Bear Creek Uranium Company's self_ bonding application particularly in terms of how the indemnitors' financial position measures up against the EPA criteria.
In addition, we request your advice and comment concerning the appropriateness of our adopting the EPA criteria as guidance for the uranium milling industry.
If you have any questions or wish to discuss this request for assistance, please contact Kathleen Hamill of my staff at 427-4546.
/s/
Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste fianagement
Enclosures:
As stated 1
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- _ _ _ _ _ _ _ _ _ _ _ _ : _JKb t lDATE:82/04/06
- 4/ 7/82
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