ML20059M133
| ML20059M133 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1990 |
| From: | Scroggins R NRC OFFICE OF THE CONTROLLER |
| To: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20059M128 | List: |
| References | |
| REF-WM-3 NUDOCS 9010030178 | |
| Download: ML20059M133 (2) | |
Text
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NUCLEAR MEGULATORY COMMIS$lON
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l MEMORANDUM FOR:
Robert M. Bernero, Director 1
office of Nuclear Material Safety ant Safegvards
.i FROM:
Ronald M. Scroggins l
Controller
SUBJECT:
DECOMMISSIONING FINANCIAL ASSURANCE SUBMITTALS This responds to your memorandum dated August 13, 1990,
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indicating that certain materials licenses would be annotated to identify and document receipt of decommissioning financial i
assurance submittals.
The proposed annotation would be used to, referance all financial assurance documents, including those submitted as part of an application for a new license, license l
renewal or amendment.
We have no objection.to this approach.
Since neither a health and safety review nor an approval is required, and since the licenses will not be amended, the annotations are not subject to license fees nder 10 CFR 170.
i Ronald M. S Controller i
9010030178 900P21 PDR WASTE WM-3 PDC ENCLOSURE 2
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MEMORANDUM FOR:- Ronald M. Scroggins, controller' l
FROM:
Robert M. Bernero. Director Office of Nuclear Material Safety and Safeguards-
SUBJECT:
EXEMPTION OF DECOMMISSIONING FINANCIAL 1
ASSURANCE SUBMITTALS FROM FEES The purpose of this memorandu:r is to discuss our plans for processing decommissioning financial assurance submittals, and to propose that licensing actions initiated by NRC-to document receipt of the submittals should be fee exempt.
The new decomissioning rule (53 FR 24018). requires dat i:ertain materials.
licensees submit financial assurance documents.
0GC W s ncently advised us that a close reading of the history of the rule indicates Vat it may not-have been the intent of the Commission that we incorporate speci:ic financial i
assurance commitments into materials licenses as conditions ef operation.
OGC notes that the Statements of Consideration-state that funding plans wot d.
not be incorporated into reactor licenses.
This statement could also be extended to apply to material licenses.
However, thu rule specifically.
requires that in certain cases financial assurance'certi'icates and funding l
plans must be submitted with an application for a new materials license or license renewal.
In addition, some licensees might submit financial assurance documents-together with other specific amendment requests.
We believe that it is important to annotate materials licenses.in order to identify those licenses that require decomissioning financial assurance submit'als, and to document receipt of the submittals. We have developed an annotition for inclusion in the license (enclosed) which would accomplish these goe without binding the licensee to any specific submittal.
The proposed-m otation would be used to-reference all financial assurance documents.
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< Guding those submitted as part of an applicatfon for a new license, license renewal, or amendment. Although new license, renew.1, and amenGment-l applications would be referenced in the standard " tie-: town conditicn" when the licensing action is issued, we do-not intend to amend the tie-down candition to l
reference subsequent submittals that only1 involve changes to financial assurance documents.
Instead, the proposed financial assurance reference annotation would be updated.
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F.NCLOSURE 3 40083xvfrr
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Ronald M. Scroggins 2-We believe that this procedure would be consistent with the intent of the Commission.
Because the addition of a financial-assurance annotation would be for the convenience of the NRC, and because the decommissioning rule does not specify that NRC must conduct a health and safety review or approve the i
submittals, we recommend that the adding of the annotation and any subseque.nt changes to the annotation should be fee exempt.
0GC has no legal objection._
Please advise us if you have 9bjection ta this' approach.
Questions may be directed to John Hickey or Kevin Ramsey at Ext. 20534.
y menea or G. A M*
I Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards
Enclosure:
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,t Proposed Lice.5e Annotation DISTRIBUTION i
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.JFunches CHaughney JGlenn RBangert STreby KRamsey GJackson JSwift GBidinger JRoberts I
ice previous concurrence
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- 8/10/90
- 8/13/90
- 8//)/90 0FFICIAL ' RECORD COPY EXEMPTION l
. EXAMPLE LICENSE ANNOTATION 1 VERIFYING THE NEED FOR FINANCIAL ASSURANCE.
FEE EXDiPT-Pursuantto10CFR[30.35or40.36or70.25],
the following documents?related to. financial assurance have been submitted to the NRC by 1
the licensee:
(Subsequent changes to this annotation will also'be
-feeexempt.)
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ENCLOSURE (ATTACHMENT to ENCLOSURE-3)
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