ML20210E135
| ML20210E135 | |
| Person / Time | |
|---|---|
| Issue date: | 06/15/1992 |
| From: | Bykoski L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Hosey C, Kinneman J, Mccann G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| REF-WM-3 NUDOCS 9206180365 | |
| Download: ML20210E135 (4) | |
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$aatoo x J 3, o UNITED STATES
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] JUN 15 re MEMORANDUM FOR: Those on the Attached List FROM: Louis Bykoski Decomissioning and Regulatory Issues Branch Division of Low Level Waste Management and Decomissioning Office of Nucitar Material Safety and Safeguards
SUBJECT:
ISSUES DISCUSSED IN FINANCIAL ASSURANCE MONTHLY CONFERENCE CALL - APRIL 8, 1992
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As you recall, Heacquarters promised to prepare a meeting report documenting the April 8,1992, monthly conference call on decomissioning financial assurance. The issues discussed were (1) the need for a license amendment when financial instruments are not executed until radioactive material:. are received by a new applicant or a licensee requesting a higher possession limit and (c) signature authority on statements of intent.
With regard to issue one, the reviewers should refer to Question and Answer A5 on page D-5 of " Revision 1 to Policy Guidance Directive FC 90-2, Standard Review Plan for Evaluating Compliance With Decomissioning Requirements,"
April 30, 1991. The Policy Guidance allows new licenses to be issued without financial assurance if the license certifies that financial assurance will be obtained prior to receipt of license material. The certification must specify the amount of financial assurance provided and the authorized funding methods to be used, and must include an executed copy of the financial instrument (s) -
stating that the instrument (s) will be effective at the time the licensee takes possession of the licensed material. A license condition, if you want to use one, could read as follows: "The licensee shall provide an executed copy of the financial instrument, required under 10 CFR 30.35, which explicitly states the effective date of the financial instrument, at or before the time the licensee takes possession of the material authorized by this license."
With regard to issue two, the reviewers should refer to the Statement of Intent format found on page C-2 of FC 90-2, Rev. 1. Since the person with authority to sign may vary from State to State, a certification is needed which provides that this person has the authority to make the comitment and that his authority is established in the accompanying documents. Thus, the licensee or applicant should provide certification that the individual signing the Statement of Intent has the authority to do so (see Regulatory Guide 3.66, pp. 3-22 and 3-26). Documentation that a legal basis exists for the individual f
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certified, we can accept the certification without a rigorous review of If the information is submitted and individual state codes.
If you have any questions, please call ne on (301) 504-2572.
Sincerely, Louis Bykoski Deconnissioning and Regulatory Issues Branch '
6;tision of Low Level Waste Managerrent and Decomissioning Office of fluclear Material Safety end Safeguards cc: L. Bykoski T.C. Johnson J. Austin '
D. Futoma OGC J. Glenn IMNS
Addressees d@ 1 E US making the connittent should be provided. If the information is submitted and certified, we can accept the certification without a rigorous review of individual state codes.
If you have any questions, please call me on (301) 504-2572.
S incerely ,
/5/
Louis Bykoski Decommissioning and Regulatory Issues Branch Division of Low Level Waste Management and Deconraissioning Office of Nuclear Material Safety and Safeguards cc: L. Bykoski T.C. Johnson J. Austin D. Futoma OGC J.-Glenn IMNS Distribution: Central File NMSS r/f RBangart WBrach JAustir. JSurmeier PLobaus MWeber TCJohnson LBykoski LLDR r/f PDR 'YES E-PDR NO Categ ry: Proprietary or CF Only ,
ACNW YES N0 SUBJECT AB3 TRACT: I S DISCUSSED lh FIMANCIAL ASSURANCE 140NThlY CONFERENCE CALL - APRIL 8, 1992
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, JUN 15199f, Attached List of Addressees John Kinneman, Region I Charles Hosey, Region II George McCann, Region III '
William Fisher, Region IV Beth Prange,-Region Y David Futoma, OGC John Glenn, IMNS
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