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| issue date = 09/18/2018
| issue date = 09/18/2018
| title = Decommissioning Funding Plans Interim Staff Guidance Presentation
| title = Decommissioning Funding Plans Interim Staff Guidance Presentation
| author name = Duvigneaud D D
| author name = Duvigneaud D
| author affiliation = NRC/NMSS/DFCSE/PORB
| author affiliation = NRC/NMSS/DFCSE/PORB
| addressee name =  
| addressee name =  
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| docket =  
| docket =  
| license number =  
| license number =  
| contact person = Duvigneaud D D
| contact person = Duvigneaud D
| document type = Decommissioning Funding Plan DKTs 30, 40, 50, 70, Slides and Viewgraphs
| document type = Decommissioning Funding Plan DKTs 30, 40, 50, 70, Slides and Viewgraphs
| page count = 7
| page count = 7
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=Text=
=Text=
{{#Wiki_filter:Update on Interim Staff Guidance Decommissioning Funding PlansMaterials Licensees Interim Staff GuidanceBackgroundNMSS has been working on a draft ISG (ML18163A087) covering:*Decommissioning Cost Estimate (DCE) reflecting current facility conditions
{{#Wiki_filter:Update on Interim Staff Guidance Decommissioning Funding Plans Materials Licensees
*Evaluating events since the last Decommissioning Funding Plan (DFP) approval
 
*Updates to financial instruments 2
Interim Staff Guidance
Interim Staff GuidanceDCE reflecting current facility conditionsPart 70 licensees covering inventory:
 
*Licensee owned  
===Background===
-contract in place where another party pays for packing, loading and shipping to an end destination
NMSS has been working on a draft ISG (ML18163A087) covering:
*Customer owned -customer retains legal title to the material and is contractually responsible for packing, loading and shipping to an end destination
* Decommissioning Cost Estimate (DCE) reflecting current facility conditions
*In-process inventory  
* Evaluating events since the last Decommissioning Funding Plan (DFP) approval
-justify a brief timeframe to process the material through into finished product, and then it will fall into licensee-owned or customer
* Updates to financial instruments 2
-owned inventoryThe draft ISG considers NEI's previous letter (ML16229A175) and NRC's response (ML16307A014)regarding DCE reflecting current facility conditions 3
 
Interim Staff GuidanceEvaluating events since last DFP approvalMake sure to include the 8 factors required by 30.35(e)(2), 40.36(d)(2) and CFR 70.25(e)(2):
Interim Staff Guidance DCE reflecting current facility conditions Part 70 licensees covering inventory:
*Spills of radioactive material impacting the subsurface
* Licensee owned - contract in place where another party pays for packing, loading and shipping to an end destination
*Waste inventory that exceeds previous estimate
* Customer owned - customer retains legal title to the material and is contractually responsible for packing, loading and shipping to an end destination
*Waste disposal costs that exceed previous cost estimated*Facility modifications
* 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
*Changes in possession limits*Remediation costs that exceed previous cost estimate
 
*Onsite disposal*Use of a settling pondTo reduce RAIs provide a narrative covering the 8 factors 4
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):
Interim Staff GuidanceFinancial instruments
* Spills of radioactive material impacting the subsurface
*Send original hard copy financial instruments directly to site PM not NRC Document Control as DC does not maintain original hard
* Waste inventory that exceeds previous estimate
-copy documents*For approval, NRC staff needs to review all agreements including any side letters to the financial instruments
* Waste disposal costs that exceed previous cost estimated
*A template sight draft is being provided for staff use Banks typically require a sight draft to draw on the financial instrument
* Facility modifications
*Guidance on addressing CPA's opinion of off
* Changes in possession limits
-balance sheet transactions for guarantees
* Remediation costs that exceed previous cost estimate
*Supporting documents for Statements of Intent*Verifying trust operations are regulated and examined by a Federal or State agency 5
* Onsite disposal
Interim Staff GuidanceNotices *August 1stFederal 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 21stan FRN was published extending the comment period to October 5, 2018 6
* Use of a settling pond To reduce RAIs provide a narrative covering the 8 factors 4
Interim Staff GuidanceNext steps*NMSS looks forward to receiving comments on the draft ISG  
 
*Working towards publishing final ISG at the end of January 2019 7}}
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}}

Latest revision as of 14:18, 20 October 2019

Decommissioning Funding Plans Interim Staff Guidance Presentation
ML18267A195
Person / Time
Issue date: 09/18/2018
From: Dylanne Duvigneaud
Programmatic Oversight and Regional Support Branch
To:
Duvigneaud D
References
Download: ML18267A195 (7)
v • d • e


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
  • 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
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