ML18267A195

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)

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