ML20198E191

Lists Deficiencies Noted in Certification of Funding Assurance for Decommissioning for Facility

ML20198E191
Person / Time
Site:	07000398
Issue date:	12/01/1992
From:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Pevey L NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL
References
NUDOCS 9212040290
Download: ML20198E191 (4)

Text

{{#Wiki_filter:_ _ _ _ _ _ - _ _ - pa ato v 4 e/ UNITED STATES 3 A .% i NUCLEAR REGULATORY COMMISSION

         %1            !                                      WASH!NoTON, D.C. 20556 N ***** /

DEC , 1992 Docket No. 70-398 License No. SNM-362 U.S. Department of Commerce National Institute of Standards and Technology ATTN: Mr. L. E. Pevey, Chief Occupational Health and Safety Division Gaithersburg, Maryland 20899 Gentlemen:

Subject:

Decommissioning Financial Assurance This is in reference to your letter dated November 28, 1991, which you provided as "cer'.ification of funding assurance for decommissioning" for your facility. We have since :mpleted a comprehensive review of your abmittal and find it deficient in the following respects:

1. PIooer Certification Statement Your certification statement does not include the names and locations of the facilities for which financial assurance is provided, nor the amount and type of materials you are licensed to possess. To ensure that no essential information is aissed, we recommend that you use the format provided on page 1-5 of Regulatory Guide 3.66, Standard Format and Centent of Financial Assurar.ce Mechanisms for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72. A copy of the sample format, with instructions for completing it, is enclosed (Enclosure 1).

2. Statement of Intent Yoar submittal does not include a Statement of Ir. tent, which, we recommend, should be submitted as a separate dbcument. Guidance and a checklist for the Statement of Intent are given in Regulatory Guide 3.66 on pages 3-25 and 3-26, excerpts from wnich are enclosed (Enclosure 2).

3. Evidence That the Party Sianino the Statement of Intent It Authorized to Represent the Oraanization Such evidence may be provided by a certified excerpt from an organi-zational manual describing the authorities of the signatory or by an express authorization by the head of the organization. A recitation of such authority by the person signing the document is not considered

 ,                 sufficient evidence.

040000 [S$" ASM Bf!gs, PUR d i i

l

.. DEC1 1992 a .

! Mr. L. E. Pevey 1

                                                                                                                                                                     ~

i We hope this clarifies the documentary requirements for the submittal of a i certification for decommissioning financial assurance. We request that you e -submit the required deruments within 30 days of the date of this letter. ! Questions may be_ directed to Amar Datta at 301-504-2536. I Sincerely,_ i l M S p ed g 77775dd o q ! John 11. N. Hickey, Chief Fuel Cycle Safety Branch 1 Division of Industrial and' ,

l. Medical Nuclear Safety,-NMSS

Enclosures:

As stated i Il \ k i-i i i i Distribution: iDocket;70-398f PDR9 !NRC4ile Center .IMUF R/F - IMSB R/F MTokar- JGreeves NMSS R/F VTharpe-{2) ADatta Region I EKeegan [ OGC OFC IMU)i;3 - 'IMUF:d IMi!W~Jy O'GC: k- IMSM i1 NAME Abi VTharpe: MTokb:' RFonnerD ~ JHicke b DATE 11/20/92 11/M/92 11/A /92 M l/92 11 / / /92 i 0FFICIAL RECORD COPY

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Enclosure  ; 1 Recommended Wordina For Certification Of Financial As prance CERTIFICATION OF FINANCIAL ASSURANCE l Principal: [ Legal names and business address of licensee or applicant) o

 ,                            NRC license number, name, and address of the facility-Issued to:    U.S. Nuclear Regulatory Commission J

This is to certify that (name of applicant] is licensed to possess. type of material] in the following amounts (amounts), and that financiai ass [urance in the amount prescribed by 10 CFR [ Parts 30, 40, or 70), j has been obtained for the purpose of decommissioning.-.[ amount prescribed), ! Signature (s) and title (s) of official (s) of institution j Corporate seal Date I i

                                                                                                                 ~
                              !!QIE: The following instruction; for completing the above form would. apply to-l                              the case of the National Institute of Standards and Technology.

Type of materials: Source, byproduct, and spccial nuclear materials. != Amounts of materials: Please list all the materials in your SNM license in l-- tabular form, along with the maximum possession limits of each. . 1 p Applicable regulation: 10 CFR Part 70 L Amount prescribed: $750,000 L i: I

Enclosure 2 Guidance on Statement of Intent A statement of intent may be used by federal, state, or local government licensees to provide evidence of financial responsibility for decommissioning. The purpose of the statement of intent is to ensure that, early in the life of the licensed facility, government licensees make their funding bodies aware of decommissioning requirements and costs and the eventual need for funding. The statement must identify the facility (ies) for which it guarartees financial assurance and the corresponding decommissioning costs. Alrm 5. must indicate that funds for decommissioning costs will be requested ar:' W ained sufficiently in advance of decommissioning to prevent deu cf ryired activities. The statement of intent should include evide..co of the authority of the officials of the federal, state, or local government entity to sign the statement of intent. Checklist of Criteria for Review of Statements of Intent Copy of evidence indicating that parties signing the financial instrument (for the applicant) are authorized to represent the organization in the transaction. Evidence that the statement of intent is an originally signed duplicate. Identification of federal, state, or local government licensee. Description of facilities for which the statement of intent provides financial assurance and corresponding decommissioning costs. Statement that funds for decommissioning will be obtained when necessary. Recitation of authority to sign the statement of intent.

• Date.
• Names and positions of signatories.
• Signatures.}}