ML18101A006

Interim Staff Guidance on Financial Assurance

ML18101A006
Person / Time
Issue date:	04/11/2018
From:	Dylanne Duvigneaud Programmatic Oversight and Regional Support Branch
To:
Duvigneaud D
Shared Package
ML18100B106	List: ML18101A001 ML18101A002 ML18101A003 ML18101A004 ML18101A005 ML18101A006 ML18101A007 ML18101A008 ML18106B170 ML18106B171 ML18122A281
References
Download: ML18101A006 (8)

Text

Interim Staff Guidance Decommissioning Funding Plans Materials Licensees

Interim Staff Guidance Overview

- Decommissioning Funding Plans (DFPs) covering current facility conditions including onsite inventory onsite

- Efficiencies preparing DFPs

- Three items pertaining to Financial Instruments 2

Interim Staff Guidance DFPs Covering Current Facilities Conditions

- Part 70 licensees covering inventory

- (ML16307A014) NRC response to NEI which outlines a number of acceptable ways to meet the regulation

• 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 3

Interim Staff Guidance Efficiencies Preparing Decom Funding Plans

- 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 producing additional residual radioactivity in onsite subsurface material

• Waste inventory increasing above the amount previously estimated

• Waste disposal costs increasing above the amount previously estimated

• Facility modifications 4

Interim Staff Guidance Efficiencies Preparing Decom Funding Plans (Continued)

• Changes in authorized possession limits

• Actual remediation costs that exceed the previous cost estimate

• Onsite disposal

• Use of a settling pond Based on these requirement, providing a narrative in the DFP describing these factors will assist to reduce the number of RAIs and in completing the approval process, the Safety Evaluation Report.

5

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 a sight draft as typically banks require a sight draft to draw on the financial instrument 6

Interim Staff Guidance Other Areas

• Working to identify other areas in guidance which may need updating to include in the ISG 7

Interim Staff Guidance Schedule

• Draft ISG is scheduled to be completed end of June 2018

• 45-day public comment on draft ISG

• Final ISG is scheduled to be completed end of October 2018 8