ML18101A006
| ML18101A006 | |
| Person / Time | |
|---|---|
| Issue date: | 04/11/2018 |
| From: | Dylanne Duvigneaud Programmatic Oversight and Regional Support Branch |
| To: | |
| Duvigneaud D | |
| Shared Package | |
| ML18100B106 | List: |
| 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