ML18267A195
| 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 PlansMaterials Licensees Interim Staff GuidanceBackgroundNMSS 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 GuidanceDCE reflecting current facility conditionsPart 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 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):
- 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 pondTo reduce RAIs provide a narrative covering the 8 factors 4
Interim Staff GuidanceFinancial 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 CPA's 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 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
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