Financial Assurance Requirements

[Steve Deitch <73552.546@CompuServe.COM>]

To: Radsafe Mailing List:

I am publishing an inquiry regarding compliance with financial assurance regs.
Follows is a letter from our Tech Services Mgr.  Please reply to me via the bbs,
or to Charlie by those old fashioned and inefficient fiber optic telephone
cables.

Thanks!

Radsafers,

Requesting input from other licensees out there that have had to deal with the
requirements in 10 CFR 30.35 regarding financial assurance.

We are interested in hearing how licensees that do not have the luxury of being
a government facility that can provide a "statement of intent," or a large
corporation that can provide a "parent company guarantee" have been able to meet
the financial assurance criteria.

We have found no one to date that will provide a surety bond or insurance policy
that will meet the requirements of this regulation.  

1)	Has anyone been able to obtain a negotiated  payment plan with their
regulating agency regarding this issue?
2)	Has any licensee been able to obtain an exemption based on a historical
compliance record?

A serious flaw in the Agreement State program seems to be that Agreement State
licensees are suddenly faced with a new regulation because it has become a
matter of compatibility with NRC regulations.  They are never asked to comment
on NRC proposed regulations because the only ones who get notification of
proposed changes are NRC licensees, and Agreement State regulating agencies who
do not request comments from their licensees. With the majority of the States
being in the Agreement State program ( I believe about 35 out of 50), proposed
changes in radiation regulations very rarely reach the people that must live or
die with the changes. 

Charles Gallagher
Technical Services Manager
Telephone 713-641-0391 
Fax 713-641-6153