RE: Financial Assurance Requirements

["Spell, Bill" <bills@deq.state.la.us>]

The State of Louisiana has had some success with financial assurance 
requirements, but I cannot give you specifics off the top of my head, and 
the individual most knowlegeable of this is out for the rest of the week. 
 We'll try to get you something shortly.

My opinion is that you are correct in how these things come about, and I 
suspect some, but not all, do not communicate new proposed requirements to 
their licensees very well.  I hope I'm wrong.

As for the number of Agreement States, currently there are 29, but it's 
still more than 50% and about 75% of the licensees.  Four states are in the 
process, so look for #30 shortly.

Bill Spell
bills@deq.state.la.us

 ----------
From: radsafe
To: Multiple recipients of list
Subject: Financial Assurance Requirements
Date: Tuesday, October 22, 1996 9:48AM

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