Re: Financial Assurance Requirements

[Doug Turner <turners@earthlink.net>]

While working for SCE I prepared a state RML application and submitted a
statement that SCE was self insured, and had sufficient financial assets in
lieu of a security bond.  This was accepted in 1993.  On the other hand, I
spent a couple of days cleaning up behind a small company tagging research
proteins that went bankruptafter changing their name a couple of times and
walked out of their rented building leaving radioactive material and mixed
waste in a rented structure.  12 months later the company officers and
employees were all working with radioactive material for someone else, the
landlord couldn't rent the property with radioactive material on site, the
state had not terminated the RML, and there was no money to ship the analyze
the mixed waste or ship the radwaste for decay in storage.  So I can
understand why financial assurance is required.

Doug Turner < turners@ earthlink.net>   At 09:48 AM 10/22/96 -0500, you wrote:
>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
>
>
>