Updated guidance to support the implementation and auditing of Provision 11 (Insurance, Closure Plan, and Financial Responsibility) has been published in the R2 Guidance Document, which can be found in R2 Document Library section of the SERI website. This new guidance replaces the prior Provision 11 guidance contained in the September 1, 2014 version of the R2 Guidance Document. The new content was developed by the R2 Technical Advisory Committee (TAC). Some notable changes and clarifications to the guidance:
- Guidance on pollution liability insurance and how to determine if it is needed.
- Parameters for using pollution liability insurance as a sufficient financial instrument for closure.
- Parameters for using a corporate guarantee as a sufficient financial instrument for closure.
- Parameters for using non-inventory assets as a sufficient financial instrument for closure.
- The role of the Independent Administrator.
- How to calculate estimated closure costs.
The R2 Guidance Document is intended to offer further explanation of complex requirements in the R2 Standard, and may also include examples and audit recommendations. However, Guidance itself is not auditable and cannot be cited in relation to any nonconformances. The explanations in the Guidance Document are intended to prevent misinterpretation of the R2 Standard – they are not intended to add to, subtract from, or modify the R2 Standard. The examples cited are not necessarily the only way to fulfill a requirement of the R2 Standard.