ML20028H542
| ML20028H542 | |
| Person / Time | |
|---|---|
| Issue date: | 12/12/1990 |
| From: | Remick NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9101090118 | |
| Download: ML20028H542 (2) | |
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SAMUEL J. CHILK, SECRETARY OF THE Col 44ISSION FROM:
C0l44ISSIONER REMICK
SUBJECT:
SECY-90-386 - NRC POLICY ON THE ACCUMULATION PERIOD FOR DEC0l44ISSIONING FUNDS FOR PREMATURELY SHUT DOWN REACTORS y/c,,, u- /
APPROVED DISAPPROVED X ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION C0t44ENTS:
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$2 co==issioner-Resick's Ce==ents on SECY-90-386 I disapprove the staff's10ptions A, B and c as discussed in its proposed policy-on the accumulation period for decommissioning funds-for prematurely shut-down reactors.
I prefer Option D, which would not establish an accumulation period equally applicable'to'all' licensees, but would evaluate the factual situation-for each licensee and specify the collection, period accordingly.
I agree with-the staff that Option D-would be less arbitrary than a general' collection period _ that might not be-justified for a-particular licensee, and that Option D is consistent with the more flexible approach specified in 50.82 for licensees that permanently shut down their facilities before July 27, 1988.
Option D also-has the principal benefits attributed-to Option c:
Under Option D, the staff can, perhaps even more easily.than it could:under Optionic, determine a-collection period which-constitutes a " middle ground" between requiring all funds immediately and_ permitting an-extended collection period, and assures-that funds will be available before commencement of substantial _ decommissioning activities.
I recognize that Option D may result in inconsistencies in treatment of different licensees. Therefore, as the staff itself
- states,-it will need to_take-great care to assure consistent application-of " adequate protection" standards in each case-by-case assessment.
I approve-the staff's subsidiary. recommendations (1) that certification _to_the formula' amount be-waived for_the.three plants discussed'in Section-II of SECY-90-386,_provided that each licensee's decommissioning-funding plan be based on a site--
specific. study'which the licensee submits.or commits.to submit within a reasonable period after being informed by the staff of-
. the adoption of: the policy; and (2)- that the-licensees of all-plants,-includingLthose: prematurely shutdown, should continue-to
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be: required to guarantee or maintain. funds in external accounts untilithe_ funds are actually-expended for_ decommissioning.-
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