ML20046A803
| ML20046A803 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1993 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9307300076 | |
| Download: ML20046A803 (2) | |
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- L RELEASED TOTHE PDRD N 0 T A T<I 0.N-V 0 T ( gff//9y 4*
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' SAMUEL J. CHILK, SECRETARY-OF THE-L COMISSION FROM:
C0MISSIONER CURTISS,
SUBJECT:
SECY-93-124 - FINANCIAL ASSURANCE FOR" CLEANUP:0F ACCIDENTS:FOR ALL-MATERIALSL LICENSEES-WITH POTENTIAL FOR SIGNIFICANTc
-ACCIDENTAL' CONTAMINATION r
J x-2 APPROVED DISAPPROVED w/ comment-ABSTAIN-
. NoT' PARTICIPATING.
REQUEST DISCUSSION.
j COM ENTS:
a See attached comments.
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Commissioner Curtiss' comments on SECY-93-124:
I do not believe that the staff has made a sufficient case to justify termination of this effort, particularly in~ view of the General Accounting Office's report to Congressman Synar that identifies this effort as a matter for. Congressional-consideration.
I recommend that staff reconsider the proposal-and explicitly address GAO's concerns.
I-have the following-specific suggestions for that reconsideration:
1)
Address more fully the relationship to decommissioning funding requirements.
I understand that the' main reason' States are no longer concerned.about the 1985 rulemaking for financial assurance for accidents'is the protection afforded by the 1988 decommissioning' rule, financial requirements.
Further, by memorandum to'the Commissioners dated May 28, 1993, the EDO-informed'the-Commission about actions.in progress and plans for E
future actions to. evaluate and improveLthe decommissioning funding requirements for_ materials licensees.
If the 1985 effort has been overtaken by' events or subsumed into the broader decommissioning funding efforts, this should be made clear.
2)
Provide a more complete and documented evaluation-of the insurance and financial assurance market.
3)
Include information on FPA experiences with funding-requ ~ements under RCRA and other agency experiences referenced in the 1985 notice,.if such'information is available.
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