ML20059H938
| ML20059H938 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1993 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Heltemes C NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML19348B041 | List: |
| References | |
| FRN-58FR68726, RULE-PR-30, RULE-PR-40, RULE-PR-50, RULE-PR-70, RULE-PR-72 AE16-2-005, AE16-2-5, NUDOCS 9401310245 | |
| Download: ML20059H938 (2) | |
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om ch k la MEMORANDUM FOR:
C. J. Heltemes, Jr., Deputy Director for Generic Issues and Rulemaking
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FROM:
Robert M. Bernero, Director Sh 4
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Office of Nuclear Material Safety DD and Safeguards Mel
SUBJECT:
COMMENT ON FINAL RULE:
"SELF-GUARANTEE AS AN ADDITIONAL FINANCIAL ASSURANCE MECHANISM" By memorandum dated August 6,1993, the Office of Nuclear Regulatory Research requested our concurrence on a Final Rule on Self-Guarantee as an Additional Financial Assurance Mechanism. We concur with'the rulemaking, but ask that you consider the following comments:
1.
Pg. 5 -
With regcrd to deleting the $1 billion tangible net worth requirement, the analysis should provide a strong rationale why the staff is relaxing a requirement beyond the General Electric Company and Westinghouse Electric Corporation-request fcr rule change. The effects of deleting this requirement should be more fully developed since it would allow an additional 7 firms to use the proposed guarantee.
The tangible net worth of these firms are not presented nor are the reasons of why allowing them to qualify is not riskier in terms of financial assurance than the proposed rule. A discussion of hov bond rating services include net worth in their evaluations should also be presented.
2.
Pg. 8 & 9 - With regard to a bond rating of A or better it should be clearly stated that a lower bond rating (such as A-) would not be acceptable and does not satisfy the A or better bond rating requirement.
3.
Pg. 9 & 10 - With regard to non-profit entities, the response is not
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concise. Perhaps the entire discussion on non-profit entities presented in Enclosure B should be moved into the I body of Enclosure A.
9401310245 940121 PDR PR 30 SOFR68726 PDR
1 C. J. Heltemes, Jr. 4.
Pg. 10 -
With regard to requiring an additional written binding commitment by self-guarantors, the response should state that the adoption of this reconnendation would require a revision to the regulations rather than existing guidance.
Please have your staff coordinate wi h Timothy C. Johnson on (301) 504-3603 regarding the above.
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[,,, ffice of Nuclear Material Safety bert
. Bernero, Director and Safeguards t
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