ML20149M635
| ML20149M635 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1986 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Sniezek J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20149B764 | List: |
| References | |
| FOIA-87-714 NUDOCS 8802260209 | |
| Download: ML20149M635 (1) | |
Text
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C 9"4, UNITED STATES 4
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NUCLEAR REGULATORY COMMissl0N
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w a MEMORANDUM FOR:
James H. Sniezek Deputy Executive Director for Regional Operations and Generic Requirements FROM:
G. Wayne Kerr, Director Office of State Programs
SUBJECT:
RESUBMITTAL 0F FINAL PROPERTY INSURANCE RULE TO THE CRGR We have redrafted the final property insurance rule as directed by the CRGR in its minutes dated June 13, 1986. As indicated in the enclosed memoranda from NRR, a technical justification for requiring property insurance based on a rigorous analysis of averted persrn-rem exposure cannot be developed from existing technical studies.
Also note that OGC, although finding no legal objection to the final rule, has both re-evaluated the conclusions of the backfit analysis and recorrnended a trust fund approach to assuring availability of insurance proceeds as proposed by the Bar Association of the City of New York. We do not agree with OGC's reconmended approach and our reasons are stated on pages 39-41 of the FR notice and in Enclosure 6 (Alternative 3A).
Principal objections to the OGC approach are, (1) adverse l
effects on the operation of the non-nuclear portion of insurance, (2) it is inconsistent with the staff approach being taken for accumulating funds for uecomissioning of reactors, and (3) potential administrative costs and potential legal conflicts.
Further, OSP believes that such a significant change would require reissuance as a proposed rule since the public has not i
had an opportunity to cornent on this approach.
Fifteen copies of the final rule package are enclosed for CRGR's use.
Any questions should be directed to Darrel Nash (x29882) or Robert Wood (x29885).
.U w Mjm Wayne kerr lirector a
s Office of Stat p -
Enclosures:
As stated cc:
T. Rehm M. Taylor 8802260209 8002P7 PDR FOIA WEISSO7-714 PDR
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