ML20198J355

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Responds to Draft Changes to Frn,Both Supplementary Info & Proposed Rule Wording
ML20198J355
Person / Time
Issue date: 06/04/1997
From: Lewis S
NRC
To: Richter B
NRC
Shared Package
ML20008B465 List:
References
FRN-62FR47588, RULE-PR-50 AF41-1-038, AF41-1-38, NUDOCS 9710160126
Download: ML20198J355 (1)


Text

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/e nt Frosa Stephen Lewis Tot TWD2.TWP9.BJR Dates-

-6/4/97 9:27am subjects INSERT TO FRN ON PROPOSED RU1.E -Reply Brian and Bob:

I have only the following suggestjons regrading the draft changes to the FRN,

-both the. Supplementary Information and t*e proposed rule wording, h response to. comments last week from the Chairman's Offices Regarding the need for an initial 'baselining' report from licensees on the status of their accumaulation of decommissicsing funds, the wording should refer to the "effmtive date" of the rule, thus:

fp. 55 of FRNs "...after the effective datti of this rule..."; and

+

- p. 79, proposed change to 50.75 (f) (1) :

".. .within 9 months after the

'ef fective date of this rule, and at least e very three months thereaf ter, . . . "

'An 'to "securitization", I have no problems with the write-up. It seems to me that Brian logically placed it under "Stranted costs." It seems less logicval g

. / ! to as mesuggested for it to be placed under "When Doe 6 aut operator cease to be a Utility,"

by Bob.

As to the text of the write-up on " benchmarking," my comments cre o- the next to last paragraph. Too many uses of " current.lya. Hence, my suggestion for second sentence:

- *These decommissioning estimates are being ev,tluated as part of a rulemaking I effort that is currently on hold pending accu:tulation of actual decommissioning cost data."

I 6

'In that same paragraph,' there is only a mer:taca of comments to the ef fect that

. the minimum values currently in 50.75 ()d are ts.o high. For the sake of balsnee, shouldn't'there also be'a rention of concerns voiced by some that the current values may be too low because of.the increasing costs of low-level waste disposal.

It is my understanding that the Chairman had this concern.

As to the. placement of this write-up within the JRN, it seems disjointed in the response to.' Financial Test Qualifications," which I do not believe encompanad this concern.

It might be better'placed in the response to j " Funding Assurance if Plants Shut Down Prematurely," (pp.18-19) .

Please advise me if you need any further input from me,'and transmit me a copy of,what you provide tot'he Chairma.n's Office.

CC:

WND2.WNPS.RSW1, TWD2.TidP9.RCA, WND2.WN75.DBM, SAT b'

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