Re: Financial Assurance Requirements and Agreement States

["Rad. Health Unit"<raldrich@emi.com>]

To: Radsafers

	Charles Gallegher's assertion that Agreement State licensees are not 
provided an opportunity to comment on proposed regs is not true in New York. 
This 
State has very strict procedures which afford the public the opportunity to 
comment on all proposed new regulations. The process is time consuming and 
costly to taxpayers.
	The problem is that the Agreement States are asked (if they are asked) 
to submit comments to NRC proposed regs within very short time frames: typically 
a few weeks. Rarely enough time to read and digest lengthy and complex 
proposals. (Note that NRC has a sizable staff dedicated to doing nothing other 
than generate new regulations, whereas very few state programs have this 
luxury.) When comments are submitted they are typically ignored and states are 
required to adopt whatever NRC decides on.
	With regard to Financial Assurance, the attached comments were submitted 
by the NYS Dept. of Labor in April of 1995, and repeated comments made to NRC in 
March of 1994 on essential flaws in its regulatory impact analysis for the 
initial rule. NO response was received to the 1995 letter and no changes were 
made by NRC in the final rule.


Clayton J. Bradt
Assoc. Radiophysicist
NYSDOL
"Rad. Health Unit"<raldrich@emi.com>

<<Attachment: USNRC.TXT>>