ML19316A694
| ML19316A694 | |
| Person / Time | |
|---|---|
| Issue date: | 03/18/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19316A693 | List: |
| References | |
| NUDOCS 8005230729 | |
| Download: ML19316A694 (4) | |
Text
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MAR 181580 MEMORANDUM FOR: William J. Dircks, Acting Executive Director for Operations FRUM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
IMPLEMENTATION OF RECOMMENDATIONS OF SPECIAL TASK FORCE ON THREE MILE ISLAND CLEANUP This is in response to your request to analyze resource needs for publication of the environmental impact statement related to TMI-2 cleanup.
The current schedule calls for the publication of the DE5 on June 30, allows for Federal Register Notice and 60 oay coment per'od, and calls for FES publication on November 15.
Based upon a series of. actions that appear to be within the capability of our supporting national laboratory, Argonne National Laboratory (ANL), and the Headquarters staff..it is possible to_ accelerate the schedule so that the FES publication can occuf as early as September ljf.~16 ordeO6 do th_ts;-ther- -
'fblTowing additionsi resource commitments are required:
1.
Additional funds in the amount of $200,000 will be made available in FY 80 to ANL to cover the overtime and extra manpower required to expedite the schedule and.repare the DES and FES for puulication. The additional requirement will involve additional professional staff and full-time commit-ment of technical editors and production staff, along with.a signiticant amount of overtime for both professional and support staff.
It should be
/of5100000inFY81 noted that. acceleration should result in a decreased rescurce requirement
, although overall, the total cost for thg effort will De increased by $100,000.
2 v The full-time effort of a licensing assistant will be scheduled starting
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approximately 2 weeks prior to the issuance of the DES and 2 weeks prior to the rES as well as during the month of August to assist.in the pro-cessing of.coments on the DES. This is a Headquarters staffing problem which can be expectad to effect other licensing assistant related activities during these periods, especially other casework.
7 Early involvement of the NRR staff is being scheduled to review preliminary 3
dratts at ANL and a comitment of the NRR staff to orepare the Headquarters supplied input to the DES by April 30, and to the FES within 15 working days after close of the coment period. This effort will not be substan-tially different in terms of the current or expeoited schedule as tar as resource requirements are concerned, but it means an earlier and more
William J. Dircks MAR 181380 concentrated effort that can be expected to impact the schedules associated with Task Action Plans, Lessons Learned, and other TMI related activities as well as other current work. This should be a short term effect, but cotild be disruptive since the most affected branches (Radiological Assessment Branch and Accident Analysis Branch) can have a significant impact on several of the above mentioned activities.
Enclosed is a table which further displays the current and accelerated schedules and estimated resource requirements.
In order to accomplish the accelerated schedule the following additional requirements must be met:
1.
Tne laboratory (ANL) must have full and unrestricted access to the
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licensee and its subcontractors. This.is expected to be of short (6 to 8 weeks) duration, but can have a significant impact on the licersee schedules because of its limited resources.
2.
One of the NRC Environmental Project Managers must begin a nearly full time presence at ANL in order to ensure early review and coment
,j on DES input as it is prepared. EP management and OELD attorneys will be required to be at ANL much of the time during the later stages of DES preparation.
3.
Steps need to be taken to eliminate the delay associated with the y
publication of the EPA Federal Register notice concerning the DES (currently 10 days after publication). Action has been initiated to overcome this delay.
4.
Limit the comment period on the DES to 45 days and indicate in the Federal Register notice that comments received after that point and prior to 60 days will be considered and addressed in a supplement to be issued by October 31, 1980. CEQ regulations call for a comment period of 45 days with a 15 day extension if requested, consistent with the provisions of NRC's regulations in 10 CFR Section 51.25.
[5. A nomal review of the DES is conducted thereby eliminating any extra-ordinary review by Headquarters management or Commission prior to issuance.
Other factors which should be considered in the decision to accelerate the schedule are:
1.
ANL and the staff believe the quality of the document may suffer since the actual writing of descriptive sections must be accelerated in order to allow time for impact assessments to be made. This acceleration could lead to overlooking factors that should otherwise be considered.
2.
Some of the reports which would form the basis for the FES will not be completed in final form by ANL until December although the substance will be in-hand by the time the FES is issued on either the current or accelerated schedule.
William J. Dircks t/AR 131380 If it is decided to accelerate the schedule, we neecl an early decision and request that it be made by March 20.
Otherwise, it will be very doubtful whether any advancement of the DES issuance date can be accomplished.
/
Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated
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SCHEDULE DES FR Notice End Coment FES Original
- June July September December Current June 30 July 10 September 10 NoYember15 Accelerated June 13 June 13 July 30 September 10
- 0riginalschedulecalledforissuanceoftheDESandFESinMayandNoYember respectively. These dates slipped one month because the initiation of work at ANL slipped one month from December 1979 to January 1980.
RESOURCES ANL Current
$1.6 million FY 80 0.3 million FY 81 Accelerated
$1.8 million FY 80 0.2 million FY 81 NRC ET SA El Current 2m 2m 24 m Accelerated 3m 3m 30 m
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