ML20198E396
| ML20198E396 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 11/24/1998 |
| From: | Jazel Parks ENERGY, DEPT. OF |
| To: | Ten Eyck E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9812240045 | |
| Download: ML20198E396 (8) | |
Text
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o n c,.k Department of Energy
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Oak Ridge Operations f
Post Office Box 62 Oak Ridge, Tennessee 37831 -8651 November 24, 1998 Ms. Elizabeth Q. Ten Eyck Division of Fuel Cycle Safety and Safeguards, NMSS 0
U.S. Nuclear Regulatory Commission
[9 ho' q gD}
11545 Rockville Pike MS T8A33 q0' Rockville; Maryland 20852
Dear Ms. Ten Eyck:
TRANSITION COSTS FOR THE GASEOUS DIFFUSION PLANTS In your letter dated November 4,1998, you requested more detailed information regarding the costs incurred during the transition of the gaseous diffusion plants (GDPs) from U.S. Department of Energy (DOE) oversight to U.S. Nuclear Regulatory Commission (NRC) regulation. These transition costs were described in our letter from Mr. Randall DeVault to Mr. Robert Pierson dated September 14, 1998 (enclosed).
In particular, you requested further information regarding th' basis for the total transition costs, the basis for the assignment of cost categories, and the plant and programmatic upgrades assigned to NRC regulation that were identified in our September 14 letter.
Section 1403 (d) of the Energy Policy Act (EPAct) of 1992 assigns DOE responsibility for payment of any costs of decontamination and decommissioning, response actions, or corrective actions related to conditions existing before the United States Enrichment Corporation (USEC) leased the GDPs. The Lease Agreement Between the United States Department of Energy and the United States Enrichment Corporation (Lease) dated July 1, 1993, and the
\\
Memorandum of Agreement Relating to the Transfer of Functions and Activities from the United States Department of Energy to the United States Enrichment l
Corporatten (M0A) dated December 15, 1994, define DOE's responsibilities under j
the EPAct more precisely.
In accordance with the Lease and M0A, DOE is g
required to reimburse USEC for all costs reasonably incurred for all work k(0 necessary to bring the GDPs into initial compliance with NRC standards, or to meet the requirements of the Regulatory Oversight Agreement (R0A), or to achieve any safety improvements required or directed by D0E.
9912240045 981124 Y l
PDR ADOCK 07007001
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Ms. Elizabeth Q. Ten Eyck November 24, 1998 Thus, the total cost for the transition of the GDPs is based on provisions of l
the EPAct, Lease, and M0A. The transition costs associated with the activities described in the Lease and M0A are referred to as nuclear safety upgrades (NSU) costs. DOE has reimbursed USEC for NSU costs totaling $220 million in accordance with its responsibilities under the EPAct, Lease, and M0A. This cost settlement formalized by the M0A, as amended by Amendment FY 98-1 dated May 18, 1998, encompasses the majority of the transition costs as shown in Table 1.
This table identifies several other components of the total transition cost of which DOE is aware, the entity liable for these costs, i.e., DOE or USEC, and the basis for each of these costs. The total cost for all these activities based on current information is approximately
$301 million.
This total cost could increase as USEC cont'nues to implement the NSU program, e.g., if the cost of the seismic modifications at the Paducah GDP exceeds the previous estimate by $30 million.
In our letter of September 14, 1998, the transition costs were assigned to two major categories to identify the regulatory basis for the costs as shown in Table 2.
The first major category includes costs for activities that were clearly unique to NRC requirements such as preparation of the certification applications. This category also includes the portion of plant and programmatic upgrades at the GDPs that were needed to initially meet NRC requirements. These upgrades are identified in more detail in Table 3.
The second major category includes costs for activities that were not unique to NRC requirements and that would have been required to achieve compliance with DOE orders and standards had the transition from DOE oversight to NRC regulation not occurred. This category includes plant and programmatic upgrades such as the seismic upgrade at the Paducah GDP that was directed by DOE during the transition period. The bases for the cost categories in our r
letter are described in Table 2.
The detailed transition costs associated with the NSUs at the GDPs are shown in Table 3.
These costs include costs for the plant and programmatic upgrades (Items D and E).
Portions of the costs for the plant and programmatic upgrades were assigned to NRC regulation based on a DOE evaluation of the objective of the upgrade and an estimate of the portion of the uporade that was required to meet NRC requirements as shown in Table 3.
As mentioned in your November 4 letter, the cost of the plant and proarammatic vogrades assigned to NRC regulation totaled approximately $90 million:
- 1) about $55 million for upgrades that were directly related to NRC requirements and required by the Compliance Plans, i.e., reimbursable by DOE under the Lease and M0A, and 2) about $34 million for upgrades identified by USEC as supporting NRC certification, but not required by the Compliance Plans, i.e.,
not reimbursable by D0E. The assignment of these transition costs for each of the plant and programmatic upgrades is identified in Table 3.
Ms. Elizabeth Q. Ten Eyck November 24, 1998 If you have any questions.regarding this cost information or need additional
--.information, please' contact Randy DeVault of my staff at (423) 241-4497.
Sincerely,.
k Assistant Manager for Enrichment Facilities Enclosures ccw/ enclosures:
R. C. Pierson, NRC, White Flint S. Harlow, NE-40, GTN J. D. Jackson, EF-20 R. M. DeVault, EF-20/0STI m
(
n
,. [a k Department of Energy Oak Ridge Operations Q /j Post Office Box 62 Oak Ridge, Tennessee 37831 -8651 September 14, 1998 Mr. Robert C. Pierson Chief, Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS United States Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Mr. Pierson:
TRANSITION COSTS FOR THE GASEOUS DIFFUSION PLANTS The purpose of this letter is to update the information related to the gaseous diffusion plant (GDP)' transition costs that was provided to the Nuclear Regulatory Commission (NRC) in the letter to Walter S. Schwink from J. Dale Jackson dated August 9, 1996. Now that the certification process is complete and many of the activities identified in the Denartment of Energy (D0E) compliance plans for the GDPs have been completed, it is possible to provide a new estimate of the costs for completion of the transition.
Prior to the start of the transition from DOE oversight to NRC regulation, DOE recognized, based upon extensive compliance assessments of the GDPs, that substantial funding would be required to achieve full compliance with the DOE orders and standards.
Subseqtantly, during the transition period, the GDPs have further progressed towards compliance with the Regulatory Oversight Agreement (ROA) and progressed toward compliance with the NRC certification standards of 10 CFR 76. Although the ROA incorporated, in a performance oriented manner, DOE orders and standards required for safe operation, it did not include all of the administrative requirements (e.g., cost accounting standards, asset protection criteria, project management requirements) within the DOE directives that were associated with DOE operation of the GDPs.
- Thus, there was no period during the transition in which the GDPs were in full compliance with all DOE orders and standards.
Furthermore, the R0A was designed so that its requirements were more like the NRC requirements.
This regulatory approach was much more cost-effective in establishing compliance
. with the 00E standards required for safe operation and in achieving compliance L
with NRC regulations than requiring that the GDPs achieve full compliance with DOE standards and then requiring that their operatic.s be modified again to l
achieve compliance with NRC standards.
6%I%n.w.3,,
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i Mr. ilobert C. Pierson September 14, 1998 Nevertheless, bod 1'00E and USEC have incurred substantial transition costs in upgrading the GDPs to achieve compliance with NRC standards.
Now that the transition is complete, DOE is in a position to provide updated information regarding these costs.
Based upon current information, the total cost to DOE and USEC associated with-the transition ;of the GDPs from DOE oversight to NRC regulation was approximately $301' million. The cost to DOE was $228 million, comprising about $183 million for nuclear safety upgrades at the GDPs and about $45 million for direct certification costs, such as preparation of the application and compliance plans mandated by 10 CFR 76 and Special Nuclear. Material (SNM) surveys required to demonstrate compliance with the NRC established SNM possession limits. $220 million of this amount was reimbursed to USEC by DOE in the-form of uranium material transfers to USEC as a part of a settlement of l
the nuclear safety upgrade portion of the DOE statutory liabilities for
{
correction of pre-existing conditions under the Nemorandum of Agreement V
Relating to the Transfer of Functions and Actiyities from the United States l
Department of Energy to the United States Enrichment Corporation, as amended l
by Amendment FY 98-1, dated May 18, 1998. The reimbursed costs include the certification costs, exclusive of the preparation of the DOE Compliance Plans L
wnich were funded directly by DOE (approximately $8 million), and the costs for Compliance Plan corrective actions. The non-reimbursed costs to USEC for i
i transition that DOE is aware of were.approximately $73 million.
These costs l
included $38 million paid to DOE to c6ver DOE costs for regulatory transition l
'of USEC under the ROA, $34 million for plant and programmatic upgrades that, under the terms of the DOE - USEC agreements did not meet the standards for reimbursable actions to correct pre-existing conditions, and $1 million for application preparation.
It is difficult to clearly separate the costs of meeting NRC regulations from the total transition costs.
However, our analysis indicates that l
approximately $173 million was spent for activities that would not have been required to meet DOE orders and standards. This amount consists of: (1) $46 million for direct certification costs ($45 million DOE liability and $1 l
.million USEC liability), including the preparation of the certification l
applications and compliance plans mandated by 10 CFR 76 and SNM surveys required to demonstrate compliance with the NRC established SNM possession limits; (2) $34 million for plant and programmatic upgrades not meeting the l
standards for reimbursable actions to correct pre-existing conditions; (3) $55 i
million for other plant and programmatic upgrades unique to NRC requirements;
~
f and (4) $38 million for regulatory transition of USEC under the R0A.
The $173
.million transition cost is unique to the certification process for the GDPs t
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=s Mr. Robert C. Pierson September 14, 1998 and those costs associated with items 1 and 4 should not be generalized when predicting the costs associated with transition to external regulation for other facilities.
These costs reflect a multi-year effort and the involvement l
of a new third party (USEC) with a significant learning curve.
It is estimated that the cost of item 4, the DOE R0A oversight, would have been no more than $20 million if an initial certification application acceptable to j
the NRC had been submitted by USEC. Furthermore, DOE would have incurred a portion of these costs of oversight to monitor compliance with DCE orders and standards irrespective of transition.
Similarly, the cost for item 1 would have also been considerably reduced since additional expenditures were involved in the preparation of the additianal applications and the compan,on l
compliance plans.
Also, it should be noted that if the GDPs had been in compliance with DOE orders and standards prior to initiating transition, it is estimated that preparation costs for the compliance plans would have been reduced by about $5 million dollars.
The direct costs in item 1 are those that were included in Mr. Jackson's letter, of August 9,1996, to Mr. Schwink.
The costs in item 4 above, although clearly not required to meet DOE orders and standards, relate to the way in which the transition was conducted rather than the cost of meetir.g NRC requirements.
The remaining $128 million in transition costs compr ses costs i
that would have been incurred achieving compliance with DOE orders and standards. The transition cost information contained in this letter is summarized in the enclosed table.
If you have questions or need additional information, please contact me at (423) 241-4497.
Sincerely, Vl Randall M. DeVault Regulatory Oversight Manager Office of Assistant Manager l
for Enrichment Facilities 1
i Enclosure l
cc w/ enclosure:
l E. Q. Ten Eyck, NRC, White Flint S. Harlow, NE-40, GTN J. W. Parks, EF-20 J. D. Jackson, EF-20' l
l l
Table 1. Regulatory Transition Coste for the Gaseous Diffusion Plants j
DOE USEC Liability Liability Total Liability Transition Costs for Compliance with NRC Requirements Direct Certification Activities
- 1. USEC Certification Application Preparation, 537,000,000
$ 1,000,000
$38,000,000 Fees, and related activities
- 2. DOE Compliance Plans
$8,000,000
$0
$8,000,000 Plant & Programmatic Upgrades (nonreimbursable by
$0
$34,000,000
$34,000,000 DOE) l Plant & Programmatic Upgrades (unique to NRC
$55,000.000
$0
$55,000,000 requirements)
Other Transition Costs 1
- 1. Regulatory Transition Under ROA
$0
$38,000,000
$38,000,000 Subrotal
$100,000,000
$73,000,000
$173,000,000 l
Transition Costs for Compliance related to DOE Requirements Plant & Programmatic Upgrades (nct unique to NRC
$128,000,000
$0
$128,0 cum 00 \\
requirements-wo Ad have been incurred achieving cumpliance with DOE orders and standards).
Total Transition Costs
$228,000,000
$73,000,000
$'301,000,000 i
.~.
.Tcbla L Braia for Totti TrIn2itien Co2t3 for ths Gutous Diffu2 ion Plant 2 in DOE Letter dated September 14,1998 Cost Category Cost Liability i Basis i
I i
Reimbursable Nuclear Safety Upgrades (NSU)l
$220,000,000.1 DOE l Statutory liability for correction of pre-
, existing conditions based on Energy i
l Policy Act of 1992 as further defined l
(by Lease and MOA agreements; j
j
l
- compliance with NRC requirements jcontained in the Compliance Plans or i
l
!with ROA requirements (evaluated l
l
!and considered reimbursable by l
DOE); DOE liability settlement by the l December 15,1994 MOA, as l
{with USEC.
amended by Amendment FY 98-1 1
i i
i i
Nonreimbursable Nuclear Safety Upgrades
$34,000,000 USEC l Transition cost incurred by USEC for other NSUs to support NRC l
jeertification (not considered reimbursable by DOE, i.e. not required by Compliance Plans).
I Regulatory Transition under the ROA
$38,000,000l USEC Transition cost incurred by DOE and j
l regulation under the ROA during the transition (interim) period for July 1, i
1993, through March 3,1997.
i i
Compliance Plan Preparation l
$8,000,000!
DOE Transition cost incurred by DOE for l
l preparation of the Plans for Achieving I ompliance with NRC Regulations at j
C ithe GDPs required by 10 CFR 76.
i I
i Legal Services to USEC
$1,000,0001 USEC l Transition cost incurred by USEC for 4
f f! ifty percent of cost for outside legal l
services (per MOA) for preparation of l
l
. certification application required by 10 j
l lCFR 76; DOE reimbursed the other l
}
(50% of this cost in the first item i
l
!above.
I i
Total Transition Costst
$301,000,0001 L
i i
i
e.
- y l.
Tcbis 2. Ba:is far A2:Ignmrr.t cf Cret Cttegrries fer Tr:niitlan Co:ts fir ths G:sscua Diffuri:n Planta
- in DOE Lett:r dited S:ptember 14,1998 Cost Category i
Cost Basis i
transition Costs for Compliance with NRC Requirements j
l Transition costs directly related to NRC requirements:
costs for bringing the GDPs into initial compliance i
i l
!with NRC requirements as Mned in the Compliance Plans and the USEC NSU Program Plan supporting l
i LNRC certification.
__ Direct Certification Activities i
+
- 1. USEC certificanon activities
$38,000,000. Certification application preparation, certificauon fees.
4 l
! legal fees, nuclear safety culture upgrade, l confirmatory sweeps, contaminated area reduction, i
!and relateo activities. (items B.1 & B 3,8.2 B.4, B.5,
!D.2.C. D.8R, E.33, and E.40 in Table 3L
- 2. DOE Compliance Plan preparation
$8,000.000 DOE preparation of Plans for Achieving Comphance lwith NRC Regulations at the GDPs as required by 10 iCFR 76.
Plant & Programmatic Upgrades (non reimbursable by DOE)
$34,000.000. Portion of costs for USEC Nuclear Safety Upgrades l
{to plant facilities and programs identified by USEC as jsupporting NRC certification, but not required by 1
- Compliance Plans. (See Table 3)
Plant & Programmatic Upgrades (unique to NRC requirements)
$55,000,000 Portion of costs for USEC Nuclear Safety Upgrades 1
to plant facilities and programs required to meet NRC I
' requirements. (See Table 3) t i
i Other Transition Costs
$38,CJ0.000: Regulatory transition under ROA i
Subtotalt
$173,000,000
~
I Transition Costs for Compliance related to DOE Requirements jTransition costs for bnnging the GDPs into
[ compliance with NRC requirements as defined in the t
Compliance Plans and the USEC NSU Program Plan
{ supporting NRC certification that are not unique to l
- NRC requirements and would have been incurred by
' standards.
$128,000,00b Portion of costs for US5C Nuclear Safety Upgrades Plant & Progranimatic Upgrades (not unique to NRC requirements) l l
- to p' ant facilites and programs required to meet NRC I
requirements; not unique to NRC requirements.
Total Transition Costs >
$301.000.000-l 1
l l
ll' i
l l
l i
l l
l l
l l
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___m_
1 Tabis 3. Trtnrition Co;ts for Nuclxr Stfity Upgredra at ths Gzescus Diffu lon Plint)
I 1
i
\\
Plant and i
l DOE Estimate of {
Programmatic Reimbursable Nonreimbursable NSU Project Percentage due to Upgrade Costs to
! NRC Requirements' l Meet NRC NSUs
]
8 Requirements f
A. ROA CompHance i
A.1 NSU Management
$754.903 :
0%!
$1.760 A.2 DOE Regulatory Support
$2.978,114 6 0%i
$222,811 A.3 Seif Assessment
$386,422 0%i A.4 Seismic Modifications to C-331 and C-335 (PGDP) :
$24.553.800 i 0%l
$128,742 A.4A Seismic Modifications as a Result of SAM Update i
$10,000.000 l 0%
$3.000.000 A.5 PGDP Motor Overicad Alarm
$140.0001 0%I t
B. NRC Certification 2
B.1 & B.3 NRC Interaction & Application Preparation
- 0,861,514 i 100%
$342,416 B.210CFR 76 Review'
$183.314 =
100 % :
8.4 NRC Site Support'
$170,776 i 100 %i B.5 NRC Certification Fee'
$9.930,799 100 %I i
C. DOE Requests i
C.1 Support to ISA
$124.852 i 0%;
C.2 Non ROA Visits
$2,000 :
0%i C.3 Event Report ORPS 1
$50.8551 0%I D. Programmatic Upgrades i
D.1 and D.5 Procedures and Training
$33,064,671 i 55 %
$18,185.569i
$5,213.444 D.2.A & B Management Controls & Oversight /OOOP i
$441,000 :
100 % !
$441,000 t D.2.C Culture / Coaches' i
$2,006.3901 100 %
i
$3.911.571 D.2.D Corrective Action
$73.885.
0%l
$04 D.3 Operations
$80,192 l 0%
$0i l
D.4 Engineering / Configuration Management i
$9.844.000 i 0%!
$0j
$9.528 D.41 Instrument Setpoints & Calibration Program
$6,184.000 e 50 %
$3,092.000l
$4.816.000 i
D.6 Quality Assurance
$8.722.447 1 30 %
$2.616,734I
$253.563 D 7 Maintenance (M&TE) i
$127,748 i 0%
$0!
D.8 Radiation Protection (Not including outside surveys i
$18,781,000 =
30 %
$5.634.3001 i
3 D.8R Contaminated Area Reduction i
$3.216,9531 100 %
I D.8 Radiation Protection - Outside Surveys (G _
0%
$0i
$1,900.000 1
l' D.9 Nuclear Criticality Safety
$7,504.000 >
15%i
$1,125.600 t
$1,20T l
l D.10 Fire Protection
$127,025 0%
$0i
)
D.11 Environmental Monitonng
$31.346 !
0%
$0i D.12. A Nuclear Materials Controls & Accountability
$11,744 i 0%
501 i
D.12.D Detect Unauthonzed Production i
$72.0001 100 %.
$72,000 t j-D.12 E NDA Measurement
$122,897 :
100 %
$122,897:
D.13 Emergency Management
$1,392.000 :
30 %
$417,600L_
i D.14 Radioactive Matenal Packaging & Transportation !
$550.476 100 %
$550.476)
$0 i 0%i D.15 Sampling i
D.16 Waste Management
$5,394 '
0*Il
$0:
l D.17 Accident Analysis i
$36,365 0%'
$0; i
D.18 Secunty.
$7.231 0%
$0:
D.19 Chemical Safety
$2.800,
0%;
$0 D'20 90E Safety Evaluation Report (SER)
$3,041,135 1 0%
$0 D.20A integrated SAR Update
$15.310,126 93 %
$14.238 417'
$4.736,231 D.21 Safety Basis Development
$935.000 -
100W
$935,000.
$0 E. Plant Upgrades
$0i
+
E.1 Autoclave Modifications (PORTS)
$0.769.000 t 0%
$0l E.2 Relocation of NCS Radiation Alarm Clusters (PGDP-
$0 !
OW
$0-
$374.834 E.5 Calciner Piping Modifications (PGDP)
$30,787 >
100%
$30.787:
E.8 X-705 Microfiltration influent pH Modification
$107,563 !
0%!
$0-E.7 PORTS HEPA Filter Upgrades
$1.188,491 100 %
$1.188.491 i
$680 i
E.9 Upgrade Plant Public Address System (PGDP)
$1,082.665 +
0%
, _ $0' i
E.10 Public Waming System Upgrade (PGDP)
$832,917 -
0%
$0 l
l.
L
, y-Ttbla 3. Trtnrition Colts for Nuclztr Saf2ty UpgradIs at tha Grasou2 Diffullon PlInta 1
E.11 C-720 Cnticahty Alarm System Upgrade (PGDP)
$639.000 i 0%:
$0!
l E.12 Fire Alarp_t UpJrades (PGDP)
$228,821 !
100 %I
$228,821 !
E.13 Fire Water Pumps (C-361)
$984,000,
0%
S0r E.14 C-360 Cranes (PGDP)
$659.939 I 100 %i
$659.939i
{
E.16 X-705 Handtable Heat Exchanger Replacement-
$1.155.22I~
0%7
$0,
$1,312 1
$105,368 -
0%
$0-
^.17 X-705 Recovery Area Pre-& Post-Evaporator (PO '
$.18 Assay Blendmg for HEU refeed
$07 100 %
$0-
$736.000 E.19 ERP Crano Replacement (PORTS)
$0 0%
$0i
$644.962 E.20 UF6 Leak Detection Upgrade (PGDP)
$1,000.000 ;
100 %
$1,000.000
$5.116.000 E.21 C-333A/C-337A/C-360 Autoclave Instruments (PG
$1.277,000 i 0%
$0i l
E.22 ERP/ LAW /7 ails Sump Modifications for NCS (PO
$254,6041 0%
$0 E.23 C-315 High Pressure Fire Water System -
$342.000 100*5l
$342,000:
I E.24 PGDP HEPA Testing and M_odifications
$709.000 i 100 %
$709.000:
E.25 X-705 NCS Modifications (PORTS)
$936.000 >
0%
Soc
)
E.26 Unslaved CAAS Facilities (PORTS)
$443.162 t 0%:
$0:
i E.28 NSA Section Upgrades
$0 i 100 %
$0 51,286.000 E.29 improved Containment Testeg (Autoclave) (PGD
$229.400 (
100 %
$225 400 E 30 Emergency Egress Ughting (PORTS) 50 :
0%
$0:
$225,000 E.31 Cascade Deposit Monitonng System (PORTS)
$0,
100 %
$0'
$285.000 l
E.32 Air System Moisture Meter & Alarm System
$182.000 i 0%
$0 E.33 X-705 Confirmatory Surveys (PORTS)3
_ $1.066.344 l 0%
$0
$319,000 100 %
E.34 CADP and Smoke Detection Modification E.35 C-710 CAAS Replacement / Upgrade (PGDP)
$2,312.000 :
80 %
$1,849.600:
E.36 Eval & Repair UF6 Cyiindar Crane Runways
$0 i 100 %
$0:
$195.000 E.37 CAAS for Technical Safety Requirement
$0 :
100 %!
$0i
$678.000 E.38 Fire Loading - NSU.
$239.000 0%
$0-1 E.39 UF6 Feed. Witndrawal, and Transfer System Upgr !
$485,000 !
0%
$0' 3
E.40 X-326 Secunty Sweeps
$3,746.0001 100 %
4 E.113 PGDP CAAS for Nearby Buildings (PGDP)
$156.822 ;
0%
$0 E.114 PGDP instrument Calibration Buildings (Study)
$0 i 0%j
$0
$100,000 E.115 NDA Mass Determination for Cylinder Wash NCS
.$288.000 i 0%
$0 E.116 CAAS Hom Audibility (PGDP)
$5.081.714 i 0%
$0:
. Subtotal Reimbursable NSUsi
$213,680,000 t i
Supplemental Labor
$6,026,000 20 %
$1,205.200 Supplemental Taxes
$294.000 0%
Subtotal. Plant & Prog, Upgrades due to NRC:
$54,874,831, Subtotal. Nonreimbursable NSUs,
$34,180,054 Total-Reimbursable NSUsi
$220,000,000 IEstimate based on DOE evaluation of the NSU project 1
!ExcludingDirect Certification Activity Costs 3Direct Certification Activity i
l l
_-,,