ML20205E524
| ML20205E524 | |
| Person / Time | |
|---|---|
| Issue date: | 03/22/1999 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | GENERAL, MINNESOTA, STATE OF, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF, WISCONSIN, STATE OF |
| References | |
| SP-99-016, SP-99-16, NUDOCS 9904050213 | |
| Download: ML20205E524 (9) | |
Text
_
e ALL AGREEMENT STATES E 2 2 1938 i
MINNESOTA, OHIO, OKLAHOMA, PENNSYLVANIA, WISCONSIN PROGRAM MANAGEMENT INFORMATION: INFORMATION REQUEST FOR POTENTIAL FUNDING ASSISTANCE FOR FORMERLY LICENSED SITES (SP-99-016)
I am writing to request your assistance in obtaining supporting information on the costs to conduct file reviews; site surveys; and perform site characterization and remediaiton, if necessary, for formerly NRC-licensed sites in Agreement States. The enclosed March 15,1999 Staff Requirements Memorandum (SRM) and November 20,1998 Commission Paper SECY-98-273," Potential Funding Assistance for Agreement States for Closure of Formerly Terminated NRC Licenses"(Enclosures 1 and 2) provide further information regarding this request.
Specifically, the Commission has directed staff to develop a grant program for Agreement States, supported by a separate appropriation from the General Fund, to fund remediation of formerly NRC-licensed sites when the original owner or successor cannot be found or does not -
have sufficient funds. Prior to submitting a request to Congress, the Commission has asked staff develop a clear basis for the request and decision framework to describe how NRC would allocate funds to individual Agreement States. Therefore, we ask that you provide the information set out in Enclosure 3 for the remaining sites in your State that have not been closed out to date. Other information that may assist in justifying a reasonable cost estimate should also be provided. For example, the Commission has asked that earlier cost estimates be re-evaluated in view of the much higher known costs for cleaning up Site Decommissioning Management Plan Sites. The lack of sufficient supporting information to justify the cost estimatas may Jeopardize the Commission's ability to obtain Office of Management and Budget (OMB) approval for a funding request. Finally, as stated in the SRM, the Commission has asked that we obtain stakeholder (e.g., the States, industry, Nuclear Energy institute, and citizen groups) views on this proposal. We plan to request stakeholder views separately.
However, if you have comments at this time, we would appreciate receiving them.
We would appreciate your response to this letter by April 30,1999. (The OMB voluntary collection burden estimate is contained in Enclosure 3).
/?
Please contact me or the individual below if you have any questions.
POINT OF CONTACT: Dennis Sollenberger INTERNET:
DMS4@NRC. GOV TELEPHONE:
(301) 415-2819 FAX:
(301) 415-3502 OriginalSigned By:
9904050213 990322 PAUL H. LOHAUS
~
PDR STPRG ESG N
Paul H. Lohaus, Director j
Office of State Programs g()O
Enclosures:
As stated
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Distribution:
DlR RF DCD (SP03)
- SDroggitis PDR (YESj_) (NO__)
A/S File i
DOCUMENT NAME: G:\\SP99016.DMS T* receive a copy of this doct..mont, Indicate in the box: "C' = Copy _Mattachment/encio1As" Mopy with attattnent/ enclosure "N" = No copy l
OFFICE OSPfu%
OSP M OM[]
l NAME DSollenberddErib KHsueh ' ' "4C PLohadsf' VT DATE 03/ 7 4 /99 03/22/99 "
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NUCLEAR REGULATORY, COMMISSION 2
WASHINGTON, D,C. 20066 4 001-
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March 22, 1999
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' ALL AGREEMENT STATES
)
MINNESOTA, OHlo, OKLAHOMA, PENNSYLVANIA,' WISCONSIN -
1 PROGRAM MANAGEMENT INFORMATION: INFORMATION REQUEST FOR POTENTIAL FUNDING ASSISTANCE FOR FORMERLY LICENSED SITES (SP-96'-016)
. I am writing to request your assistance in obtaining supporting informatien on the costs to conduct file reviews; site surveys; and perform site characterization and r,emediaiton, if necessary, for formerly NRC-licensed sites in Agreement States. The enclosed March 15,1999 Staff Requirements Memorandum (SRM) and November 20,1998 Commission Paper SECY-98-273," Potential Funding Assistance for Agreement States for Closure of Formerly Terminated NRC Licenses" (Enclosures 1 and 2) provide further information regarding this request.'
Specifically, the Commission has directed staff to develop a grant program for Agreement States, supported by a separate appropriation from the General Fund, to fund remediation of formerly NRC-licensed sites when the original owner or successor cannot bn found or does not have sufficient funds. Prior to submitting a request to Congress, the Commission has asked
. staff develop a clear basis for the request and decision framework to describe how NRC would allocate funds to individual Agreement States. Therefore, we ask that you provide the information set out in Enclosure 3 for the remaining sites in your State that have not been closed out to date. Other information that may assist in justifying a reasonable cost estimate should also be provided. For example, the Commission has asked that earlier cost estimates be re-evaluated in view of the much higher known costs for cleaning up Site Decommissioning Management Plan Sites. The lack of sufficient supporting information to justify the cost estimates mey jeopardize the Commission's ability to obtain Office of Management and Budget (OMB) approval for a funding request. Finally, as stated in the SRM, the Commission has asked that we obtain stakeholder (e.g., the States, industry, Nuclear Energy Institute, and citizen groups) views on this proposal. We plan to request stakeholder views separately.
However, if you have comments at this time, we would appreciate receiving them.
We would appreciate your response to this letter by April 30,1999. (The OMB voluntary collection burden estimate is contained in Enclosure 3).
- Please contact me or the individual below if you have any questions.
POINT OF CONTACT: Dennis Sollenberger INTERNET:
DMS4@ NRC. GOV TELEPHONE:
(301) 415-2819 FAX:
j (301) 415-3502 Paul H. Lohaus, irector Office of State Programs
Enclosures:
As stated m
3 NO MOUq s
k UNITED STATES
'g-j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 20656-0001
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March 15,1999 MEMORANDUM TO!
William D. Travers
)
Executive Director for Operations Jesse L. Funches Chief Financial Officer.
i i
Karen D. Cyr General Counsel FROM:
Annette Vietti-Cook, Secretary
/s/
SUBJECT:
STAFF REQUIREMENTS - SECY-98-273 - POTENTIAL FUNDING ASSISTANCE FOR AGREEMENT STATES FOR CLOSURE OF FORMERLY TERMINATED NRC LICENSES The Commission has approved the staff recommendation to implement Program Option 1 to continue Agreement State jurisdiction over formerly licensed sites and develop a grant program to make funds available to Agreement States for file review and remediation in certain cases.
The staff should reevaluate the remediation cost estimates for the Agreement State sites in
. view of the much higher known costs for cleaning up Site Decommissioning Management Plan
. sites. In further communication with Agreement States on this matter, it should be clear that a lack of responsiveness could limit NRC's ability to obtain the necessary funds to cany out further remediation of these sites. The revised cost estimates should include funding for the file reviews and site remediation, if necessary, of sites located in non-Agreement States.
j
' The Commission also has approved the staff's recommendation to pursue a separate appropriation from the General Fund to establish a fund for use by Agreement States through grants to assist in the remediation of formerly NRC-licensed sites when the original owner or i
. successor cannot be found or does not have sufficient funds. The staff should first seek stakeholder views (i.e., the States, industry, NEl, and citizens groups) before pursuing a General Fund appropriation. In submitting a General Fund Appropriation request to Congress for FY2001 and FY2002, the staff should provide the Commission with a clear basis for the request and a decision framework that describes how NRC will allocate the appropriated funds to individual Agreement States.
The staff should develop a decision framework for providing funds to individual Agreement States to ensure a relatively fair and equitable allocation of available funds. One option would be for NRC to provide funding to an individual Agreement State based on the estimated cost for each site to comply with a 25 millirem / year public dose standard. In these cases, any additional cleanup costs for compliance with rnore conservative criteria, as determined by the Agreement State, would be funded by the State. In addition, it may be necessary to conduct further risk-ENCLOSURE 1
ranking of the sites to ensure that funds are available for the " higher risk" sites in the event that appropriated funds are less than requested or prove to be insufficient to fully remediate all sites identified to date. Such a plan is instrumental for NRC to fine-tune its funding request which, based on the Site Decommissioning Management Program experience, could result in a higher estimate and could play a critical role in receiving Congressional appro/al of the requested funds.
The staff should provide the Commission with its revised cost estimates and a basis for the estimates, the decision framework, and a draft letter requesting appropriation from the General Fund.
(EDO/CFO)
(SECY Suspense:
7/23/99)
Should a request for an appropriation from the General Fund become unviable, the NRC should be prepared to notify the Governors of Agreement States concerning their responsibilities under the Agreements to ensure that the appropriate legislative and financial support are provided to the respective Agreement State Programs to address these sites.
The staff should seek to resolve NRC/ Agreement State jurisdictional issues over regulatory responsibility and evaluate possible approaches for returning identified sites to NRC Jurisdiction, if desired by the State. The staff should evaluate the different possible approaches that would allow Agreement States to return jurisdiction of these sites to the NRC and should forward its findings to the Commission in a Commission paper that contains options and a staff recommendation. The staff evaluation should consider whether these sites constitute a class or category of sites that could be included or excluded from an Agreement without amending the Atomic Energy Act.
(EDO/OGC)
(SECY Suspense:
9/30/99) cc:
Chairman Jackson Commissioner Dieus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield CIO OCA OlG j
OPA Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
)
1 ENCLOSURE 1 u
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4 1
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' November 20;1998 SECY-98-273 EQB:
The Commissioners.
FROM:
William D. Travers /s/
Executies Director for Operations
SUBJECT:
POTENTIAL FUNDING ASSISTANCE FOR AGREEMENT STATES FOR CLOSURE OF FORMERLY TERMINATED NRC LICENSES PURPOSE:
To report on Agreement State actions and the staff actions in response to Staff Requirements Memorandum SRM-SECY-98-011, dated March 3,1998 and to present options for Commission consideration for potentially funding Agreement States' efforts in addressing formerly licensed NRC sites.
BACKGROUND:
The Commission previously approved the staff's proposal: (1) for the discontinuance of _.
. detailed reviews by the NRC staff of license files and inspections for follow up on formerly AEC or NRC licensed sites identified for further investigation in Agreement States; (2) for the referral
'of identified cases directly to the Agreement States for follow-up investigation; and (3) to hold the Agreement States responsible for addressing remediation of those sites where excessive contamination is confirmed by inspection (see SRM-SECY-97-188, dated November 7,1997).
The Commission directed that State actions in these cases should not affect findings of adequacy under the Integrated Materials Performance Evaluation Program (IMPEP) unless 1
there is a clear, significant threat to public health and safety resulting from the lack of State action. The Commission also directed the staff to work with the Agreement States to identify a mutually acceptable mechanism to provide Federal assistance to the Agreement States, such j
as a general fund appropriation outcide the NRC fee base, in dealing with these cases. The i
+
Contact:
Dennis M. Sollenberger, OSP 301-415-2819 4
ENCLOSURE 2 a
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[Mo&@Desi %9V.
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The Commissioners status of the staff efforts was presented to the Commission in SECY-98-011, dated January 22, 1998. By SRM-SECY-98-011, dated March 3,1998, the Commission directed the staff to continue monitoring the Agreement States' progress in closing out the case files associated with sites located in Agreement States that were formerly licensed by the NRC or its predecessor, and to collect additional information from the individual Agreement States regarding the associated costs and potential funding mechanisms to provide Federal assistance. In implementing this monitoring and information collection program, however, the staff.was also directed to undertake the following additional measurcs:
Inquire 'whether the initial site surveys and assessments to determine the scope of the problem are themselves so significantly expensive and difficult as to preclude the States from undertaking even this preliminary step in the cleanup process, in the absence of
- other funds or some other form of resource assistance from the NRC.
ensure that the file review being conducted by Oak Ridge National Laboratory is completed by March 1998, that the files are subsequently transferred to the States promptly, and that milestones are established on when NRC needs to receive information from the Agreement States. The staff should make an initial recommendation on whether NRC should request a general fund appropriation, to cover the associated Agreement State costs for those States providing a response consistent with the FY 2000 budget cycle.
consider the merits of an alternative approach to providing financial assistance to individual Agreement States by developing a narrowly focused amendment to the Atomic Energy Act that would allow the Agreement States to return their regulatory authority and responsibility for formerly licensed sites to the NRC if the licenses in 1
. question had been terminated before the State became an Agreement State and permit the NRC to receive appropriations off the foe base to cover the costs associated with closure of these sites.
Finally, the Commission directed the staff to inform it of any difficulties experienced by the NRC or Agreement States in attempting to require further remediation of these sites.
DISCUSSION:
Clean-up Process Preliminary Step Proclusion:
The staff contacted the Agreement States through an All Agreement States letter (see
- ) and requested the States to indicate, among other things, whether the cost to review the files was so prohibitive as to preclude the State from performing this initial step. As discussed below under Staff Coordination Efforts With the Agreement States, in many cases, replies to this_ inquiry were not definitive or there was no reply at all. From the information received, the staff concludes that for reasons of expense, regulatory difficulty, and disagreements about the responsible regulatory authority (NRC or Agreement States), initial l
site surveys and assessments to determine the scope of potential contamination problems have not been completed in Arizona, California, Colorado, Massachusetts, and'New York. These
. States have a total of 71 loose material sites and 44 sealed source sites.
ENCLOSURE 2 I
The Commissioners :
TO ORNL Contract Work:
Oak Ridge National Laboratory (ORNL) completed its Phase 3 Review of Terminated Nuclear Material Licenses in March 1998. The review included docket file reviews for sites where loose materials were used and sites where sealed sources were used and licenses terminated
' between 1985 and 1996 with some additional sites revisited outside this time frame. ORNL submitted the following summary reports in preparation of the final report:
1.~
! Nuclear Material Use Sites identified for Additional Review. This document lists all sites, organized by State, which ORNL identified for additional review.
2.
Material License Files Contained in Phase 3 Review. This document lists sites, organized by State, reviewed during Phase 3.
3.
Site Summaries and Recommandations, Phase 3 Review of Terminated Nuclear Material Licenses. This report summarizes each site identified for further review during Phase 3 of the project.
4.
Licenses identified for Sealed Source Review. This report identifies all licenses with sealed sources, organized by State, which required additional review.
j 5.
Licenses with Sites identified for Site Review. This report identifies all loose material licenses with sites, organized by State, which required additional review.
The final report for the terminated nuclear material license review phase'of the ORNL contract was sent to be published as NUREG/CR-6592, and will be available in November 1998.
Staff Coordination Efforts With the Agreament States:
The staff sent letters to each of the Agreement States identifying the sites that needed futther
. evaluation. The letters also asked the States for the location where these files should be sent.
Several States responded that they did not want the files based on their disagreement with the Commission's decision in this araa, or by lack of response did not request the files. The other States either requested the files or reviewed their records for the sites on the lists.
To update the status of sites in Agreement States and to collect additional information, the staff prepared and sent an All Agreement States letter, dated April 2,1998, requesting the status of the progress made in reviewing the files and any hindrances keeping the State from proceeding with the review (see Attachment 1). Only a fe,v States (AZ, CO, IL, KY, NV, NY, TN, and WA) responded. Subsequently, the staff called a number of States that have potentially
- contaminated sites (AL, CA, GA,' LA, NE, NV, NY, TN, TX, and UT). Together these Statas covered all the loose material sites identified by NRC and the majority of the sealed source sites.
.Two States (CA and NY) noted their previous position that they do not consider the formerly licensed sites review and remediation a State responsibility and do not intend to conduct work on this project. Others (AZ and CO) said that they would conduct the file reviews and surveys ENCLOSURE 2 1
1
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The Commissioners:.
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i upon receipt of funding from the NRC. - California and New Yck also commented that, if NRC i
wanted them to conduct this work under contract with NRC then they would be willing to conduct this work. Other States identified work in progress with a number of files closed.-
Agreement States to whicf. U.s were sent and the status of work in the Agreement States is j
summarized in Attachment... Illinois completed all the work for the sites within the State and requested teimbursement for the completed work if funding for State actions were to be i
approved.
Staff Estimates for Decommissioning Costs:-
Costs for Agreement State regulatory authorities and potentially contaminated site responsible
~
parties (if identified) inclu& both regulatory costs and site remediation/ decommissioning costs.
Regulatory costs can inc2.de license / inspection file review, initial or periodic site surveys, and licensing and inspection. The'se' costs.may be recovered, at least in part, through fees assessed to responsible parties, if identified. The costs of detailed site characterization and i
remediation/ decommissioning should be the responsibility of the former licensee or current responsible party. However, in some cases, it may be difficult or impossible to identify the
- former licensee or a responsible party. In other cares, the former licensee or responsible party may not have adequate funds for site remediation/ decommissioning. If the former licensee or responsible parties are not identified, or if suffs::ient funding for the costs'of detailed site characterization and remediation/ decommissioning are not available, clean-up funding through the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) may be a possibility for some sites, if such sites do not qualify for CERCLA funding and no responsible party is identified, some Agreement States (CA, CO and NY) have indicated that State govemment may take on the liability for funding the costs of site characterization and remediation/ decommissioning in order to protect the citizens of their State.
' Because of the uncertainty described in the above paragraph, the staff estimated an upper bound for the costs for regulatory efforts and remediation/ decommissioning of the remaining sites in the Agreement States. The estimate, between $3,000K and $4,000K, is based on regulatory costs of $30K per site for sites with ORNL scores between 100 and 300 and an average cost for remediation of $500K for two-thirds of the sites with ORNL scores greater than 300, and on staff knowledge that four of the remaining sites are known to be contaminated.
Included in this estimate is tne cost estimate of $1,500K for one site which has been submitted to NRC in a Tort Claims filing. The Agreement States may identify some additional contaminated sites based on their sites investigations, but the estimate assumes no significant coets for sites with ORNL scores below 100, only regulatory costs (no remediation required) for sites with ORNL scores between 100 and 300, and two c dde'onal sites with scores above 300, and not currently known to be contaminated, need remedieuon (i.e., six of nine sites are estimated to require remediation). This upper-bound approach assumes that no Agreement State regulatory costs are recovered from licensees or responsible parties, that no necessary cleanups are funded under CERCLA, and that Agreement States bear the full responsibility for i
costs associated with remediation/ decommissioning at sites needing cleanup. This cost estimate is summarized in Attachment 3.
ENCLOSURE 2
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J 7
The Commissioners -
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- i Funding Options:
The Commission has two unding options:
Request a' separate appropriation from the General Fund (i.e., o itside the fee base) to be made available only for the purposes'of review and closure of these formerly licensed sites. The funds could be used for State regulatory efforts including surveys,-
characterization and remediation when the original responsible party or successor cannot be found or does not have sufficient funds. The funds could be made available to the States through grants with a ceiling amount based on an estimate for the specific sites in that State.
' Allocate funds from fee-based funding to assist the Agreement States in the performance of the remaining activities to close out these formerly licensed sites. This 1
would place additional financial burden on NRC licensees and would add to the concems expressed by the Commission, NRC licensees and Congress regarding the fairness and equity of charging current NRC licensees for agency expenses which can not be attributed to these licensees.
Since the costs associated with closure of the formerly terminated NRC licenses are not attributable to current NRC licensees, the staff recommends that these costs be funded by a separate appropriation from the General Fund excluded from fee recovery. If OMB or the Congress does not approve such an appropriation exempt from fee recovery, then the Commission will need to consider using the agency's fee-based funding, within the limits of the other agency mission priorities.
Amendment to the Atomic Energy Act:
In accordance with the Commission's direction, the staff has considered the merits of developing a narrowly focused amendment to the Atomic Energy Act that would allow the Agreement States to retum their rgslatory authority over formerly licensed sites. Under current law, it is unclear whether an Agreement State could voluntarily terminate its Agreement
-with respect to material at formerly licensed sites. The issue of " partial" Agreements was
~ ddressed in SECY-97-087 in the context of a proposal from Oklahoma for an Agreement with a
the Commission. The Commission approved a general approach to address the creation of such limited Agreements. If the Commission were able to conclude that sites formerly licensed L and decommissioned under AEC or NRC authority met these criteria, an Agreement State could request an amendment to its Agreement with NRC to terminate State authority over formerly licensed sites.
Absent such a conclusion, an amendment to the AEA would be necessary to allow a State to terminate its Agreement with respect to these sites. Such an amendmsnt could be drafted that
-would reassert NRC jurisdiction in the absence of an Agreement State indication that it wants to
' retain regulatory authority.
Such an the amendment would eliminate any existing disagreements between NRC and Agreement States regarding current legal authority over these sites in Agreement States. Those
- ENCLOSURE 2
?'
The' Commissioners - States that are willing to take the steps necessary to close out these sites would continue to do so under their current Agreements. NRC would have the responsibility to close all other formerly L licensed sites located in Agreement States. While the amendment should resolve existing concerns, it would add an unbudgeted, currently unspecified, amount of work that would become NRC's resporisibility. The cost estimate for this activity would be for NRC staff efforts and are
)
identified in the Resources section of this paper. This approach would likely result in continued
' inaction by a number of Agreement States during the period of time Congress considers the
- amendment. As noted in the Funding Options section of this paper, NRC could request a
, separate appropriation from the General Fund or fee based funding for this requirement.
Difficulty in Further Remediation:
The difficulties identified to date are that no responsible party is in existence or no funds are available, the current site owner has no direct relationship with the former licensee and does not -
have the resources to remediate the site, and Agreement States that do not agree with the Commission's decision are not addressing the sites identified by ORNL. As an example, a specific case is described below.
A site in Califomia was licensed in the 1950s and early 1960s for waste collection and storage, source manufacturing, and commercial radiochemistry laboratory operation. The current owner knew of the site's history but understood that all radioactive material had been removed and the license had been terminated. NRC and State inspectors performed a cursory radiological survey q
of the site in 1996. These surveys indicated that several areas inside the site buildings and outside were contaminated above NRC release criteria. Analysis of samples determined that Th-230/232 and Cs-137 are the contaminants. The surveys also indicated that source material may be buried on site. NRC sent a letter to the State of California on April 8,1996 indicating that regulatory responsibility for this site rests with the State. The State responded that it did not agree with NRC's determination on responsibility. The current site owner, which has no relationship with the former licensee, is proceeding with site characterization. The owner has filed a claim against NRC under the Federal Tort Claims Act due to lack of NRC follow up on the property since the initial survey. However, that claim was rejected by NRC and was not pursued further.. The owner has not been able to lease or sell the property since the NRC inspection.
Currently, this site has raised the most significant Agreement State related concerns in the formerly licensed sites program. The staff is cooperating with the State to resolve these issues in a manner acceptable to all parties involved and that will not delay site characterization and remediation.
Program Options:
The staff has identified three program options:
Option 1 -. Agreement State Jurisdiction, with NRC Assistance Through Funding: Develop a i
grant program that _would make funds available to complete the formerly licensed sites file reviews and provide funds for remediation, if necessary, when.no responsible party can be located, or the responsible party does not have the resources to conduct the remediation, and i
ENCLOSURE 2 i
4 1
r
The Commissioners ' the site does not qualify for cleanup under CERCLA. The Commission would request a separate f appropriation from the General Fund (i.e., outside the fee base) in the amount of $2,000K per year for FY 2001 and FY 2002 to fund this option and would need to consider fee-based funding
' if exempt funds are not available.
Pros:
NRC licensees, which receive no benefit from this program, do not provide the
. funding support through fees.
No financial burden placed on the Agreement States.
Assures all formerly licensed sites in Agreement States are assessed and remediated,if necessary.
Cons:
Congressional approval of funding uncertain.
Agreement States may have to use contractors since any newly hired staff members could not be retained after NRC funding stops.
Funding support would not begin until FY 2001.
Option 2 - Agreement States Return Jurisdiction to NRC: Propose an amendment to the Atomic Energy Act that authorizes NRC to regulate formerly licensed sites located in Agreement States, unless an Agreement State requests continued authority.- NRC regulatory costs for this option are estimated to be 2 FTE (about $200K).' The Commission would fund this effort by requesting Congressional approval for a separate appropriation from the Gene al Fund (i.e., outside the fee base) in the FY 2001 budget and budgets for future years, as neces,sary. Under this approach, NRC licensees would not provide funding through fees for this purpose. Under this option, sites requiring remediation, but having no responsible party, or no financially solvent responsible party, would be candidates for cleanup under CERCLA.
Pros:
Would resolve the NRC/ State dispute over regulatory responsibility for these sites.
Assures all formerly licensed sites in Agreement States are assessed. Most, if not all, sites needing cleanup would be remediated.
No unwanted financial burden placed on Agreement States.
NRC licensees, which receive no benefit from this program, do not provide funding through fees.
Cons:
Sites with no responsible party and having a low radiological risk would be highly unlikely to be addressed under CERCLA.
Congressional approval uncertain.
i Would not reimburse Agreement States for work previously completed.
Budgeted resources are not available until FY 2001.
Option 3 - Continue Current Status: Continue to encourage the Agreement States to review the remaining files and remediate any identified contaminated sites. Existing NRC budgeted resources are ' sufficient for this option, but a number of the formerly licensed site file reviews and remedial actions, if necessary, may never be accomplished. Additionally, under this option, some sites requiring remediation, but having no responsible party, or no financially solvent responsible party, would be a candidate for cleanup under CERCLA.
ENCLOSURE 2
O The Commissioners ' Pros:
No additional recources required.'
May leave some sites unaddressed.
Cons:
Sites with no responsible party and having a low radiological risk would be highly
- unlikeiy to be addressed under CERCLA.
Disagreements about the responsible regulatory authority would not be resolved.
' NRC licensees fund NRC effort through fees.
<v Places financial burden on Agreement States'.
7 The staff recognizes that these options are not mutually exclusive and that it would be prudent to
? continue working with the Agreement States to reduce the number of sites that need to be considered under Options _1 and 2. Options 1 and 2 could also be pursued in parallel with both options resolving the jurisdictional issue with the States.
RESOURCES:
The resources discussed above are not included in the FY 2000 budget. Due to the limited information provided by the States in response to the April 2,1998 letter, the staff was not able to develop these estimates in time to incorporate them in the FY 2000 budget package. The
' staff is recommending that $2,000K be included in the FY 2001 and FY 2002 budgets as a separate appropriation from the General Fund. The FTE required in OSP and OCFO to administer a grant program is less than 0.25 FTE in each office and is available eithin currently budgeted resources.
If the Agreement States were to return all the currently open sites to NRC, the resources needed to complete the file reviews and close out all but a few problem sites would be approximately '
2 FTE (approximately $200K) which are currently not included within the budget. The problem sites could then be transferred to the Site Decommissioning Management Program with the
= long-term resources incorporated into that program's budget when they are transferred. Since NRC does not have the authority under the AEA to pay for remediation under SDMP, the estimated $3,000K-$4,000K for remediation would not be required under Option 2.
COORDINATION:
The Office of General Counsel has no legal objection to this paper. The Office of the Chief Financial Officer has reviewed this Commission paper and has no objections.
RECOMMENDATIONS:
The staff recommends the Commission:
1.
Approve the implementation of Program Option 1. This would continue Agreement State Jurisdiction and bring the formerly licensed site program to closure with NRC funding assistance.
I I
ENCLOSURE 2 i
p 1
~
The Commissioners
. 2
~
2.
. Note that the staff will continue to work with the' Agreement States to support their closure of as many of the file reviews as possible in parallel w:th implementing Program
' Option 1.
William D. Travers Executive Director.
for Operations-Attachments:
1.
April 2,1998 Letter to Agreement States w/o enclosures 2.
Status of Agreement State Actions 3.
Cost Estimate Table I
ENCLOSURE 2 I
The Commissioners
-9 t
2.
Note that the staff will continue to work with the Agreement States to support their closure of as many of tho file reviews as possible in parallel with implementing Program Option 1.
William D. Travers Executive Director for Operations Attachments:
1.
April 2,1998 Letter to Agreement States w/o enclosures 2.
Status of Agreement State Actions 3.
Cost Estimate Table i
)
Distribution:
DlR RF (9700277)
DCD (SPX2)
SDroggitis PDR (YES NO_/__)
-l Decommissioning File DOOUMENT NAME: G:\\FLSCOMR3.DMS.
- See previous concurrence. "Reconcurred Tr receive a copy of this document, Indicate in the box: "C' = Copy without attachrnent/ enclosure "E" = Copy with attachmenvenclosure "N" = No copy OFFICE OSP-l OSP:DD l NMSS l OCFOl OGC OSP:Dl DEDR l EDOl 1
NAME DSollenberger:nb PHLohaus CPaperiello JFunches FCameron RBangart HThompson WTravers DATE 10/08/98*
01/08/98*
10/09/98* ~
10/29/98vi 10/27/98*
10/08/98*
11/ /98 11/ /98 11/16/98" a E-mail 11/10/98" 11/ /98 11/16/98" OSP FILE CODE: SP-D-1 ENCLOSURE 2
1 C CE:v,t gy k
UNITED STATES
('
j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 20555 4 001
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DATED: APRIL 2,1998 SIGNED BY: PAUL H. LOHAUS ALL AGREEMENT STATES OHIO, OKLAHOMA, PENNSYLVANIA i
TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-98-025)
Your attention is invited to the enclosed correspondence which contains:
INCIDENT AND EVENT INFORMATION........
PROGRAM MANAGEMENT INFORMATION.. XX AGREEMENT STATE VIEWS ON COST / IMPACTS FOR CLOSURE OF FORMERLY TERMINATED NRC LICENSES i
TRAINING COURSE INFORMATION...............
TECHNICAL INFORMATION..........................
OTH ER I N FO R MATION....................................
Supplementarv information: Enclosed is a copy of a January 22,1998 Commission paper, SECY-98-011 " Potential Funding Assistance For Agreement States for Closure of Formerly Terminated NRC Licenses," and associated March 3,1998 Staff Requirements Memorandum (SRM). Your attention is directed to the recommendations in SECY-98-011 (See page 4) and direction provided in the SRM. To assist in better understanding the costs and impacts of your activities to "close" these sites, we request that you provide the following information. We would appreciate your responsa to items 1,2 and 3 by June 30,1998. We would appreciate your response to item 4 by May 15,1998.
1.
Status of your activities to review background materials and license files on sites located in your State to identify sites which may be eliminated from further consideration based on existing available information, and those that will require further assessment and possible remediation; 2.
Identification of the number of sites that may need remediation (or have been remediated), the regulatory efforts necessary to ensure appropriate remediation, the costs for remediation and difficulties likely to be encountered in requiring further remediation; 3.
Identification of any assistance, including funding assistance, that you believe is needed from NRC to complete the site file reviews, assessment and remediation activities. If you believe funding assistance is needed, we request your views on the funding mechanism or mechanism which should be considered to fund the QwI..t vy N w,A, g t' inQ mr
- SP-98-025 ' 1 activities'(e.g..' general fund appropriation request by NRC, amendment to Atomic Energy Act, as described in the SRM).
4.
Whether you believe the initial site surveys and assessments to determine the scope of potential remediaiton work at sites in your State are themselves so significantly expensive and difficult as to preclude you from undertaking even this
. preliminary step in the cleanup process, in the absence of funds or some other
~
form of resource assistance form NRC.
As a result of responses to All Agreement Stafes letter SP 97-080, Formerly Licensed Sites and 1
Jurisdcition for Remaining Residual Materials, we note.that several States have already provided specific information relating to portions of the above items and we will use and consider that information in development of our response to the Commission. We are also providing below additional information to assist in your efforts to determine the significance of the _" scoring" assigned by the Oak Ridge National Laboratory (ORNL) to each site, and expectations as to what actions would be required to close out particular types of sites with -
particular scores.
1.
The sianificance of the scorina: ORNL uses an expert system to evaluate the likelihood and possible magnitude of contamination at a site associated with a given license. The score assigned by the ORNL expert system does not indicate any absolute risk value.
Instead, the score provides a relative estimate of the likelihood and magnitude of
. contamination amor'g the licenses. The overall license site scores can be compared to provide prioritization guidelines for determining which licenses have the highest review priority. A detailed discussion of the License Evaluation & Document Information System (LEADIS) is presented in the enclosed paper entitled, "LEADIS - A Computer Decision System For Identifying Potentially Contaminated Nuclear Material Use Sites."
i 2.
NRC actions reauired to close out particular tvoes of eites with carticular scores:
l Temporary Instruction (TI) 2800/026, " Follow up Inspection of Formerly Licensed Sites identified as Potentially Contaminated," provides guidance to the Regions on how to close out license files identified by ORNL. We recommend that Agreement States follow guidance set out in this Tl, or equivalent guidance developed by the Agreement
' State. NRC staff is currently revising Tl 2800/026 to incorporate rr s specific guidance on dealing with specific types of sites and on interactions with Agraent States regarding transfer of bhckground information and licensing files for sites in an Agreement State. A copy of Tl 2800/026 is enclosed for your information.
This information request has been approved by OMB 3150-0029, expiration April 30,1998.
The estimated burden per response to comply with this voluntary collection request is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Forward any comments regarding the burden estimate to the information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC
'20555-0001, and to the Paperwork Reduction Project (3150-0052), Office of Management and Budget, Washington, DC 20503. If a document does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information."
)
p
- SP-98-025 1 If you have any questions regarding this correspondence, please contact me or the individual named below.
' POINT OF CONTACT:
Dennis M. Sollenberger TELEPHONE:
-(301) 415-2819 FAX:
(301) 415-3502 INTERNET:
DMS4@ NRC. GOV Paul H. Lohaus, Deputy Director Office of State Programs
Enclosures:
' As stated i
l i
5 1
r--
SP-98-025 If you have any questions regarding this correspondence, please contact me or the individual named below.-
POINT OF CONTACT:
Dennis M. Sollenberger TELEPHONE:
(301) 415-2819 FAX:
(301) 415-3502 INTERNET:
DMS4@ NRC. GOV Paul H. Lohaus, Deputy Director Office of State Programs 1
Enclosures:
As stated l
i Distribution:
DIR RF DCD (SP03)
SDroggitis PDR (YES4 Agreement State File i
DOCUMENT NAME: G:\\PHL\\SP98025.PHL Ta esceive a cop r of this document, Indicate in the box: 'C' = Copy without attachment / enclosure "E* = Copy with attachment / enclosure 'N' = No copy OFFICE OSP l
OSP:DD l
NMSS:DWM OSP:D l
l NAME PLohaus:nb/gd DSollenberger JGreeves RBangart DATE 03/ /99 03/ /99 03/ /99 03/ /99 OSP FILE CODE: SP-A-4 i
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5
COST ESTIMATE TABLE STATE ORNL>300 ORNL>100 but <300 Arizona 1
1 ($30K)
7 ($210)
Colorado 0
3 ($90K)
1 ($30K)
New York 2
2 ($60K)
Texas 0
1 ($30K)
Utah 0
1 ($30K)
Total by Col.
9 Costed 6 ($3,000K) 16 ($480K)
Grand Total
$3,480K
{
The assumptions for this table are:
)
1.
All sites found to have an ORNL score > 100 are included in the table with all being loose material sites except for one sealed source site in California.
I l
2.
On the average, each site with an ORNL score > 300 will cost $500K to remediate. NRC is aware that 4 of these sites have been confirmed to be contaminated and assumed that 2 additional sites will need remediation for a total of 6 sites costed at $500K. The 300 score was used since, according to Temporary Instruction 026, sites with scores greater than 300 were to be addressed first since they posed higher potential for radiation risk.
3.
It was assumed that, on the average, each site with an ORNL score > 100 and < 300 will cost $30K to survey and characterize to determine if remediation is necessary. Sites with scores between 100 and 300 have a slight potential and should be surveyed or assessed to determine if there is any real contamination at the site. S!tss with scores below 100 have little likelihood of contamination but should be reviewed to ensure that a justification for closing the file can be made, j
4.
Costs identified by various States in Attachment 2 are considered included in the cost estimates above.
t
q
)
L*-
' COST ESTIMATING INFORMATION.~
SP -
Information for the State of DATED:
I. Loose Material Sites Type of Action
- of Actions Cost per Action Total Cost I
File Reviews
.l Initial Site Surveys -
Site Characterization -
Site Remediation 1 s
Regulatory Oversigid for Site Char. & Remediation Other Costse.-
- ll. Sealed Source Sites j
' of Actions ;
Cost per Action Total Cost Type of Action -
File Reviews 1
Site Surveys Source Disposal Regulatory Oversight Notes:
1.
- Please fill out the above tables after reviewing the information in Attachment 2 to SECY-98-273.
- 2. -
The cost per action should be based on your State's experience in conducting similar actions if there is no current experience under the formerly licensed sites program.
3.
Where there is actual case specific experience, please attach the detailed cost breakdown so that your experience may be used to better estimate unknown costs.
- 4. ~-
Please provide any assumptions used in making a cost estimate so that we might be able to use
- similar assumptions for similar cost estimates.'
This information request has been approved by OMB 3150-0029, expiration 04/30/01. The estimated
- burden per response to comply with this voluntary collection request is 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (s). Forward any comments
~
regarding the burden estimate to the Information and Records Management Branch (T-6 F33), U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project.
_ (3150-0029), Office of Management and Budget, Washington, DC 20503. If a document does not display L a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information.
ENCLOSURE 3 I-
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