ML20211E793
| ML20211E793 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1999 |
| From: | NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| References | |
| SECY-99-193-ERR, SECY-99-193-R, NUDOCS 9908300118 | |
| Download: ML20211E793 (4) | |
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August 26,1999 CORRECT lON NOTICE 1
TO ALL HOLDERS OF SECY-99-193 - COST ESTIMATES FOR COMPLETION OF FORMERLY TERMINATED NRC LICENSED SITES PROGRAM PLEASE REPLACE PAGES 4 THROUGH 6 OF SECY-99-193 WITH THk ATTACHED REPLACEMENT PAGES. THESE CHANGES CORRECT THE TABLE ON PAGE 4 AND PROVIDE ADDITIONAL CORRECTIONS TO PAGE 6.
ATTACHMENT:
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l i-j The Commissioners l characterization and remediation at an average cost of $0.43M for a total of $1.7M. This would bring the total cost for remediating former sites to $4.3M. To date, for the sites within NRC jurisdiction that have been remediated, the current site owners or previous licensees have paid i
for the remediation costs for their respective sites. The regulatory oversight cost to complete clean up of the contaminated sites is estimated to be $0.1M for the Agreement States (See Attachment D). NRC regulatory oversight costs are not explicitly identified since NRC conducts this effort as part of its decommissioning program and does not separate out these resources.
Total Cost Estimate For the Formeriv Licensed Sites Proaram Staff has summarized the program costs for FY 2001-2002 in the table below. The costs for non-Agreement State activities are not included in the General Fund appropriation request discussed laterin this paper.
Agreement State Sites ($M)
Non-Agreement State Sites Total
($M)
($M) 0.9 FTE in FY 2001 $0.1M File review and initial 0.7 FTE in FY 2002 $0.1M survey
$0.6M 1.6 FTE
$0.2M
$0.8M Site characterization and remediation
$2.6M
$1.7M
$4.3M Regulatory oversight
$0.1M Work done through NRC
$0.1M decommissioning program l
Subtotal
$3.3M
$1.9M
$5.2M Administer grant 0.75 FTE in FY 2001 $0.1M program in 0.75 FTE in FY 2002 $0.1M Agreement States 1.5 FTE
$0.2M 0
$0.2M j
Grand Total
$3.5M
$1.9M
$5.4M Items 4,5,6, and 7: Pursuing a Separate General Fund Appropriation:
Stakeholder Views The staff in a Federal Reaister (FR) notice (64 FR 28014) requested stakeholders' views and comments on the use of a separate General Fund appropriation as well as information to assist in development of more accurate cost estimates. The staff also requested comments on the approach of administering the funds to the Agreement States through a grant program. In i
response to the FR notice, the staff received three responses: two from Agreement States (Illinois and Maine) and one from an industry group (Nuclear Energy Institute (NEI)). The comments and responses are presented in Attachment E.
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,a The Commissioners In summary, the commenters made the following major comments. Two commenters agreed with the proposal as 'the only fair and equitable method of dealing with these sites." The other j
commenter disagreed with the proposal mainly on the basis that the proposal is prospective and does not dea! with reimbursement of costs already incurred by the Agreement States that took the initiative to address and close former sites on their own. One commenter suggested that NRC use a phased approach to funding site activities. One commenter stated that the 25 mrem
/ year dose standard can be used as guidance, but it should not be the cleanup standard.
Licenses terminated under earlier standards should be evaluated against the standard in effect at the time of license termination.
Seoarate General Fund Appropriation The staff has prepared draft language (Attachment F) for appropriation of $1.65M from the General Fund for the purposes of funding the former sites program for FY 2001 through grants from the NRC. These funds are to be held until expended for the former sites program or retumed to the U.S. Treasury. The relationship of this request to the current budgeted resources is discussed in the Resource section of this paper. A similar appropriation would be included in the FY 2002 budget request.
Although staff has estimated the cost of cleaning up the sites located in non-Agreement States, the proposed legislative language found in Attachment F would only appropriate funds for the cleanup of Agreement State sites. Congress has not enacted (nor has the Commission sought) legislation which would authorize the NRC itself or an NRC contractor acting under the direction and on behalf of the NRC to remediate sites in non-Agreement States, in this paper, the staff i
does not set forth nor analyze the issues that would need to be considered before the Commission could propose legislation aimed at facilitating the cleanup of sites in non-Agreement States.
Grant Proaram Staff has outlined a grant program which entails three phases for allocation of funds:
(1) completion of the file reviews and initial site surveys to determine if there is any contamination requiring remediation, (2) characterization of the identified contaminated sites, and (3) remediation of contaminated sites. The first two phases would be administered based on the number of sites in a State and the State's labor rate and site specific cost for each site.
The funding for remediation would be issued based on a prioritization of the sites. Staff would j
propose that the Agreement States be given a specific time frame under which they could j
choose to participate in the funding program. This would enable staff to approve the three phases of the funding program. In particular, this would enable the awarding of the remediation funds with consideration of the risk ranking of the sites, if appropriated funds are not sufficient.
These phases are discussed in more detailin Attachment G. The grant program would be administered in accordance with Management Directive 11.6," Financial Assistance Program."
The detailed forms and implementing procedures for the grant program would be developed l
upon Commission W~ rl of this approach for the grant program and approval of funding by Congress. Grants would rn, w remediation efforts taking place after the enactment of the appropriation legislar...
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i The Commissioners RESOURCES:
Staff estimates that a total of $5.4M will be required to complete the formerly licensed sites program in Agreement and non-Agreement States over a 2-year period. Of this amount, $3.3M and 1.5 FTE ($0.2M) are required for Agreement States, and $1.7M and 1.6 FTE ($0.2M) are required for non-Agreement States.
NRC will request funding each year (FY 2001 and FY 2002) from the General Fund appropriation to support the grant program for Agreement States only. The additional staff effort (0.75 FTE each fiscal year)is not included as part of the General Fund appropriation request.
The FY 2001 budget request includes a planning wedge of $2M for funding assistance to Agreement States to complete the former sites program. The 0.5 FTE (0.25 for OSP and 0.25 for ADM) to administer the grant program was to be accomplished within current resources.
The same planning wedge assumptions ($2M and 0.25 FTE (OSP) and 0.25 FTE (ADM)) are also identified in FY 2002. After evaluating this program in more detail, staff believes the FTE needed in FY 2001 to implement all three phases will take a level of effort higher than originally anticipated. Staff estimates an FTE level of 0.75 FTE per yearinstead of 0.5, with the 0.25 increase being needed by OSP to administer the Agreement State portion of this program. This level of effort is slightly above the existing resources noted above.
Staffing resources for NRC to conduct file reviews and regulatory oversight activities for non-Agreement State sites are included in the current fee-based budget (0.9 FTE in FY 2001 and 0.7 FTE in FY 2002). Funds needed to facilitate the cleanup of sites in non-Agreement States ($1.7M) are not included in the budget and will not be requested as part of the General Fund appropriation.
FY 2001 FY 2002 PROGRAM
$M FTE
$M FTE Agreement State Former Sites (OSP, ADM) 1.65 0.75 1.65 0.75 Non-Agreement State Sites 0.9 0.7 Waste Management (NMSS)
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 for resource implications and has no 1
objections.