ML20211F537

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Discusses Concerns Re Proposed Funding Reduction in HR 2605 & Language Rept House Rept 106-253 Re Status of Activities for Consideration by House/Senate Conference Committee
ML20211F537
Person / Time
Issue date: 08/17/1999
From: Dicus G, The Chairman
NRC COMMISSION (OCM)
To: Bennett R, Burns C, Byrd R, Callahan S, Clyburn J, Cochran T, Craig L, Dorgan B, Edwards C, Frelinghusen R, Gorton S, Hollings E, Inouye D, Knollenberg J, Kohl H, Latham T, Matthew Mcconnell, Murray P, Pastor E, Rogers H, Stevens T
HOUSE OF REP., SENATE
References
NUDOCS 9908310005
Download: ML20211F537 (65)


Text

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August 17, 1999 CHAIRMAN The Honorable Thad Cochran United States Senate Washington, D.C. 20510

Dear Senator Cochran:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

1 i

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses j

Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potentialimpact on the very efforts being lauded by a number of stakeholders,

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including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and conpfete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel

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fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

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.With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested staksholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commksion plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report a!ao requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budp is submitted to

U 3

Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, e

e

- ea Joy Dicus

t I

UNITED STATES

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 r,

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August 17, 1999 1

CHAIRMAN I

The Honorable Slade Gorton United States Senate Washington, D.C. 20510

Dear Senator Gorton:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

.$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

U 2

With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with appropriate celiberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Govemment Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

u 3

Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations.. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely,'

M eta Joy Dicus

UNITED STATES

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NUCLEAR REGULATORY COMMISSION g

WASHINGTON. D.C. 2055tH)001 0

e August 17, 1999 CHAIRMAN The Honorable Mitch McConnell United States Senate Washington, D.C. 20510

Dear Senator McConnell:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself l

recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE i

compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

2 With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory l

requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures- (1) participation by all interested stakeholders; i

(2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Cong, ass to be updated at

)

appropriate intervals. The Commission is moving forward with appropriate deliberateness I

because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are j

examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-baseC organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

1 These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to 1

)

3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, ta Joy Dieus l

)

4 UNITED STATES g

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 e

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August 17, 1999 CHAIRMAN The Honorable Conrad Burns United States Senate Washington, D.C. 20510

Dear Senator Burns:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed i

rede-tion and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

2 With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules conceming these efforts to the Congres to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not a!! regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, 1

3-eta Joy icus J

4

/

UNITED STATES p*

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NUCLEAR REGULATORY COMMISSION g

WASHINGTON, D.C. 20655-0001 a.,

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August 17, 1999 CHAIRMAN The Honorable Robert F. Bennett United States Senate Washington, D.C. 20510

Dear Senator Bennett:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potentialimpact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that :nuch work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

2 With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to i

3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. Tha NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, e

4 eta Joy Dicus 1

r

/

UN ED STATES 3"

t NUCLEAR REGULATORY COMMISSION g

WASHINGTON. D.C. 20665-0001 e

k...../

August 17, 1999 CHAIRMAN The Honorable Larry E. Craig United States Senate Washington, D.C. 20510

Dear Senator Craig:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and ito potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, tr.e NRC's FY 2000 budget request accommodates a

{

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE j

compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been j

accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

I

2 With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety J

insights and operating experience, and to be more performance-based. The Committee would

]

direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches j

where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by encuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory I

requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commisson plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2005 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Govemment Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

m 4

s.

3 Congress; likewiso we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new ragulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move fonvard with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, wJ CAP Gida Joy Dicus O

l

[%

UNITED STATES p

4, NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20 % 5 0001 8

August 17, 1999

%, *.. *

  • p, CHAIRMAN The Honorable Robert C. Byrd United States Senate Washington, D.C. 20510

Dear Senator Byrd:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more j

efficient and effective regulatory process. However, I want to bring to your attention the j

Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language j

in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a numtier of stakehoHers, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

i To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

=

2 With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Comr.littee would direct the Cornmission to complete these efforts no later than December 31,2000, in addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using i

performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to i

)

r-3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding !evel of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you, Sincerely,

'ik Ecm f

n reta Joy Dieus

1

/

UNITED STATES f-

\\

e NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20t40001 e

O%

August 17, 1999 CHAIRMAN The Honorable Daniel K. Inouye United States Senate Washington, D.C. 20510

Dear Senator Inouye:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed redue"on and its potential impact on the very efforts being lauded by a numbe of stakeholders, j

including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, rear: tor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

q 2

With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC

)

activities, the House Committee supports the move to safety-focused, performance-based j

regulation, and notes that it is aware that the Commission has recently directed its staff to begin j

to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power t

reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and j

will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory j

requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress :o be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

c 3

Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic I

Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, h

O o

Greta Joy Dicus i

f UNITED STATES p*

q NUCLEAR REGULATORY COMMISSION g

WASHINGTON, D.C. 20%H001 e

\\..... p!

August 17, 1999 CHAIRMAN The Honorable Ernest F. Hollings United States Senate Washington, D.C. 20510

Dear Senator Hollings:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reductio:. and its potential impact on the very effcrts being lauded by a nurr.'.)er of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself

{

recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

j I

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such i

as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

e 2

With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000, in addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot

{

tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Comn.:ssion plans and schedules concerning these efforts to the Congress to :.,e updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

1 3

Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is cornmitted to I

providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our

)

regulatory operations. We are also working with our stakeholders to update the NRC Strategic

)

Plan to present the new performance goals and strategies that will be used to shift the NRC to

{

the new regulatory paradigm that the Commission has adopted.

i in summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, fth u%

Greta Joy Dicus l

)

[

UNITED STATES p-

\\

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 e

k**.,*/

August 17, 1999 CHAIRMAN The Honorable Herb Kohl United States Senate Washington, D.C. 20510

Dear Senator Kohl:

1 The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission bekeve are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

4 2

With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than Decgmber 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any 1

changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot

(

tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; l

however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance I

and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

l These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

c 3

Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

~ Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC cah move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely,

'at O. W Greta Joy Dicus

r _,

M j

UNITED STATES p*

\\

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 E

August 17, 1999 CHAIRMAN The Honorable Patty Murray United States Senate j

Washington, D.C. 20510 i

Dear Senator Murray:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potentialimpact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reforrn initiatives are realized. The Commission agrees, and it is for this reason that the Commir,sion respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in'a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

I i

n 2

With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious senedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with approPate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Perfermance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

. Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted, in summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, Y

eta Joy Dicus

e 6

UNITED STATES

  1. ,4 NUCLEAR REGULATORY COMMISSION g

WASHINGTON, D.C. 20555 4001 k

August 17, 1999 CHAIRMAN The Honorable Byron L. Dorgan United States Senate Washington, D.C. 20510

Dear Senator Dorgan:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduuion and ;ts potentialimpact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation, The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest

)

budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the

)

NRC's budget request at this time.

2 With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congres: to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency j

planning, budgeting, operations, and reporting, consistent with the Government Performance

]

and Results Act requirements. Products of this process include the NRC's strategic plan, pedormance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to l

3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

- Additionally, the Commission believes that to develop such a report at this time and within the

timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, S

- e cb Greta Joy Dicus

O

[

%g UNITED STATES NUCLEAR REGULATORY COMMISSION p

WASHINGTON, D.C. 20555-0001 e

...../

August 17, 1999 CHAIRMAN I

The Honorable Ted Stevens United States Senate Washington, D.C. 20510

Dear Senator Stevens:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives j

are realized. The Commission agrees, and it is for this reason that the Commission j

respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the impcrtant regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE

]

compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

o e.

2

- With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would i

direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and j

careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Govemment Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones j

and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to i

F..

,C e

3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Cor,gress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, Ab tch Greta Joy Dicus

o t'

%g f

UNITED STATES o

NUCLEAR REGULATORY COMMISSION p'

+

WASHINGTON, D.C. 20655-0001 5

E

%..... p' August 17, 1999 CHARMAN The Honorable Harold Rogers United State House of Representatives Washington, D.C, 20515

Dear Congressman Rogers:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomphshments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106 253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate I

the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by u number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, tr.e NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been j

accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

O O

2 With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these etforts no later than December 31,2000, in addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriato improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders';

(2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts,in lieu of establishing a firm date for completing these efforts as proposed in the House Repoit, we provide Commisc'on plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving fonvard with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using j

performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; I

however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to J

3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, A

] Muv>

(

Greta Joy Dicus t

[#

%g UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205W0001 5

August 17, 1999 CHARMAN 4

The Honorable Joe Knollenberg I

United States House of Representatives Washington, D.C. 20515

Dear Congressman Knollenberg:

j The FY 2000 Energy and Water Development Appropriations Billa (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

j i

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate l

the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a number of stakeholders,

{

including the Congress. We strongly believe this is a time for sustained support from Congress

)

as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives j

are realized. The Commission agrees, and it is for this reason that the Commission j

respectfully requests that you adopt S.1186 which funds the President's Budget request for our l

Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform

)

initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

o 2

With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are tcchnically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts,in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is muving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget rr.quirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

l 3

Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and 3.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

)

Sincerely, l

wht)

(

Gbta Joy Dicus J

0 UNITED STATES

[4 NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555-0001 e

k...../

August 17, 1999 CHAIRMAN The Honorable Rodney Frelinghuysen United States House of Representatives Washington, D.C. 20515

Dear Congressman Frelinghuysen:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potentialimpact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

4 2

With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technicalissues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts,in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Co gress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

1 The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the j

current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, o

Greta Joy Dieus i

l

)

i

UNITED STATES

\\

NUCLEAR REGULATORY COMMISSION g

WASHINGTON. D.C. 20655-0001 e

k...../

August 17, 1999 CHAIRMAN The Honorable Sonny Callahan United States House of Representatives Washington, D.C. 20515

Dear Congressman Callahan:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, j

1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reductice and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

2 With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would direct the Commission to complete these efforts no later than December 31,2000, in addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-l oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot s

tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly,

)

the Commission recommends that, given the magnitude of these efforts, in lieu of establishing

]

a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at apprcpriate intervals. The Commission is moving forward with appropriate deEberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and

)

require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

r i

)

l 3

Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the I

timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted, in summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, ich o

Greta Joy Dicus i

i l

.e UNITED STATES k

NUCLEAR REGULATORY COMMISSION p

WASHINGTON, D.C. 20555 4 001 e

August 17, 1999 CHAIRMAN The Honorable Tom Latham United States House of Representatives 3

Washington, D.C. 20515

{

J

Dear Congressman Latham:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports I

recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate 1

the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Exper.ses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

J

r 2

With respect to language in House Report 106-25'3 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commission has recently directed its staff to begin j

to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Comrnittee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technicalissues and highlighting areas for additional evaluation. There are also statutory

{

requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders;

'(2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, I

the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify najor milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

g -,

_x-w 3

Congress, likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, ib Geta Joy Dicus

t f

UNITED STATES p

y NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555-0001 O

E August 17, 1999 CHAIRMAN The Honorable Chet Edwards United States House of Representatives Washington, D.C. 20515 f

Dear Congressman Edwards:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the 1

Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language

)

in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses i

Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our l

Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE l

compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

I

2

)

With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulation, and notes that it is aware that the Commiscion has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based. The Committee would I

direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technicalissues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. TL efore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by all interested stakeholders; (2) sufficient time to ensure the revisions are tecnnically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Conress to be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-basei organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

)

e 3

Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the President's Budget and S.1186 funding level of

- $465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, e

s Greta Joy Dicus

r

((

k NUCLEAR REGULATORY COMMISSION UNITED STATES WASHINGTON. D.C. 20555-0001

~t o,

August 17, 1999 CHAIRMAN The Honorable James E. Clyburn United States House of Representatives Washington, D.C. 20515

Dear Congressman Clyburn:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Canate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed j

reduc %n and its potentialimpact on the very efforts being lauded by a number of stakeholders, l

including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the j

Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FIE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

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With respect to language in House Report 106-253 accompanying H.R. 2605 regarding NRC activities, the House Committee supports the move to safety-focused, performance-based regulaSon, and notes that it is aware that the Commission has recently directed its staff to begin to revise the regulations to change their scope and technical requirements based on safety insights and operating experience, and to be more performance-based.. The Committee would direct the Commission to complete these efforts no later than December 31,2000. In addition, the Committee would direct that by 2004, the Commission complete its review of existing power reactor regulations to eliminate those that are outdated and revise those that are paperwork-oriented to reduce unnecessary regulatory burden, using performance-based approaches where appropriate.

The Commission is committed to appropriate improvements to its power reactor regulations.

However, the complexity of the undertaking, the need to carefully ensure that we maintain safety, and the large number of interested stakeholders, will require numerous interactions and careful execution. The Commission believes that this stakeholder interaction has provided, and will continue to provide, a substantial benefit by ensuring a mutual understanding of safety and technical issues and highlighting areas for additional evaluation. There are also statutory requirements under the Administrative Procedures Act (APA) which we must follow for any changes to our requirements. Therefore, the Commission is developing plans and schedules to accomplish the tasks in a fashion which ensures: (1) participation by a!I interested stakeholders; (2) sufficient time to ensure the revisions are technically sound, and when appropriate, pilot tested; and (3) proceeding on an expeditious schedule consistent with the APA. Accordingly, the Commission recommends that, given the magnitude of these efforts, in lieu of establishing a firm date for completing these efforts as proposed in the House Report, we provide Commission plans and schedules concerning these efforts to the Congress *o be updated at appropriate intervals. The Commission is moving forward with appropriate deliberateness because not all regulations can be made performance-based. We are committed to using performance-based, risk-informed efforts in regulation to achieve necessary efficiencies; however, we are committed, first and foremost, to maintaining plant safety. These efforts are examples of activities that must be accomplished to improve our regulatory program and require adequate resources to complete.

The H.R. 2605 report also requests a five-year plan as part of the FY 2001 budget request.

The plan is to include detailed staffing and organizational analysis, and corresponding budget

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requirements for FY 2001 through FY 2005. The Commission is in the process of transitioning to a more outcome and performance-based organization through the implementation of a disciplined Planning, Budgeting, and Performance Management process. This process was implemented with the FY 2000 budget cycle and supports an integrated approach to agency planning, budgeting, operations, and reporting, consistent with the Government Performance j

and Results Act requirements. Products of this process include the NRC's strategic plan, performance plan, budget, performance report, and assessments of progress toward our goals.

These products establish the strategic direction for the agency and identify major milestones and other details for the Congress to evaluate the Commission's resource needs. Given the current uncertainties associated with many of its regulatory initiatives, the Commission believes that it is premature to make detailed organizational and staffing projections through FY 2005.

i For example, we have begun a pilot of our new reactor oversight process, but this pilot will not be completed until the Summer 2000, which is after the FY 2001 budget is submitted to

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3 Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

i in summary, we request your support of the President's Budget and S.1186 funding level of

$465.4 million for the Salaries and Expenses Appropriation so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, d.ro rata Joy Dicus

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 E

o k..... p August 17, 1999 CHAIRMAN The Honorable Ed Pastor United States House of Representatives Washington, D.C. 20515

Dear Congressman Pastor:

The FY 2000 Energy and Water Development Appropriations Bills (S.1186 and H.R. 2605) were passed by the Senate and House of Representatives on June 16,1999, and July 27, 1999, respectively. The Commission appreciates the Senate and House Committees' reports recognizing the accomplishments of the Commission and its staff in moving toward a more efficient and effective regulatory process. However, I want to bring to your attention the Commission's concerns regarding the proposed funding reductions in H.R. 2605 and language in its accompanying report (House Report 106-253) regarding the status of NRC activities for consideration by the House / Senate Conference Committee.

With regard to specific funding provisions, the Senate passed bill (S.1186) would appropriate the $465.4 million requested in the President's Budget for the NRC's Salaries and Expenses Appropriation. The House passed bill (H.R. 2605) would reduce our Salaries and Expenses Appropriation by $10 million. The Commission is deeply concerned about the proposed reduction and its potential impact on the very efforts being lauded by a number of stakeholders, including the Congress. We strongly believe this is a time for sustained support from Congress as the NRC moves aggressively forward to implement important regulatory changes that the Congress, our stakeholders, and the Commission believe are needed. H.R. 2605 itself recognizes that much work remains to be done before the benefits of these reform initiatives are realized. The Commission agrees, and it is for this reason that the Commission respectfully requests that you adopt S.1186 which funds the President's Budget request for our Salaries and Expenses Appropriation. The NRC's full funding request for FY 2000 is essential if we are to continue, and complete in a timely manner, the important regulatory reform initiatives that we have underway.

To place our funding request in context, the NRC's FY 2000 budget request accommodates a

$12 million increase for government-wide pay raises, without an increase above our FY 1999 appropriation. Thus, the buying power of our funding request is already reduced compared to FY 1999. Even at this level, the NRC budget, when adjusted for inflation, represents the lowest budget request in the history of the agency. Our budget request reduces staff by 77 FTE compared to FY 1999 and 173 FTE compared to FY 1998. These reductions have been accomplished while the Commission is accommodating an increasing workload in areas such as reactor license renewal, reactor license transfers, and review of mixed oxide (MOX) fuel fabrication and use, while at the same time implementing major reforms to the NRC regulatory programs and continuing efforts to improve efficiencies in our own processes. The Commission believes it is premature and detrimental to future progress in regulatory reform to reduce the NRC's budget request at this time.

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Congress; likewise we are just beginning our major efforts to risk-inform our reactor regulations.

Additionally, the Commission believes that to develop such a report at this time and within the timeframe requested would be duplicative of its current efforts. The NRC is committed to providing the appropriate detail, analysis, and budget requirements, and will continue to focus

- on identifying opportunities for improvements in the effectiveness and efficiency of our regulatory operations. We are also working with our stakeholders to update the NRC Strategic Plan to present the new performance goals and strategies that will be used to shift the NRC to the new regulatory paradigm that the Commission has adopted.

In summary, we request your support of the Presidenis Budget and S.1186 funding level of

$465.4 million for the Safaries and Expenses Approprianon so that the NRC can move forward with the major regulatory reform initiatives that the Congress, stakeholders, and the NRC believe are needed. We also request your support for changes of the report language to recognize the current status of activities at the NRC. I would be pleased to discuss these issues with you.

Sincerely, akc~

tcd ta Joy Dicus

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O ADDRESEES The Honorable Thad Cochran United States Senate Washington, D.C. 20510 The Honorable Slade Gorton United States Senate Washington, D.C. 20510 The Honorable Mitch McConnell United States Senate Washington, D.C. 20510 The Honorable Conrad Burns United States Senate Washington, D.C. 20510 The Honorable Robert F. Bennett United States Senate Washington, D.C. 20510 The Honorable Larry E. Craig United States Senate i

Washington, D.C. 20510 The Honorable Robert C. Byrd United States Senate Washington, D.C. 20510 The Honorable Daniel K. Inouye United States Senate Washington, D.C. 20510 The Honorable Ernest F. Hollings United States Senate Washington, D.C. 20510 The Honorable Herb Kohl United States Senate Washington, D.C. 20510 The Honorable Patty Murray United States Senate Washington, D.C. 20510 The Honorable Byron L. Dorgan United States Senate Washington, D.C. 20510 l

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i The Honorable Ted Stevens I

United States Senate Washington, D.C. 20510 The Honorable Harold Rogers United State House of Representatives i

Washington, D.C. 20515 j

I The Honorable Joe Knollenberg United States House of Representatives j

Washington, D.C. 20515 The Honorable Rodney Frelinghuysen United States House of Representatives Washington, D.C. 20515 The Honorable Sonny Callahan United States House of Representatives 1

Washington, D.C. 20515 The Honorable Tom Latham United States House of Representatives Washington, D.C. 20515 The Honorable Chet Edwards United States House of Representatives Washington, D.C. 20515 The Honorable James E. Clyburn United States House of Representatives Washington, D.C. 20515 The Honorable Ed Pastor United States House of Representatives Washington, D.C. 20515 i

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