ML20236S072
| ML20236S072 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1998 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Conway J ENERGY, DEPT. OF |
| Shared Package | |
| ML20236S074 | List: |
| References | |
| NUDOCS 9807240111 | |
| Download: ML20236S072 (2) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 3
l j July 14, 1998 CHAIRMAN The Honorable John T. Conway, Chairman U.S. Defense Nuclear Facilities Safety Board 625 Indiana Avenue, NW, Jite 700 Washington, D.C. 20004
Dear Mr. Conway:
I am responding to your April 9,1998, request for data, reports, and information on extemal regulation of the U.S. Department of Energy's (DOE) defense nuclear facilities. The Nuclear Regulatory Commission (NRC) has focused on the potential for external regulation of non-defense program facilities. There are no present plans for the NRC to provide external regulation to Defense Prograrn (DP) facilities.
in order to accurately respond to Questions 1 and 2, DNFSB should provide an updated list of which DOE facilities the DNFSB considers defense facilities, along with a description of each facility's activities. Such a list wculd allow comparisons with existing facilities under the NRC's jurisdiction, and allow the estimation of direct and indirect costs to regulate each such facility type (Item 1, page 2). After receiving the lists as described, we will be pleased to respond to Questions 1 and 2.
Question 3 asked for the NRC's estimate of direct and indirect costs that would be incurred using the gaseous diffusion plants (GDPs) as a reference nuclear facility, if such a plant were subjected to: (a) full commercial licensing; (b) certification as compliant with NRC requirements; and (c) independent assessments with advisories and/or recommendations to DOE. This is a hypothetical question for wnich we have no direct experience. The review and certification of the GDPs were (ique and any extrapolation of the costs incurred has great uncertainty. Therefore, the following should be taken, at best, as an educated guess.
The estimates of the cost of transitioning the two GDPs at Paducah, Kentucky, and Portsmouth,
' Ohio, (as provided in the August 9,1996, letter from J. Dale Jackson, DOE, to Wdter S.
Schwink, NRC, ' enclosed) are:
Activitv S. thousands Application preparation 20,000 Compliance plan 8,000
)
NRC certification fee 7,200 f
Procedures and trainirg 4,000 I
..,,;G NRC Reporting System 250 10 CFR review and comment 185 Y
3 NRC Office modifications 170 l
Costs to bring the two plantr.,into compliance with existing DOE orders, standards, regulations and guidelines were excluded and were estimated to be about $200,000,000. The costs provided above, attributable to coming under NRC jurisdiction, are for Portsmouth and 9907240111 990714 5
CORRESPONDENCE PDR g
2 Paducah. The activity, "NRC certification fee," includes 12 full-time equivalents (FTEs) per year for four years including two resident inspectors at each site, and is for the initial certification of the Paducah and Portsmouth Plants. NRC believes this cost would be an upper limit for regulating non-DP facilities.
For the continuing oversight inspection and re-certification of the two plants, NRC is spending about 12 FTEs per year, including 2 resident inspectors at each site. This level of effort could be somewhat higher if NRC were to license the GDPs. Licensing of the GDPs could require about 3 or more FTEs in addition to those expended on the certification, to address environmentalissues and the learning process. Conversely, there may be some savings of resources in a licensing review since the technical issue resolution is better defined. The continuing oversight and inspection costs would remain the same. However, we have no estimate of the costs to backfit licensing requirements on the GDPs. Because of the uncertainty of costs in this area, and since the GDPs were already constructed and had operated for several decades, the certification option was chcan. If NRC were to just be an advisor making recommendations concerning the GDPs, the resources would be less and would be very dependent on the extent and complexity of any requested assistance.
In general, the costs for external regulation of a DOE facility will vary according to the regulatory mechanism applied and the means chosen to implement it. There are a variety of possible regulatory mechanisms that could be used to regulate DOE facilities includhg a specific license, a generallicense, a broadscope license, a Master Materials License, concurrence, orders, and certi'ication along the lines of the United States Enrichment Corporation (USEC) model. On the basis of NRC's experience and practice in applying these mechanisms to existing regulated facilities, NRC would implement these options in different ways, depending on the characteristics and risks associated with a DOE facility or activity under review. Since DOE's facilities and hazards differ widely, a "one site fits all" regulatory approach would not work. For example, broadscope licenses may be suitable for research facilities, and a specific liconse could be issued for spent fuel storage facilities. NRC and DOE are about to complete the first pilot project which has taken place at the Lawrence Berkeley National Laboratory (LBNL).
Among the preliminary findings are: there would be value added by NRC regulation of LBNL, the best regulatory mechanism would be through issuance of a broadscope materials license under 10 CFR Part 33, there would be cost savings to the tax payer, and NRC's costs would be about 0.6 FTE to transition to NRC regulation of LBNL and about 0.2 FTE per year thereafter.
NRC believes this represents the lower bound of NRC costs to regulate DOE non-DP nuclear facilities. Fu ther, NRC Anticipates backfitting requirements only where it is necessary to 1 nprove safety.
I trust this reply responds to your concerns.
Sincerely, Shirley Ann Jackson
Enclosure:
As stated