ML20249C365

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Statement of SA Jackson,Chairman of Nrc,Before Subcommittee on Energy & Power,Committee on Commerce Us House of Representatives on Status of NRC Pilot Program on External Regulation of Doe
ML20249C365
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Issue date: 05/20/1998
From: Shirley Ann Jackson, The Chairman
NRC COMMISSION (OCM)
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NUDOCS 9806290119
Download: ML20249C365 (19)


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STATEMENT OF SHIRLEY ANN JACKSON Chairman U.S. Nuclear Regulatory Commission Before the 1

l SUBCOMMITTEE ON ENERGY AND POWER Committee on Commerce U.S. HOUSE OF REPRESENTATIVES ON STATUS OF THE NUCLEAR REGULATORY COMMISSION l-PILOT PROGRAM ON THE EXTERNAL REGULATION

.OF THE DEPARTMENT OF ENERGY l

Submitted: MAY 20,1998 E'*IS$" EE

Hearing on Oversight of the Department of Energy Mr. Chairman, Members of the Subcommittee, I am pleased to appear before you today to discuss the status of the pilot program for external regulation of certain Department of Energy (DOE) faci:ities.

In December 1996, based on a study by the DOE Working Group on External Regulation and the recommendations of the Advisory Committee on External Regulation of DOE Nuclear Safety, the Secretary of Energy announced that the Administration would introduce legislation in fiscal year (FY) 1999 to give the Nuclear Regulatory Commission (NRC) responsibility for regulating nuclear safety at certain DOE facilities, to be phased in over a 10-year period. After considering the DOE announcement, as well as public comments received on this topic during the NRC Strategic Assessment and Rebaselining Initiative, the Commission endorsed the NRC oversight of DOE facilities, to include nuclear safety and radiation protection, contingent upon its being given adequate resources and a clear delineation of its authority.

Both the Advisory Committee and the Working Group concluded that the transition to NRC regulation would involve significant legal, financial, technical and procedural adjustments for both agencies. The Working Group recommended that the NRC be the regulator of DOE nuclear facilities, with a phase-out of the Defense Nuclear Facilities Safety Board; that the transition to external regulation be accomplished over a 10-year period, beginning after a 2-year legislation development phase; that within the first five years of the transition, all Nuclear Energy and Energy Research facilities would be transferred to external regulation; that within 10 years all Environmental Management nuclear facilities would be externally regulated; and that Defense Program facilities be placed under NRC regulation at the end of the 10 years.

However, given the wide variability in facility types and hazards, the Working Group recognized that the "one-size-fits-all" approach to regulation would not work, and did not attempt to outline fully the structure or method of external regulation. Thus, in early 1997, there were gaps in information and analyses on how external regulation would be implemented. Open issues included questions as to: (1) whether a facility would be licensed or certified; (2) who would be 2

the regulated entity (the DOE and/or the contractor); (3) what rulemakings would be required; a'nd (4) what resources would be needed.

In addition, it should be noted that the NRC already regulates, among other ertivities, the fabrication of Navy nuclear fuels, the stabilization of Title I uranium mill tailings, and the long-term storage and disposal of certain radioactive wastes (see Table A for a complete list). All of the current situations in which the NRC is regulating DOE facilities have been developed in a piecemeal fashion over a number of years, and none have looked at the whole of the DOE to i

identify all of the contributing issues prior to assuming regulatory authority. Thus, it was not evident that the experience base of current NRC oversight of DOE activities wahrepresentative of the entire DOE complex. In part for this reason, DOE Secretary Pe6a and I, representing the Commission, agreed to pursue the NRC regulation of certain DOE nuclear facilities on a pilot program basis. The pi!ot program was established in a Memorandum 'of Understanding (MOU) effective November 21,1997, to provide a comprehensive framework to support legislation for the external regulation of certain DOE nuclear facilities or classes of facilities.

The Pilot Program Purpose The purpose of the pilot program is to gather quantitative and qualitative information on external regulation, to provide a basis on which the NRC and the DOE can determine whether to seek legislation (and what kind of legislation would be needed) for a transition to external regulation. The pilot program is testing regulatory concepts at certain DOE nuclear facilities, through simulated regulation, by evaluating a facility and its standards, requirements, procedures, practices, and activities against the standards that the NRC believes would be appropriate to ensure safety at that facility.

Pilot Program Objectives The November 1997 MOU details the specific objectives associated with the pilot 3

program, including the following:

Determine the value added by the NRC regulatory oversight of activities at a pilot I

set of DOE nuclear facilities.

l Test regulatory approaches that could be used by the NRC in overseeing 1-l activities at a pilot set of DOE nuclear facilities (e.g., licensing, certification).

Determine the status of a set of DOE pilot facilities with respect to meeting existing NRC requirements, or acceptable alternatives, and identify any significant safety issues.

Determine the costs (to the DOE and the NRC) related to NRC regulation of the pilot facilities and other DOE facilities that might be in a similar class and condition.

Evaluate alternative regulatory relationships among the NRC, the DOE and DOE contractors at the pilot facilities. Identify DOE contract changes that would be needed to provide for NRC oversight of contractor operatiens.

L identify issues and solutions associated with a transition to NRC oversight of

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DOE nuclear facilities.

Identify legislative and regulatory changes necessary or appropriate to provide for NRC regulatory oversight of DOE nuclear facilities.

l' Evaluate how stakeholder should be involved if the NRC assumes broad external regulatory authority over DOE nuclear facilities.

The DOE proposed Lawrence Berkeley National Laboratory (LBNL) as the first pilot

. project. The NRC accepted this proposal because the laboratory is similar to current NRC licensees, so that the pilot program methodology could be developed and tested m 4

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the field without encountering more complex and controversial issues that might exist at other DOE facilities. The FY 1999 pilot program willinvolve more challenging and complex facilities to broaden the overall NRC understanding of the complexities and ramifications of regulating DOE nuclear facilities. The NRC understands that the DOE will include a non-power reactor in the FY 1999 pilot program. There is agreement between the NRC and the DOE not to include Defense Program facilities in the pilot program. Finally, the NRC and the DOE believe that facilities that will be deactivated and/or decommissioned within the 10 years should not be included in the pilot program, because the long term cost of compliance with NRC requirements in the interim period before deactivation would exceed the short-term benefits of NRC extern'ai regulation.

This is consistent with the DOE Working Group recommendation that such facilities should not be regulated by the NRC.

A major goal of the pilot program is to develop a clear understanding of the NRC resource implications for regulating DOE facilities. Lack of adequate Congressional appropriation for this activity would unacceptably impact the existing NRC core mission.

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i Status of Pilot Program First Pilot Project - Lawrence Berkeley National Laboratory (LBNL) l The first pilot project began in the Fall of 1997 at Lawrence Berkeley National l

Laboratory (LBNL). NRC staff conducted " simulated regulation" at LBNL through developing a mock license and performing typical NRC inspection activities. The license developed was typical of that of an NRC-licensed major research and development center such as the National Institutes of Health (NIH) or the University of Missouri (a 10 CFR Part 33 broad-scope license in NRC terminology). The inspection against NRC regulatory criteria showed the current radiation safety program at LBNL to be acceptable, with some minor exceptions. The cost of NRC regulation of LBNL likely would be the same as that for a similar very large facility (like the NIH).

Separate meetings were held to discuss the policy issues identified above (e.g., the 5

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I form of the license or certificate, whom to license). Meetings were also held in Berkeley, I

California with members of the public to obtain their views on external regulation of LBNL. A draft of the final LBNL report has been completed and is being reviewed by DOE and NRC management. Once approved by senior DOE and NRC officials, it will be sent to your subcommittee and other appropriate Congressional oversight committees.

j Second Pilot Project - Radiochemical Engineering Development Center (REDC)

The second pilot project, at the Radiochemical Engineering DevelopmentCenter (REDC) at Oak Ridge National Laboratory (ORNL), began in February 1998. Meetings similar to those held at LBNL were held at REDC; however, due to the more complex nature of ORNL, an additional site visit will be required to examine the extent to which conclusions based on the REDC pilot project can be extrapolated to the remainder of ORNL, other DOE Energy Research laboratories, or Nuclear Energy facilities. The site j

work is anticipated to be complete in June 1998.

4 Preliminary inspection results indicate that REDC appaars to be licensable and is close to completing an integrated safety management system. Certain NRC regulations, such as 10 CFR Parts 70,73, and 74, may have to be changed to reflect the quantities of certain radionuclides in use at this facility.

Since the REDC is only a small facility within the larger ORNL site, the last site visit will cover the entire ORNL site in order to determine the extent to which REDC is representative of other ORNL facilities.

Potential Benefits of External Regulation As stated in the MOU, "an external regulator, free of the responsibility for DOE's missions, and not answering to DOE, can ensure that safety receives consistent and adequate attention.

External regulation would also ensure more effective enforcement by placing such authority in I

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I-independent hands engaged only in achievement of safety. Taken together, the move to e'xternal regulation is seen as the best way to ensure the safety of DOE nuclear facilities, protect the safety and health of workers across the DOE complex, and build public trust."

l Specific benefits of external regulation identified to date, include:

More effective and consistent safety management: Clear regulations, roles, and lines of accountability, plus well established mechanisms for inspection and enforcement, will promote more effective management of the safety programs and more efficient

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utilization of safety resources.

Enhanced competitiveness: Uniform safety standards that apply across both DOE and non-DOE laboratories will remove artificial barriers to scientific ' collaboration.

A strengthened partnership between the DOE and the laboratory contractor: With safety oversight handled completely by an external regulator, the relationship between the laboratory contractor and the DOE will focus on mission development and execution.

The DOE will no longer face the conflict-of-interest dilemma of providing safety oversight to its own operations.

Increased credibility and public confidence: Independent oversight by the same agencies that regulate the civilian nuclear industry will reduce the perception of conflict ofinterest between mission and safety. Public perception of safety management at DOE facilities will be enhanced through the open public processes of the NRC.

Cost savings to the taxpayer: The DOE facilities could realize efficiencies in more l

clearly defined roles and responsibilities with a single regulator for each function, minimizing ~ overlapping and conflicting requirements.

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H With regard to the cost of backfitting NRC regulation to DOE existing facilities, based on our experience at the Gaseous Diffusion Plants, it appears that the major costs will be associated with old facilities coming into compliance with DOE orders, requirements, 7

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and regulations. For example, DOE Oak Ridge Operations Office has estimated that the cost to certify the two Gaseous Diffusion Plants to be about $40 milliori with an additional $200 r:Jilion required to come into compliance with existing DOE requirements. On the other hand, thus far during the piiot program, we have not identified facility upgrades that would entail significant costs. Further, we do not foresee significant regulatoy costs for new facilities that would receive regulatory scrutiny from the outset.

Major issues The major issues identified in the pilot program to date are discussed in this section. The pilot program experience provides great insights and depth in understanalng the implementation of these issues, many of which were identified by the DOE Working Group Who Would Be the Regulator?

Potentio. external regulators of radiation are the NRC, individual Agreement btates, and OSHA. The scope and types of activities involving the use of radioactive materials at many DOE facilities are very similar to activities at civilian facilities regulated by the NRC and Agreement States. A number of DOE activities already are belng regulated by the NRC. However, there are other DOE facilities that differ significantly from facilities externally regulated under the Atomic Energy Act (AEA).

The NRC currently is responsible for regulating nucleer safety and radiation protection associated with nuclear reactors and AEA materials, which include source, special nuclear, and byproduct materials, except for those within the DOE complex. However, under the Agreement States program, the NRC has relinquished its regulatory authority to to.uw the Agreement States to regulate most non-Federal uses of source, byproduct, I

and small quantities of specia! nuclear materials. As a result of sovereign immunity, State regulations generally do not apply to activities at Federal facilities. For example, the NRC has retained responsibility for regulating radiation protection at Federal 8

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I facilities in Agreement States, such as tne Department of Veterans Affairs hospitals and the non-weapons facilities of the Department of Defense. If subjected to external regulation under the AEA, the DOE, as a Federal agency, normally would be regulated by the NRC.

l The issue of the NRC/ OSHA responsibilities and ints-face is being examined in the pilot program of extemal regulation. (At commercial reactor facilities, NRC/ OSHA interactions are guided by a Memorandum of Understanding between the two agencies.)

Who Would Be the Licensee?

i This generalissue of who should be named in the license currently is being considered in several different contexts by the NRC (i.e., in the current lice'nsing actions concerning independent spent fuel storage installations owned by the DOE, in the exteinal regulation of the DOE pilot program, and in the retctor regulation program where the issue of non-owning operators is being analyzed). Typically, the NRC licenses the entity that owns the facilities and materials, which is usually the entity carrying out licensed activities. For example, the DOE owns the facilities and materials at LBNL and leases the land from the University of California, the land owner. However, since DOE facilities and hazards differ widely across the DOS complex, it may be that a "one-size-fits-all"

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regulatory approach would not work. Any potentiallegislative authority would need to be flexible, to permit different regulatory approacnes for different situations. The NRC is now examining four possible models for externally regulating DOE nucisar facilities:

l A DOE-only license j

A DOE contractor-only license Ajoint DOE / DOE con'ractor license 1

Individuallicenses to DOE and to its contractor l

Policy discussions are focused on structuring a regulatory relationship that avoids adding an NRC layer to the existing DOci oversight of its contractors.

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Regulation of Naturally Occurring and Accelerator Produced Radioactive Material (NARM)

Regulatory jurisdiction over accelerators, accelerator-produced isotopes, and other electronic sources of radiation is not assigned to the NRC by the AEA. The States now have jurisdiction over non-DOE accelerators and NARM at non-Federal facilities. All NRC activities and responsibilities have a link to the neutron chain reaction. Seeking jurisdiction over DOE accelerators and NARM would be a significant extension o! WRC authority and activities,' but would allow a single external regulator and a unified regulatory approach for all sources of ionizing radiation at DOE facilities.' Such an extens!on could be accomplished effectively through changes to the NRC regulatory framework and in cooperation with State radiation protection agencies, which have substantial experience regulating civilian accelerators.

5 Decommissioning i

NRC regulations (e.g.,10 CFR 30.36) describe the conditions under which

- decommissioning must begin at a licensed commercial facility. Under the NRC timeliness rule, for example, if no principal activities have beer? conducted in a building or separate outdoor area for 24 months and if residual radioactivity is present th t precludes the release of the facility for unrestricted use, then the licensee must, within 60 days, inform the NRC in writing that the principal activities have ceased, in addition, the licensee is required either; (1) to begin decommissioning the facility and complete it within 24 months, or (2) to submit a decommissioning plan to the NRC within 12 months and to begin decommissioning in accordance with the plan once it is approved by the ERC. The DOE deactivates and decommission its facilities on the basis of safety concerns, mission priorities, and funding availability, but not on the besis of a timeliness requirement. This issue may neeo to be addressed in NRC rulemaking. The issue as to I

what entity should oversee the decommissioning of DOE nuclear facilities (the DOE or the extemal regulator) may need to be addressed in legislation on extemal regulation of DOE. As you are aware, the NRC promulgated an all-pathways cleanup standard for its l

licensees in July 1997. The NRC ru!e could serve as a basis for applying cleanup 10 1

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standards to DOE facilities.

Legacy Material There are four components of the legacy of the DOE and its predecessors' activities since 1946. These components are stored waste, contaminated environmental media, surplus facilities, and materials in inventory. In 1989, the Secretary of Energy created the Office of Environmental Re 4toration and Waste Management (later renamed the Office of Environmental Management) to consolidate into a single DOE program office the budgets and staff that are devoted to similar environr' antal tasks. Tite Office of Environmental Management, through the many DOE field and operations offices, is acting to mitigate the risks and hazards posed by this legacy. According to the DOE, essentially all of the identified legacy waste and environmental' damage situations have been or are being addressed under the provisions of Fedoct! and State law, including the Federal Facility Compliance Act and the agreements made pursuant thereto if the NRC were to regulate DOE act'!ities, the enabling legislation may have to address these legacy issues in order to avoid unooing existing agreements.

Conflict ofInterest A potentially serious issue and one raised by the stakeholder is the possibility of an organizational conflict of interest when a DOE laboratory performs work for the NRC.

The Commission has directed the NRC staff to utilize other sources of expertise to perform technical analyses. The NRC has taken this direction in order to ameliorate any potential organizational conflict of interest. However, DOE laboratories are major contractors to the NRC for confirmatory research and a source of experts who serve on advisory boards such as the Advisory Committee on Reactor Safeguards. To determine the availability of commercial contractors and universities as potential alternate sources when organizational conflict of interest issues exist for work related to regulating the DOE or its contractors, the NRC is c,onducting a source assessment in parallel with the pilot program for regulation of DOE facilities to assess fully the availability of resources to perform NRC work. Given the limited scope of DOE activities currently licensed by 11

the NRC, the staff has concluded that the use of a dedicated Federally Funded Research and Development Center offers the best prospect for avoiding the conflict of interest issues inherent in the NRC regulation of DOE activities, and would ensure the availability of needed expertise on a long-term basis. However, if the scope of DOE activities licensed by the NRC is expanded significantly, the staff has concluded that legislative changes likely would be needed. In the absence of legislation, the staff has also concluded that long-term solutions other than a new or expanded Federally Funded Research and Development Center will be needed for facilities (e.g., large hot cells) that cannot realistically be replaced. The pilot program for regulation of DOE facilities, in conjunction with the survey descr! bed above will provide a clearer unders'tanding of the need for recommending either specific legislation, or other actions that should be taken by the Commission.

Civil Penalties Enforcement mechanisms for existing NRC licensees include: notices of violations; orders that can amend, uuspend, or revoke a license, or direct that an individual be barred from participating in licensed activities; civil penalties 6d'u ined by Section 234 of the AEA); and referral to the Department of Justice for crimunal prosecution under Sections 222 and 223 of the AEA, among other statutory provisions. The use of such mechanisms is intended to deter violations, to emphasin the importance of compliance with duty established requirements, and to encourage prompt identification and comprehensive correction of violations.

The NRC has a history of successful enforcement against other Federal agencies, including the imposition of civil penalties. From the viewpoint of the overall U.S. budget, a civil penalty imposed by the NRC on a Federal agency may appear to be only a transfer of money from one Government account to another. However, from the viewpoint of the Federallicensee, the civil penalty is a transfer out of some account of the Federallicensee, a transfer that must be compensated for either by increased appropriations or by work foregone. In either case, the effect of the penalty on the Federallicensee is very much the same as the effect of a similar penalty on a private 12 l

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l li,censee. The pilot program is examining the issues of enforcement mechanisms i

against the DOE and/or its contractors.

Fees Any approach implemented by the NRC for funding external regulation of the DOE would need to be structured so that current NRC licensees do not pay for the regulation of DOE facilities. The Omnibus Budget and Reconciliation Act of 1990 (OBRA-90), as amended, requires that, for FY 1991 through FY 1998, the NRC recover approximately

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100 percent of its budget authority through the assessment of fees, less the amount appropriated from the DOE-administered Nuclear Waste Fund. The FY 1999 President's budget proposes extending this requirement through FY 2003. To ensure that the current NRC licensees would not be paying for the N.N pilot program on external regulation of the DOE, the NRC received FY 1997 fundina through reimbursements from the DOE.

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Since the NRC is required to request appropriations directly from the Congress for l

i activities in support of NRC statutory responsibilities, continued funding through reimbursable agreements would not be acceptable. For NRC FY 1998 activities in support of the pilot program on extemal regulation of DOE, the Congress appropriated funds directly to the NRC which are excluded in NRC appropriation legislation from license fee recovery. Similar funding is proposed in the FY 1999 President's Budget.

l For the longer-term, it may be more desirable for the Congress to appropriate funds for the NRC regulation of DOE facilities which are subject to fee recoverv. This approach is l

consistent wRh how NRC mission responsibilities are funded. However, to ensure that current NRC licensees would not pay for these activities, legislation would be required to authorize the NRC to recover the costs from the DOE. Under current law, the NRC may not assess fees for services to another Federal agency such as the DOE. Further i

evaluation of this funding method is needed.

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Tasks Remaining During the remainder of FY 1998, the NRC will continue the pilot program by adding the 1

Receiving Basin for Offsite Fuel (RBOF) at the Savannah River Site (SRS). The NRC currently is working with the DOE to identify sites of increased complexity that would be included in the l

FY 1999 pilot program. The DOE has been asked to propose potential sites to enable the NRC l

to choose the mix of facilities that will provide the broadest overview of DOE facilities.

I Areas of Discussion between the NRC and the DOE

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The timing for proposing legislation giving the NRC regulatory responsibility for certain DOE nuclear facilities is still under discussion. The MOU calls f,or a 2-year pilot program of simulated rege'ation of a set of DOE facilities, followed by a r'eport to the Secretary of Energy and the Commission on the advantages and disadvantages of the NRC regulating DOE nuclear facilitics, based on the pilot program, if the Secretary and the Commission determine that some or all DOE non-defense nuclear facilities should be regulated by the NRC, draft legislation would be prepared giving the NRC such authority, in the November 21,1997 letter transmitting the signed MOU to the DOE, the Commission suggested that revisions to the MOU be made at the conclusion of the first pilot project. Under the revised MOU, if the DOE and the NRC agreed, legislation would be prepared and submitted promptly for Congressional consideration to give the NRC regulatory authority for a specific pilot facility or class of facilities. The NRC currently is drafting a revision to the MOU, hopefully to proceed along this line.

Costs i

An estimate of NRC costs incurred from October 1997 through March 1998 is $318,000 for staff l

review time, $32,000 for travel, and $600 for contractor support activities. The NRC budget for I

pilot program oversight of the Department of Energy is $1 million each for FY 1998 and 1999.

' NRC expects these amounts to be adequate to support the remaining pilot program activities in FY 1998, and to support three additional pilot projects in FY 1999.

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i Conclusions Based on the results of the pilot facilities thus far, the NRC sees no insurmountable obstacles to l

regulating Energy fsesearch facilities and stands ready to work with the DOE and the Congress to draft legislation to regulate them, contingent upon the NRC being given adequate resources and a clear delineation of its authority.

This concludes the NRC testimony. I would be pleased to answer any questions.

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Table A, Existing Regulatory Relationships between NRC and DOE

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Facility / Activity Nature of Legal Basis issues Oversight l-Uranium Mill Ta lings l

- Title I site Review, concur on UMTRCA Law requires completion of (Remedial action remedial action surface reclamation by sites) plan and license 9/30/98. DOE not making DOE forlong term timely submissions.

care

- Title 11 site After termination of UMTRCA none 1

(Active sites) commerciallicense, DOE becomes the generallicensee High Level Waste relicensing Energy Reorg.

Resolution of key tech.

Repository consultation; Act 1974, Section issues at Yucca Mnt.

license 202, NWPA HLW standards for Yucca l

Commission views on i

viability assessment Independent Spent Fuel Storage Facilities

- Fort St. Vrain License Energy Reorg, none l

Act 1974, Section 202

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- TMl-2 Spent Fuel Potential License Energy Reorg.

none s

- Debris -

Act 1974, Section 202 Naval Reactors

- Cores Review Economy Act rone

- Transport / Packages Certify Economy Act none Fuel Fabrication

- Nuclear Fuels' License AEA (AEC Authorization of new fuel by 4

Service.

Regulatory Nov. 98 Decision)

Renewal of License in FY98

- Babcock and Wilcox License Technologies 16 L

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Table A. Existing Regulatory Relationships between NRC and DOE, continued Facility / Activity Nature of Legal Basis issues Oversight Gaseous Diffusion Certification AEA, Energy Backfit to meet seismic Plants Policy Act of design c-iteria 1992, USEC SAR upgrade Privatization Act USEC Privatization of 1996 Non-site specific Review Energy report is non-site specific centralinterim storage Reorganization facility topical report Act of 1974, (SNF)

Section 202 DOE dry transfer-Review Energy Par' of the centralinterim system topical report Reorganizcf.an stor ge facility Act of 1974, Section 202 l

DOE bumup credit Review Energy none l

topical report Reorganization Act of 1974, Section 202 DOE Transpodation Review, certify AEA, HMTSA none Packages (3l)

West Valley Develop D&D WVDP Act,1980 Criteria for D&D Demonstration Project criteria, review, Reinstatement of license for i

consult; State after completion WIPP Transportation Review and certify WIPP Land none packages Withdrawal Act of 1992 Test of Tritium Review; issue AEA Possible package review Production in ~

conforming license Legislative framework Commercial Reactors amendments 17 l

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Table A. Existing Regulatory Relationships between NRC and DOE, continued Facility / Activity Nature of Legal Basis issues Oversight Greater than Class C License Low-Level Rad Storage until disposal Waste Disposal Waste Policy Timely availability of Amendments Act disposal capacity of 1985 Cost of disposal Impact on reactor decommissioning Foreign Research Review AEA Public concern about Reactor Spent Fuel transportation l

Shipments / Package l

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4 Table B. Potential Regulatory Relationship Between NRC and DOE Facility / Activity Nature of Legal Basis issues Oversight MOX Fuel Fabrication Relicensing Economy Act, Legislative framework Consultation,.

AEA Need to update Part 51, S-3 Technical Assistance, Consultation on Potential License Hanford TWRS Technical 1997 Approp. Act Legislation needed to Assistance; authorize NRC regulation Potential License Savannah River Review; potential Economy Act Application of incidental Tanks (residues) license for HL5N NWPA; Energy waste criteria to tank residues Reorg Act of waste 1974 4

Aluminum Based Review Economy Act Criteria for storage Spent Fuels dry NWPA; Energy Suitability for disposal storage Reorg Act of 1974 l

I Brookhaven High Flux Review; technical Economy Act Review start date I

Beam Reactor assistance Pilot Projects

-LBNL Potentiallicense 1998 Approp. Act Legislation needed

- ORNL REDC Potentiallicense 1998 Approp. Act Legislation needed

- SRS RBOF Potentiallicense 1998 Approp. Act Legislation needed Privatization Spent Nuclear Fuel Proje. cts

- Peach Bottom Unit 1 License Energy none Cores I and 11-Reorganization

- Shippingport LWBR License Act of 1974, none

-TRIGA License Section 202 none i

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CONGRESSIONAL CORRESPONDING SYSTEM i

' DOCUMENT PREPARATION GECEIST Dis check list is to be submitted with each document (or group of Qs/As) seuforpmcessing.

into the CG

1. BRIEFDESCRIPTION OFDOCUMENT(S) b.

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TYPE OFDOCUMENT X CORRESPONDING HEARINGS (Qs/As)

3. DOCUMENT CONTROL SENSITIVE (NRC ONLY) X NON-SENSITIVE
4. CONGRESSIONAL COMMITIEE AND SUBCOMMITTEE (inapplicable)

Congrenional Comminee Subcommittee

5. SUBJECT CODES (A)

(B)

(C)

6. SOURG OFDOCUMENTS (A) 3520 (DOCUMENT NAME

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(B)

SC4N (C)

ATTAWMENTS (D)

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7. Sni LQGDATES (A) fi di/190 DATA OC4 SENTDOCUMENT TO CCS 1

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DATE CCS REGIVED DOCUMENT (C)

DATE RETURNED TO OCA FOR ADDITIONAL INFORMAtl0N (D)

DATE RESUBMITTED BY OC4 TO CCS (E)

DATE ENTERED INTO CCS BY (F)

DATE OC4 NORFIED THATDOCUMENTISIN CCS

COMMENTS

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