American Indians, bureaucracy, fat cat salary, Geologic repository, High Level Nuclear Waste, High Level Nuclear Waste Dump, Indian Tribe, Indian Tribes, local government, NRC budget, nuclear waste, nuclear waste dump, Nuclear Waste Fund, overhead, public participation, regulatory burden, State Government, Tribal Consultation, Tribal Government, US NRC, US NRC comment, Yucca Mountain
There is a Monday 11.59 pm deadline regarding Disposal of High Level Nuclear waste in Geologic Repositories. “Information Collection: Disposal of High-Level Radioactive Wastes in Geologic Repositories” Due Jul 20, 2015 11:59 PM ET, Posted: 05/19/2015ID: NRC-2015-0108-0001/”OMB clearance package for 3150-0127, 10 CFR Part 60, Disposal of High-Level Radioactive Wastes in Geologic Repositories” http://www.regulations.gov/#!docketDetail;D=NRC-2015-0108
The most obvious point is that they only mention State and American Indian Tribal governments, whereas local governments are supposed to be included – by law, as well as by moral right: “(a) State, local governmental bodies, and affected, Federally-recognized Indian Tribes may participate in license reviews as provided in subpart J of part 2 of this chapter. A State in which a repository for high-level radioactive waste is proposed to be located and any affected, Federally-recognized Indian Tribe shall have an unquestionable legal right to participate as a party in such proceedings.” http://www.nrc.gov/reading-rm/doc-collections/cfr/part060/part060-0063.html
But, their document repeatedly discusses the “burden” of doing their job and the outrageous claim of $279 per hour cost! $279 per hour is $580,320 per year. US minimum wage is $7.25 USD per hour. Even if they charge 60% overhead, like some US universities claim for funding, that would be $232,128 per year.
That’s a whole lot of overhead! Some, but not all, NRC workers earn fat-cat salaries compared to the average taxpayer and ratepayer, but not that fat-cat! Any extra money by location still doesn’t account for the high figure. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2015/salhrl.pdf
Even navel gazing by the NRC workers costs money, as well as writing inane documents, like the one they request comment on, so why not just do their work? The NRC’s proposed FY 2016 budget is over one billion dollars, which they write as $1,032.2 million, clearly in order to confuse people. This includes 3,754.1 full-time equivalents (FTE). http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1100/v31/
This $279 per hour cost is not for participation! It is the alleged cost of their reviewing requests and proposals for participation by State and American Indian Tribal governments, despite the fact that States and Tribal governments “shall have an unquestionable legal right to participate as a party in such proceedings.“!
This is what the document to comment says: “Section 60.62 involves NRC staff review of requests for consultation. This should require no more than 40 hours of staff time per response. At $279 per hour for staff time,this would be $11,160 per respondent. The total for one response is $11,160.
Section 60.63 involves NRC staff review of proposals for participation in site review and licensing procedures. This should require no more than 80 hours of staff time per response. At $279 per hour,this would be $22,320 per respondent. The total for one response is $22,320.
Section 60.65 involves NRC staff review of the statement of representation. This should require no more than one hour of staff time per response. At$279 per hour, this would be $279 per response. The total for one response is $279.
Total cost to the government is $33,759(121 hours x $279/hr). Costs are not anticipated to be recurrent and thus cannot reasonably be annualized. Rather, all costs are likely to be incurred within a year or two following selection of a repository site or submittal of a license application. These costs are fully recovered by NRC through appropriations from the Nuclear Waste Fund which was established by the Department of Energy pursuant to the Nuclear Waste Policy Act of 1982.” http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0108-0002&disposition=attachment&contentType=pdf
There won’t be many State, Tribal or Local Government participants but they are going to make these few apply for help from the NRC and charge a fortune for it! Shouldn’t it be assumed that they need or want assistance?
They end by saying that the amount will be recovered from the Nuclear Waste Fund, which itself has been funded by the ratepayer, but in 2014 “As a result of a lawsuit brought by the National Association of Regulatory Utility Commissioners (“NARUC”)… the U.S. Department of Energy (“DOE”) was forced late last week to halt collection of fees added to the bills of nuclear power customers for the Nuclear Waste Fund (“NWF”), which was instituted in 1982 to pay for a national storage site for the nation’s civilian nuclear waste.” http://www.psc.state.ms.us/commissioners/northern/press%20releases/2014/Presley%20Celebrates%20Victory%20in%20Nuclear%20Waste%20Fund%20Dispute.pdf
“§ 63.63 Participation in license reviews.
(a) The State, affected units of local government, and affected Indian Tribes may participate in license reviews as provided in subpart J of part 2 of this chapter.
(b) In addition, a State, or an affected unit of local government, or an affected Indian Tribe may submit a proposal to the Director to facilitate its participation in the review of the license application. The proposal may be submitted at any time and must contain a description and schedule of how the State, or affected unit of local government, or affected Indian Tribe wishes to participate in the review, or what services or activities the State, or affected unit of local government, or affected Indian Tribe wishes the NRC to carry out, and how the services or activities proposed to be carried out by the NRC would contribute to this participation. The proposal may include educational or information services (seminars, public meetings) or other actions on the part of NRC, such as establishing additional public document rooms or employment or exchange of State personnel under the Intergovernmental Personnel Act.” http://www.nrc.gov/reading-rm/doc-collections/cfr/part063/part063-0063.html
“ON-SITE REPRESENTATIVE–The Secretary shall offer to any State, Indian tribe or unit of local government within whose jurisdiction a site for a repository or monitored retrievable storage facility is located under this title an opportunity to designate a representative to conduct on-site oversight activities at such site. Reasonable expenses of such representatives shall be paid out of the Waste Fund.” NUREG-0980 Vol. 1, No. 10, Nuclear Regulatory Legislation http://pbadupws.nrc.gov/docs/ML1327/ML13274A489.pdf
Nuclear Waste Statute: http://www.gpo.gov/fdsys/pkg/STATUTE-96/pdf/STATUTE-96-Pg2201.pdf
NUREG-0980 Vol. 1, No. 10, Nuclear Regulatory Legislation, 112th Congress; 2nd Session http://pbadupws.nrc.gov/docs/ML1327/ML13274A489.pdf
Other volumes: http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0980/
“Home > NRC Library > Document Collections > NRC Regulations (10 CFR) > Part Index > § 60.61 Provision of information Subpart C–Participation by State Governments and Affected Indian Tribes Source: 51 FR 27164, July 30, 1986, unless otherwise noted.
§ 60.61 Provision of information.
(a) The Director shall provide to the Governor and legislature of any State in which a geologic repository operations area is or may be located, and to the governing body of any affected Indian Tribe, timely and complete information regarding determinations or plans made by the Commission with respect to the site characterization, siting, development, design, licensing, construction, operation, regulation, permanent closure, or decontamination and dismantlement of surface facilities, of such geologic repository operations area.
(b) For purposes of this section, a geologic repository operations area shall be considered to be one which “may be located” in a State if the location thereof in such State has been described in a site characterization plan submitted to the Commission under this part.
(c) Notwithstanding paragraph (a) of this section, the Director is not required to distribute any document to any entity if, with respect to such document, that entity or its counsel is included on a service list prepared pursuant to part 2 of this chapter.
(d) Copies of all communications by the Director under this section are available at the NRC Web site, http://www.nrc.gov, and/or at the NRC Public Document Room, and copies are furnished to DOE.
[51 FR 27164, July 30, 1986, as amended at 64 FR 48954, Sept. 9, 1999]
Page Last Reviewed/Updated Thursday, July 10, 2014”