ML19344C195
| ML19344C195 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/20/2019 |
| From: | Norton W Decommissioning Plant Coalition |
| To: | Office of Administration |
| References | |
| 84FR51189 00019, NRC-2019-0073 | |
| Download: ML19344C195 (5) | |
Text
November 20, 2019 Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Program Management, Announcements and Editing Staff.
Re: 84 FR 51189; Docket# NRC-2019-0073 The Decommissioning Plant Coalition (DPC)l is pleased to comment on the best practices regarding engagement with communities near nuclear power plants that permanently shut down and undergo decommissioning. Our members represent 13 decommissioning sites that have either successfully reached a SAFSTOR condition, are pursuing accelerated decommissioning, or are decommissioned but for the ISFSI. Combined, our group has many years of experience designing, implementing and evaluating diverse and successful engagement methods.
From these experiences, we conclude regulatory direction cannot fit all situations and no single, one-size-fits-all best practice for engagement is better than another.
Instead, the method of engagement should be tailo.red to reflect the preferences and needs of the local community and state where the decommissioning nuclear piant is located. DPC members have and conti'nue to welcome vigorous and continuous engagement with its respective communities. Below is an overview of a variety of diverse engagement options, including: plants with community advisory panels, plants without panels, and hybrid models.
Plants wth community advisory panels A number of sites have taken the lead in creating advisory bodies. Establishing a community advisory panel made sense for the Maine Yankee (MY) plant community.
As stated in its original charter, "(T)he Community Advisory Panel is established to enhance open communication, public involvement, and education on Maine Yankee decommissioning issues." MY's initial community advisory panel meeting was held in 1997 before a packed house. The dynamics of the panel led to increased trust on the part of the community in the information exchanged among the licensee, panel and members of the community. The advisory panel issued a report in 2005 entitled, "A Model for Public Participation in Nuclear Projects," which documents the panel's success. DPC recommends the NRC review this document when compiling its report for Congress.
1 The Decommissioning Plant Coalition (DPC) was established in 2001 to ensure a coordinated focus on legislative and regulatory issues unique to what was then a relatively small number of decommissioning plants. Permanently shutdown plants represented by the DPC ha*,e include: Connecticut Yankee (CT), Crystal River (FL), Duane Arnold (IA), Humboldt Bay (CA), Kewaunee (WI), La Crosse (WI), Maine Yanke (ME), Pilgrim (MA), RanÉho Seco (CA), San Onofre (CA), Vermont Yan1<ee (VT), Yankee Rowe (MA),Big Rock (Ml), and Zion (IL).
SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD= Marlayna Doell, Kimberly Conway COMMENT (19)
PUBLICATION DATE: 9/27/2019 CITATION 84 FR 51189
Plants without advisory panels The experience at Crystal River provides another successful path forward. Their decommissioning team expended considerable resources researching and evaluating the interests, preferences and needs of the community near the reactor site and professionally measured the best way to engage and communicate with plant neighbors and customers. Every year since the decommissioning decision was announced, the Crystal River team has implemented an active and structured engagement plan with its community without forming a formal advisory panel. The Crystal River example provides a strategic and effective model for communities with similar demographics and interest levels.
Hybrid models The DPC has two examples of hybrid models, one that includes "built-in" advisory panels and another that includes state-mandated engagement.
The DPC views governing boards of co-ops or public power supply licensees as having "built-in" advisory panels that effectively communicate and engage with surrounding communities during the operation of the nuclear plant.
Plants with "built-in" advisory panels may not need to establish additional engagement measures. Ft. Calhoun and Lacrosse are good examples. These plants established a community engagement network during operations, which continued to serve them well during decommissioning as well.
Some states have mandated establishing a community advisory panel by law. In these cases, the panels continue to evolve. With leadership and patience, like what is happening in Vermont, mandated panels should arrive at the same level of effectiveness as Maine Yankee's panel.
Other licensees, similar to MY, have created engagement panels voluntary to help facilitate early engagement.
Regardless of the engagement model employed, and especially in communities with diverse and distinct views, panels will experience growing pains when transitioning from an operating plant to a decommissioning one. Regulatory direction cannot fit all situations, and a prescriptive or weighted list of best practices from the federal regulator has the potential to aggravate these pains. In contrast, an optional menu or listing of best practices can serve all models of public outreach discussed above.
Therefore, the DPC recommends providing a variety of successful stakeholder engagement options and examples and allowing local factors to dictate the best methods of engagement. This approach will be the most consistent with a recurring theme we have heard at your round of meetings to explore, "best practices;" these are matters best left to local considerations as regulatory direction will not and cannot fit all situations.
The DPC is providing general answers to your questions in your NEIMA Community Advisory Board Questionnaire. We will be pleased to assist in answering any specific questions you may have as you fulfill the legislative mandate concerning this report.
Wayne Norton Executive Spokesperson Decommissioning Plant Coalition
- 1) Why was the local CAB established?
The variance in the reason or reasons a specific local CAB was established, or not established, vary according to local factors. In each case, decisions were made locally to best fulfill needs in the local community. Identifying a single or limiting set of reasons why a CAB has or has not been established does not capture the best practices of ensuring local engagement fits local needs.
Each CAB has a charter. Each locality that does not have a CAB has established a successful program of engagement based on local efforts and factors.
- 3) What is the historical and current frequency of the CAB meetings?
Each CAB has developed its own frequency of meetings, and they often relate to the maturation of the board's interactions with the licensee and the public.
- 4) What is the historical and current composition of the local CAB?
Almost all CABs consist of local citizens of some civic stature in the community and will include one or more individuals who are critical of the facility's operations prior to shutdown and are willing to participate in a collegial manner. Some CABs include licensee and/ or governmental representation; some do not. CABs do rely on collegial interaction.
SJ What is the selection process for board members? Has this changed over the lifetime of the CAB?
These processes vary according to local considerations such as the charter of the CAB, the availability of members, the amount of activity the CAB requires over time, etc.
- 6) What are the terms of board members?
This too varies according to each specific CAB.
- 7) Are there any specific rules or protocols followed by the CAB ( e.g., Robert's Rules of Order)?
As noted above, a commitment to collegiality among members is of greatest importance. Over time all CABs seem to mature and have a free exchange of views with greater informality than afforded by such Rules.
- 8) Are there any specific logistics required to support the board's meetings and other routine activities? For example, are meetings transcribed, or close captioned, and/or is there audio/visual support for presentations at meetings?
Some CABs trace their beginnings to the early days of media in existence today that ease the use of A/V, internet, and transcription. All these fared well. These tools can enhance the conduct of CAB meetings, but their absence does not indicate an obstacle to successful conduct of CAB business.
- 9) Who sponsors (funds) the CAB expenses? What kinds of activities are included in the CAB budget ( e.g., transcription service, audio /visual support, meeting venues, meals and per diem for CAB members)?
This is another item that depends mostly upon local conditions. The financial outlay may be minimal for locations that have local governmental facilities available for meetings and the members are local citizens as described in the answer to 4, above.
Our members are committed to ensuring that information needs of CABs and the public in locales that do not have CABs are met. The matters of what shape that takes and what are the resulting support needs are best tailored to local conditions.
lO)What topics have been (or could be) brought before a local CAB? What other topics could be useful to stakeholders' understanding of the decommissioning process?
Our members have generally welcomed discussion of ongoing operations at their facilities and of their forward looking efforts, especially that of hastening the day
when the safely stored spent fuel will be removed from the site and the site can be re-used for other purposes.
11)How is the board's input used to inform the decision-making processes of stakeholders for various decommissioning activities?
While some stakeholders have greater decision-making responsibilities as local or state elected officials, a CAB and alternate information processes have almost universally led to a greater understanding of the need to re-invigorate the nation's spent fuel management program.
12)What interactions does the local CAB have with the NRC and other Federal regulatory bodies (to support the board members' overall understanding of the decommissioning process and promote dialogue between the affected stakeholders and the licensee involved in decommissioning activities)?
The NRC's recurring participation in reporting on the decommissioning process and on its inspection findings during decommissioning and dry cask storage periods is valuable. Promoting dialogue between affected stakeholders and licensees is a process best left to development according to and defined by local conditions.
13)How does the local CAB offer opportunities for public engagement throughout all phases of the decommissioning process?
Aside from security related details, most elements of decommissioning and dry cask storage have been freely discussed at CAB meetings.
- 14) In general, what are the advantages of having a local CAB? 15) In general, what are the disadvantages of having a local CAB?
There are no inherent advantages or disadvantages of having a local CAB. As stated above, there are locations that are successful in keeping dialogue open and information flowing without a CAB.
16)Please share any best practices or other lessons learned related to having a local CAB.
The two lessons learned about CABs are that the decisions on whether to have them or employ an alternate means of communications is best left to local considerations and decision-making; and that success occurs when members are imbued with a commitment to act collegially.