ML20135C564

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Comments on DSI-6 Re High Level Waste
ML20135C564
Person / Time
Issue date: 12/02/1996
From: Mendelsohn B
NRC
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
DSI-6-00026, DSI-6-26, NUDOCS 9612060353
Download: ML20135C564 (2)


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bSZ - (o db From:

Barry Mendelsohn i

To:

WND1.WNP2.SECY Date:

12/2/96 4:07pm

Subject:

Strategic Assessment -Issue Papers 6 and 23 Attached are some comments on Slrategic Assessment Iss.ues 6 and 23. The views are my own and were not submitted to my management for their review.

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l Comments on issues 6 and 23 o r t e.ei Ar

  • and Re W c o E. m!'ence Backgrcund:

As the independent regulator of both DOE and the nuclear industry, the NRC has tended to remain silent on broad, national programmatic 1ssues and has addressed only tech'11 cal.

regulatory issues. However, as a leader on nucleir safety issues noridnide. the question of whether the agency should play a larger role in national policy issues is raised. The Comnnssion particularly seeks public comment on anat additional activities the NRC might reasonably undertake.

Comment:

The Commission should be Cautious in assuming any role that involves fostering the development of the nuclear industry. because of the potent!al for the public to percei<e a conflict of interest when the regulator is also an advocate. The Energy Reorganization Act of 1974 split the NRC from the rest of AEC for that very reason.

Thus if we strongly advocate dry cask storage at sites near or at reactors. does our credibility with the public in ensuring the safety of those ISF51s suffer? If the Commission advocated geologic disposal as a sound means for disposing of the Natton's HLW an? asked Congress and the Administration to establish the developme'it af an integrated spent fuel storage and disposal system with proposed sched. ales and bucqets, might that compromise our dbility to raise safety issues about the repository trat might threaten the proposed schedule?

On the other hand. we should use our knowledge of safety 155ues to make the puDlic and their elected representatives anare of any safety issues that could affect their policy decisions.

That 15. It is appropriate for the NRC to say that passive dry cask storage has feo >r safety concerns than pool storage that requires active systems, but not appropriate for us to adwocate that interim dry cask storage should be pursued as a national polic,, pending the completion of an acceptable geologic repository. It should not be NRC's concern to assure the future of the nuclear industry 4