ML20137H997

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Submits Documents Being Released to Public Re HLW & Spent Fuel DSI-6, High-Level Waste & Spent Fuel
ML20137H997
Person / Time
Issue date: 04/01/1997
From: Hoyle J
NRC OFFICE OF THE SECRETARY (SECY)
To:
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20137J002 List:
References
COMSECY-96-056, COMSECY-96-56, DSI-6, SECY-96-056-C, SECY-96-56-C, NUDOCS 9704030187
Download: ML20137H997 (13)


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l April 1, 1997 SECY NOTE:

The following documents are being released to the public at this time:

1.

Text of DSI 6 (High-Level Waste and Spent Fuel) 2.

Staff Requirements Memorandum dated March 17, 1997.

3.

Views of Chairman Jackson dated January 16, 1997.

4.

Views of Commissioner Rogers dated January 21, 1997.

5.

Views of Commissioner Dicus dated January 22, 1997.

6.

Views of Commissioner Diaz dated January 27, 1997.

7.

Views of Commissioner McGaffigan dated January 24, 1997.

John C. Hoyle Secretary of the Commission 9704030187 970401 PDR NRCSA I 6

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Swnhary Analysis of Comments COMSECM6-4)3fp o e

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3.4 HIGH-LEVEL WASTE AND SPENT FUEL (DSI 6) j w

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4 3.4.1 The Direction-Setting issue and the Options

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H In recognition of current uncertainties, how should NRC approach the presen} $

high-level waste (HLW) situation?

Approach Congress and the Administration to Refocus the Nationa Oh Option 1:

Program

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criij h d Option 2

Reduce Uncertainty by Modifying NRC's Programs Option 3:

Maintain NRC's Existing High-Level Waste (HLW) Repository Progrpm Option 4:

Take a Minimal Approach to NRC's High-Level Waste (HLW) Repository Program Option 5:

Take a Position on the Storage of Spent Fuel 3.4.2 Commission's Preliminary Views The Comission's preliminary view is to proceed with Option 3 (Maintain NRC's existing HLW Program). This approach would enable NRC to continue to support i

the national HLW program at whatever level is appropriate to keep pace with the national program. However, the Comission intends to revisit this issue if, and when, the Congress provides further legislation on this issue.

2 In addition, the Comission would like to explore taking a more active role in resolving issues in the national HLW program, consistent with NRC's mission.

The Commission particularly seeks public comment on what additional activities the NRC might reasonably undertake.

3.4.3 Summary of Comments A.

Significant/Important Coments Directly Affecting the Preliminary Views or the Direct?on-Setting Issue i

Support for the Comission's preliminary view as stated was limited, with most 4

comenters calling for some modification of the preliminary view. Overall, the commenters were divided in their support of the various options.

Participants in the HLW program external to NRC tended to support the preliminary view in some manner (U.S. Department of Energy Office of Civilian Radioactive Waste Management [ DOE /0CRWM), State of Nevada, Nevada Nuclear Waste Task Force, Clark County).

One commenter (DOE /0CRWM) stated that although some aspects of the various options that merit further consideration, it supports the Commission's preliminary view of maintaining the NRC's existing program until a national This comenter further stated that certain aspects policy decision is made.

of the other options, such as revising regulations and licensing procedures, could be accomplished within the existing NRC program.

This comenter stated that the preliminary view was the most compatible with the current DOE program strategy as described in DOE's revised program plan. This comenter also stated that in the existing program, NRC could continue to streamline its Page 3-35 Phase H Stakeholder interaction Repon

High-Level Waste and Spent Fuel organizational structure and clarify and streamline the technical requirements in 10 CFR Part 60, as well as develop requirements specific te Yucca Mountain In addition, th e comenter as mandated by the Energy Policy Act of 1992.licensieg prxedurea to streamline encouraged NRC to evaluate ether eristit,9 j

the hearing process.

One commenter (Agency for Nuclear Projects, Nuc? ear Waste Project Office,

)

Nevada) agreed with the Commission's preliminary view, g should be prepared to revisit the issue if future legislation requires such i

The commenter stated that prelicensing interactions between 1

reconsideration.

NRC and DOE should constitute only " informal conferences," not binding resolution of any licensing issues, in order to maintain NRC's independence and objectivity.

Another commenter (Nevada Nuclear Waste Task Force Inc.) agreed with the preliminary view, provided that additional steps are taken to expand andThis enhance public input and involvement.

are considered by NRC that would expedite the process by reducing uncertainties, the assumption is that the result will be fewer and less effective opportunities for input and involvement, and that safety will not be assured.

Another commenter (Clark County) agreed with the preliminary view, and wrote that consideration should be given to applying certain aspects of Option 2 to create greater program efficiencies and reduce uncertainties associated with This commenter also said that, aloag with the repository licensing.

preliminary view, the NRC should be a stronger advocate for options that are This commenter proven and available, such as at-reactor dry cask storage. stated tha contentious issues, such as transportation, while sustaining pressure for the characterization and completion of a permanent repository.

The members of the Organization of Agreement States (0AS) were divided on which options they preferred, but :nme members supported the Commission's 1

preliminary view to maintain NRC's existing HLW repository One commenter (Michigan) supported Options 1 and 2, endorsing seve N of the examples presented in the paper as providing for progress in the natunal program, as well as centralized interim storage presented u However, this state preferred Option 3 over Option 4.

comparison.

One commenter (Nuclear Energy Institute [NEl]) stated that the " wait-and-see approach" of the Commission's preliminary view was " who This commenter also said that the NRC should focus on the development and implementation of methods to meet the goals of the national program without compromising its independent regulatory mission, and should not focus on broa Three other commenters (Yankee Atonic Electric Company policy changes.[YAEC), ABB-Combustion Engineering [ABB-CE) and South Car Gas [SCEG]) endorsed these comments with varying emphasis on particular aspects of the comments.

Phase 11 Stakeholder interaaion Repon Page 3-36

High-Lew! Waste and Spent Fuel

, Sumniary Analysis of Cc;=nts One commenter (Entergy) concurred with the preliminary view, while also suggesting that it would be appropriate for the Comission to take a more active role in resolving issues in the national HLW program, consistant with This commenter added that it would welcome NRC support in NRC's mission.

issuring the timely availability of appropriate safe-storage facilities for 6ther comenters (NEI, YAEC) spent nuclear fuel under the existing program.

also said that NRC needed to do what it could to expedite the approval of dry storage and transportation systems under the existing program.

One commenter (SAIC) stated that the views of DOE /0CRWM and U.S. Department of Energy, Environmental Management (00E/EM) need to be considered before NRC makes a final decision on this DSI.

One comenter (Erickson) agreed that the NRC should continue with its existing program, but proposed that NRC could possibly strengthen the program by approaching Congress for more ftnding and authority to enable greater involvement.

One commenter (Randall) had problems with Option 3, stating that repeated redirection of the DOE HLW program, with the latte' undergoing major redirection every two to four years, has impaired f1RC's ability to manage its This comenter noted that for Option 3 to be viable, NRC may have to program.

approach Congress and the Administration to suggest ways to stabilize the national HLW program.

Another commenter (McCartin) said that the current structure of NRC's program was working well, and that expanding Option 3 to take an aggressive look at issue resolution would be appropriate. This comenter pointed out that there are a number of uncertainties that have significant potential to adversely affect the licensing of a repository (i.e., excessive delays and boundless speculation), particularly in a licensing hearing. This comenter suggested that resolving issues, before the licensing hearing, was of tantamount importance for having a meaningful, focused licensing hearing.

One comenter (Barkley) agreed with the preliminary view to retain NRC's This existing program, but wanted it be done with limited resources.

comenter.said that only one site will be reviewed and that the ultimate decision on using the site will be based more on political considerations than on technical matters, since almost any site can be made suitably safe for HLW disposal through additional engineered barriers.

This Another comenter (McDuffie) also agreed with the preliminary view.

commenter said that the Comission should exercise restraint in trying to influence the overall direction of the repository program, and that the In this overall policy direction should be left to Congress and DOE.

comenter's view, NRC should focus on regulating whatever facilities the Congress and DOE decide to construct.

Another comenter (Reed) thought that the Comission should approse Option 1 in conjunction with the preliminary view, Option 3.

This comenter said that the agency should play a larger role in the national policy issues on HLW disposal by virtue of its position as a laader on worldwide nuclear safety issues.

Page 3-37 Phase 11 Stakeholder interaction Report 1

High-Level Waste and Spent Fuel

~

summery Ma@sts vjTomments One commenter (Environmental Coalition on Nuclear Power [ECNP]) felt that thc nation's program for the management of radioactive waste is an " abysmal failure and needs a completely independent review (non-NRC, non-D0E, and non-nuclear industry).

ECNP urged NRC to eliminate use of the term " disposal" and adopt a waste management approach based on the concepts of " waste isolation and guardianship."

1 B.

Comments on Other Options The support for other options was divided. Opinions varied on the appropriateness of NRC pursuing an aggressive role in the national program.

Several commenters noted that the options were not mutually exclusive and, as i

did many who endorsed the preliminary view, recommended some combination of the options. None of the commenters endorsed Option 4.

Two commenters (State of New Jersey [NJ], Conference of Radiation Control Program Directors (CRCPD]) suggested that it would be inappropriate for the Commission to pursue Option 1.

These commenters said it was appropriate for the NRC to resoise technical issues and be proactive in informing the public on nuclear waste issues, but that it was inappropriate for the agency to become an advocate for the HLW program and that such advocacy would lead to public mistrust.

However, these commenters noted that NRC intercession on budgetary constraints placed on the HLW program could help put risks and costs into perspective. These commenters stated that examining the costs of the HLW i

program and the radiation risks from spent fuel, and comparing these risks and costs to other regulatory programs would help to frame the issue for the general public and Congress.

Two commenters (LA,GA) stated that they endorsed the comments of CRCPD).

Another commenter (OH) stated that it was inappropriate for the Commission to pursue Option 1, stating that enhancement of the national HLW program is not a regulatory function. This commenter said it would be better to expand funds in support of the regulatory effort only as prescribed by Congress.

This commenter also thought that it would be inappropriate for NRC to lobby Congress, and said that DOE should be the party submitting the plans for the HLW progrr.m to Congress.

With respect to the specific examples provided under Option 1, this commenter had the following reactions:

Unless NRC is aware of an overall approach that is not licensable, the decision on whether to pursue geologic disposal integrated with interim storage is a decision to be made by DOE.

The acceptability of the Yucca Mountain site should not be prescribed in law unless it is based on public health and safety criteria based on NRC rules and supporting policy.

j The proposal that certification be pursued in lieu of licensure in the interest of lessening the burden in the process gives the appearance of

" backing dowr" from a full regulatory role.

If the licensing process is unduly burdensome, then it should be changed without sacrificing public health and safety.

One commenter (Lewis) said that the example provided in the issue paper under Option 1 in which the NRC would propose that Congress determine the acceptability of Yucca Mountain by law was inappropriate because a political decision would be made rather that a scientific one.

Phase 11 Stakeholder Interaaion Report Page 3 38

High-frx! Waste and Spent Fuel Sund.:ary Analysis of Comments With respect to Options 1 and 5, one commenter (D0E/0CRWM) stated that the current policy for management of HLW and spent fuel, including the role of interim storage and geologic disposal, will be reconsidered in the coming This comenter wrote that those who are intimately involved with these years.

issues have an obligation to help inform the policymakers and the public so that "an astute and enlightened decision can be made." Therefore, DOE /0CRWM encouraged the Commission to adopt an approach that includes knowledgeable and effective participation in the policy debate.

One comenter (Randall) recommended adoption of Options 1 and 5 with the HLW indefinite storage with no program being restructured in one of two ways:

repository program or centralized storage with a well-planned, politically and Either way, this commenter also managerid ly stable repository program.

recommended that nuclear utilities manage the HLW program through a public corporation.

With respect to Option 2, one ccmmenter (D0E/0CRWM) commended the effort to identify methods for streamlining activities to reduce uncertainty associated This commenter stated that it would welcome the with the licensing process.

opportunity to explore further with staff the potential for streamlining the currently applicable licensing process by incorporating "more informal procedures."

Another commenter (OH) wanted NRC to direct its efforts towards Option 2.

However, this commenter thought it was unclear how the example suggested under this option to elevate NRC's HLW program to an " office" status would enhance This commenter, along with some others (NEI, YAEC, NRC staff) the program.

opposed the idea presented under Option 2 of designating DOE employees as NRC representatives for certifying that the regulations are met in the licensing of a repository or interim storage facility.

Some of these commenters suggested that implementing this idea would be tantamount to allowing self-regulation by D0E.

Under Option 2, one commenter (NEI) endorsed ine idea of establishing an issue resolution process for the repository, as well as revising Part 72 to extend the license term for independent spent fuel storage installations (ISFSIs) to This commenter also made several recommendations that would be 100 years.

This commenter suggested that NRC shou.d modify its l

consistent with Option 2.

regulations on the basis of experience and should impose a risk-informed discipline, as well as completely review its regulations and programs in an This commenter also stated that NRC should effort to streamline activities.

update its generic environmental impact statement for transportation (NUREG-Further, this commenter thought that NRC should advise the 0170).

Environmental Protection Agency (EPA) on an appropriate, implementable Three other commenters (YAEC,SCE&G,ABB-CE) repository performance standard.

endorsed these comments and placed varying emphasis on particular aspects of the comments.

Some members of the Organization of Agreement States (0AS) supported Option 2, stating that NRC should proceed on the assumption that because cf the recent court decision regarding DOE's obligation to take the spent fuel by 1998, DOE will dedicate its resources accordingly.

They also stated that NRC should une that the national program will involve a repository, centralized interim storage, and onsite dry cask storage.

Simclification of the hearing process, pursuing binding resolution, and early negotiation of issues were all considered worthwhile.

Page 3-39 Phme 11 Stakeholder Interaction Repon

^

Swnmery Analysis of Comngnis liigh-Inel Waste and Spent Fuel With respect to Option 4, one commenter (DOE /0CRUM) suggested that it would be inappropriate for NRC to reduce its program to a bare minimum. This commenter i

i said that this app oach would run counter to the need to address ' disposal in a comprehensive and 'imely manner as mandated by Congressional legislation, and would run counter ts 0CRWM's Program Plan, in which DOE and NRC will be 1

increasingly engagec over the next few years.

Other commenters (Ohio [0H],

NEI) also suggested that this approach was not acceptable.

Some members of the OAS supported Option 5, stating that interim storage provides a near-term solution.

These members said that if Yucca Mountain is found to be unsuitable, a fallback posf tion, such as dry-cask storage, should already be in place.

These members thought the NRC should encourage Congress to move towards dry storage, using DOE sites.

These OAS members also stated that since DOE owes the utilities, it should be part of the interim solution.

One commenter (Clark County) stated that contrary to statements made in the issue paper, public opposition to storage at reactor sites does not appear to be very significant. One commenter (OH) noted that with respect to Option 5, a "de facto" national approach to dry-cask storage already existed in the form of present storage at nuclear power plants.

This commenter said that tt-reactor storage would be the preferred option. Another commenter (Micnigan

[MI]) cautioned NRC against advocating one particular storage option over another. This commenter suggested that such NRC advocacy would appear to be an endorsement of one option as being safer than the other.

Even if this were not NRC's intent, this commenter feared that the public may perceive it in this manner.

Two commenters (CRCPD, New Jersey) found it contradictory that assured storage, as a concept for managing low-level Waste (LLW), is not fully These commenters said explored, but that spent fuel can be stored in ISFSIs.

that if the Commission chose to pursue Option 5, and advocated at-reactor storage, it would need to explain the apparent contradiction with the LLW Two commenters (LA,GA) stated that they endorsed the comments of program.

CRCPD.

One commenter (Public Citizen) supported Option 5, stating that ti,a waste is going to have to be watched in perpetuity, and that disposal will always meet public opposition. Another commenter (Flering) simply stated that she wts in favor of NPC getting involved and finding a solution, although she did not favor spent fuel being stored thro'ughout the country at reactor sites.

One commenter (McDuffie) found it appropriate for the Commission to pursue Option 5, supporting spent fuel storage at a centralized facility. This commenter stated that, recognizing the impact on operating reactors as spent fuel pools reach capacity, it would be appropriate for the Commission to be This more proactive in addressing the need for dry spent fuel storage.

commenter suggested that if a centralized facility were available, the reactor licensees could concen& ate on their primary concern, safe reactor operation, rather than on the need to maintain an onsite spent fuel storage facility.

This commenter also said that the Commission should not become involved in the issue of regional equity (i.e., one site ver as several sites), since this is a public policy issue and not a health and safety issue.

One commenter (W) supported strong involvement by NRC to help achieve progress and thought that a combination of Options 1, 2, and 5 would be appropriate.

This commenter supported having Congress and the Administration establish an Phase 11 Stakeholder interaction Repon Page 3-40

SumEnary Analysis of Comments High-Level Waste and Spent FM integrated spent fuel storage and disposal system with proposed schedule and budgets, as outlined in Option 1, in parallel with NRC taking steps to reduce uncertainty in its programs, as described in Option 2.

In addition, this commenter suggested that NRC should also pursue development of regulatory acceptance criteria, allowing for the public debate to be more focused on With respect to Option 5, this commenter said that with compliance issues.

the current national HLW program in a state of debate, a realistic interim approach involving spent fuel storage would be appropriate.

With respect to possible options that were not discussed in the issue paper, one commenter (League of Women Voters) suggested that if feasible, it may be better to entomb fuel rods, possibly in the reactor, and/or other long-lived HLW on site rather than transporting it to a special site for disposition.

Another comenter (Prairie Island Indian Community) noted that ceasing production of HLW materials should be considered as an option.

An anonymous comenter wrote that the responsibility of dealing with the final disposal of HLW and spent fuel is DOE's, and, therefore, NRC should only deal with temporary storage of the waste and nothing more.

Several commenters (CRCPD, OR, MI, IL, PGE, YAEC, Detroit Edison) said that the " greater than Class C" (GTCC) waste needed to be considered with respect to storage at ISFSis and/or ultimate disposal in a HLW repository, and that appropriate regulations needed to be in place. One of these commenters (CRCPD) noted that there is some naturally occurring and accelerator-produced radioactive material (NARM) that is in the same source strength range as GTCC and that these sources should be tracked and be taken care of in the same way and at the same time as the GTCC. Two commenters (LA,GA) stated that they endorsed the comments of CRCPD.

C.

Comments on Important Omissions One commenter (Agency for Nuclear Projects, Nuclear Waste Project Office, Nevada) stated that this DSI should address both safety and safeguards aspects of HLW and spent fuel transportation. Although agreeing with the DSI's acknowledgement that there is public concern over spent fuel shipments the commenter was disappointed that the DSI did not examine the sources of public concern, nor did it recomend actions to address specific safet.) issues raised by stakeholders and the general public. The commenter urged that " Careful consideration of stakeholder concerns, in our opinion, means that at a full minimum, NRC should reevaluate its position on three critical issues:

scale physical testing of shipping casks; the use of probabilistic risk assessment in transportation risk analyses; and the vulnerability of spent fuel and HLW shipments to sabotage and/or terrorist attack." The commenter concluded that "If the Commission, as it has said, is interested in taking a more active role in resolving national HLW issues, it could begin to address the issue of public confidence by reviewing and responding to regulatory issues that continue to be raised by Nevada and others about the storage and transportation of HLW."

Another commenter (Clark County) also said that NRC should have paid more attention to transportation in the issue paper. This commenter said that the NRC needs to be proactive in determining significant transportation issues and the potential need to modify its current regulatory authority. This commenter stated that NRC involvement in transportation will become more important if DOE's current objective to privatize waste transportation is implemented.

Page M1 Phme 11 Stakeholder interaction Report

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"* I liigh-kvel Waste and Spent Fuel This commenter also said that the Licensing Support System (LSS) should have been addressed, noting the importance of the system in enhancing the stakeholder's role in licensing ar ell as offering the potential for making the licensing rev b more efficient.

rinalit this commen!et suggested that terrorism should lave been addre m d., Stating that NRL, M a %Uclear expert, needs to t' more proactive in wtsidering stentiO ru:.bm threats and ways by preventing such danger to the,public.

One commenter (NEI) wrote that the impacts of the uuttome cf the U.S. Court of Appeals ruling that DOE must accept spent fuel from romercial nuclear power reactors by January 31, 1998, should have been discussed along with the impact on NRC to review more applications for at-reactor storage if DOE does not meet this deadline. This commenter noted that public mistrust was mentioned in the paper, but the DSI did not examine whether NRC has contributed to that The commenter suggested that a comparison of the EPA approach to mistrust.

chemically hazardous wastes with NRC's program for HLW could show why the hazardous waste program was relatively more successful.

Finally, this commenter indicated that the discussion on transportation issues was incomplete, in particular, noting the impact of the cancellation of DOE's Three other commenters multi-purpose canister (MPC) system on utilities.

(YAEC,SCE&G,ABB-CE) endorsed these comments, placirg varying emphasis on particular aspects of the comments.

One commenter (ATL International, Inc.) was perplexed that the defense HLW program was not discussed, noting its significance with respect to its volume and curie content.

One commenter (Creed) felt that the role of private industry was missing from the paper and suggested that a private, for-profit organization could be drawn into the process to help solve the problem of dealing with the nation's high-level waste.

D.

Comments on Internal / External Factors Several commenters (Clark County, Nevada Nuclear Waste Task Force, Utah, League of Women. Voters, NRC staff) noted spent fuel transport as a significant factor for the HLW repository and spent fuel storage programs.

One commenter (Nevada Nuclear Waste Task Force) said that the issue paper gave unwarranted safety assurance to future transportation programs and dry cask This commenter said that there are unresolved issues in these areas storage.

and that giving assurances is premature and raises doubts in the public's mind about whether adequate testing will be done, or if existing and future problems will be satisfactorily resolved.

One commenter (League of Women Voters) stated that before any plans are finalized, the possibility of leakage from transportation casks needr to be resolved, along with environmental issues concerning any proposed s %.

One commenter (NRC staff) pointed out that public concerns about spent fuel transport associated with centralized storage could be allayed through an Such a education campaign by DOE or the reactor licensees, but not by NRC.

campai p could focus on cask construction and cask performance in accident scenarlos.

Phase 11 Stakeholder interaaion Repon Page 3-42

SNnmary Analysis of Comments High-Level Waste and Spent Fuel Some commenters (UT, Farron, Sweden /Swedish Nuclear Power Inspectorate

[ Sweden / SKI]), noted the politics of the HLW issue. One of these commenters (Sweden / SKI) said that international convergence on safety requirements and what is meant by " reasonable assurance" of long-term safety of waste repositories will be crucial for public acceptance.

An anonymous commenter wrote that the NRC needed to clarify the roles and responsibilities of the Office of Nuclear Reactor Regulation (NRR) and the Office of Nuclear Material Safety and Safeguards (NMSS) in the dry-cask storage program, stating that activities related to reactors, including dry cask storage, should be handled by NRR.

One commenter (Patriot) stated that contrary to one of the key factors in the paper, there is a significant consensus in the industry, the scientific community, and among the various parties interested in the HLW program.

E.

Commente on Staff Requirements Memorandum Questions In its preliminary view, the Commission stated that it would like to explore taking a more active role in resolving issues in the national HLW prognm, consistent with NRC': mission, and requested comments on what additional activities the NRC might reasonably undertake.

Although commenters did not speak to thi.s question, some made suggestions as noted below.

One commenter (UT) endorsed the idea NRC taking a more active role consistent with its mission, suggesting that a process needs to be est?blished to work through the politics of the program. This commenter noted that the public perception of spent fuel shipments is a significant issue and that more information on transportation safety needs to be disseminated, suggesting outreach materials be developed by NRC.

Another commenter (NEI) wanted NRC to take a much stronger role in advising Congress and the general public about the safety of the spent transport, storage, and disposal of nuclear fuel. This commenter said that NRC should also recommend changes to legislatively imposed processes that would enhance the Nation's ability to manage HLW and sient fuel. One commenter (SCE&G) stated that they endorsed the comments o' NEI.

Three commenters (Paul Farron, ECNP, NRC staff) felt that more involvement by NRC may not be appropriate.

In order to have credibility as a regulator, the commenters felt it was important for the NRC to be neutral.

Two commenters (Holmes, NRC staff) suggested that given the NRC's role to protect public health and safety, it may be appropriate for the NRC to advocate safety when there is a clear safety benefit to pursing one direction versus another, whether it be regarding a particular approach to dealing with HLW or any other subject.

One commenter (Erickson) stated that holding public meetings like the Strategic Assessment meetings could be one way for the NRC to be more involved yet remain neutral. The commenter found this type of meeting very beneficial and said that it would increase public and licensee awareness, and improve public communication.

t Page 3-.13 Phase !! Stakeholder Interaction Report

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liigh Level Waste and Spent Fuel Summary Analysis of Comments 3.4.4 List of Commenters WRITTEN COMMENTS 1.

October 21, 1996, Orgarization c: Agrane t. States (Pobert Quillin) 2.

October 17, 1996, John D. Randau, U.3. m 3.

October 28, 1996, State of Washington, Departa nt of'riealth (Terry Frazee) 4.

October 28, 1996, Richard S. Barkley, U.S. NRC 5.

November 3, 1996, Marvin I. Lewis 6.

November 4,1996, State of New Hampshire, Department of Health and Human Services (Diane E. Tefft) 7.

November 5, 1996, M. Rose Byrne, U.S. NRC 8.

November 5, 1996, Nevada Nuclear Waste Task Force, Inc. (Judy Treichel) 9.

November 5,1996, State of Michigan, Department of Environmental Quality (Fl. int C. Watt) 10.

November 6,1996 Environmental Coalition on Nuclear Power (ECNR)

(Judith H. Johnsrud) 11.

November 7, 1996, State of Mississippi, Department of Health (Robert W.

Goff) 12.

November 8, 1996, Timothy J. McCartin, U.S. NRC 13.

November 13, 1996, State of Oregon, Office of Energy (David Stewart-Smith) 14.

November 14, 1996, State of Nevada, Nuclear Waste Project Office (Robert R. Loux) 15.

November 14, 1996, League of Women Voters, Rockford, Illinois (Betty Johnson) 16.

November 14, 1996, State of Oregon Department of Human Resources (Ray D.

Paris) 17.

November 14, 1996, South Carolina Department of Health and Environmental Control (Max K. Batavia) 18.

November 20, 1996, U.S. Department Of Energy (Daniel A. Dreyfus) 19.

November 21, 1996, State of Louisiana, Department of Environmental Quality (Ronald Wascom) 20.

November 21, 1996, State of Georgia, Department of Natural Resources (Thomas E. Hill)

Page 3-44 Phee 11 Stakeholder Interaction Report

High-trvel Waste and Spent Fuel Su. =y Analysis of Cc::v.:nts 21.

November 21, 1996, State of Utah, Department of Environmental Quality (William J. Sinclair) 22.

November 22, 1996, South Carolina Electric and Gas Company (Gary J.

Taylor) 23.

November 22, 1996, Steve McDuffie, U.S. NRC 24.

November 25, 1996, Westinghouse Electric (N.J. Liparulo) l 25.

November 27, 1996, Nuclear Energy Institute (Thomas D. Ryan) 26.

November 27, 1996, Conference of Radiation Control Program Directors (William P. Dornsife) 27.

November 27, 1996, Portland General Electric (Stephen M. Quennoz) 28.

November 27, 1996, Detroit Edison (Douglas Gipson) 29.

December 2, 1996, Swedish Nuclear Power Inspectorate (Lars Hogberg) 30.

December 2, 1996, Phillip R. Reed, U.S. NRC 31.

December 2, 1996, Barry Mendelsohn, U.S. NRC 32.

December 2, 1996, Mel Silberberg & Associates (Mel Silberberg) 33.

December 2,1536, State of Ohio Department of Health (Robert E. Owen) j 34.

December 2, 1996, State of New Jersey (Jill Lipoti) 35.

December 2,1996, Yankee Atomic Electric Company (Jane M. Grant) 36.

December 2,1996, Entergy (mchael J. Meisner) 37.

December 2,1996, ABB-Combustion Engineering (Charles B. Brinkman) l 38.

December 2, 1996, Clark County Nevada, Nuclear Waste Division (Dennis Bechtel) 39.

December 2, 1996, State of Illinois, Department of Safety (Thomas W.

Ortciger) 40.

December 3, 1996, No Name 41.

December 6, 1996, James Creed, U.S. NRC ORAL COMMENTS Washington, D.C. (October 24 - 25, 1996) pages 59 - 90 1.

Jim Riccio, Public Citizen's Critical Mass Energy Project 2.

Jane Fleming, NNSN D.N.A.C.

3.

Dennis Bechtel, Clark County Nevada Page 3-45 Phase 11 Stakeholder Interaction Repon

High-Lew! Waste and Spent Fuel Summary Analysis of Comments

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4.

Greg Gurican, Patriot, GPU Nuclear, Inc.

5.

Steve Collins, 0AS 6.

Sid Crawford, SAIC 7.

Chris Einberg, DOE /0CRWM 8.

Lynne Fairobent, ATL International, Inc.

Colorado Springs, CO (October 31 - November 1, 1996 pages 397 -413 1.

Bill Sinclair, State of Utah 2.

Ken Weaver, C0 Department of Public Health & Environment 3.

Mr. Holmes, CRCPD Chicago, IL (November 7 - 8, 1996) pages 161 - 182 1.

Heather Westra, Prairie Island Indian Community 2.

Kristin Erickson, Michigan State University 3.

Paul Farron, Wisconsin Electric Power Company 4.

Thor Strong, State of Michigan Page 3-46 Phase 11 Stakeholder interaction Report