ML20149L987
| ML20149L987 | |
| Person / Time | |
|---|---|
| Issue date: | 12/02/1996 |
| From: | Mendelsohn B NRC |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| DSI-23-00016, DSI-23-16, NUDOCS 9612110080 | |
| Download: ML20149L987 (2) | |
Text
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From:
Barry Mendelsohn To:
WND1.WNP2.SECY Date:
12/2/96 4:07pm
Subject:
Strategic Assessment - Issue Papers 6 and 23 Attached are some comments on Strategic Assessment issues 6 and 23. The views are my own and were not submitted to my management for their review.
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Comments on Issues 6 and 23: High Level Waste and Regulatory Excellence l
Background:
As the independent regulator of both DOE and the nuclear industry, the NRC has tended to l
remain silent on broad, national programraatic issues and has addressed only technical.
i regulatory issues. However, as a leader on nuclear safety issues worldwide, the question of whether the agency should play a larger role in national policy issues is raised. The Commission particularly seeks public comment on what 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 potential for the public to perceive 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 ISFSIs suffer? If the Commission advocated geologic disposal as a sound means for disposing of the Nation's HLW and asked Congress and the Administration to establish the development of an integrated spent fuel storage and disposal system with proposed schedules and budgets, might that compromise our ability to raise safety issues about the repository that might threaten the proposed schedule?
On the other hand, we should use our knowledge of safety issues to make the public and their elected representatives aware of any safety issues that could affect their policy decisions.
That is, it is appropriate for the NRC to say that passive dry cask storage has fewer safety concerns than pool storage that requires active systems, but not appropriate for us to advocate that interim dry cask storage should be pursued as a national policy pending the i
completion of an acceptable geologic repository. It should not be NRC's concern to assure the future of the nuclear industry.
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