ML20216J906
| ML20216J906 | |
| Person / Time | |
|---|---|
| Issue date: | 07/30/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| COMSECY-96-054, COMSECY-96-54, SECY-96-054-C, SECY-96-54-C, SECY-97-169, SECY-97-169-01, SECY-97-169-1, SECY-97-169-R, NUDOCS 9709180146 | |
| Download: ML20216J906 (12) | |
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POLICY ISSUE (NEGATIVE CONSENT)
July 30.1997 SECY-97-169 EDB: The Commissioners EBQM: L. Joseph Callan Executive Director for Operations 1
SUBJECT:
PROPOSED CHANGE TO THE INDEPENDENT RADIATION MONITORING PROGRAM UNDER WHICH THE NRC CONTRACTS WITH STATES TO MONITOR THE ENVIRONMENT AROUND NRC-LICENSED FACILITIES PURPOSE:
This paper responds to COMSECY-96-054 to present for the Commission's consideration the staff's recommendation regarding the scope of work performed by States under contract to the Office of Nuclear Reactor Regulation (NRR) for the Independent Radiation Monitoring Program (IRMP).
BACKGROUND:
In the 1970s, the NRC initiated a radiation monitoring program in which NRC contracted with States to measure radioactive materials released into the environment from NRC-licensed facilities. The IRMP contracts provide for two C[
types of monitoring:
radioassay of environmental measurement using thermoluminescence dosimeters (TLDs). The cost tosamples the NRC and direc for this program in fiscal year 1997 is $1.167 million. Most of the facilities that are monitored under this program are nuclear power plants.
Contact:
NOTE: TO BE MADE PUBLICLY AVAILABLE Stephen P. Klementowicz, PERB/N".R WHEN THE FINAL SRM IS MADE AVAILABLE 301-415-1084
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The Commissioners The IRMP is a collaborative effort between NRC and the States that provides a comparison with the environmental measurements made by NRC-licensed facilities. The program serves as an avenue for the NRC to assist State radiological health programs to develo programs, but not to fully fund them. p their own environmental monitoring NRR maintains 35 contracts with 34 States and the University of Florida. Participation by the States is voluntary.
j In late 1994, NRR considered terminating the environmental monitoring portion i of the IRMP in calendar year 1995. The consideration to eliminate that t portion of the IRMP arose from a perception that the information received from the States was of limited value from a safety perspective. In addition, NRR believed that the States had been provided amale opportunity to fully develop I
their radiological programs, considering the 4RC financial and technical assistance that was provided since the mid-1970s, NRR sought informai feedback from the affected States, the Office of Nuclear I Material Safety and Safeguards, the Office of State Programs, the Office for the Anal Counsel ysis and Evaluation and NRC of Operational regional offices. Data, the As expected, the Office of States affected the General and the regional offices strongly supported the program, while the others expressed limiteu support, The support focused on the program's merits to promote mutual cooperation between the NRC regional offices and the States, the '
" independent" nature of the data, problems the States would have with their budgets if funding was cut so late in the year, and the negative public perception if the program was terminated.
Upon consultation with NRC senior management, including the Executive Director for Operations and the Chairman, the staff decided to take the following course of action, The program would be funded for calendar year 1995. A letter would be sent to the States asking for comments on NRC's prc% sed plan to eliminate the environmental monitoring part of the cooperative agreement program in 1996 and beyond. Additionally, a Federal Register notice would be issued requesting comments on the proposed elimination of the environmental monitoring Jart of the State contracts, NRR would evaluate the comments and decide on t1e status of the program for 1996 and beyond.
On April 11, 1995. NRR published an announcement in the Federal Register (60 FR 18428) of its intent to eliminate the environmental monitoring portion of the IRMP. The announcement stated that eliminating the data supplied by the States should not interfere with NRC's ability to effectively monitor and regulate NRC licensees, considering the excellent record maintained by the facilities in controlling the release of radiological effluents into the environment within reguletory limits. combined with effective radiological environmental monitoring programs. It stated that NRR believed that eliminating this portion of the IRMP was prudent to ensure that public health and safety are protected in a cost-effective manner.
A total of 17 rets of comments were received on the IRMP. Of the total, 15 sets of comments came from State or local government agencies that were
i The Connissioners against reducing the program. The other two sets of comments came from the nuclear power industry and supported NRC's proposed action.
Comments that opposed reducing the program focused on public )erce) tion of nuclear power and the environment. These commenters stated t1at t1e public demands that independent environmental monitoring be performed to ensure that nuclear power plants are not causing a long-term change in the environment.
Also, some commenters indicated that the public does not trust the NRC or the atilities to fully monitor the environment and disclose any problems.
l Some States noted that a reduction in NRC funding would likely cause a l reduction in pettoniel who work for State environmental monitoring laboratories.
Certain States believe that a reduction in the environmental monitoring performed by the States will send a message to licensees that they can decrease their vigilance. This course of action, they believe, will cause a long-term degradation of the nuclear power plant radioactive effluent discharge programs.
In the r .vs of some States, the environmental monitoring program ensures that operating monitoring equipment and supporting laboratory capability will continue to be available in the State programs in the event of an accident at a nuclear facility.
Comments supporting NRC's proposed action came from the Nuclear Energy Institute (NEI) and were based on a survey of the nuclear power industry. NEI
'tated that the environmental monitoring performed by the States has been veneficial but that incurring continued costs to gather and analyze the comparison data, given a record of several years of excellent comparisons from several facilities, is not the most cost-effective use of the NRC's, and ultimately the nuclear industry's, resources. One nuclear utility added that the State environmental monitoring program has demonstrated very good comparisons among State, NRC, and licensee environmental monitoring programs, and the continuation of the program is redundant and unnecessary on the basis of technical merit and cost-effectiveness.
In October 1995, at the direction of NRC senior management, the information on the IRMP was submitted to the Strategic Assessment and Rebaselining Committee for consideration. The committee included the IRMP as part of the Strategic Assessment issue Paper 4 (DSI 4) on NRC's relationship with Agreement States.
In response to DSI 4, the Commission directed the staff to evaluate the cost effectiveness of the program and make a recommendation for the continuation or elimination of the program.
DIEMM103:
All licensed U.S. nuclear power plants are required by General Design Criterion 64 of Appendix A and Section IV.B of Appendix ! to 10 CFR Part 50 to r periodically collect and analyze samples from the environment and perform t
l The Commissioners ,
i direct radiation measurements around the plant site for indications of radioactive materials originating from the plant. This environmental monitoring program is to verify that measurable concentratinns of radioactive -
material and levels of radiation are not higher than allow o or expected on the basis of a measurement of 31 ant effluents and the analytical modeling of the environmental exposure pat 1 ways. In turn, the meesurements arogram i certifies that the plant is in compliance with regulations and t1st the measured releases do not exceed the amounts defined in the final environmental statements as representing very small risks to members of the public.
Extensiv: monitsring is required for each plant, with sampling / measurement frequencies ran s)ecifications.ging Thefrom weekly toenvironmental radiological annually in accordance with its technical monitoring program records w1en, if ever, radioactive materials above natural background levels are detected around the plant site. Samples come from sources such as lakes, rivers, and well water for waterborne contaminants; radiciodine adsorbers and particulate dusts for airborne contaminants; and milk, fish, shellfish, and vegetables for radioactive materials that might be ingested as foods. As part of this program, the laboratories of the licensee and of the licensee's contractors where environmental sample analyses are performed must participate in an interlaboratory comparison program Such participation ensures that independent checks.are performed on the precision and accuracy of the measurements of radioactive materials in environmental samples. In addition -
to the radioassay of environmental samples, licensees also monitor direct radiation using TLDs in each of up to 16 sectors of land surrounding the plant. The TLDs measure the cumulative radiation dose at locations in each sector for each calendar quarter. A!4 licensee measurements in the radiological environmental monitoring programs are recorded in a radiological environmental monitoring report, which is submitted annually to NRC and placed in the local public document rooms.
NRC periodically inspects licensees' radioactive 6ffluent and environmental monitoring programs. The inspection program requires an NRC inspector to review the licensee's effluent release program, the environmental monitoring ,
program, calculated doses to members of the public, the meteorological-monitoring program, the environmental monitoring quality assurance program, and the licensee's audits and self-appraisals. The inspection program will continue to ensure that licensees operate and maintain effective programs in compliance with NRC requirements.
Although the IRMP provides su)plemental data that the regions may use as part of their inspection effort, tie program represents only a small part of NRC's oversight activities of licensed facilities to ensure compliance with NRC requirements. The data are not routinely included as part of the NRC inspection program.
The States have the option of participating in either or both of the components of the-IRMP: environmental monitoring and direct radiation measurement. The environmental monitoring portion of the contract requires the State to obtain and analyze environmental samples (air, water, soil, and 4
The Commissioners I food products) that duplicate as closely as possible certain parts of licensee environmental monitoring programs. .The States send an annual report to NRC noting all analyses they perform and comparing them with similar analyses performed by individual nuclear facilities. NRC regional offices can use these data to supplement their assessments of environmental monitoring programs conducted by nuclear power plants. Not all States participate in the environmental monitoring portion of the contracts. Twenty-seven States, of a possible 34, are under contract to perform this monitoring. Of the total
$1.167 million budgeted for the IRMP, the cost of the environmental monitoring portion of the contracts is $975,000.
The direct radiation measurement portion of the contract involves the placement of TLDs to continuously measure radiation exposure rates in the air outside the licensee's facility. This program was initiated following the accident at Three Mlle Island to supplement the monitoring performed by licensees. The TL0s provide the NRC with the capability to independently assess the radiological impact in the event of an accident. State personnel place TLDs on poles in specific locations around a nuclear facility, typically near the licensees' TLDs. The exposed TLDs are re) laced quarterly and are shipped to NRC's Region I office, which performs tie analyses and compares TLD data with lictnsee data. The cost to NRC of this portion of the IRMP contracts is $192.000.
Under the IRMP, the States act as agents of NRC by providing personnel, equipment, and analytical services to conduct an independent environmental monitoring program. The States do not directly inspect NRC-licensed facilities. NRC regional staff members constitute the principal contact with the States, providing administrative and technical coordination and conducting periodic performance a)praisals to determine the adequacy of State performance under the contract. 11e regional offices work with the States to uncover problems and to assist the States as necessary. NRC Headquarters manages the administraticn of the contracts and funds the program.
An important aspect of the IRMP is NRC's appraisal of each participating State's environmental monitoring program. The appraisals, conducted every 3 years by fMC regional inspectors, are used to assess the adequacy of the State's program to determine whether to renew the contract. The appraisal process examines the following aspects of the State's program: management support, policies and standards, organization, staff, training, communications, quality assurance, facilities and equipment, and performance.
On the basis of this appraisal, the region makes a recommendation on whether the NRC should continue to maintain a contract with the State. No State contract has ever been denied renewal; however, there was a situation in which payment of an invoice from a State was delayed pending actions by the State to correct significant deficiencies in its program.
A selected review of the appraisal reports indicates that the capability and performance of the States vary widely. Some State programs are very good and provide useful material to the regional office concerning licensees' -
capabilities in environmental monitoring. On the other hand, some States
t The Comissioners 6-maintain only a limited radiological measurement program and treat the NRC contract as a low priority, in recent years, some States have requested relief from specific monitoring or analysis requirements in the contract because of technical or financial constraints. These requests have generally been granted with no reduction in the amount of funding provided. Also in numerous instances. States have not delivered the annual data comparison report within the 120 days specified in the contract. Other situations i I
involve States sending NRC an invoice for work not performed, and in one i unusual case, the NRC was not sent an invoice for work until several years '
after the work was performed.
Overall, the NRC reactor inspection program has shown that licensees are conducting their radioactive effluent and environmental monitoring programs in conformance with NRC regulations. The confidence that has been gained in licensee programs through the inspection program was used es the basis for NRR to originally consider eliminating the environmental monitoring portion of the State contracts and recently to include elimination of the TLD program as well. Recent inspections of licensees' environmental monitoring procrams continue to show that these programs are maintained in conformance with NRC requirements, tous providing further support for NRR's position.
CONCLUSION:
The staff has concluded that although the program has provided a source of data inde>endent from the NRC ana' the liccasee, the data are not needed to support tie NRC inspection program to ensure that licensee programs are operated and maintained in compliance with NRC requirements.
Eliminating both components of the IRMP will save the NRC $1,167 million per year in direct contract costs. These funds have not been included in the NRC's fiscal year 1999 Internal Program / Budget proposal.
Note: There are staff members who disagree with the information in this paper and believe it misrepresents the value of the NRC TLD Direct Radiation Network. A pro attached memo. The posed Differing differing Professional opinion Opinion is will be handled inpresented accordancein the with the agency DPV/0P0 procedures, but we are forwarding this paper and the DP0 memo to the Commission because they could affect Commission decisions on the FY 1999 budget.
C0 ORDINATION:
OGC has no legal objection to the staff's position contained herein.
TM Office of the Chief Financial Officer has no objection to the resource est1 mates contained in this paper.
s l
The Commissioners !
RECOMMENDATION:
The Commission note that, unless otherwise directed by the Commission, the staff will eliminate the IRMP beginning in fiscal year 1999. The staff believes that one year is adequate time for States to prepare for an orderly termination of their program or to find other sources of funding in order to continue the program, s
L. Jh idi Call'an Exec ive Director for Operations
Attachment:
Memo to H. Miller, RI dtd 7/21 fm DRS. RI members re: DP0 SECY NOTE: In the absence of instructions to the contrary. 3ECY will notify the staff on Friday, August 15, 1997 that the Commission, by negative consent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners oGC oCAA U1G OPA oCA AcRS CIo CFo EDO-REGIONS SECY
, AL-31-1997 13108 USlRC Rl/OFC OF REG ADN 6103375341 P.02/06 p* **eg\ UNITfo STATES
, NUCLEAR HEQULATORY COMMISSION REGloN 1 KINO oF PR Ss A. NN VAN A 19451416 July 21, 1997 MEMORANDUM TO: Hubert J. Miller, Regional Administrator s' FROM: John R. White, Chief '
Radiation Safety Branch Division of Reactor Safety I e, / /
Roben J. Smt, bk.D., Senior Project Manager y Division of ravn Safety ,
Ronald L. Nimitz, CMP, Senior Radiation Specialist Radiation Safety Branch 49 l
Division of Reactor Safety Frank M. Costello, CHP, Chief Nuclear Materiais Safety Branch 3 8g Division of Nuclear Materials Safet s _ __ ,
m m-Richard K. Struckmeyer, . ,, Se or roject SclMist Emergency Preparedness and Safeguards Branch Division of Reactor Safety
SUBJECT:
DIFFERING PROFESSIONAL OPINION-PROPOSED CHANGE TO THE INDEPENDENT RADIATION MONITORING PROGRAM This Differing Professional Opinion (DPO)is submitted in accordance with Management Directive 10.159. We recognize that the issue involves a Commission action that is not within the 9egion's decision authority. Accordingly, we recommend that this matter be forwarded to Office of Nuclear Reactor Regulation or the Executive Director of Operations for formal pro (essing as specified in the Management Directive.
The attached dratt memorandum for The Commissioners presents the staff's recommendation f 3r eliminating all the components of the Independent Radiation Monitoring Program (IRMP) Contract with the States. The primary focus of this Differing Professional Opinion is to provide more complete information and clarify misperceptions that may have led the staff to depreclate the value of the NRC TLD Direct Radiation Network (TLD Network) and include the system in its proposal for program eliminatlun.
Similarly, this DPO provides information that we believe will show that the value of the environmental sampling and analysis component of the IRMP has also been underestimated.
C6htact: JohriR. White (JRWl)
(610) 337-5114 a-
, Ju.-at-8997 a3 ce upac Rietrc C REG @r 6t03375341 P.03/06 i
l l
Though we have attempted to influence this matter in the course of normal business, we found that there was no time afforded or opportunity available to present our view in a manner that we believed would assure a fair hearing. While we appreciate end value the management resources required to process a DPO, we believe that th!s matter is sufficiently important to warrant this attention, in several aspects, the attached staff memorandurn does not adequately characterize the i TLD Network. For example, the basis for the origia of the program is not accurately portrayed, the benefits that NRC has derived from its implementation are not fully 1 expressed, and the possible deleterious effects of not having such a program are not !
explored. Accordingly, the intent of this DPO la to provide clarification and Information that may be useful to the Commission in attaining a more accurate view of the value and utility of the TLD Network, and better understanding of the benefit provided by the independent sampling and analysis component of the IRMP, The TLD Network was formed as an outcome of several assessments, analyses, and critiques of the agency following the TMI 2 accident, including a special President's Commission review. Those reviews examined several aspects of the agency's performance and technical assessment ability, including the capability to provide reliable and timely post accident estimate of population exposure in the event of a nuclear accident. Lack of this distinct capability was evidenced by the extreme difficulty experienced by the agency in establishing a reliable and conclusive dose estimate to the public following the TMI 2 accident. As a result, a specific requirement for NRC to establish a TLD network
, surrounding each reactor site was carried forward in the "NRC Action Plan Developed as a Result of the TMi 2 Accident," (NUREG 0860, item lli.D.2) in order to effect a reliable independent assessment of population dose in the case of future radiological accidents or events. Consequently, the TLD Network was established by NRC to meet that express
- purpose, and by doing so also accomplished the following; (1) establishment of a reliable, uniform, and consistent method of handling, calibrating, and processing the TLD devices, and reporting dose monitoring results; (2) establishment of baseline dose information for the environment surrounding each reactor site, nationally; (3) provision of reliable and timely post accident dose information following an accident or radiological event; (4) provision of an independent confirmatory evaluation of licensee's environmental radiation dose monitoring programs; and (5) provision of uniform, consistently derived, accurate, and high quality dose information for the use of the public, Congress, state and local governments, and other federal agencies, in fact, the program directly serves to support one of NRC's fundamental missions by providing independent knowledge and information of actual exposure to the public and the environment as the result of normal reactor operations or in the case of an accident or event. Given that background, and in the absence of any other existing compensatory program that accomplishes the same objective, a proposal to eliminate state contract support for the NRC TLD Direct Radiation Monitoring Network appears contradictory to the very rationale and bases for its establishment.
From its inception in August 1979, the TLD Network nrogram has been low cost and efficient. Current implementation costs are about $200,000 per year for state contract support,1 FTE of dedicated NRC technical support, and various other administrative expenditures incidental the publication and distribution of reports and information on program results.
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g JUL-21-1997 13808 U9RC Rl/CFC CF REG ADr1 6103375241 P.04/06
- 4 Though economical, the output of this program has been a continuous and highly reliable database of the radiological dose Impact of nuclear power plant operation on the public and environment that is virtually indisputable. Off normal conditions or events that result in radioactive releases can be readily discerned and assessed to confirm and determine actual radiological significance and health and safet/ Impact to the public. Due to the high level of quality assurance and data reliability Incorporated in the program, the TLD Network has been successfully demonstrated to be usefulin addressing public concerns involving radiological releases, bounding and confirming the radiological health and safety
, significance of actuel radiological events, and verifying and validating the environmental measurements made by licensee and State monitoring programs. Actual events in which the TLD Network was used to support NRC dose assessment efforts, include, but are not limited to: the Glnna steam generator tube rupture event in 1982;the Hope Creek south plant vent release in 1096; the inadvertent radiological release from the auxiliary boiler at FitzPatrick in 1991; and the "C-10" organization's assertion of a significant release from Seabrook in 1996. The TLD Network was also valuable in monitoring and assessing several materials sites, including Clntichem, the Royersford sewerage facility, Reed Kepplar Park In Chicago, and DOE's West Valley Demonstration Project. Without the TLD Network, the agency wr uld need to rely, exclusively, on licensee or other data sources, if available, to ascertain safety significance and impact; and become engaged in extensive inspection, plant data review, and various radiological measurement verification and validation efforts to estimate actual dose to the public and environment. In such case,it is possible that our ability to establish a timely, reliable, and conclusive ast.assment would suffer, just as it did at TMIin 1979.
Further, even when such efforts are pursued, experience indicates that conclusiveness is not always assured, it has been observed that lack of information on which to base reliable decisions and responses tends to result in strong criticism of the agency's ability and performance, relative to expectations of the public and congressional overseers. The consequence is a poor perception of NRC credibility and effectiveness. Obligatory remedial efforts are usually implemented that require the expenditure of additional agency resources to respond to the criticism; develop ad hoc compensatory efforts; determine and implement corrective actions to address perceived weaknesses; and establish long term program improvements. All of these aspects were factors that led the agency to establish the TLD Direct Radiation Monitoring Network in the first place.
Additionally, lack of a independent measurement resource would require the agency to rely on non-Independently determined data. Such reliance requires dependency on the quality of the licensee's or other supp!Ier's procedures, hardware, and equipment used to develop the information. Such dependency at a time when there is a real public expectation that our agency willindependently derive data on which to base conclusions and safety assessment may tend to create the perception of the NRC as weak and ineffectual. As stated in the program bases published in NUREG 0837,"NRC TLD Direct Radiation Monitoring Network, Progress Report," the agency concluded from its experience during the TMl accident, that reliance on licensee estimates of population exposure during an accident sltuation was unacceptable, i
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4 g JUL-21-1997 13803 LSRC Rl/CFC CF REG PM 6103375241 P.05/06 e
Recognizing the perceptions currently held by a large portion of the public and media regarding the veracity and performance of several nuclear utilities, and even the NRC, reliance on licensee supplied information appears imprudent. Many nuclear utilities are transitioning to leaner and more competitive organizations that may not have, or be able to sustain, the necessary technical ability and resource to implement and maintain a high Quellty environmental monitoring system. Further, by NRC electing to eliminate the TLD Network in f avor of minor budget savings, we will may inadvertently reinforce the notion that such monitoring programs lack worth and value. Given this likely outcome, the continued maintenance of this economical, highly reliable, independent confirmatory measurement and monitoring program appears politically and technically advisable. Rather than a liability, this program has been demonstrated as a proven asset. Its elimination, without an equally effective compensatory measure, would impair the agency's performance.
In 1995, NRR dropped funding for the Confirmatory Measurements inspection Program.
This program provided an Independent verification and validation of the licensees' ability to effectively and accurately measure and analyze effluent releases to the environment. At the same time, NRR ended contractor (DOE) support for the confirmatory measurements program. This eliminated qualified independent laboratory support to the NRC for the measurement of the more difficult radionuclides at power plants (principally, the short lived noble gases which influence emergency preparedness activities). The same year, NRC also declined to support the long standing EPA environmental cross check program that was previously required by technical specifications, resulting in a less effective regulatory requirement. Additionally, the staff proposalindicates that If the TLD Network and the environmental monitoring portion of the state contract were eliminated, the NRC could still verify compilance with the requirements of the environmental program. While true, it should be noted that the requirements do not define program performance or quality, but rather establish the processes for sampling, analytical schedules and various adminlstrative specifications. We also understand that the rationale to eliminate the Confirmatory Measurements Program (and the staff's 1995 proposal to terminate contract support for the environmental sampling and measurement component of the IRMP) considered the continued availability and maintenance of the TLD Network in support of those actions, if true, acceptance of the current recommendation would undermine some of the bases for those earlier endeavors.
Notwithstanding these arguments, by elimination of the TLD Network, the NRC would lose the only independent confirmatory tool that it has to promptly estimate the consequence and significance of radiological events involving every U.S. nuclear power plant.
Accordingly, we believe that the staff proposal underestimates the value of the TLD Network and the state contract programs, and does not adequately explore or address the potential consequences of such action.
We also offer the opinion that confirmatory measurement type activities are efficient methods in gaining insight on licensee performance due to the ability to provide direct information on actual outcomes, and consequently determine the success of the associated processes and programs. Accordingly, NRC an inspection program that combines program and process review aspects with confirmatory measurement endeavors should result in increase ' efficiency and effectiveness.
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AL-21-1997 13109 USNRC Rl/0FC OF REG ADM 6103375241 P.06/06 e
RECOMMENDED ACTION Though NMSS and OSP have already concurred on this recommendation, we believe that the decision deserves more critical review and justification then provided by the staff's memorandum. Given the lessons learned basis for the estabilshment of the program resulting from NRC's TMI 2 accident experience, the demonstrated benefit afforded by the availability of a reliable and continuously functioning monitoring system and database, and the potential to impelr the agency's ability to be fully effective and perceived as credible, the program offices and the Commission should consider allof the aspects that determine the worth of TLD Direct Radiation Monitoring Network to the NRC's mission and purpose.
Additionally, the Commission should reconsider the advisability of elimination of state contracts for environmental sampling and analysis in view of the compensatory coverage that this program provides to NRC assessment of licensee performance. Further, since there are many other entities that are directly affected by the Commission's decision in this matter,it is recommended that comment and input be solicited from other stakeholders including NRC regional staff, and members of the pubile and affected state egencies.
Attachment:
As Stated cc:
W.L. Axelson, DRA J.T. Wiggins, DRS A.R. Blough, DNMS 5
, TOTAL P.06