ML23031A090
| ML23031A090 | |
| Person / Time | |
|---|---|
| Issue date: | 01/27/2023 |
| From: | Brooke Clark NRC/SECY |
| To: | Nordhaus T Breakthrough Institute |
| Shared Package | |
| ML22361A170 | List: |
| References | |
| LTR-22-0360 | |
| Download: ML23031A090 (4) | |
Text
1 NRCExecSec Resource From:
NRCExecSec Resource Sent:
Friday, January 27, 2023 4:07 PM To:
Ted Nordhaus; NRCExecSec Resource Cc:
adam@thebreakthrough.org; rani@thebreakthrough.org; Wesley Held; Bridin McCloskey
Subject:
RE: Re: NGO participation in Commission briefings Hello Mr. Nordhaus -
Thank you for the follow-up. Pursuant to your request, The Breakthrough Institutes letter to the Commission and the response thereto have been placed in public ADAMS and may be found at the following ADAMS accession numbers: ML22361A168 and ML23004A201. Youll find the links below:
View ADAMS Properties ML22361A168 Open ADAMS Document (LTR-22-0360 Ted Nordhaus, Founder and Executive Director, The Breakthrough Institute, Letter re: request for balanced NGO stakeholder participation at the NRC Commission briefings)
View ADAMS Properties ML23004A201 Open ADAMS Document (LTR-22-0360 01-03-23 Response to Letter from Ted Nordhaus The Breakthrough Institute re: Request for Balanced NGO Stakeholder Participation at the NRC Commission Briefings)
Office of the Secretary U.S. Nuclear Regulatory Commission From:TedNordhaus<ted@thebreakthrough.org>
Sent:Wednesday,January25,20231:24PM To:NRCExecSecResource<NRCExecSec.Resource@nrc.gov>
Cc:adam@thebreakthrough.org;rani@thebreakthrough.org;WesleyHeld<Wesley.Held@nrc.gov>;BridinMcCloskey
<Bridin.McCloskey@nrc.gov>
Subject:
[External_Sender]Re:NGOparticipationinCommissionbriefings
Dear Ms. Clark,
Thank you for your attention and timely reply. The Breakthrough Institute appreciates future consideration for participation in the Commission briefings. We respectfully request that the formal letter sent to the Commission on December 22, 2022, be made publicly available in ADAMS, and that the Commission respond in kind with a formal reply letter that is also made publicly available in ADAMS.
Sincerely,
Ted Nordhaus Founder and Executive Director The Breakthrough Institute
OnTue,Jan3,2023at4:51PMNRCExecSecResource<NRCExecSec.Resource@nrc.gov>wrote:
Dear Mr. Nordhaus:
2 Thank you for your letter, which has been received and distributed within the NRC. When the Commission decides who will participate in its meetings, it does attempt to achieve a balance in the points of view represented at the meeting, with a goal that participating stakeholders will give the Commission information on a range of views on a given topic. We do appreciate your interest in participating and will keep The Breakthrough Institute in mind for future meetings on advanced reactor licensing topics.
- Best, Brooke Poole Clark, Secretary U.S. Nuclear Regulatory Commission From:TedNordhaus<ted@thebreakthrough.org>
Sent:Tuesday,December27,202211:07AM To:ChairResource<Chair.Resource@nrc.gov>;CMRBARANResource<CMRBARAN@nrc.gov>;CMRWrightResource
<CMRWright@nrc.gov>;CMRCaputoResource<CMRCaputo.Resource@nrc.gov>;CMRCrowellResource
<CMRCrowell@nrc.gov>
Cc:WesleyHeld<Wesley.Held@nrc.gov>;AdamStein<adam@thebreakthrough.org>;RaniLeaFranovich
<rani@thebreakthrough.org>
Subject:
[External_Sender]NGOparticipationinCommissionbriefings
DearCommissioners,
PleasefindattachedandpastedbelowcorrespondencerelatedtotheDecember8thcommissionbriefingadvanced reactorfuelactivities.WerespectfullyrequestthatthecommissionsolicitabroaderrangeofNGOperspectivesin futurecommissionbriefings.
Thankyouforyourconsideration.
Ted
Chair Christopher T. Hanson; Commissioner Jeff Baran; Commissioner David A. Wright; Commissioner Annie Caputo; Commissioner Bradley R. Crowell U.S. Nuclear Regulatory Commission
3 Washington, DC 20555-0001
Subject:
Request for balanced NGO stakeholder participation at the NRC Commission briefings
Dear Commissioners,
I write to express concerns about the December 8, 2022, Commission briefing on the Overview of Advanced Reactor Fuel Activities, in which the following stakeholders were offered the opportunity to engage the Commission:
Andrew Griffith, Department of Energy; Sander van Til, Nuclear Research and Consultancy Group; Jennifer Wheeler, TRISO-X; Dr. Christina Back, General Atomics; James Volmer, TerraPower; Dr. Rusty Towel, Abilene Christian University; and, Dr. Edwin Lyman, Union of Concerned Scientists (UCS).
While we applaud the NRC for extending an opportunity for members of the NGO community to contribute to the discussion, we object to the decision to limit NGO participation to a single NGO, UCS, that does not reflect the balance of opinion among NGOs regularly engaged with the NRC.
Open discussion and debate at Commission meetings with NGOs, as well as other stakeholders, on advanced reactor topics is, of course, welcome. Facilitating a discussion requires that a range of viewpoints and perspectives be present and represented. UCS stressed a number of concerns regarding advanced fuel qualification and advanced fuel performance, implying that the NRC was being pressured to accelerate approvals by weakening its safety standards for the demonstration of fuel performance and equating efforts to assure the timely licensing of advanced reactors with compromising safety in the licensing process. These views are not widely shared by most NGOs that have been engaged in NRC proceedings related to the licensing of advanced reactors.
Although other non-NGO stakeholder panelists countered the claims presented by UCS, it is important for the Commission to recognize the critical difference between government and industry stakeholders and NGOs. As independent, civil society entities bringing broader public interest concerns to issues regarding licensing and regulation of advanced reactors, NGOs play a different role.
In response to questioning from Commissioner Crowell, Lyman further expressed satisfaction with and support for the NRC staffs work on the proposed Part 53 rule and engagement with stakeholders. While this may be true for Lyman and UCS, it is not a sentiment that is widely shared within the NGO community. To the contrary, both NGO and industry stakeholders have repeatedly urged the staff to engage stakeholders more seriously in the development of the proposed rule and have consistently raised concerns that the current proposal is overly burdensome and complicated while failing to comport with congressional direction to develop a risk-informed and performance-based framework for advanced reactor licensing.
This recent commission briefing reflects a pattern that we, along with other stakeholders, have recently observed.
Despite a notable increase in NGO engagement at NRC public meetings over the last several years, there has been an absence of NGO participation in many NRC Commission briefings. When NGO participation is solicited, it has almost exclusively been offered to Dr. Lyman and UCS.
It is our view that this failure to solicit a fuller range of perspectives from the NGO community through direct engagement with the Commission has proven harmful to informed, constructive decision-making on matters related to the licensing of advanced reactors that are critical to the national interest. Moving forward, we would request that the commission and staff provide more opportunities for NGOs representing a more diverse set of perspectives to directly engage with the Commission at future briefings. A consistently well-balanced representation of NGOs representing the publics interest is crucial to informing meaningful actions by the commission. In this regard, we, along with other members of the NGO community, which has spent countless hours attending NRC proceedings and reviewing and commenting on NRC proposals, should be given equal opportunities to participate and contribute to these meetings.
Sincerely,
4 Ted Nordhaus Founder and Executive Director The Breakthrough Institute Washington, DC 20005
TedNordhaus,FounderandExecutiveDirector BreakthroughInstitute 2054UniversityAve,Suite500 Berkeley,CA94704
Mycellphoneis5104108011
TedNordhaus,FounderandExecutiveDirector BreakthroughInstitute 2054UniversityAve,Suite500 Berkeley,CA94704
Mycellphoneis5104108011