ML24295A084

Comments from Bill Dam on Advance Act

ML24295A084
Person / Time
Issue date:	10/16/2024
From:	NRC/EDO
To:	NRC/EDO
References
Download: ML24295A084 (1)

Text

From:

do-not-reply@nrc-gateway.gov To:

ADVANCE-Act Resource

Subject:

[External_Sender] Response from "Contact Us About the ADVANCE Act of 2024" Date:

Wednesday, October 16, 2024 1:53:08 PM ContactUsID: 6794 ContactUsNotificationRecipient: ADVANCE-Act.Resource@nrc.gov ContactUsNotification

Subject:

Response from "Contact Us About the ADVANCE Act of 2024" Category: NRC Licensing Processes ContactUsDocumentTitle:

ContactUsNumberTitle:

Question or Comment: I attended public meetings today and on September 25th, 2024. So far at both meetings, the NRC requested public "scoping" comments on the ADVANCE Act but has not provided proposed decisions that must soon be provided to Congress. I submitted comments on Section 506 to modernize nuclear reactor environmental reviews on September

26. The report to Congress on Section 506 is due in early January 2025. Will there be an opportunity to review and provide comments to this draft report to Congress or will it be considered a final report? How can the public provide comments in the process to evaluate NRC recommendations? At the meeting today, the NMSS Director responded to a question that the ADVANCE Act is being considered beyond the Congressional direction for "advanced nuclear reactors" and being considered for all parts of the agency. This increase in scope warrants an increase in public awareness to all programs nationwide and internationally with participation including from IAEA, other federal agencies, state and local governments and sovereign Native American tribal governments. For example, questions were asked at today's meeting about nuclear waste storage and disposal but no one from the Department of Energy responded. However, the Advance Act (Section 506 items D-F) directs NRC to coordinate with other agencies during the NEPA process. Before changes are made to the process, more public meetings are needed to involve these other groups with public engagement to understand what the NRC recommends. I recommend NRC consider providing the draft report on Section 506 to Congress and offer a public comment period to review and incorporate comments as is typically done in the EIS process: scoping, draft EIS, final EIS.

This would enable NRC to meet its obligation for submitting a report on time and for including additional public input. Support for carbon-free nuclear power is increasing and this is a timely opportunity to increase public pressure on Congress for finding a permanent geologic repository for high-level radioactive waste. The statement that taxpayers will be subsiding about half of the increased mandates resulting from the Act needs to be detailed.

What aspects of the pre-application and application process will be paid by the industry or by taxpayers? The public are not generally involved in pre-application meetings so using tax payer dollars would be inappropriate. While the current process of 25 tasks presented today is efficient for NRC to accomplish requirements on many different timelines over the next few years, a reasonable person will not be able to put the pieces together. Therefore, I recommend one overarching mission document is needed in responding to the ADVANCE Act. A question today asked how will these changes might change Reg Guides and other documents. No

answer was provided. The industry and public need clarity for what will be affected by regulatory changes and the timelines. For example, Reg. Guide 4.2 to prepare environmental reports will need to be updated for changes to the Act Section 506 and 10 CFR Part 51. With the 50th anniversary of NRC and preparing for the RIC in March 2025, I suggest the EDO recommend to the Commission: 1) that the ADVANCE Act is vital for the nation's civilian nuclear program and necessitates demonstration as an independent regulatory, similar to the Federal Reserve 2) one holistic agency-wide document describing all functions of NRC will be prepared focusing on proposed changes 3) the NRC organize a panel for the RIC involving a wide number of agency experts to describe the changes being made from the Advance Act.

Would you like to remain anonymous?: False Name: Bill Dam E-mail: billydam@gmail.com Organization: Independent Environmental Consultant Address:

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Country: United States of America Phone: 970-260-8915 ContactUsCaptcha:

Form inserted: 10/16/2024 5:52:39 PM Form updated: 10/16/2024 5:52:39 PM