Site Suggestions 

A couple of suggestions:
- Display the number of I Agree/I Disagree votes, as well as the average, for example: I Agree(5) and I Disagree(10), total -5. (1)Agree + (1)Disagree = 0 is not very useful.

- Display date and time for each post, to provide more context.

Congratulations on this effort.

Nuclear Waste Disposal 

Make it clear to the public what is currently being done about nuclear waste, and what the future of nuclear waste disposal is.
Since Yucca Mountain is not open, there are no options beyond illegal overflow storage at individual facilities.
How will future facilities contribute to the waste stream?

Provide vision into NRC regulatory costs 

NRC is primarily funded by fee from current licensing and certification projects. I am interested in obtaining a view into the regulatory process to determine if there are areas where a disproportionate amount of time is spent while producing only a small (or negligible) safety improvement. Is it possible to invent a new tool that would allow decision makers and the public to figure out where the majority of regulator's time is spent when certifying new reactor designs or reviewing new COL license applications?

Making licensing information available online 

[Submitted by a member of the public through Regulations.gov]

We welcome this opportunity to provide comments regarding which data sets the NRC could most usefully place online. I discussed this issue more extensively in a law review article entitled "Spotlight on Safety at Nuclear Power Plants: The View from Oyster Creek," 26 Pace Environmental Law Review 365 (2009), which may be found at:
http ://digitalcommons. pace.edu/envlaw/569/

That article concludes that there are a number of extremely high value data sets related to the safety of nuclear power plants that are not currently available to the public. These include:

i)a compilation of links to documents that would allow the public to determine the Current Licensing Basis("CLB");
ii)a database of issued exemptions, violations (including NCVs), and license amendments, as well as ongoing corrective actions and investigations, with links to the relevant detailed documents;
iii)a log of documents that have been withheld from public release with an explanation of the reason for the lack of disclosure;
iv)licensee documents that the NRC has reviewed to make determinations regarding licensing, license amendments, exemptions, or violations (including NCVs).

We believe that the NRC is already in possession of all of the information that would be required to publish the information relating to. ii) and iii) online. In addition, the agency has, or should have, most of the information to compile i), although we recognize that could take considerable effort to assemble. With regard to iv), we request that the NRC make it a policy to place all reviewed licensee documents online from now on. We are not asking the agency to go back and compile all the documents that it reviewed in the past.

Decommissioning Fund information 

[Submitted by a member of the public through Regulations.gov]

The NRC should publish information on the current status of all decommissioning funds for operating nuclear power plants. This data set should be kept up-to-date as new information becomes available. Having such information readily accessible is necessary in light of recent revelations that many nuclear power plants across the country do not have sufficient decommissioning funds. A 2009 Biennial Decommissioning Funding Assurance Analysis indicates that at least 26 nuclear reactors had projected trust fund shortfalls.l" This has led to major concerns about how nuclear reactor sites will be properly and timely decommissioned once plant operations cease. ,For example, at Indian Point, acknowledging that the decommissioning fund for Unit 2 was projected to be almost $40 million short, the NRC approved a plan by owner/operator Entergy to delay decommissioning of the reactor for 50 years (to 2063) in order to allow time for the trust fund to accumulate the necessary funds. 12 The merits of allowing nuclear reactor sites to sit in "safe storage" for decades while trust funds increase to legally mandated amounts is highly questionable. Having current information readily available the public will assist in keeping the NRC answerable to the many concerns that arise from the existence of decommissioning fund shortfalls, including excessive delay of proper site remediation.

Moreover, having decommissioning fund information available will allow the public to more easily evaluate whether required trust fund amounts are going to be adequate to cover all actual decommission costs. Indeed, the NRC uses a highly conservative formula to determine the minimum amount of funds required to be in decommissioning accounts. This formula fails to accurately account for all aspects of decommissioning needed to return sites to Greenfield status,such as extensive groundwater contamination plumes like those at Indian Point.13 In fact, plant decommissioning costs estimates have actually demonstrated that projected costs have been far in excess of what NRC would require. 14 Accordingly, having decommissioning fund information accessible to the public will hold the NRC accountable to respond to concerns about insufficient trust fund balances, as measured against NRC's own minimum requirements.

Decommissioning fund information is also "high-value" information as contemplated by OMB, since it will: "improve public knowledge of the agency and it& operations" 15 by allowing thepublic to understand how NRC is handling the decommissioning process and problems therewith; "further the core mission of the agency" 16 by permitting the public to more effectively evaluate NRC's efforts toward ensuring proper protection of people and the environment at the time of decommissioning' 7; and "respond to need and demand as identified through public consultation,"18 since it would respond to public concerns about the ability of nuclear lower plant owners to sufficiently complete decommissioning activities in a timely manner.

Thus, the NRC should compile and maintain decommissioning fund information for every operating nuclear power plant for public scrutiny. This data set should include current decommissioning trust fund amounts, any information about actual decommissioning costs estimates, details about any current shortfalls along with the number of years it would take the licensee to accumulate the funds at a reasonable rate of return, and proposed or approved plans to deal with any identified shortfalls. This data set should also list all nuclear plants that have been decommissioned thus far, with the original estimate of decommissioning costs, and the final, actual cost listed side by side. Having this information available will undoubtedly foster public participation and inquiry about important environmental concerns associated with decommissioning.

__________________________________
11"2009 Biennial Decommissioning Funding Assurance Analysis, ADAMS Accession No. ML091940387.

12 See Letter from John P. Boska (Office of Nuclear Reactor Regulations, NRC) to Vice President, Operations, Entergy Nuclear Operations, Inc., Re: Indian Point Nuclear Generating Unit No. 2 - Decommissioning Funding Status Report (TAC NO. ME0528), December 28, 2009, ADAMS Accession No. ML093450778, at 1.

13 For an explanation of flaws in NRC decommissioning cost methodology, see generally, Comments Submitted by
the State of New York Concerning the NRC's Proposed Rulemaking.to Amend 10 C.F.R. Parts 20, 30, 40, 50, 70
and 72 to Require Certain Changes in Decommissioning Planning, NRC Docket No. RAN 31 5-AH45 (May 8, 2008),
ADAMS Accession No. ML081340325.

14 See, e.g., Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 2 (October 2008),
ADAMS Accession No. ML092260723 (estimating decommissioning costs for IP2 to be almost a billion dollars,
over double what NRC's regulations would require).

15 NRC Implementation of Open Government Directive, 75 Fed. Reg. at 1419.

17 NRC's website banner touts "Protecting People and the Environment." See http://www.nrc.gov/.
18 NRC Implementation of Open Government Directive, 75 Fed. Reg. at 1419.
19 See, e.g. supra Note 13.

Nuclear power plants' current licensing basis 

[Submitted by a member of the public through Regulations.gov]

One "high-value data set" that NRC should publish is the current licensing basis ("CLB") for all currently operating nuclear plants in the United States. NRC defines the "current licensing basis" as

--the set of NRC requirements applicable to a specific plant and a licensee's written commitments for ensuring compliance with and operation within applicable NRC requirements and the plantspecific design basis (including all modifications and additions tosuch commitments over the life of the license) that are docketedand in effect. 5

When confronted directly, the NRC has had noted difficulty defining what constitutes the CLB for particular nuclear power plants. This has become evident in license renewal proceedings, where NRC staff have not been always been able to adequately define current licensee commitments. Accordingly, there is a growing concern that many of the safety requirements that nuclear power plants must meet are vaguely defined and poorly understood by the NRC.6

With an increasing number of nuclear power plants applying for license extensions, this is very problematic, since issues pertaining to the CLB are considered outside the scope of license renewal review, However, the underlying assumption that nuclear power plants are in compliance with the CLB is wholly undermined by the inability of NRC staff to even identify what the CLB is?

A comprehensive understanding of what requirements are governing individual nuclear power plants is necessary to ensure proper oversight by the NRC. The efficacy of publishing the CLB for every operating nuclear power plant is, thus, quite apparent. This is precisely the kind of information "that can be used to increase agency accountability and responsiveness,'' that OMB
was contemplating as "high-value data" in the Open Government Directive. Indeed, publishing individual plant CLB's would hold the NRC directly responsible for knowing what regulations are applicable to each nuclear power plant, and assist the NRC in being able respond when problems with compliance arise.

Public availability of this information would also "improve public knowledge of the agency and its operations," 8 by allowing the public to develop an understanding of what requirements nuclear plants must obey and by helping to restore public confidence that the NRC understands its regulations and how to safely govern the operation of nuclear plants across the country.

Publication of individual plant CLB's would certainly "further the core mission of the agency," 9 which is ostensibly to ensure the safe operation of nuclear plants. Lastly, publishing the CLB would indeed "respond to need and demand as identified through public consultation," '0 since members of the public have raised concerns over the NRC's lack of understanding of the CLB.
Accordingly, Riverkeeper urges the NRC to publish individual nuclear plant CLB's as one of NRC's "high-value data sets," to comply with OMB's Open overnment Directive.

_________
5 10 C.F.R. § 54.3(a); see also NRC Generic Letter 92-03, Compilation of the Current Licensing Basis: Request for
Voluntary Participation in Pilot Program (March 19, 1992) ("A definition of CLB was set forth in Section 54.3.
Although set out in Part 54 [the plant license renewal Part], that definition represents the staff s understanding of the
scope of the CLB and should be applicable to all reactor licensees.").

6 See, e.g., Letter from Richard Webster (Eastern Environmental Law Center) to Joseph A. McMillan (Assistant
Inspector General for Investigations, U.S. NRC Office of the Inspector General), Re: NRC Staff Comments
Regarding License Commitments (June 1, 2009), attached hereto as Exhibit A.
7 NRC Implementation of Open Government Directive, 75 Fed. Reg. at 1419.

8 Id

9 Id.

10 Id.

Stakeholder process workshop 

[Submitted by a member of the public through Regulations.gov]

There should be a stakeholder process conducted annually that includes not just the usual beltway crowd, but critics of the NRC from around the U.S., who provide areview of how well the agency is doing in its alleged quest to become "transparent." Transparency is easy when there is nothing to see because the important material cannot be located and viewed or is withheld from public view. Becoming publicly transparent and actually making information and processes both visible and available to participate in, that is another matter entirely--and one that the NRC has a long, long way to go in achieving.

Make information easily accessible to public  

[Submitted by a member of the public through Regulations.gov]

All baseline data, past and current licensing basis data, licensing amendment, violations, corrective actions, exemption determinations, and any determinations not to make such data, documents, reports and materials available to the public should be available on-line at a single mouse click in a location that is accessible and easily navigated by a 6th grader.

Unavailability of certain document  

[Submitted by a member of the public through Regulations.gov]

The agency needs to review all past determinations concerning which documents should be public and get them on-line and available. I have complained numerous times to persons working at the highest levels of the NRC and the IG concerning the unavailability of certain document that should not have been classified "non public" -- e.g., a transcript of a telephone conference in the Yankee Rowe license termination case, annual reports of the Homestake Mining company and dozens of related documents (which were not released to the public until several years later when the licensee's own attorney's FOIAed them so they would not have to undergo the expense of copying them when providing them in a due diligence process). This kind of shoddy classification of documents is untenable and will not be eliminated until there is a top to bottom review of the classification process AND a complete review of all documents currently classified as "non-public".

ADAMS access 

[Submitted by a member of the public through Regulations.gov]

The U.S. NRC needs to go a very long way to comply with the White House initiative on open government. ADAMS access is abysmal. Even if documents are there, unless one is working at NRC Head Quarters, documents cannot be easily accessed with an adequate indexing system to make locating desired documents feasible. I was lucky enough to get a consultant at NRC to configure my MAC to have access. That lasted about two weeks. Then it stopped and the expert told me that there were problems and the entire system was going to be changed. Fat lot of good that does for anyone trying to meaningfully participate in an NRC proceeding or to intervene. Without access from outside to a decent, indexed system for document location and retrieval, anything else the agency does is just window-dressing.

Make all office instructions public  

[Submitted by a member of the public through Regulations.gov]

Currently, some of NRR's Office Instruction's (01's) are publicly available. However, some are non-publicly available. Since the OI's describe activities involving NRR's stakeholders, including the public, all of them should be made publicly available.

Note, some of the OI's that are currently non-publicly available, were previously publicly available. A decision was made in recent years to change the availability, however, it's not clear why that decision was made.

Database of environmental data results for nuclear power plant 

[Submitted by a member of the public through Regulations.gov]

Would it be possible for the NRC to share the database of all the environmental data results collected each year surrounding nuclear reactor sites? The database might include sample results from nuclear utilities, state oversight programs and the NRC. This would also address the openness concern raised some years ago in Illinois concerning the tritium releases from Exelon plants.

Sealed Source and Device Registry 

[Submitted by a member of the public through Regulations.gov]

I suggest the NRC provide access to the Sealed Source & Device Registry, if not to the public at large, at least to current licensees. I don't feel there is anything particulary sensitive to security contained in these certificates, and they are of invaluble use to licensees and others working with the manufacture, distribution, service, and purchase of these devices.

Daily Event Notifications in a map format 

[Submitted by a member of the public through Regulations.gov]

I would like to see the NRC publish the Daily Event Notifications in a map format, similar to the Google Maps mash-up employed by EPA (http://www.epa.gov/compliance/resources/reports/endofyear/eoy2009/2009-mapallactions.html). This form of viewing events would be particularly beneficial to a concerned public and would hopefully facilitate better understanding and tracking of events by the affected public. For example, if a citizen is concerned about a local nuclear plant, the current NRC website does not provide an intuitive or reliable method for summarizing events in a locale (or a facility).

It is my suggestion that the Daily Event Notifications y in a map format that allows aggregation of events over a selected time period (a user could see all events for last week, month, year, etc) and could sort by event types. A model for this type of data visualization is CrimeReports.com (http://www.crimereports.com/map?search= 1347+Maryland +Ave+NE%2C+washington+DC) Thank you for your consideration of this idea.

Metrics for Non-part 50  

[Submitted by a member of the public through Regulations.gov]

The NRC is without a doubt one of the most transparent organizations in the country. Relative to operating commerical nuclear power plants, the NRC already provides public access to the most comprehensive performance metrics for each licensee possible. I would not recommend a dramatic change in NRC transparency relative to power reactors or DOE facilities due to the sensitive nature of infomation that deeper transparency could reveal. The NRC web site and commission briefings are extremely forthcoming and reveal discussions on seemingly every detail of oversight associated with the commission.

If there were an area for improvement, I would state that there seem to be no metrics established for non-part 50 special nuclear material holders that the public can easily view. There seem to be a high number of medical, radiographic and geologic instrumentation incidents that recur. I believe the NRC could improve oversight structure and publish metrics for this area of regulatory service.

Make public meetings more accessible by putting them online live 

It's good to see that NRC Commission meetings are available on the website. I wish that I could also watch live online video from public meetings in other locations where it's not convenient to attend.

OpenNRC v2.0: A next gen opensource/opensocial portal 

A pilot project to build a next-gen Nuclear Regulatory Commission portal for the Federal Community Cloud. The idea is to build a suite of opensocial portals, one at each Federal Agency, based on The Open Stack that will enable communication with all opensocial partners.

Useful Links:
http://tinyurl.com/yks78pg
http://bit.ly/cUrTv8

NRC should live webcast all meetings 

NRC should live webcast all meetings for proposed rule making and regulations where the public comment should take place. They should make these meetings available for on demand viewing and have the ability to have that content be indexed for video search. By doing this the public and stakeholders will be able to see the inner workings of the rule making process and make the content and proceedings transparent to the public. It will also use effectively use internet video technologies for transparency and government efficiencies.

Provide the public access to an NRC FINDING search forum  

The NRC should give the public access to an NRC FINDING SEARCH FORUM/ a finding search engine.

This would have the benefit of the public being able to quickly search plants in their area or plants of interest with regards to NRC inspection findings. It would also allow groups such as the Union of Concerned Scientist (UCS) and Institute of Nuclear Power Operations (INPO) and individual licensees to do these searches thereby improving openness and hopefully industry response to NRC findings to help prevent recurrence. There is no reason why this information in this format - using a seach forum/ seach engine should not be made available to the public. These findings are publicly available information already, and this valuable tool should be made available to the public (exceptions for security related NRC findings would be allowed, of course, since these are not publicly available normally).

NOTE: The current internal NRC search engine for findings is available for NRC users only at:
http://nrr10.nrc.gov/ope-info-gateway/insp-findings-index.html

Publicly available documents in ADAMS searchable by Google, etc  

The NRC should make all publicly available ADAMS documents searchable by outside search engines (suchs as Google...and other search engines).

Also all Generic Communications (GCs) should be made searchable by the NRC public web page for GC's - after about 2007 the agency stopped posting the pdf file versions to our webpage generally, instead they startedlinking the GC's by ML number into ADAMS. This had the unintended consequence of making the GC's less searchable - only the titles are now being searched for items posted after 2007 (not the whole GC document). This should be corrected until, all Publicly Available ADAMS documents are made visible to external search engines.

See this web page where the search problem exits now:
http://www.nrc.gov/reading-rm/doc-collections/gen-comm/index.html

10 CFR 2.206 public participation  

Assign a senior NRC official to a petitioner. His job would be to help negotiate around the NRC bureaucracy and be a technical advisor to a petitioner. He’d be like NRC assigned lawyer or a NRC assigned public defender. His job would be to wholly serve the petitioner, then the community. The NRC bureaucracy and nuclear issues are technically too complex for the average person...let alone for the professionals.

So the petitioner needs a NRC professional advocator and he needs horsepower!

Searching for NRC documents 

The old Adam citric was a abomination. When this system (old adam) first came on the line years ago it was revolutionary...microfiche was the pits. The internet Adams search engine and the new public Adams are too frustrating to use and inefficient today. In public Adams, I have lost faith I can find documents that I know are in the NRC data base.

There is a huge frustration quotient with searching NRC documents. Public participation would be greatly enhance if the agency vastly increased the efficiency of searching NRC document.

What I see as a general statement...there is no direct NRC ownership over the public searching and participation capabilities.

Public participation on writing up inspection reports 

Revamp the ROP and the inspection report process. Make real time public participation the watch word with the NRC. With inspection reports, LERs, any other NRC special investigations...write up the report as a day by day process to and on the internet. Allow public internet questions and inputs as the report is written.

So the final report would include public participation?

Plant blog or message board...NRC participation  

How about a internet blog or message board for every plant. A member of the community and a NRC official could moderate the site...preferably a on site inspector. I suggest everyone has to be identified...no anonymous additions. On a case by case situation you might allow anonymous sources. There would have to be a respectful decorum. So members of the public and community could ask questions to the board and the NRC. NRC officials would be required to reply and within a certain time frame.

I would volunteer as moderator...how about we make VY a prototype or test plant?

Public 2.206 petition  

Make the 2.206 pre hearing internal deliberation public. Video record and place on the internet these deliberations. It would make board members more accountable to the community...not accountable to themselves in a private meeting. The prehearing is a black box and nobody knows how these deliberation work. If future users had true knowledge of the petition board member deliberation they might become more successful. I hope quality assurance people were watching these prehearings.

Really, you need to revamp the whole 10 CFR
2.206 Petitions process. I believe the last time was in 1999.

There is a too high evidence hurdle to participate in the petition process. It is too legalistic...the community and the NRC would be better served if you let people into system and everyone is continuously tested.

The NRC would be thought more of as a more transparent and credible regulator. The community would have greater assurance of safety if they knew people were banging around in the system and testing everyone?

The community and the industry would be better served if adversaries gained troubling inside information...to take out in the community and used it in any way they wanted (media). It would evolve the NRC and industry at a faster pace...we all would be better if outside people kept everyone on their toes.