The NRC Waste Confidence GEIS is No Excuse for Leaving Dangerous Nuclear Waste at Closed Nuclear Plants
Sierra Club letter to the NRC, Dec. 13. 2013
We appreciate the opportunity to comment on the above proposed regulation, known as the Waste Confidence Generic Impact Statement.
In our comments below, we present two major lines of concern:
(1) While the EIS framework has a long history in addressing environmental impacts, it may be inappropriate for risk assessment of spent nuclear fuel hazards over decades. Thus, even the most thorough EIS could be irrelevant to the critical issues at hand.
(2) The findings of the GEIS appear to seriously understate (a) generic levels of risk in storing spent nuclear fuel on-site at decommissioned reactors; (b) specific risk factors arising from characteristics of specific sites; (c) risk differentials of long-term or indefinite storage on-site rather than at a remote geologic repository; (d) added risks of on-site storage created by the use of high burn-up fuel.
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Nov. 13, 2013