Comments on the NRC’s Proposed Waste Confidence Rule Update

Comments on the NRC’s Proposed Waste Confidence Rule Update and Proposed Rule Regarding Environmental Impacts of Temporary Spent Fuel Storage ^[1]

Arjun Makhijani, Ph.D.
President, Institute for Energy and Environmental Research

The following are the comments of the Institute for Energy and Environmental Research
(IEER) on the Nuclear Regulatory Commission’s (NRC’s) proposed Waste Confidence Decision Update ^[2] and the associated Consideration of Environmental Impacts of Temporary Storage of Spent Fuel after Cessation of Reactor Operation. ^[3]

The proposed Waste Confidence Decision warrants careful examination, because it serves as the underpinning to several key safety and environmental findings regarding the operation of nuclear power plants and the disposal of the wastes that they generate.

• First, the Waste Confidence Decision presents a safety finding, under the Atomic
  Energy Act, that the NRC has reasonable assurance that disposal of spent fuel will not pose an undue risk to public health and safety. It does so via the finding that disposal is technically feasible and can be done in conformity with the assumption of zero releases in Table S-3 at 10 CFR 51.51, which specifies the environmental impacts associated with nuclear reactor operation, including those associated with nuclear wastes and emissions.
• Second, the Waste Confidence Decision provides the basis for a key assumption
  in the uranium fuel cycle rule that spent fuel can be isolated in a repository, with no radioactive releases. That finding, in turn, is key to the NRC’s conclusion that the environmental impacts of the entire uranium fuel cycle are insignificant. ^[4]
• Finally, the Waste Confidence Decision provides the basis for the NRC’s Finding
  of No Significant Impact (FONSI) regarding the environmental impacts of temporary spent fuel storage pending its disposal in a repository.

Continue reading the full comments. (PDF)