Long-Term Waste Confidence and Temporary Storage of Spent Nuclear Fuel

Blue Ridge Environmental Defense League, the Institute for Energy and Environmental Research, Natural Resources Defense Council, Riverkeeper, and Southern Alliance for Clean Energy hereby submit comments on the NRC’s draft report, “Background and Preliminary Assumptions for an Environmental Impact Statement – Long-Term Waste Confidence Update” (December 2011). The Draft Report should be withdrawn because the assumptions it proposes are inconsistent with the National Environmental Policy Act and NRC regulations. In addition, by indicating that the NRC plans to prepare an EIS that discusses the environmental impacts of long-term SNF storage without also discussing the impacts of SNF disposal in a repository and the impacts that may occur if SNF disposal is never achieved, the NRC unlawfully segments the environmental analysis for SNF disposal. Finally, the NRC’s decision to issue the Draft Report without publishing a notice in the Federal Register is inconsistent with the NRC’s open government policy and long-established practice.