Nuclear Regulatory Commission's Proposal for Generic Environmental Impact Statement for Unknown, Untested Nuclear Reactors Ruled Deficient by Expert

Strategic Insights -

The Nuclear Regulatory Commission's (NRC) proposal to produce a generic environmental impact statement (GEIS) for small-scale advanced nuclear reactors (ANRs) has been strongly opposed by Linda Black, an expert in the field. The stated purpose of this proposal is to "streamline" the environmental review process for unknown, untested types of nuclear reactors, contradicting the primary mission of the NRC, which is to protect the public health and safety.

The NRC has no experience regulating "advanced" nuclear reactors (ANRs), with only three commercial non-light-water reactors ever built in the US since the 1980s, all licensed before the NRC was created in 1975. The lack of experience in regulating such a wide variety of possible reactor designs is critical, as adequate regulation requires rigorous study, extensive knowledge of all the possible designs, and experience. The NRC has only issued GEIS's for other issues after years of real-world industry and regulatory experience, and creating a generic environmental review is an exercise in speculative fiction.

Key Takeaways:

  • The NRC lacks experience regulating "advanced" nuclear reactors (ANRs), a critical component for adequate regulation.
  • There is no such thing as a "generic" ANR, with potentially dozens of different combinations of fuel sources, fuel designs, moderators, and coolants, each with distinct safety issues and environmental impacts.
  • ANRs would generate many different kinds and forms of radioactive waste, difficult to manage, and potentially require on-site reprocessing of irradiated nuclear fuel, leading to enormous environmental impacts.
  • The environmental impacts of small-scale ANRs would have significant environmental justice impacts, from siting and construction to reactor operations, leaks, and accidents.
  • The NRC must consider the futility of streamlining the environmental review and licensing process for ANRs due to the realities of climate change and the evolution of energy alternatives.
  • "Advanced" nuclear reactors cannot be safely licensed and built quickly enough to address climate change, and their deployment would occur in the 2030s or 2040s, after dramatic changes in water temperatures, sea-level rise, weather patterns, and other siting conditions.
  • Renewable energy, energy efficiency, battery storage, smart grids, and other sustainable, carbon-free energy resources are rapidly falling in price and making technological leaps and bounds far faster than the nuclear industry can possibly keep up.

Statistics:

  • 40-60% reductions in greenhouse gas emissions (from 1990 levels) by 2030.
  • Small-scale ANRs would not be ready for widespread commercial deployment until the 2030s or 2040s.
  • Renewable energy, energy efficiency, battery storage, smart grids, and other sustainable, carbon-free energy resources are rapidly falling in price, with wind, utility-scale solar, and energy efficiency being the lowest cost energy resources available.

Sources:

  • Linda Black, MD (21797)
  • Federal Register Notice: 85FR24040
  • Docket IDNRC-2020-0101: No Generic Review for Unknown, Untested Nuclear Reactors
  • Fermi unit 1 (1966)