Nuclear Regulatory Commission's Proposal for Generic Environmental Impact Statement Sparks Widespread Concerns

Strategic Insights -

The Nuclear Regulatory Commission's proposal to produce a "generic" environmental impact statement (GEIS) for "small-scale advanced nuclear reactors" has sparked widespread concerns among experts and environmentalists. The stated purpose of this proposal is to "streamline" the environmental review process for unknown, untested types of nuclear reactors. However, critics argue that this would contradict the NRC's primary mission to protect the public health and safety, not to promote the commercial nuclear energy industry.

Key Takeaways:

  • The NRC has no experience regulating "advanced" nuclear reactors (ANRs), with no commercial "non-light-water reactors" in operation in the US since the 1980s.
  • Creating a generic environmental review for ANRs is an exercise in speculative fiction, as there is no such thing as a "generic" ANR, with potentially dozens of different combinations of fuel sources, fuel designs, moderators, and coolants.
  • There is no basis for assuming accidents with "small-scale" ANRs would not be able to cause significant offsite radiation releases, as history shows there is no such thing as an accident-proof nuclear reactor.
  • Advanced reactors would generate many different kinds and forms of radioactive waste, making it even more difficult to manage than produced by the current light-water reactors.
  • All of the environmental impacts of small-scale ANRs will have significant environmental justice impacts, from siting and construction, to reactor operations, leaks, and accidents.
  • The pursuit of the GEIS proposal is a waste of NRC's resources, and would compromise NRC's public health and safety mission.

Statistics:

  • 40-60% reductions in greenhouse gas emissions (from 1990 levels) by 2030 are necessary to address climate change, with industrial nations like the US needing to achieve reductions at the high end of that range.
  • By the 2030s or 2040s, ANR designs (small-scale or large-) would not be ready for widespread commercial deployment, by which time water temperatures, sea-level rise, weather patterns, and other siting conditions will already be changing dramatically.

Sources:

  • Vivienne Lenk (June 11, 2020)
  • Nuclear Regulatory Commission (Docket IDNRC-2020-0101: No Generic Review for Unknown, Untested Nuclear Reactors)
  • Federal Register Notice: 85FR24040
  • Comment Number: 1968 Mail Envelope Properties (146616514.681.1591883190155.JavaMail.tomcat)