Environmental coalition meets NRC's "Nuclear Waste Confidence" DGEIS public comment deadline

Environmental coalition attorney Diane Curran

(The risks of generating, storing, and ultimately "disposing" of irradiated nuclear fuel includes risks to human health, of course. Environmental coalition expert witnesses have looked at the risks of high-level radioactive waste storage pools, dry casks, and repositories leaking, and/or releasing catastrophic amounts of hazardous radioactivity due to natural disaster, accident, or attack.

Even the costs of storing and "disposing of" irradiated nuclear fuel reflects the risk to human health. After all, the high cost has entirely to do with the need to isolate the high-level radioactive waste from being released into the living environment.

Mark Cooper of Vermont Law School, expert witness on behalf of this environmental coalition, has estimated that storage and disposal of irradiated nuclear fuel could add $210 to $350 billion onto the costs of nuclear-generated electricity in the U.S. In addition, the once-per-century replacement of dry cask storage across the U.S., assumed by NRC in its "Nuclear Waste Confidence" DGEIS, would add another $100 billion per replacement, Cooper estimates. Cooper asserts that NRC cannot ignore such "staggering" costs in its EIS on the costs and risks of generating irradiated nuclear fuel in the first place -- that is, approving new reactor construction and operating licenses, and old reactor license extensions.)

An environmental coalition of nearly three dozen groups, including Beyond Nuclear, has submitted comments on the U.S. Nuclear Regulatory Commission's (NRC) "Nuclear Waste Confidence" Draft Generic Environmental Impact Statement (DGEIS). The coalition is represented by a team of attorneys, including Diane Curran (photo, left) of Harmon, Curran, Spielberg, and Eisenberg, LLP, Washington, D.C.; Mindy Goldstein, Director, and Jillian Kysor, Fellow, Turner Environmental Law Clinic, Emory University, Atlanta, GA; and Phillip Musegaas, Hudson River Program Director, and Deborah Brancato, Staff Attorney, Riverkeeper, Ossining, NY.

The coalition is also represented by a team of expert witnesses, including Dr. Arjun Makhijani, President, Institute for Energy and Environmental Research, Takoma Park, MD; David Lochbaum, Director, Nuclear Safety Project, Union of Concerned Scientists, Chattanooga, TN; Dr. Gordon Thompson, Executive Director, Institute for Resource and Security Studies, Cambridge, MA; and Dr. Mark Cooper, Senior Research Fellow for Economic Analysis, Institute for Energy and the Environment, Vermont Law School, South Royalton, VT.

The environmental coalition's comments, as well as its expert witnesses' declarations, have been posted on the Southern Alliance for Clean Energy (SACE) website, as well as at the bottom of a press release featuring the work of Dr. Cooper on the economic costs of irradiated nuclear fuel management. The coalition's comment and expert witness declarations are also posted at the NIRS website.

Curran, on behalf of three environmental groups (Blue Ridge Environmental Defense League, Riverkeeper, and SACE), in alliance with Natural Resource Defense Council, as well as four state attorneys general (CT, NJ, NY, and VT) won a landmark legal victory on June 8, 2012. The D.C. Circuit Court of Appeals ruled that NRC had to carry out an environmental impact statement on its "Nuclear Waste Confidence" policy and rule, including the on-site storage risks of irradiated nuclear fuel in pools and dry casks. The Dec. 20th public comment deadline on the DGEIS is a part of that court-ordered process.