Nuclear proponents often argue that a permanent walk-away solution to the nuclear waste problem is required so as not to burden future generations. If such a solution is not available, however, then in fact future generations have already been burdened. In such a case NRC has a responsibility to address itself to the task of laying out a program of Rolling Stewardship that will make the burden manageable for future generations.
The NRC also has an obligation not to add to that burden unnecessarily. For this reason the NRC policy allowing licensees to use high burn-up fuels should be thoroughly reexamined and reconsidered with an opportunity for full public input.
In any event, the existing DGEIS is inadequate as a basis for NRC rulemaking.
CCNR recommends that NRC elaborate a set of rules and policies related to the concept of Rolling Stewardship as applied to the intergenerational management of irradiated nuclear fuel, including detailed mechanisms for transferring responsibility for managing the wastes from one generation to the next, mechanisms for funding the long-term management of the waste including monitoring, retrieval, recharacterization and repackaging of the waste and reinstructing each successive generation.
CCNR recommends that the current suspension of licensing decisions by
the NRC be continued indefinitely until the NRC has established detailed plans for the long term management of irradiated nuclear fuel that is not based on the unwarranted assumption that a safe permanent walk-away disposal method will become available within a few decades
CCNR finds that it is imprudent for NRC to base its entire analysis on the assumption that a geologic repository will become available within a few decades. To provide a thorough analysis of potential environmental impacts of spent fuel storage, NRC needs to analyze the consequences of an indeterminate delay in the availability of such a geologic repository, as well as the implications of such a repository never becoming available. Anything less than that would be tantamount to basing policy decisions on wishful thinking.
This text was submitted to the US Nuclear Regulatory Commission on December 20, 2013, by Gordon Edwards on behalf of the Canadian Coalition for Nuclear Responsibility. It addresses the nuclear waste question head-on.