NUREG-1437 FINAL GEIS COMMENTS – January 12, 2010

NUREG-1437 FINAL GEIS COMMENTS 01122010 pdf

RE: NUREG-1437, Revision 1, July 2009 [Docket ID NRC-2008-0608]- COMMENTS ALLIANCE FOR NUCLEAR RESPONSIBILITY, Nuclear Information Resource Service, Fairewinds Associates, Beyond Nuclear, Public Citizen, GRAMMES, Greenpeace, New Jersey Environmental Federation.

 The Alliance for Nuclear Responsibility, Nuclear Information Resource Service, Fairewinds Consultants, Beyond Nuclear, Public Citizen, GRAMMES, Greenpeace, New Jersey Environmental Federal. (hereinafter “A4NR, et al”) provides comments on NUREG-1437, Revision 1 issued July 2009. Section 1 discusses procedural issues and Section 2 makes comment on each section of the document.

 Background

 In 2003, the Executive Director of Alliance for Nuclear Responsibility—then representing another San Luis Obispo, California organization—was the only member of the public to attend the Nuclear Regulatory Commission’s (NRC) initial west coast meeting opportunity for public participation in the Generic Environmental Impact Statement Revision held in California.  It should seem obvious to most governmental agencies that when only one member of the public attends (in a state with a population of 36 million) there is a cause to doubt that public believed their participation was welcomed (or accessible, or convenient).  It should have raised questions about the NRC’s ability to notify the public of meetings and opportunities for participation. 

 Comments provided that evening in 2003 included a very important point which the NRC has again failed to seriously consider in the scheduling of meetings for public comments on its latest GEIS revision—the need to hold the meetings near the reactor communities.  Here they would find the citizens—the “stakeholders” whom the NRC refers to in its publications—with the most valid concerns about continued operation of aging reactors and the ongoing creation and onsite storage of highly radioactive waste on our state’s fragile coast.  In fact, it was clear from the sign-in sheets at GEIS meetings held in 2009 that the insistence by California’s elected representatives that meetings be held near reactor sites resulted in the only meetings where more that two members of the “public” were in attendance. A4NR, et al, continues to question sincerity of the NRC’s commitment to openness and transparency when the local public has to turn to its elected officials in order for the NRC to schedule meetings in affected communities.

 When the NRC scheduled of public meetings on the GEIS Revision over a hundred miles from either Diablo Canyon, SONGS or any other reactor community, it remains difficult for the public to believe the NRC considers our input valuable.  The locations chosen by the NRC signaled to the public, to those who live within the “fallout zones” of these and many other reactor facilities—and to their elected representatives— that their input was neither encouraged nor valued.  Lack of recognition that the public can and should provide valuable insight into the NRC’s oversight process continues.  The NRC’s inability to listen to the public in 2003 resulted in wasted time and resources and shadowed the public’s perception of the purported “openness” and transparency of the NRC’s current license renewal revisions.