New York State Attorney General Eric T. SchneidermanA coalition of states (New York, Vermont, Connecticut, Massachusetts), as represented by each state's attorney general, and the Prairie Island Indian Community -- instrumental in winning the major federal court victory against the Nuclear Regulatory Commission in the first place in June 2012 -- has filed strong comments challenging NRC's Nuclear Waste Confidence Draft Generic Environmental Impact Statement (DGEIS) by the agency's Dec. 20th deadline. The Office of New York State Attorney General Eric T. Scheiderman (photo, left), as well as the Office of State of Vermont Attorney General William H. Sorrell (and the State of Vermont Department of Public Service), have led the multi-state/tribe coalition efforts.
The COMMENTS SUBMITTED BY THE ATTORNEYS GENERAL OF THE STATES OF NEW YORK, VERMONT, CONNECTICUT, AND THE COMMONWEALTH OF MASSACHUSETTS, THE VERMONT DEPARTMENT OF PUBLIC SERVICE, AND THE PRAIRIE ISLAND INDIAN COMMUNITY ON THE NUCLEAR REGULATORY COMMISSION’S DRAFT WASTE CONFIDENCE GENERIC ENVIRONMENTAL IMPACT STATEMENT AND PROPOSED RULE are backed up by extensive exhibits: Exhibit A; Exhibit B; Exhibit C; Exhibit D; Exhibit E.
The submissions also include additional comments by the States of Vermont and Connecticut, specifically, those prepared by expert witnesses Fred C. Dilger, GISP Ph.D., and James David Ballard, Ph.D. Drs. Dilger and Ballard's abstract states: This report examines the Draft Waste Confidence Generic Environmental Impact Statement (DGEIS) and the assumptions, methodology and conclusions used therein. The assumptions underlying the DGEIS prevent analysis of the real issues behind the indefinite storage of Spent Nuclear Fuel (SNF). The overall methodology used in the DGEIS does not provide a scientifically sound analysis of the issues. This report offers alternative methodologies, some of which have been used by the NRC in the past, in an effort to offer a roadmap for a more robust, valid and reliable means to analyze the environmental impacts of the proposed action. The conclusion addresses the need for the NRC to do a more meaningful and useful NEPA analysis.
The submissions also include additional ones by the State of New York, including: a Dec. 20, 2013 cover letter to NRC listing the additional submissions; a March 14, 2013 presentation by NYS Assistant AG John J. Sipos at NRC's Regulatory Information Conference; an August 20, 2013 NYS AG letter to NRC re: Aqueous Releases Following Severe Accidents at Indian Point Facilities; an Aug. 20 letter to NRC re: Oversight and Funding of Offsite Decontamination Following a Severe Accident at the Indian Point Facilities; a Dec. 20, 2013 review by International Safety Research; and Dec. 20th Additional Comments submitted by the NYS Office of AG.