ENCLOSURE 

Waste Confidence 

Generic Environmental Impact Statement 

Scoping Process

Summary Report

March 2013 

U.S. Nuclear Regulatory Commission 

Rockville, Maryland
Table of Contents 

A. The Waste Confidence Public Scoping Period ................................................................... 1

A1. Introduction ........................................................................................................................ 1 

A2. Background ........................................................................................................................ 1 

A3. Generic Environmental Impact Statement ......................................................................... 2 

A4. Scoping Process ................................................................................................................ 3 

A5. Public Webcast Meetings and Webinars ............................................................................ 4 

A6. Comments Receiving During the Scoping Period .............................................................. 5 

A7. Issued Raised During the Scoping Period ......................................................................... 6 

A8. Scope of the Waste Confidence GEIS ............................................................................. 10 

A9. Issues Outside the Scope of the Waste Confidence GEIS .............................................. 11 

A10. Consultation Requirements and Cooperating Agencies ................................................ 12 

A11. Future Opportunities for Public Participation.................................................................. 13 

A12. Comments on the December 2011 Draft Report, “Background and Preliminary 

Assumptions for an Environmental Impact Statement—Long-Term Waste Confidence Update”

 ................................................................................................................................................ 13 

B. Responses to Scoping Comments .................................................................................... 15 

B1. Organization of Responses .............................................................................................. 15 

B2. Comments Concerning Land Use .................................................................................... 15 

B3. Comments Concerning Socioeconomics ......................................................................... 16 

B4. Comments Concerning Environmental Justice ................................................................ 16 

B5. Comments Concerning Meteorology and Air Quality ...................................................... 16 

B6. Comments Concerning Hydrology ................................................................................... 17 

B7. Comments Concerning Aquatic Ecology .......................................................................... 17 

B8. Comments Concerning Transportation of Spent Nuclear Fuel ........................................ 17 

B9. Comments Concerning Nonradiological Health ............................................................... 18 

B10. Comments Concerning Radiological Health .................................................................. 18 

B11. Comments Concerning Safety ....................................................................................... 20 

B12. Comments Concerning Accidents .................................................................................. 22 

B13. Comments Concerning Security and Terrorism ............................................................. 25 

B14. Comments Concerning Cost Considerations ................................................................. 25 

B15. Comments Concerning Cumulative Impacts .................................................................. 25 
B16. Comments Concerning Alternatives ............................................................................... 26 

B17. Comments Concerning Evaluation Scenarios ................................................................ 28 

B18. Comments Concerning NEPA Process .......................................................................... 32 

B19. Comments Concerning Rulemaking Process ................................................................ 39 

B20. Comments that are Out of Scope................................................................................... 42 

C. References ........................................................................................................................... 52

D. List of Commenters on the Scope of the Waste Confidence GEIS................................. 55 

E. List of Commenters on the December 2011 Draft Report, “Background and 

Preliminary Assumptions for an Environmental Impact Statement—Long-Term Waste 

Confidence Update ................................................................................................................... 76 
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A. The Waste Confidence Public Scoping Period 

A1. Introduction

From October 25, 2012, through January 2, 2013, the U.S. Nuclear Regulatory Commission (the 

NRC or the staff) conducted an environmental scoping process for the Waste Confidence 

generic environmental impact statement (GEIS). During the scoping process, the NRC invited 

interested people and organizations to identify issues and provide recommendations to the 

agency on the development of a GEIS to support a proposed update to the Waste Confidence 

rule. The NRC’s goal for conducting the scoping process was to define the scope of issues to 

be addressed in the analyses that will be included in the GEIS. 

During the 70-day scoping period, interested people and organizations submitted hundreds of 

written comments, and many more statements were submitted orally at public meetings. This 

scoping summary report has been prepared to summarize what the NRC heard during the 

scoping process. Section A provides a summary of the determinations and conclusions 

reached during the NRC’s environmental scoping process for the GEIS. Section B contains a 

summary of comments received during the public scoping period and the NRC’s responses. 

Section C provides references cited throughout the report. Section D contains an alphabetized 

table that identifies the individuals providing comments, their affiliation if provided, and the 

Agencywide Documents Access and Management System (ADAMS) Accession number that 

can be used to locate the correspondence. Section E is a table listing comments on the NRC’s 

2011 long-term Waste Confidence pre-scoping document (NRC 2011a). A separate document, 

“Scoping Comments on the Waste Confidence Generic Environmental Impact Statement,” is 

located in ADAMS under Accession No. ML13060A130. This document lists the Waste 

Confidence scoping comments, organized by comment category. 

All documents associated with this scoping process, including comment documents, are 

available for public inspection in the NRC Public Document Room (PDR), located at One White 

Flint North, 11555 Rockville Pike, Rockville, MD 20852, or from ADAMS. The ADAMS Public 

Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. Persons 

who encounter problems in accessing documents in ADAMS should contact the NRC’s PDR 

Reference staff by telephone at 1-800-397-4209 or 301-415-4737 or by email at 

pdr.resource@nrc.gov. 

A2. Background 

The U.S. Nuclear Regulatory Commission is preparing a GEIS to support an update to the 

Waste Confidence decision and rule. The Waste Confidence rulemaking represents the 

Commission’s generic determination regarding the environmental impacts of the continued 

storage of spent nuclear fuel after the end of the licensed life for operations of a nuclear power 

plant and prior to ultimate disposal in a permanent repository (continued storage). This generic 

analysis is codified in 10 CFR § 51.23 and satisfies the NRC’s National Environmental Policy 

Act (NEPA) obligations with respect to continued storage. 
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The Waste Confidence rulemaking was first completed in 1984. The rule was amended in 

1990, reviewed in 1999, and amended again in 2010 (SRM-SECY-09-0090, under ADAMS 

Accession No. ML102580229, and 75 FR 81037, December 23, 2010). In 1984 and 1990 the 

continued storage period was 30 years, and in 2010 it was increased to 60 years. 

In response to the 2010 rulemaking, the States of New York, New Jersey, Connecticut, and 

Vermont and several other parties challenged the Commission’s NEPA analysis that supported 

the rule. On June 8, 2012, the D.C. Circuit Court of Appeals found that some aspects of the 

2010 rulemaking did not satisfy the NRC’s NEPA obligations and vacated and remanded the 

rule (New York v. NRC, 681 F.3d 471) (D.C. Cir. 2012). The court concluded that the Waste 

Confidence rulemaking is a major federal action necessitating either an environmental impact 

statement (EIS) or an environmental assessment (EA) that results in a Finding of No Significant 

Impact. The court also ruled that the NRC should have considered the potential environmental 

effects in the event a permanent repository for disposing of spent nuclear fuel is never built, and 

found other deficiencies with the NRC’s consideration of leaks and fires involving spent fuel 

pools. 

The Waste Confidence rule, though applicable only to the period after the licensed life of a 

reactor, is a part of the environmental analysis for agency decisions on the licensing and 

relicensing of nuclear reactors and independent spent fuel storage installations (ISFSIs). Prior 

to the court’s ruling, environmental review documents for each of these licensing actions 

deferred to conclusions codified in the Waste Confidence rule to address the environmental 

impacts of continued storage. In response to the court’s remand, the Commission decided to 

develop an EIS addressing continued storage, decided to develop a rule reflecting the results of 

the EIS, and determined that no final licenses (for reactors and ISFSIs) would be issued until 

the remand is appropriately addressed (Commission Order CLI-12-016) (NRC 2012a). The 

NRC is now undertaking a rulemaking effort to revise the Waste Confidence decision and rule to 

reflect the results of this EIS and to address the issues and deficiencies identified by the court. 

A3. Generic Environmental Impact Statement 

The Waste Confidence rulemaking is the proposed federal action that is the subject of this 

NEPA analysis. To fulfill its responsibilities under NEPA, the NRC is preparing a generic 

environmental impact statement (GEIS), which will assess the environmental impacts of 

continued storage. The GEIS will also determine whether the environmental impacts associated 

with continued storage are the same or similar for all plants, and can be treated on a generic 

basis codified in a rule. The GEIS will provide the regulatory basis for the Waste Confidence 

rule. 

The purpose and need for the proposed action is to develop and implement a regulatory 

approach that efficiently evaluates the environmental impacts of spent nuclear fuel after the 

licensed life for operation of a commercial nuclear reactor and prior to ultimate disposal. The 

GEIS will include an evaluation of the environmental impacts of the Waste Confidence 

rulemaking; the generic impact of the continued storage; the environmental impacts of 
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alternatives to the rulemaking, including the no-action alternative; and potential mitigation 

available for reducing or avoiding adverse impacts. 

The NRC’s methodology and approach to evaluating the environmental impacts of continued 

storage will follow the guidance in NUREG-1748, “Environmental Review Guidance for 

Licensing Actions Associated with NMSS Programs: Final Report” (NRC 2003), where 

appropriate. 

The Waste Confidence GEIS will be prepared by NRC staff with contract support from the 

Center for Nuclear Waste Regulatory Analyses (CNWRA®). CNWRA is a technical division of 

the Southwest Research Institute® and was established in 1987 as a federally funded research 

and development center. CNWRA’s technical areas of expertise include transportation of 

radioactive materials, storage and disposal of radioactive wastes, EAs, safety evaluations of 

nuclear fuel cycle facilities, and decommissioning of nuclear facilities. More information on 

CNWRA can be found at http://www.swri.org/4org/d20/cnwra/home.htm. 

A4. Scoping Process 

The first step in developing an EIS is to conduct a public scoping process. On October 25, 

2012, the NRC published a Notice of Intent to prepare an EIS and conduct scoping in the 

Federal Register: “Consideration of Environmental Impacts of Temporary Storage of Spent Fuel 

After Cessation of Reactor Operation” (77 FR 65137). The notice described the NRC’s plan to 

prepare an EIS and conduct public scoping webcast meetings and webinars, and requested 

comments on the scope of the Waste Confidence GEIS. Through the notice, the NRC invited 

federal, tribal, state, and local governments; organizations; and members of the public to 

provide comments on the scope of the NRC’s Waste Confidence GEIS. Comments could be 

submitted through January 2, 2013, via the federal rulemaking website (www.Regulations.gov) 

using Docket ID NRC-2012-0246, fax, or mail. Comments received after January 2, 2013, were 

considered and included in this scoping summary report as practicable. 

The scoping process provided an opportunity for members of the public to identify issues and 

highlight concerns related to continued storage. The Notice of Intent (77 FR 65137) identified 

the following objectives of the scoping process: 

a. Determine the scope of the EIS and identify the significant issues to be analyzed in 

depth, including potential spent fuel storage scenarios for evaluation, such as availability of a 

delayed permanent repository toward the end of the century; 

b. Identify and eliminate from detailed study those issues that are peripheral or that are not 

significant. Also note that analysis of environmental impacts for this effort would be principally 

intended to provide input to the decision-makers for the Waste Confidence rulemaking and 

would not involve analysis of site-specific issues; 

c. Identify any EAs and other EISs that are being or will be prepared that are related to but 

are not part of the scope of the EIS being considered; 
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d. Identify other environmental review and consultation requirements related to the 

proposed action; 

e. Indicate the relationship between the timing of the preparation of the environmental 

analyses and the Commission’s tentative planning and decision-making schedule; 

f. Identify any cooperating agencies and, as appropriate, allocate assignments for 

preparation and schedules for completing the EIS to the NRC and any cooperating agencies; 

g. Describe how the EIS will be prepared, including any contractor assistance to be used. 

The NRC will prepare a draft EIS in accordance with its regulations in 10 CFR Part 51; and 

h. Obtain public input on potential locations for future public meetings on the draft EIS. 

On October 25, 2012, NRC staff e-mailed the scoping notice to the Waste Confidence e-mail 

distribution list (ADAMS Accession No. ML12299A526). On October 25, 2012, the NRC’s 

WCOutreach@nrc.gov e-mail distribution list consisted of approximately 1,049 individuals, 

including individuals who expressed interest in previous spent nuclear fuel studies and efforts; 

members of the public who are on mailing lists for new reactor and license renewal 

environmental reviews; representatives from federal, state, local, and tribal governments; and 

representatives from industry and public advocacy groups and environmental organizations. 

(Note that in the months following publication of the Waste Confidence EIS scoping notice, the 

WCOutreach@nrc.gov e-mail distribution list has grown to approximately 3,752 subscribers.) A 

press release announcing the Waste Confidence EIS scoping period and the planned public 

meetings was issued on October 24, 2012, the day before publication of the scoping notice in 

the Federal Register (ADAMS Accession No. ML12298A295). 

With assistance from the NRC’s Office of Federal and State Materials and Environmental 

Management Programs (FSME), the scoping notice was mailed (and also e-mailed, when 

possible) to all federally recognized Native American tribes located within 50 miles of nuclear 

power plants, tribes that had registered with the NRC for advance notification of shipments of 

irradiated reactor fuel and nuclear waste under 10 CFR Parts 71 and 73, and tribes that had 

previously expressed interest in the NRC’s Yucca Mountain application activities (see ADAMS 

Accession No. ML12311A464 for an example of the tribal outreach letter that transmitted the 

scoping notice). Approximately 102 tribes were mailed a copy of the Waste Confidence scoping 

notice. FSME also issued the scoping notice to state liaison officers in all agreement and 

nonagreement states (ADAMS Accession No. ML12293A107). 

A5. Public Webcast Meetings and Webinars 

During the 70-day scoping period, the NRC conducted two public webcast scoping meetings 

and two scoping webinars.1

 The webcast meetings and webinars each began with a slide 

presentation by NRC staff, followed by a question-and-answer period, with the remainder of 

time dedicated to listening to and transcribing public scoping comments. All comments received 

 

1

 Webcast meetings are public meetings that are broadcasted live over the Internet via streaming video at 

the NRC’s live meeting webcast page (http://video.nrc.gov/). Webinars differ from webcasts in that they 

do not feature a live video feed of the NRC staff, but instead only share the NRC’s slide presentations 

using GoToMeeting®

, a web-based online meeting portal. 
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during the scoping meetings and webinars and written comments submitted in person at the 

November 14, 2012, afternoon meeting were considered by NRC staff and are summarized in 

this report. 

The webcast meetings and webinars were announced in two separate meeting notices that 

were posted on the NRC’s public meeting notification system website (ADAMS Accession Nos. 

ML12306A224 and ML12326A911). The meeting notices were e-mailed to the 

WCOutreach@nrc.gov distribution list. In addition, the NRC’s Office of Public Affairs authored a 

blogpost that mentioned the webcasts and webinars (http://public-blog.nrcgateway.gov/2012/10/26/introducing-the-nrcs-waste-confidence-directorate/) and issued three 

Tweets from the NRC’s Twitter account (https://twitter.com/nrcgov) to remind people of the 

December webinars. 

On Wednesday, November 14, 2012, staff conducted public scoping meetings at NRC 

headquarters in Rockville, MD, at 1 p.m. and 9 p.m. EST. The NRC chose to hold a late-night 

meeting to accommodate stakeholders in western time zones. Both meetings were viewable 

online via live webcast at http://video.nrc.gov/. A moderated teleconference line was available 

for remote participants to ask questions and present comments. Approximately 75 people 

attended the afternoon meeting in person, and 30 people participated remotely using the 

teleconference line. Of those 105 total participants, 27 people presented comments. 

Approximately 22 members of the public called in to the late-night teleconference meeting, and 

12 of those participants presented comments. Approximately 125 people viewed one of the two 

webcasts. Transcripts of both meetings are available in ADAMS under Accession Nos. 

ML12331A347 for the afternoon meeting and ML12331A353 for the late-night meeting. A 

summary of these meetings, including a list of all participants, is available in ADAMS under 

Accession No. ML12339A281. 

The NRC conducted public scoping webinars from 1 p.m. through 4 p.m. EST on December 5, 

2012, and from 9 p.m. through 12 a.m. EST on December 6, 2012. Both webinars were 

accessible online using GoToMeeting®, a web-based online meeting portal. A moderated 

teleconference line provided audio for the webinars. Participants did not need internet access 

to listen to and participate in the webinars. Approximately 63 people participated in the 

December 5 daytime webinar. Of those 63 participants, 13 asked questions or presented 

comments. Approximately 21 people participated in the December 6 evening webinar. Of those 

21 participants, 12 asked questions or presented comments. Transcripts of both webinars are 

available in ADAMS under Accession No. ML12355A174 for the December 5 webinar and 

ML12355A187 for the December 6 webinar. A summary of these webinars, including a list of all 

participants, is available in ADAMS under Accession No. ML12356A293. 

A6. Comments Received During the Scoping Period 

At the conclusion of the scoping period on January 2, 2013, NRC staff reviewed the four 

transcripts from the scoping meetings and webinars, along with all written material received, and 

identified individual comments within each piece of comment correspondence. Late comments 

were considered as practicable. Scoping comments were consolidated and categorized either 
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according to subject matter or according to the general topic if outside the scope of the GEIS. 

Comments with similar specific objectives or concerns were further grouped to capture the 

common issues that had been raised in the source comments. Once comments were grouped 

according to subject area, NRC staff determined the appropriate response for that set of similar 

comments. NRC responses to comments are presented in Section B of this report. Section C 

contains a table that identifies all commenters and the ADAMS Accession numbers where their 

comments can be found. A separate document, “Scoping Comments on the Waste Confidence 

Generic Environmental Impact Statement” is located in ADAMS under Accession No. 

ML13060A130. This document contains a table that identifies comments made in each 

category and then provides those comment excerpts, again organized by comment category. 

The NRC received approximately 700 pieces of comment correspondence via the public 

webcast meetings and webinars, via the Waste Confidence docket (NRC-2012-0246) on 

www.Regulations.gov, by mail, and by fax. Approximately 300 of these pieces of 

correspondence involved the submission of a form letter. During the NRC’s review of scoping 

comments, four form letters were identified: ADAMS Accession Nos. ML12319A466, 

ML13022A222, ML13023A405, and ML12331A278. Comments contained in these form letters 

were captured in this scoping summary report just once; however, all authors who submitted a 

substantially identical version of a form letter are listed as authors of the comments and have 

received an ADAMS Accession number where their comment submissions can be found. As an 

administrative measure, it should be noted that some form letter submissions were grouped 

together in one multipage PDF document, and consequently many form comments will be 

referenced by one ADAMS Accession number. 

A petition was submitted by Michael Mariotte (Nuclear Information and Resource Service) that 

included comments on the scope of the Waste Confidence GEIS and was electronically signed 

by approximately 2,640 people. Many of these electronic signatures are accompanied by brief 

individual comments that, among other things, generally express opposition to nuclear power 

and the Waste Confidence rulemaking, express concerns about NRC oversight of the nuclear 

industry, express general safety concerns regarding operating reactors and spent nuclear fuel 

storage, and express concerns about accidents similar to those at Fukushima Dai-ichi and 

Chernobyl power plants. Because these signature comments are substantially duplicative of 

other comments that are addressed elsewhere, the 2,640 signatures and the associated 

signature comments are not captured in this scoping summary report; however, the petition can 

be viewed in ADAMS under Accession No. ML13022A223. 

A7. Issues Raised During the Scoping Period 

As the NRC reviewed transcripts and written material, comments were extracted and organized 

into several broad categories. These comment categories and major topics and issues of 

concern within each category follow. The bulleted topics and issues under each category are 

not exhaustive, but include the most common concerns heard in the scoping comments. 

 
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Land Use 

• Bounding estimates for land use impacts from spent nuclear fuel storage 

Socioeconomics 

• Socioeconomic implications (notably economic and tax considerations) of long-term and 

indefinite onsite spent nuclear fuel storage 

Environmental Justice 

• Concerns that environmental justice cannot be evaluated generically 

• Opposition to spent nuclear fuel being stored near economically stressed communities 

Meteorology and Air Quality 

• Impacts of climate change, including severe weather events that may be a result of 

climate change 

Hydrology 

• Radiological contamination of surface water and groundwater from spent nuclear fuel 

storage 

Aquatic Ecology 

• Bounding estimates of the impacts to various ecosystems and assessment of potential 

mitigation measures 

Transportation 

• Transportation required for centralized interim storage 

• Timeframes and scenarios to consider spent nuclear fuel transportation 

• Comments suggesting the NRC should reference the U.S. Department of Energy’s 

(DOE) Yucca Mountain EIS (DOE 2002) transportation analysis 

Nonradiological Health 

• General concerns about public health and safety with regard to nuclear power 

Radiological Health 

• Bounding radiological doses 

• Doses from high-burnup fuel 

• General concerns regarding radiological impacts from spent nuclear fuel storage, 

including radiological risks from spent fuel pool leaks 

Safety

• Safety concerns regarding spent fuel pools, including fires and leaks 

• Calls for reconfiguring spent fuel pools and required dry cask storage 

• Concerns regarding dry casks and high-burnup fuel 

• Embrittlement, stress corrosion cracking, and other potential types of dry cask degradation 

Accidents 

• Concerns about accidents similar to the Fukushima Dai-ichi event 

• Incorporation of lessons learned from Fukushima into the Waste Confidence GEIS and 

proposed rulemaking 

• Hazards to spent nuclear fuel due to natural events, including flooding and other 

extreme weather events 

• Seismic risks to and general accident susceptibility of spent fuel pools and dry casks 

• Spent fuel pool criticality and loss of spent fuel pool coolant 

• Solar flares and their impact on the electrical grid 

Security and Terrorism 

• Vulnerability of dry casks and spent fuel pools to terrorist attack 
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• Concerns regarding generic analysis of environmental impacts from malevolent events 

• Collaboration with other agencies and experts 

Cost Considerations 

• Cost of extended storage of spent nuclear fuel, including transfer facilities and accident 

recovery 

Cumulative Impacts 

• Cumulative impacts from spent fuel storage leaks and other connected actions (including 

accidents) to a variety of resources, including radiological health and surface and 

groundwater 

Alternatives 

• The need for site-specific analysis of Waste Confidence 

• The no-action alternative 

• Calls to stop nuclear waste production by ending licensing and decommissioning 

existing nuclear facilities 

• Alternatives within the NRC’s regulatory requirements regarding spent fuel storage 

• Criticism or support of the Yucca Mountain EIS (DOE 2002) no-action alternative 

• Alternatives for storing spent nuclear fuel 

Evaluation Scenarios 

• Loss of future institutional control of spent nuclear fuel 

• The availability of a permanent, geologic repository and the timeframes of “temporary” 

onsite spent fuel storage 

• The need for multiple geologic repositories due to the accumulation of spent nuclear fuel 

• The future of the nuclear industry and the amount of spent nuclear fuel that will need to 

be ultimately disposed of 

• A call for the “Five Findings” in the remanded Waste Confidence Decision and Rule to 

be evaluated in the GEIS 

• Impediments to implementation of Yucca Mountain or any repository 

• Inclusion of high-burnup fuel, mixed-oxide fuel, vitrified nuclear waste, and radioactive 

wastes from reprocessing in GEIS 

• Repackaging of spent nuclear fuel and dry transfer systems (DTS) 

• The GEIS should consider a range of storage scenarios 

• A call for hardened onsite storage (HOSS) for spent nuclear fuel and expedited transfer 

of spent nuclear fuel from pools to dry casks 

• Consolidated or centralized interim spent fuel storage 

• The GEIS should include an evaluation of mitigation 

• New reactor technologies in developmental or research stages 

NEPA Process 

• The 24-month schedule for the Waste Confidence environmental review and rulemaking, 

including concerns about the 70-day scoping period 

• Requests to withdraw the scoping notice because it is inadequate 

• General comments regarding how the NRC will comply with NEPA 

• NRC environmental review documents applicable to the Waste Confidence GEIS 

• Section 106 consultation 

• Consultation with federally recognized tribes 

• Importance of scoping to eliminate peripheral issues 
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• Identification of other EISs, EAs, and technical studies to inform the GEIS 

• Calls for and against limiting the GEIS to only address the deficiencies identified by the 

D.C. Circuit Court of Appeals 

• Research and data needed for the GEIS and proposed rulemaking 

• Calls for more (in-person) public scoping meetings 

• Suggested locations for regional GEIS public meetings 

• Suggested improvements for submitting comments and overall public outreach 

• Public access to information 

• Comments received during the 2011 pre-scoping effort for the long-term Waste 

Confidence update EIS 

• Comments suggesting the NRC should consult with other government agencies 

The Rulemaking 

• General questions regarding the proposed action (i.e., the rulemaking) and 

misperceptions regarding Waste Confidence as a licensing action 

• Connection between the “Five Findings” and the revised rule 

• General opposition to the idea of “Waste Confidence” and the Waste Confidence rule as 

a generic determination of environmental impacts and safety 

• General support of the Waste Confidence rulemaking and preparation of a GEIS 

Out of Scope

• Environmental impacts of the entire nuclear fuel cycle from mining to decommissioning, 

outside of the context of their inclusion in the cumulative impacts analysis 

• Impacts of reprocessing and wastes from reprocessing 

• Greater-Than-Class C (GTCC) radioactive waste 

• Spent nuclear fuel from foreign countries 

• Vitrified waste at the West Valley Site 

• Site-specific examples of issues that the Waste Confidence GEIS should address 

• General site-specific concerns such as safety and radiological health risk at particular 

proposed and existing reactor sites 

• General concerns regarding NRC’s oversight of the nuclear industry 

• Calls for changes to NRC regulations regarding spent fuel storage and reactor safety 

• Requirements for radiation monitoring at nuclear plants 

• Calls for replacing nuclear energy with renewable forms of energy such as wind, solar, 

and geothermal 

• Site-specific emergency planning concerns 

• Comments specific to the Yucca Mountain proceeding, including frustrations about the 

lack of a permanent repository and general need for one 

• Site-specific issues about NRC activities, processes, and oversight unrelated to Waste 

Confidence 

• Suggestions for a new or different agency to address nuclear waste 

• Novel alternatives for storing spent nuclear fuel; experimental fuel cladding materials 

• Federal funding of spent fuel storage site monitoring 

• The NRC’s adjudicatory process as related to Waste Confidence, and procedures for 

raising site-specific concerns to the Atomic Safety and Licensing Board (ASLB) 

• General opposition to nuclear power that primarily cites health risks 

• General support of nuclear power in the context of preventing global warming 
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A8. Scope of the Waste Confidence GEIS 

As a result of the scoping process, the NRC staff has identified and eliminated peripheral issues 

that will not be covered in the Waste Confidence GEIS. Section B, “Responses to Scoping 

Comments,” provides responses that either discuss why particular topics or concerns are 

outside the scope of the GEIS, or indicates that these concerns or topics are in scope and will 

be evaluated and documented in the GEIS. In many cases, the NRC cannot state with any 

specificity the degree of analysis that will be applied to any of these in-scope issues. 

Commenters should not expect that every item identified as “in scope” for the GEIS will receive 

the same level of review and analysis. 

The general scope of the GEIS includes an evaluation of the environmental impacts of 

continued storage and reasonable alternatives to continued storage, including the no-action 

alternative. In the following discussion, the NRC outlines its current approach to the structure of 

the GEIS. The draft GEIS, which will be published for public comment later this year, may adopt 

a different format than is outlined here. 

Chapter 1 of the GEIS will provide an introduction to Waste Confidence; discuss the proposed 

action, purpose and need of the proposed action, and alternatives to the proposed action; 

outline the specific assumptions that informed the analyses contained in later chapters of the 

GEIS; and list applicable regulations and related environmental documents used in the 

environmental review. 

Chapter 2 of the GEIS will describe typical facility characteristics and activities that are used to 

assess the environmental impacts that may occur from continued storage. 

Chapter 3 will contain a discussion of the affected environment that exists at and around 

continued storage facilities, and will form the basis for assessing the potential impacts in 

Chapter 4. The affected environment will include the following resource areas: land use, 

socioeconomics, environmental justice, climate and air quality, geology and soils, water 

resources (surface water and groundwater), ecological resources (terrestrial and aquatic 

resources), historic and cultural resources, noise, aesthetics, waste management, 

transportation, and public and occupational health. 

In Chapters 4 and 5 of the GEIS, the NRC will evaluate the environmental impacts of continued 

storage at onsite and offsite storage facilities. These chapters will also include a discussion of 

potential mitigation that could reduce or avoid adverse environmental impacts. 

Chapter 6 will consider and evaluate the cumulative impacts that could occur from the 

incremental impact of continued storage when added to other past, present, and reasonably 

foreseeable future actions, regardless of what agency (federal or non-federal) or person 

undertakes these other actions. Other past, present, and reasonably foreseeable future actions 

that will be considered in the cumulative impact assessment include reactor construction and 

operation; decommissioning of reactors, spent fuel pools, and ISFSIs; preparation activities to 
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transport spent nuclear fuel offsite; and other federal and non-federal activities that have been 

identified near nuclear power plants and storage facilities. 

Chapter 7 will discuss the costs for continued spent fuel storage. 

Chapter 8 will include a summary of environmental consequences, including a comparison of 

environmental impacts, unavoidable adverse environmental impacts, irreversible and 

irretrievable commitments of resources, the relationship between local short-term uses of the 

environment and the maintenance and enhancement of long-term productivity, and the NRC’s 

conclusions and recommendations that will inform the Waste Confidence proposed rule. 

Chapter 9 will list preparers of the GEIS. 

Chapter 10 will be an index and glossary of terms. 

The GEIS will also include a number of technical appendices to support the conclusions in the 

main body of the report, including (but not limited to) a detailed analysis of spent fuel pool leaks 

and fires. 

There are a number of NRC environmental reviews for licensing actions that are pending 

resolution of the Waste Confidence environmental review and rulemaking. A list of these 

licensing actions is included as the enclosure to SECY-12-0132, “Licensing Actions Affected by 

Waste Confidence Remand” (NRC 2012b). The Waste Confidence final GEIS and rule will 

inform those reviews with respect to the environmental impacts of spent fuel storage postlicensed life of a reactor and prior to ultimate disposal. To the extent that the GEIS will bound 

the sites being evaluated in those ongoing licensing reviews, the Waste Confidence 

environmental review will consider relevant information related to those sites and facilities.

A9. Issues Outside the Scope of the Waste Confidence GEIS

The Waste Confidence GEIS will evaluate the environmental impacts of continued storage. 

Certain topics will not be addressed in the Waste Confidence GEIS, because they are not within 

the scope of the Waste Confidence environmental review. As noted previously, responses to 

comments on these topics discuss why these topics are outside the scope of the Waste 

Confidence GEIS. These topics include (but are not limited to) 

• Consideration of noncommercial spent nuclear fuel (e.g., defense waste, other wastes 

from reactor operations), 

• Consideration of nonpower reactor spent nuclear fuel (e.g., test reactors), 

• Need for nuclear power and alternatives to nuclear power, 

• Consideration of environmental impacts of constructing and operating reprocessing 

facilities for commercial spent nuclear fuel,

• Continued storage of commercial high level waste that would be created by 

reprocessing, 

• Emergency preparedness, and

• Uranium fuel cycle.
- 12 - 

Interested parties submitted hundreds of comments that suggested the NRC should consider a 

cessation of all licensing activities or cessation of all nuclear power plant operations as an 

alternative. A variety of other scoping comments suggested that the NRC should require the 

implementation of HOSS as an alternative. The NRC considered but ultimately dismissed these 

suggested alternatives for the purposes of this GEIS. Cessation of licensing activities and 

overall reactor operations does not satisfy the purpose and need for the GEIS. With regard to 

HOSS, the NRC is already considering implementing revised security requirements as part of 

the ongoing ISFSI security rulemaking effort. The rulemaking effort is described in the 

December 16, 2009, Federal Register notice (74 FR 66589), “Draft Technical Basis for 

Rulemaking Revising Security Requirements for Facilities Storing SNF and HLW; Notice of 

Availability and Solicitation of Public Comments.” 

Section B of this scoping summary report, “Responses to Scoping Comments,” provides 

responses to these suggested alternatives and other out-of-scope concerns. 

A10. Consultation Requirements and Cooperating Agencies 

The NRC recognizes there are specific government-to-government consultation responsibilities 

regarding interactions with federally recognized tribal governments because of their status as 

dependent sovereign nations. As such, the NRC offers federally recognized tribes the 

opportunity for government-to-government consultation consistent with the principles in 

Executive Order 13175, “Consultation and Coordination with Indian Tribal Governments” issued 

November 9, 2000 (65 FR 67249). At the request of tribal governments, the NRC, if invited, 

would be willing to participate in government-to-government meetings to discuss the Waste 

Confidence GEIS development effort. 

To date, the NRC staff has conducted outreach to all federally recognized Native American 

tribes located within 50 miles of nuclear power plants, tribes that had registered with the NRC 

for advance notification of shipments of irradiated reactor fuel and nuclear waste under 10 CFR 

Parts 71 and 73, and tribes that had expressed interest in the NRC’s Yucca Mountain 

application activities. Three tribes contacted the NRC regarding the Waste Confidence 

rulemaking: the Prairie Island Indian Community (a federally recognized tribe located 

immediately adjacent to the Prairie Island Nuclear Generating Plant, Units 1 and 2), the staterecognized Northern Chumash Tribal Council, and the federally recognized Santa Ynez Band of 

Chumash Indians (the latter two located near Diablo Canyon Power Plant). The Waste 

Confidence GEIS will include an appendix that contains correspondence related to NRC’s 

outreach with Native American tribes. The NRC encourages interested Native American tribes 

to participate throughout the Waste Confidence environmental review. The NRC will continue 

outreach efforts with Native American tribes throughout the course of this rulemaking. 

The NRC met with representatives from the U.S. Environmental Protection Agency (EPA) on 

November 5, 2012. The purpose of the meeting was to provide historical information on the 

Waste Confidence rule, to discuss the status of the Waste Confidence environmental review 

and rulemaking, to discuss how the NRC was conducting new reactor and license renewal 

reviews in the interim while Waste Confidence was addressed, and to receive advice on the 
- 13 - 

NRC’s approach. EPA provided comments on the scope of the Waste Confidence GEIS 

(ADAMS Accession No. ML13028A469), and the NRC will continue to consult with the EPA as 

the Waste Confidence environmental review proceeds. 

The Waste Confidence rulemaking does not identify specific sites for NRC licensing actions that 

would trigger consultation requirements that are normally conducted during site-specific 

licensing reviews. Additionally, the Waste Confidence rule is not a licensing action. It does not 

authorize the initial or continued operation of any nuclear power plant, and it does not authorize 

storage of spent nuclear fuel. The NRC will continue to meet these specific consultation 

requirements (for example, consultation with the U.S. Fish and Wildlife Service under Section 7 

of the Endangered Species Act, consultation with the National Marine Fisheries Service under 

the Magnuson-Stevens Fisheries Conservation and Management Act, and consultation with the 

applicable State Historic Preservation Office or Tribal Historic Preservation Office under Section 

106 of the National Historic Preservation Act, among others) in all future site-specific licensing 

reviews that rely upon Waste Confidence. 

The NRC did not identify any cooperating agencies for the Waste Confidence environmental 

review, nor did the NRC receive any formal requests for cooperating agency status. 

A11. Future Opportunities for Public Participation

Later this year the NRC will issue for public comment a draft GEIS and a proposed Waste 

Confidence decision and rule that have been informed by the GEIS. Both the draft GEIS and 

the proposed decision and rule will have concurrent public comment periods. The comment 

period offers the next opportunity for interested federal, state, and local government agencies; 

tribal governments; local organizations; advocacy groups; environmental organizations; and 

other members of the public to comment on the NRC’s Waste Confidence GEIS and 

rulemaking. All comments received on the draft GEIS and proposed decision and rule will be 

considered in the preparation of the final GEIS and final decision and rule. Comments on the 

GEIS and proposed rule, and responses to those comments (noting any edits and changes to 

the GEIS and rule as a result of comments), will be published as well. The final GEIS will 

provide the regulatory basis for the NRC’s final Waste Confidence rule, both of which are 

scheduled to be issued by September 2014. 

A12. Comments on December 2011 Draft Report, “Background and Preliminary 

Assumptions for an Environmental Impact Statement—Long-Term Waste Confidence 

Update”

In December 2010, the Commission directed NRC staff to develop an EIS that would address 

the environmental impacts of spent fuel storage beyond a 120-year timeframe and thereby 

provide a long-term update of the Waste Confidence decision and rule. Staff provided 

information about the EIS development plans to the Commission in SECY-11-0029, “Plan for 

the Long-Term Update to the Waste Confidence Rule and Integration with the Extended 

Storage and Transportation Initiative,” dated February 28, 2011 (NRC 2011b). Staff then began 

pre-scoping efforts to gather public input on the proposed activities and path forward. The NRC 
- 14 - 

held three public meetings and two webinars from September through December 2011. The 

staff issued a draft report in December 2011, entitled “Background and Preliminary Assumptions 

for an Environmental Impact Statement—Long-Term Waste Confidence Update” (NRC 2011a), 

as a means to seek public feedback on the agency’s preliminary plans to develop the long-term 

update EIS. The NRC sought to ensure that the preliminary EIS scope described in the draft 

report considered the significant factors related to the longer term storage of spent nuclear fuel 

and high-level waste. The report included background on the history of Waste Confidence, as 

well as the national regulatory and historical context. Technical topics in the paper included the 

potential purpose and need and alternatives under NEPA, methodology for analyzing impacts 

over a long timeframe, use of generic composite sites developed from site-specific data, 

potential scenarios for analysis (such as onsite storage, consolidated storage, and 

reprocessing), and assumptions to be used. The comment deadline on that report closed on 

March 19, 2012. 

Nearly 200 comment letters on the draft report were received from a variety of agencies, 

organizations, and members of the public. Comments covered a wide variety of issues. Many 

commenters’ questions included regulatory concerns, such as why Waste Confidence is or is 

not needed, whether the proposed length of study was or was not appropriate, why the NRC is 

developing an EIS, the feasibility of institutional controls and financial surety, and the need for 

periodic updates of the EIS. Comments regarding outreach focused on requests for interactions 

with state and local governments, tribes, and organizations, and the continued need for public 

meetings and webinars. Comments about the proposed scenarios included questions about 

and inclusion of offsite consolidated storage, and both support and criticism regarding the 

inclusion of reprocessing. Many comments indicated an interest in expanding the previous 

scope of Waste Confidence considerations to include alternative energy sources, HOSS, 

expedited transfer of fuels from spent fuel pools to dry casks, and site-specific concerns. 

Additionally, many commenters expressed interest in inclusion of expanded discussions 

regarding security and terrorism, natural hazards (such as lessons learned from Fukushima), 

and transportation in the scope of the long-term update EIS. 

The NRC was developing responses to the comments received during the pre-scoping 

comment period and in the public meetings when the D.C. Circuit Court of Appeals issued its 

ruling in June 2012 (D.C. Cir. 2012). Comments on the December 2011 report are available for 

review in ADAMS, and Section E of this report contains a table that lists commenters, their 

affiliation, and the date and ADAMS Accession number of their comments from that previous 

effort.
- 15 - 

B. Responses to Scoping Comments 

B1. Organization of Responses 

The NRC’s responses to comments and suggestions received as part of the Waste Confidence 

environmental scoping process are included in this section of the report. Comments were 

grouped by category, and comments with similar themes were further subgrouped to capture 

essential issues. Responses are provided for each subgroup of similar comments. Comment 

excerpts, grouped by category, can be found in a separate document titled, “Scoping Comments 

on the Waste Confidence Generic Environmental Impact Statement.” This document is located 

in ADAMS under Accession No. ML13060A130. 

Section D of this report contains a table that identifies, in alphabetical order, the individuals 

providing comments, their affiliation if provided, and the ADAMS Accession number than can be 

used to locate the correspondence. 

Accession numbers indicate the location of the written comments in ADAMS. All documents 

associated with this scoping process are available for public inspection in the NRC Public 

Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, MD 

20852, or from ADAMS. The ADAMS Public Electronic Reading Room is accessible at 

http://www.nrc.gov/reading-rm/adams.html. Persons who encounter problems in accessing 

documents in ADAMS should contact the NRC’s PDR Reference staff by telephone at 

1-800-397-4209 or 301-415-4737 or by e-mail at pdr.resource@nrc.gov. 

B2. Comments Concerning Land Use 

The NRC received one comment recommending that the GEIS consider bounding estimates for 

the worst-case loss of agricultural land and production. The NRC plans to use existing 

information to generically assess land use impacts by reviewing the evaluations in other generic 

environmental impact statements and site-specific EAs and EISs. This approach follows the 

Commission’s direction in Staff Requirements Memorandum for COMSECY-12-0016, 

“Approach for Addressing Policy Issues Resulting from Court Decision to Vacate Waste 

Confidence Decision and Rule” (NRC 2012c) to “coordinate and take appropriate advantage of 

existing documents and studies, including through adoption and incorporation by reference.” 

The appropriate use of existing information is sufficient to generically demonstrate the range of 

expected impacts that could occur from continued spent fuel storage. As with all NEPA 

analyses, the GEIS will analyze reasonably foreseeable events; the NRC will not analyze worstcase impacts. 

Comment: (0286-54) 

 
- 16 - 

B3. Comments Concerning Socioeconomics 

A. General Concerns 

The NRC received comments recommending that the GEIS consider socioeconomic issues, 

such as tax and economic implications of indefinite storage of spent nuclear fuel at reactor sites. 

These issues will be considered in the GEIS. 

Comments: (0275-11) (0275-3) (0291-2) (0291-21) (0291-22) (0291-23) (0291-24) 

B. States’ Rights and Responsibilities 

The NRC received a comment that expressed concerns about states’ rights and responsibilities. 

States and other interested parties will be able to participate in the NEPA and rulemaking 

process through the notice-and-comment period on the proposed rule and the draft GEIS. 

Comments: (0004-25-15) (0004-25-16) (0296-11) 

B4. Comments Concerning Environmental Justice 

The NRC received comments recommending that the GEIS consider local and intergenerational 

environmental justice, such as economically depressed areas and future generations bearing 

the burden of spent nuclear fuel. The GEIS will include a discussion of the incremental impacts 

of continued storage on environmental justice. Site-specific licensing actions, such as initial or 

renewed reactor licenses, will include a site-specific assessment of environmental justice 

issues. 

Comments: (0004-14-4) (0004-23-4) (0004-4-4) (0041-3) (0118-17-13) (0118-17-3) (0118-17-5) 

(0269-20) (0269-5) (0273-5) (0284-4) (0286-57) (0286-87) (0290-6) (0296-19) (0296-20) (0321-

7) 

B5. Comments Concerning Meteorology and Air Quality 

A. Long-term Heat from Spent Nuclear Fuel 

The NRC received comments recommending that the GEIS consider the environmental impacts 

of heat generated by spent nuclear fuel. The GEIS will consider the environmental impacts of 

heat generated by spent nuclear fuel on surface waters and climate. 

Comments: (0004-25-5) (0296-29) 

B. Climate Change 

The NRC received comments recommending that the GEIS consider the environmental impacts 

of climate change, including the impact of weather events that may be linked to climate change. 

The NRC also received comments concerning the ability to assess climate change impacts in 

the future. The GEIS will consider the environmental impacts of climate change on the 

continued storage of spent nuclear fuel, including severe weather events that may be linked to 

climate change. 
- 17 - 

Comments: (0004-15-4) (0004-18-6) (0004-25-10) (0005-17-7) (0005-7-1) (0009-4) (0021-2) 

(0053-3) (0058-11) (0092-6) (0118-11-2) (0118-9-2) (0118-9-4) (0129-5) (0148-31) (0225-3) 

(0269-7) (0272-7) (0277-6) (0285-17) (0285-5) (0286-83) (0286-84) (0296-27) (0296-28) (0323-

3) (0323-4) 

C. Carbon Dioxide 

The NRC received comments recommending that the GEIS consider the amount of carbon 

dioxide generated by the nuclear fuel cycle. The GEIS will consider the impacts of air emissions 

from the continued storage of spent nuclear fuel, including greenhouse gases like carbon 

dioxide. Environmental impacts associated with parts of the fuel cycle outside of continued 

storage (e.g., mining, disposal) are outside the scope of the GEIS. 

Comments: (0005-17-1) (0053-4) 

B6. Comments Concerning Hydrology 

The NRC received comments recommending that the GEIS consider radiological contamination 

of surface and groundwater. The GEIS will consider the potential environmental impacts of 

continued storage on surface and groundwater. 

Comments: (0005-11-4) (0005-17-4) (0049-7) (0110-2) (0113-2) (0135-2) 

B7. Comments Concerning Aquatic Ecology 

The NRC received comments recommending that the GEIS consider bounding estimates of the 

impacts to various ecosystems and assess potential mitigation measures. The GEIS will 

consider the impacts to aquatic resources that could be affected by continued storage, including 

potentially affected riverine, lacustrine, and estuarine ecosystems. The GEIS will also describe 

potential mitigation measures to the extent these measures would be readily and generically 

available and could reduce or minimize any significant impacts. 

Comments: (0286-118) (0286-53) (0286-55) 

B8. Comments Concerning Transportation of Spent Nuclear Fuel 

A. General Concerns 

The NRC received comments recommending that the GEIS consider transportation of spent 

nuclear fuel to a repository or central storage location, including various timeframes and 

scenarios for shipments and future trends affecting transportation. Other comments requested 

that transportation costs be excluded because the impacts would be evaluated later when 

facilities are licensed. One commenter expressed concern regarding the time required to 

transport spent fuel to a repository. The NRC also received comments that recommended using 

the impact analysis that was conducted by the DOE for the Yucca Mountain proposed repository 

EIS (DOE 2002) to evaluate similar types of impacts. Transportation of spent nuclear fuel will 

be discussed in the cumulative impacts analysis in the GEIS. 
- 18 - 

Comments: (0004-8-5) (0096-3) (0118-9-1) (0119-9-1) (0148-33) (0244-11) (0263-18) (0265-12) 

(0265-16) (0265-17) (0265-18) (0265-26) (0266-3) (0267-4) (0271-14) (0271-16) (0272-11) 

(0278-2) (0286-20) (0286-71) (0286-72) 

B. Details of Transportation 

The NRC received a comment recommending that the GEIS include a map showing nuclear 

power plant locations and their spent fuel storage destinations across the United States. The 

NRC will consider this suggestion as it develops the GEIS. However, any map will be limited to 

the locations of nuclear power plants because there are no currently operating facilities for 

centralized spent fuel storage and disposal. 

Comment: (0274-8) 

C. Volume of Spent Nuclear Fuel Transportation Activities 

The NRC received a comment regarding the volume of spent nuclear fuel transportation, 

including a request to minimize the transportation of spent nuclear fuel. Transportation of spent 

nuclear fuel will be discussed in the cumulative impacts analysis in the GEIS. 

Comment: (0294-4) 

B9. Comments Concerning Nonradiological Health 

The NRC received comments expressing general concern about public health and continued 

storage. The GEIS will evaluate the environmental impacts of the continued storage, including 

health impacts. 

Comments: (0058-5) (0143-1) (0240-1) 

B10. Comments Concerning Radiological Health 

A. General Concerns 

The NRC received several comments about general radiological health and impacts from 

exposure to radiation. The GEIS will address potential radiation doses and associated public 

and occupational health effects associated with continued storage. The environmental impacts 

of operating reactors and disposal of spent nuclear fuel in a repository will not be considered 

beyond their inclusion in a discussion of cumulative radiological impacts. These matters are 

considered when those types of facilities receive NRC site-specific licenses and are outside the 

scope of this generic analysis, which concerns the continued storage of spent nuclear fuel 

beyond the licensed life of a nuclear power plant. 

Comments: (0004-13-9) (0004-16-1) (0004-5-1) (0005-16-1) (0005-17-5) (0005-2-4) (0005-2-5) 

(0071-1) (0075-4) (0090-2) (0090-3) (0119-5-2) (0119-9-2) (0121-2) (0145-2) (0169-1) (0176-1) 

(0196-2) (0199-1) (0215-5) (0217-2) (0246-7) (0269-17) (0277-1) (0285-1) (0285-11) (0285-2) 

(0285-20) (0286-17) (0286-22) (0286-23) (0286-25) (0286-75) (0286-95) (0286-96) (0286-97) 

(0287-1) (0296-25) (0336-1) 
- 19 - 

B. Environmental Pathways 

The NRC received two comments requesting that the GEIS cite specific information on the 

inventory of irradiated fuel rods and the biological pathways these radionuclides could take 

through the environment. This type of information will be provided in the GEIS to the extent it is 

necessary to describe the generic environmental impacts of continued storage. 

Comments: (0118-3-3) (0138-1) 

C. Radiological Impacts of Storage and Disposal 

The NRC received comments asking that the GEIS include an analysis of the advantages and 

disadvantages of continued storage as opposed to disposal in a repository. The purpose of the 

GEIS is to generically assess the environmental impacts of continued storage. A comparison of 

environmental impacts resulting from different continued storage scenarios may be included in 

the GEIS. 

Comments: (0265-11) (0265-13) (0271-13) (0271-15) 

D. Occupational Exposure 

The NRC received one comment expressing concern about the improper handling of radioactive 

materials and toxic exposures to site workers. Handling of radioactive materials is a regulated 

activity. Site-specific licensing conditions specify the proper radioactive material handling 

procedures and appropriate corrective actions. The Waste Confidence GEIS will consider the 

potential environmental impacts and health effects associated with off-normal operations and 

accidents to workers, as well as the public. 

Comment: (0005-17-3) 

E. Bounding Radiation Values 

The NRC received comments concerning the use of bounding values for assessing radiological 

risk in the Waste Confidence GEIS. The NRC plans to use existing information and radiological 

data to create a baseline for assessing environmental impacts and health effects. These 

comments will be considered during the development of the GEIS. 

Comments: (0286-26) (0325-9) 

F. Radiological Monitoring 

The NRC received comments about current requirements for radiological monitoring and 

reporting under normal and off-normal events. The GEIS will address effluent monitoring 

associated with continued storage. Comments requesting additional effluent monitoring are out 

of scope because the GEIS is a generic analysis of environmental effects and cannot place 

specific requirements on nuclear power plants. 

Comments: (0004-25-4) (0118-22-1) (0119-10-4) 
- 20 - 

G. Groundwater Contamination 

The NRC received comments concerning contamination of groundwater (including tritium) 

around nuclear power plants and public notification of contamination. Impacts to groundwater 

during continued storage, including impacts from spent fuel pool leaks, will be analyzed in the 

GEIS. 

Comments: (0092-5) (0096-4) (0118-10-1) (0286-119) 

H. Site-Specific Radiation Monitoring 

The NRC received a comment regarding site-specific radiological monitoring. The GEIS will rely 

primarily on existing NRC requirements for licensee radiological monitoring and reporting 

programs, and monitoring data reported to the NRC from these programs that would support 

generic conclusions concerning the environmental impacts related to continued storage of spent 

nuclear fuel. 

Comment: (0296-15) 

I. Contamination From Decommissioning 

The NRC received comments about contamination from decommissioned and decommissioning 

nuclear facilities. These activities are not related to the impacts of continued storage. However, 

the cumulative impacts assessment will consider the past, present, and reasonably foreseeable 

activities that could result in radiological contamination near nuclear power plants and awayfrom-reactor storage facilities. 

Comments: (0118-17-8) (0297-3) 

B11. Comments Concerning Safety 

A. Dry Cask Impacts 

The NRC received several comments expressing concern about the safety of currently loaded 

dry cask designs, including materials, aging, and handling casks that need to be repaired or 

replaced. The GEIS will consider the environmental impacts of continued spent nuclear fuel dry 

storage, including degradation and aging management of dry cask storage systems, highburnup fuel, and the potential need for repackaging. 

The NRC has 30 years of experience demonstrating that spent nuclear fuel can be stored 

safely. While concerns about the NRC’s safety programs—such as quality assurance and 

safety evaluations in licensing—are outside the scope of the GEIS analysis, when the NRC 

issues certificates for specific dry cask storage systems and license ISFSIs, the staff makes a 

determination that the designs provide reasonable assurance that the spent nuclear fuel will be 

stored safely for the term of the license or certificate. All dry cask designs and ISFSIs currently 

storing commercial spent nuclear fuel have been approved by the NRC. The NRC staff is 

aware of concerns that were raised with respect to specific designs and storage systems; 
- 21 - 

however, all dry cask storage systems certified by the NRC and in use at ISFSIs are operating 

safely and meet all NRC regulations. 

Comments: (0004-13-12) (0004-6-7) (0005-5-14) (0005-5-15) (0005-5-6) (0055-7) (0062-10) 

(0062-11) (0063-6) (0067-4) (0068-10) (0068-9) (0069-8) (0071-7) (0072-10) (0074-3) (0080-7) 

(0080-8) (0093-7) (0093-8) (0118-17-2) (0118-2-7) (0118-2-8) (0118-9-3) (0148-29) (0163-4) 

(0189-4) (0207-2) (0215-4) (0242-12) (0246-6) (0265-10) (0265-20) (0265-3) (0270-1) (0270-11) 

(0272-6) (0277-8) (0279-1) (0280-5) (0285-13) (0285-7) (0286-19) (0286-38) (0289-3) (0291-10) 

(0291-9) (0296-36) (0323-10) (0325-3) (0325-4) (0326-12) (0326-13) 

B. General Aging and Degradation Comments 

The NRC received comments about a number of general safety issues regarding spent nuclear 

fuel aging and degradation. The GEIS will analyze the environmental impacts from the 

continued storage of spent nuclear fuel in spent fuel pools and in dry casks. The GEIS will also 

evaluate impacts from accidents, as well as impacts from aging and degradation of spent fuel 

storage systems. 

Comments: (0001-3) (0004-18-10) (0004-25-6) (0005-10-1) (0005-11-3) (0005-16-2) (0038-6) 

(0049-6) (0069-1) (0083-2) (0091-1) (0119-7-4) (0131-1) (0148-28) (0148-37) (0148-8) (0150-1) 

(0196-3) (0239-1) (0244-4) (0271-9) (0278-3) (0282-1) (0286-100) (0286-107) (0286-39) (0286-

41) (0286-62) (0286-63) (0286-65) (0286-68) (0296-26) (0325-12) 

C. Spent Fuel Pools 

The NRC received a number of comments regarding the impacts of continued storage in spent 

fuel pools, including storage under various design conditions (such as low- and high-density 

pool storage). The GEIS will consider the environmental impacts of continued storage in spent 

fuel pools, including leaks, fires, floods, severe weather events, security concerns, and highburnup fuel. The Waste Confidence GEIS is a generic analysis of environmental effects and 

cannot place specific requirements on nuclear power plants. Therefore, imposing requirements 

on a specific licensee, requiring all licensees to use low-density open-frame layouts, or requiring 

licensees to move fuel out of the pools after 5 years is outside the scope of this analysis. 

Comments: (0004-13-11) (0004-14-7) (0004-18-1) (0004-20-3) (0004-20-5) (0004-25-13) (0004-

26-1) (0004-4-5) (0004-7-5) (0004-7-7) (0004-8-4) (0005-5-10) (0005-5-2) (0005-5-3) (0005-5-4) 

(0005-5-9) (0008-2) (0008-3) (0009-6) (0027-1) (0030-1) (0030-2) (0037-5) (0038-2) (0038-4) 

(0038-5) (0044-1) (0052-1) (0055-1) (0055-4) (0061-2) (0061-4) (0061-5) (0062-5) (0062-7) 

(0062-8) (0063-4) (0063-5) (0064-5) (0065-2) (0065-4) (0065-5) (0066-2) (0066-4) (0066-5) 

(0067-2) (0068-1) (0068-5) (0068-7) (0069-6) (0069-7) (0070-1) (0071-5) (0071-6) (0072-7) 

(0072-8) (0074-2) (0076-2) (0076-4) (0077-1) (0080-3) (0080-5) (0080-6) (0084-2) (0084-3) 

(0087-1) (0087-3) (0087-5) (0087-7) (0092-7) (0093-3) (0093-5) (0093-6) (0097-1) (0105-4) 

(0108-1) (0112-1) (0118-3-4) (0118-4-2) (0118-7-4) (0118-8-1) (0118-8-2) (0118-8-4) (0119-10-

1) (0119-6-6) (0119-6-8) (0148-13) (0148-15) (0148-17) (0148-18) (0148-21) (0148-22) (0148-

23) (0148-25) (0148-26) (0148-4) (0148-9) (0167-1) (0187-3) (0189-3) (0189-5) (0194-2) (0207-

1) (0211-1) (0221-2) (0226-1) (0238-1) (0241-4) (0242-10) (0242-11) (0242-6) (0246-9) (0260-

3) (0263-14) (0263-25) (0265-27) (0266-1) (0267-2) (0267-3) (0269-23) (0269-24) (0269-3) 

(0270-3) (0270-4) (0270-6) (0272-5) (0272-8) (0273-9) (0275-8) (0277-4) (0281-5) (0281-7) 

(0284-11) (0285-8) (0286-10) (0286-105) (0286-106) (0286-108) (0286-109) (0286-110) (0286-
- 22 - 

111) (0286-112) (0286-113) (0286-115) (0286-116) (0286-117) (0286-120) (0286-15) (0286-34) 

(0286-36) (0286-37) (0286-43) (0286-44) (0286-45) (0286-46) (0286-58) (0286-59) (0286-6) 

(0286-9) (0289-2) (0293-2) (0295-3) (0296-13) (0296-14) (0296-6) (0296-7) (0300-4) (0300-5) 

(0315-2) (0321-21) (0321-5) (0321-8) (0321-9) (0322-6) (0322-7) (0323-1) (0323-2) (0323-6) 

(0325-6) (0325-7) (0326-11) (0331-1) (0331-2) (0335-2) 

D. Generation of Low-Level Waste 

The NRC received a comment about the consideration of low-level radioactive waste in the 

GEIS. The potential environmental impacts of low-level radioactive waste generation, 

management, and disposal caused by continued storage will be addressed in the GEIS. 

Comment: (0285-12) 

B12. Comments Concerning Accidents 

A. General Comments About Accident Analysis 

The NRC received comments requesting that the GEIS consider the environmental impacts of 

accidents at nuclear facilities. The GEIS will analyze the risk and possible consequences of 

accidents during continued storage of spent nuclear fuel. The GEIS will consider accidents 

caused by equipment failures, man-made hazards, and natural phenomena hazards, such as 

earthquakes and floods. The GEIS will not analyze the impacts of nuclear reactor accidents or 

the impacts of spent fuel storage accidents during the licensed life for operation of a reactor. 

The NRC analyzes these environmental impacts in site-specific licensing proceedings. The 

Waste Confidence environmental review is a generic analysis of the environmental impacts of 

continued storage. 

Comments: (0026-1) (0029-1) (0037-6) 

B. Lessons Learned from the Fukushima Dai-ichi Nuclear Accident in Japan 

The NRC received comments requesting that the GEIS include in its analysis consideration of 

the March 11, 2011 Fukushima Dai-ichi nuclear accident and lessons learned from that event. 

These comments also outline, in light of the Fukushima accident, several possible accidents 

caused by natural and man-made events and request that the GEIS consider these possible 

accidents. The NRC also received comments concerning accident risk at specific nuclear 

power plant sites. One comment stated that the MELCOR Accident Consequence Code 

Systems 2 (MACCS2) software used by the NRC was outdated considering the lessons learned 

from Fukushima. 

The GEIS will describe in a generic manner the environmental impacts of postulated accidents 

during continued storage of spent nuclear fuel. This includes accidents caused by equipment 

failures, man-made hazards, and natural phenomena hazards, such as earthquakes and floods. 

The GEIS will describe both preventive and mitigating plant design features and response 

measures. The GEIS will also describe the NRC’s responses to lessons learned from the 

Fukushima Dai-ichi nuclear accident, as they relate to the continued storage of spent nuclear 

fuel. 
- 23 - 

Comments: (0001-4) (0004-17-2) (0004-17-3) (0004-18-2) (0004-26-2) (0005-5-11) (0021-1) 

(0038-3) (0055-5) (0056-2) (0061-3) (0062-9) (0065-6) (0068-8) (0072-9) (0087-2) (0087-4) 

(0105-3) (0106-2) (0107-7) (0111-2) (0118-9-6) (0148-12) (0148-38) (0156-1) (0194-3) (0246-4) 

(0269-26) (0269-27) (0271-23) (0272-12) (0285-9) (0286-5) (0291-19) (0307-2) (0315-1) (0326-

9) 

C. General Comments About Accidents 

The NRC received comments requesting that the GEIS include consideration of the risk and 

potential consequences of accidents caused by equipment failures, man-made hazards, and 

natural phenomena hazards, such as earthquakes and floods. Some of these comments raised 

concerns about site-specific accident risks and acts of terrorism. Some of these comments also 

requested that the GEIS include consideration of accidents that the NRC currently addresses in 

nuclear power plant design and operation, such as the risk of particular reactor design features 

or accidents caused by natural phenomena at an operating reactor at a particular site. The 

GEIS will generically consider the risk and potential consequences of accidents and acts of 

terrorism in its analysis of continued storage of spent nuclear fuel. The GEIS will not address 

these impacts during the licensed life for operation of a reactor. 

Comments: (0004-23-5) (0004-25-9) (0005-3-2) (0005-7-2) (0035-4) (0053-5) (0055-8) (0058-8) 

(0118-17-1) (0118-2-5) (0129-4) (0192-1) (0196-1) (0237-4) (0265-14) (0269-25) (0275-9) 

(0285-16) (0286-24) (0286-40) (0296-30) (0310-1) (0316-1) (0323-7) 

D. Dry Cask Accident Risks 

The NRC received comments requesting that the GEIS analyze the risk and potential 

consequences of dry cask accidents caused by natural events, including flooding and 

earthquakes. Several commenters noted that their concerns stemmed, in part, from the 2011 

earthquake in central Virginia that affected North Anna Nuclear Generating Station and the 2011 

nuclear accident at Fukushima Dai-ichi in Japan. Some commenters raised these concerns 

with respect to specific nuclear power plant sites such as Diablo Canyon Power Plant. 

The GEIS will consider the potential for environmental effects of natural phenomena hazards, 

including flooding and earthquakes, on dry cask fuel storage during continued storage. 

Comments: (0004-15-3) (0005-7-3) (0062-13) (0067-6) (0068-12) (0072-12) (0148-30) (0187-4) 

(0189-6) (0207-4) (0242-13) (0295-4) (0296-21) (0326-14) (0328-1) 

E. Spent Fuel Pool Accidents 

The NRC received comments recommending that the GEIS analyze accident scenarios 

involving criticality of spent fuel pools, loss of pool coolant, and the potential for spent fuel pool 

leaks and fires due to natural phenomena or as the result of loss of power. Some commenters 

raised concerns regarding the risk of spent fuel pool accidents at specific sites. The GEIS will 

apply current data and information to its generic assessment of the potential impacts of 

accidents involving spent fuel pools, including criticality, loss of coolant, and spent fuel pool 

leaks and fires. The GEIS will generically analyze the potential impacts of accidents. 
- 24 - 

Comments: (0058-1) (0058-2) (0087-6) (0118-9-5) (0180-1) (0272-4) (0277-5) (0296-24) (0326-

10) (0329-1) (0332-1) 

F. Accident Scenario Bounding Estimates 

The NRC received comments requesting the use of bounding values or worst-case scenarios 

for accident frequencies and consequences. The NRC plans to use existing information to 

generically assess accidents by reviewing the evaluations in other generic environmental impact 

statements and site-specific EAs and EISs. This approach follows the Commission’s direction 

in Staff Requirements Memorandum for COMSECY-12-0016, “Approach for Addressing Policy 

Issues Resulting from Court Decision to Vacate Waste Confidence Decision and Rule” (NRC 

2012c) to “coordinate and take appropriate advantage of existing documents and studies, 

including through adoption and incorporation by reference.” The appropriate use of existing 

information is sufficient to generically demonstrate the range of expected impacts from 

accidents that could occur from continued spent fuel storage. As with all NEPA analyses, the 

GEIS will analyze reasonably foreseeable events; the NRC will not analyze worst-case impacts. 

Comments: (0106-3) (0244-14) (0286-52) (0286-56) (0325-10) (0325-11) 

G. Environmental Justice and Cultural Resources 

The NRC received comments requesting that the GEIS consider environmental justice and 

cultural resource impacts resulting from accidents caused by natural phenomena, including 

seismic events. One commenter raised these concerns in the context of nuclear power plant 

operation. Another commenter raised concerns about the risk of seismic accidents and the 

potential for impacts on environmental justice matters and cultural resources on the California 

coast. 

The GEIS will analyze the potential impacts of accidents caused by equipment failures, and 

man-made and natural hazards. Accidents that occur during reactor operations are outside the 

scope of this review, which analyzes the impacts of continued storage of spent nuclear fuel. 

The GEIS will generically analyze the potential impacts of postulated accidents during continued 

storage. 

Comments: (0284-5) (0284-6) 

H. Reactor Accidents Impacting Spent Nuclear Fuel 

The NRC received a comment recommending that the GEIS consider reactor accidents leading 

to spent fuel pool accidents. The NRC will consider the environmental impacts of accidents 

involving spent nuclear fuel at facilities that are beyond the licensed life for operation of the 

reactor. As part of its analysis, the NRC will consider various initiating events, both internal and 

external. 

Comment: (0005-5-13) 

 
- 25 - 

I. Solar Flares 

The NRC received comments about a petition filed with the NRC on March 14, 2011 (PRM-50-

96; ADAMS Accession No. ML110750145), that suggests a solar flare could potentially disable 

large portions of the U.S. electrical grid for an extended period of time. In response to the solar 

flare petition, the NRC will undertake a rulemaking, “Long-Term Cooling and Unattended Water 

Makeup of Spent Fuel Pools” (77 FR 74788, December 18, 2012). The NRC will evaluate 

impacts from natural events in the GEIS, including impacts from the loss of electrical power that 

can be caused by events like solar flares. 

Comments: (0009-5) (0223-1) 

B13. Comments Concerning Security and Terrorism 

The NRC received several comments requesting that the GEIS consider safety and safeguards 

in its analysis, including the potential impacts associated with acts of terrorism, theft, illegal 

diversion, attack, sabotage, cyber attacks, and other malevolent acts. Some commenters also 

requested that the GEIS consider vulnerabilities of a specific reactor design to malevolent acts. 

The GEIS will include safety and safeguards considerations during the continued storage 

period. The GEIS will generically analyze the potential impacts of credible malevolent act 

scenarios during the continued storage period. The Waste Confidence GEIS is a generic 

analysis of environmental effects and cannot place specific requirements on nuclear power 

plants. 

Comments: (0004-11-3) (0004-24-1) (0004-25-14) (0035-2) (0037-2) (0061-6) (0119-6-5) (0125-

1) (0127-3) (0148-19) (0148-20) (0246-8) (0262-3) (0275-12) (0286-30) (0286-98) (0296-38) 

(0296-39) (0323-8) (0334-1) (0004-6-6) (0005-5-5) (0062-12) (0067-5) (0068-11) (0072-11) 

(0118-11-3) (0118-2-9) (0118-7-3) (0118-8-5) (0265-19) (0271-17) (0286-99) (0323-5) 

B14. Comments Concerning Cost Considerations 

The NRC received comments requesting that the GEIS analyze the impacts of the costs of and 

payment for continued storage. Some commenters also mentioned concerns regarding the cost 

of and payment for other stages of the nuclear fuel cycle, including reactor operation. The GEIS 

will assess the environmental impacts of costs of and payment for continued storage. The GEIS 

will not address the costs of and payment for other stages of the nuclear fuel cycle. 

Comments: (0004-15-5) (0004-15-6) (0004-15-7) (0004-25-11) (0005-5-7) (0091-2) (0091-3) 

(0091-4) (0118-14-1) (0118-14-2) (0118-17-6) (0118-21-2) (0118-26-3) (0137-1) (0244-6) 

(0251-2) (0258-3) (0272-10) (0275-10) (0291-12) (0291-13) (0291-14) (0291-16) (0291-17) 

(0296-31) (0296-32) (0296-33) 

B15. Comments Concerning Cumulative Impacts 

The NRC received comments requesting that the GEIS consider the cumulative impacts of 

continued storage, including the cumulative impacts of potential spent fuel pool leaks and fires. 

The GEIS will consider and evaluate the cumulative impacts that could occur from the 

incremental impact of continued spent fuel storage when added to past, present, and 

reasonably foreseeable future actions, regardless of what agency (federal or nonfederal), 
- 26 - 

person, or entity undertakes these actions. The analysis will include an assessment of 

cumulative impacts to groundwater, surface water, public health and safety, and other relevant 

resource areas. 

Comments: (0004-25-3) (0271-20) (0286-114) (0286-47) (0291-20) 

B16. Comments Concerning Alternatives 

A. Generic Versus Site-Specific Approach 

The NRC received a number of comments on the use of a generic approach to assessing the 

potential environmental impacts of continued storage instead of preparing site-specific analyses 

of continued storage. Some commenters supported a generic approach, while others supported 

a site-specific analysis. Some commenters requested that the GEIS identify issues that cannot 

be resolved generically. A number of commenters questioned how a generic approach could be 

conducted for certain resource areas, including ecology, hydrology, geology, socioeconomics, 

environmental justice, accidents, and historic and cultural resources. 

The courts have supported a generic evaluation of continued storage since the late 1970s 

(Minnesota v. NRC, 602 F.2d 412) (D.C. Cir. 1979), and the Court of Appeals for the D.C. 

Circuit recently noted that a generic assessment was an acceptable way to evaluate the 

environmental impacts of continued storage (New York v. NRC, 681 F.3d 471) (D.C. Cir. 2012). 

Examples of other NRC GEISs include nuclear power plant decommissioning (NUREG-0586, 

NRC 2002), nuclear power plant license renewal (NUREG-1437, NRC 2009a), and uranium 

recovery in-situ leach facility licensing (NUREG-1910, NRC 2009b).

Comments: (0004-10-4) (0004-12-7) (0004-15-2) (0004-22-4) (0004-23-6) (0004-25-7) (0004-

27-3) (0004-4-9) (0004-5-3) (0004-6-3) (0009-10) (0009-2) (0009-3) (0009-7) (0075-2) (0075-3) 

(0118-4-3) (0118-6-1) (0118-6-2) (0119-7-6) (0165-3) (0200-1) (0228-1) (0263-16) (0263-17) 

(0263-7) (0265-15) (0268-9) (0272-1) (0272-9) (0275-16) (0275-18) (0275-2) (0281-1) (0281-10) 

(0286-48) (0286-49) (0286-50) (0286-51) (0286-85) (0286-86) (0288-4) (0291-6) (0296-12) 

(0296-16) (0321-13) (0321-17) (0321-3) (0321-4) (0321-16) 

The NRC received one comment suggesting that groupings of reactors could be used to support 

a generic analysis. The NRC does not intend to group reactors by region or similar 

environmental characteristics. For this effort, the NRC plans to use existing information and 

data on environmental resources to create a baseline and an "envelope" of parameters and 

impacts for analysis in the GEIS. 

Comment: (0004-6-4) 

B. Alternatives 

The NRC received many comments on alternatives to the Waste Confidence rulemaking, 

including suggested alternatives such as stopping all NRC licensing activities, halting any 

further production of spent nuclear fuel, and shutting down all existing nuclear power plants. As 

Chairman Macfarlane noted in a December 5, 2012 letter (ADAMS Accession No. 

ML12319A309), the federal action is the update to the Waste Confidence rule. As noted in the 

same letter, one alternative to the proposed action is to not update the rule and to analyze these 
- 27 - 

impacts on a site-specific basis. The NRC is considering whether additional alternatives would 

be appropriate in the GEIS based upon the feedback it has received during the scoping 

comment period. The NRC will consider these comments as it develops the draft GEIS. 

Comments: (0003-6) (0004-11-4) (0004-12-5) (0004-13-7) (0004-14-3) (0004-17-1) (0004-18-9) 

(0004-20-6) (0004-6-2) (0004-7-6) (0005-11-5) (0005-13-1) (0005-14-1) (0005-15-1) (0005-3-1) 

(0005-8-1) (0012-3) (0027-2) (0038-8) (0040-1) (0041-2) (0042-1) (0044-2) (0046-1) (0048-4) 

(0049-8) (0053-2) (0062-1) (0062-2) (0063-1) (0063-2) (0064-1) (0064-2) (0064-3) (0068-2) 

(0069-2) (0071-2) (0071-3) (0072-1) (0072-2) (0072-3) (0074-1) (0077-2) (0077-3) (0079-3) 

(0080-1) (0084-1) (0085-4) (0092-1) (0115-1) (0118-16-4) (0118-17-14) (0118-8-3) (0119-6-4) 

(0119-7-3) (0119-7-5) (0121-1) (0124-1) (0125-2) (0127-1) (0128-1) (0129-1) (0132-1) (0136-1) 

(0140-1) (0141-1) (0145-1) (0147-2) (0148-7) (0153-1) (0157-1) (0158-1) (0161-1) (0175-1) 

(0177-1) (0182-1) (0186-1) (0187-1) (0189-1) (0193-1) (0194-5) (0198-1) (0201-1) (0202-1) 

(0210-1) (0213-4) (0213-7) (0215-1) (0216-4) (0227-4) (0231-1) (0234-1) (0236-1) (0237-3) 

(0241-1) (0242-4) (0242-7) (0243-1) (0246-1) (0247-3) (0248-1) (0249-1) (0251-3) (0252-2) 

(0253-1) (0257-1) (0258-2) (0262-5) (0262-6) (0263-22) (0263-5) (0263-6) (0266-4) (0269-1) 

(0269-10) (0269-14) (0269-15) (0269-21) (0271-18) (0271-19) (0272-15) (0273-4) (0274-10) 

(0274-2) (0274-5) (0275-14) (0275-4) (0277-11) (0281-11) (0281-3) (0285-14) (0286-1) (0286-

88) (0286-92) (0286-93) (0287-2) (0288-2) (0290-5) (0293-1) (0295-1) (0296-40) (0298-6) 

(0298-7) (0298-8) (0300-1) (0303-1) (0304-1) (0315-4) (0323-12) (0326-6) (0326-7) (0336-3) 

C. The Yucca Mountain No-Action Alternative 

The NRC received comments regarding the use of the Yucca Mountain EIS (DOE 2002) noaction alternative analysis as a resource in the development of the GEIS. The Commission 

directed the staff to incorporate by reference existing studies and documents, including the DOE 

Yucca Mountain no-action alternative, in the development of the GEIS. Therefore, NRC staff 

will independently consider, to the extent applicable and reasonable, the information contained 

in the DOE's Yucca Mountain EIS when drafting the GEIS. 

Comments: (0004-10-2) (0004-6-1) (0004-7-3) (0244-2) (0263-13) (0265-2) (0265-5) (0267-1) 

(0283-2) (0322-2) (0322-4) 

D. Future Updates to the Waste Confidence Rule 

The NRC received one comment regarding when the NRC would be required to prepare future 

updates to the GEIS and the Waste Confidence rule. The NRC staff will identify the 

assumptions and bases of its analysis in the GEIS. After an action is finalized, NRC will 

consider revisiting this analysis when warranted. If, in the future, changes in circumstances or 

information arise that challenge any results codified in an updated 10 CFR § 51.23, then 

interested parties may challenge those conclusions in site-specific licensing processes under 10 

CFR § 2.335(b). In addition, an interested party may petition the NRC to change its regulations 

under 10 CFR § 2.802. The NRC will discuss future updates to the Waste Confidence GEIS 

and rule in the Federal Register notice for the proposed rule. 

Comment: (0272-2) 

 
- 28 - 

B17. Comments Concerning Evaluation Scenarios 

A. New Requirements and Technologies 

The NRC received numerous comments about the adoption or development of specific 

technologies or requirements for dry cask storage, such as HOSS, retrievable storage in a 

repository, or other as yet undeveloped technologies and regulatory requirements. The 

commenters expressed their beliefs that these new technologies or additional requirements 

would improve the security and safety of spent nuclear fuel storage. For the purposes of its 

environmental analysis, the GEIS scenarios will assume that the current state of technology 

remains the same throughout the time periods analyzed. Further, the GEIS is not a licensing 

action. It cannot impose new storage requirements. The scope of the Waste Confidence GEIS 

will be limited to an assessment of the generic impacts of continued storage. With regard to 

HOSS, independent of the Waste Confidence rulemaking, the NRC is already considering 

implementing revised security requirements as part of the ongoing ISFSI security rulemaking 

effort. The rulemaking effort is described in the December 16, 2009, Federal Register notice 

(74 FR 66589), “Draft Technical Basis for Rulemaking Revising Security Requirements for 

Facilities Storing SNF and HLW; Notice of Availability and Solicitation of Public Comments.” 

Comments: (0004-11-2) (0004-14-5) (0004-14-8) (0004-18-3) (0004-25-12) (0005-5-12) (0038-

9) (0043-4) (0058-4) (0058-7) (0062-4) (0063-3) (0064-4) (0065-1) (0066-1) (0067-1) (0068-4) 

(0069-4) (0071-4) (0072-5) (0076-3) (0077-4) (0080-2) (0092-3) (0093-2) (0095-2) (0105-2) 

(0118-8-6) (0134-1) (0141-2) (0147-1) (0148-24) (0148-27) (0152-4) (0163-2) (0163-5) (0180-2) 

(0187-2) (0189-2) (0194-1) (0195-1) (0198-2) (0207-3) (0215-2) (0227-3) (0238-2) (0241-2) 

(0242-9) (0256-2) (0262-7) (0265-22) (0266-2) (0269-22) (0270-2) (0271-24) (0273-10) (0273-

12) (0281-8) (0286-42) (0286-104) (0286-33) (0288-3) (0289-1) (0293-3) (0296-34) (0296-37) 

(0314-1) (0315-3) (0323-11) (0326-8) (0327-1) (0336-4) 

B. Movement of Spent Nuclear Fuel to Dry Cask Storage 

The NRC received comments asking the NRC to require licensees to move spent nuclear fuel 

from spent fuel pools to dry cask storage after a certain, limited period of time (for example, 

some commenters suggested that pool storage be capped at 5 years). The GEIS is not a 

licensing action, and the NRC cannot impose new requirements or regulations on the duration 

of spent fuel pool storage through this action. The NRC is separately considering expedited 

transfer of spent fuel from spent fuel pools as part of lessons learned from the March 11, 2011 

Japan earthquake and subsequent tsunami. 

Comments: (0003-1) (0058-3) (0058-6) (0062-6) (0064-6) (0065-3) (0066-3) (0067-3) (0068-6) 

(0069-5) (0072-6) (0076-5) (0080-4) (0089-1) (0092-4) (0093-4) (0139-1) (0158-3) (0198-3) 

(0198-4) (0215-3) (0277-7) (0285-10) (0295-2) (0296-35) (0323-9) 

C. Reracking of Spent Fuel Pools 

The NRC received comments asking the NRC to require licensees to adopt low-density spent 

fuel pool configurations. The GEIS is not a licensing action, and the NRC cannot impose new 

requirements or regulations on the density of spent fuel pool storage. Further, the NRC has 

 
- 29 - 

previously reviewed license amendments to approve higher density storage in spent fuel pools, 

and the NRC is not aware of any new information that would cause it to reconsider this position. 

Comments: (0118-11-4) (0119-7-2) (0262-8) 

D. Away-From-Reactor Storage 

The NRC received comments on whether away-from-reactor storage, which includes 

consolidated interim storage, should be considered in the GEIS. The NRC will evaluate the 

environmental impacts of spent fuel storage at an away-from-reactor storage facility as part of 

the GEIS. Should any away-from-reactor storage facility be proposed at some point in the 

future, the NRC will conduct a site-specific NEPA assessment as part of the licensing process 

for that proposed facility. 

Comments: (0004-10-5) (0004-9-5) (0096-2) (0180-3) (0204-2) (0241-3) (0259-5) (0263-24) 

(0265-25) (0282-6) (0293-4) 

E. Maintenance and Institutional Controls 

The NRC received a number of comments on the topic of maintenance and institutional controls 

over the longer timeframes that will be considered in the GEIS, including whether the federal 

government would be held responsible for the maintenance of these institutional controls and 

whether future generations would have the knowledge and capability to effectively manage 

spent nuclear fuel storage. The NRC believes it is reasonable to assume that licensees remain 

responsible for the spent nuclear fuel stored on their sites and that institutional controls and, 

specifically, continued oversight by the NRC will remain in place for the duration of the 

scenarios under evaluation. However, the GEIS will include a discussion of the environmental 

impacts associated with the loss of institutional controls. 

Comments: (0004-9-3) (0004-9-4) (0095-3) (0118-17-7) (0204-1) (0233-4) (0244-10) (0244-13) 

(0244-16) (0244-19) (0244-8) (0244-9) (0259-4) (0259-6) (0271-11) (0280-6) (0280-7) (0286-11) 

(0286-27) (0286-29) (0286-73) (0286-80) (0286-81) (0291-18) (0325-2) 

F. Spent Mixed Oxide (MOX) Fuel 

The NRC received a number of comments on the inclusion of MOX fuel in the GEIS. Because 

production and use of MOX fuel is reasonably foreseeable, it is within the scope of the GEIS 

and will be included in the assessment of environmental impacts of continued storage. MOX 

fuel was produced and used in the United States before the mid-1970s, and spent MOX fuel 

remains in storage at multiple facilities as part of the U.S. inventory of spent nuclear fuel. MOX 

fuel is not currently being produced in the United States; however, there is an application 

pending before the NRC for Shaw AREVA MOX Services (formerly Duke COGEMA Stone & 

Webster) to manufacture MOX at the Savannah River Site (Shaw/AREVA 2010). 

Comments: (0004-18-5) (0004-26-4) (0118-17-12) (0265-7) (0281-9) (0288-5) (0301-1) (0325-5) 

 
- 30 - 

G. Repackaging Spent Nuclear Fuel 

The NRC received comments on the repackaging of spent nuclear fuel. Repackaging will be 

considered in the GEIS. Two of the three scenarios that the NRC now plans to consider in the 

GEIS will assume that the spent nuclear fuel needs to be repackaged. The GEIS will assume 

that a DTS, or a facility with equivalent capability, will eventually be constructed to enable 

retrieval of spent nuclear fuel for inspection or repackaging. A DTS would allow for repackaging 

at ISFSI-only sites and provide management flexibility at all dry storage sites by enabling 

repackaging without the need to build a new pool. The NRC will assume in its GEIS analyses 

that the need for DTS facilities will increase over time as the duration and quantity of fuel in dry 

storage increases. 

Comments: (0005-5-8) (0096-5) (0118-2-10) (0244-12) (0270-5) (0280-4) (0291-11) 

H. Advanced Nuclear Reactor Designs 

The NRC received comments on advanced reactor technologies, such as Generation IV power 

plants, and their inclusion in the GEIS. The GEIS will not consider spent nuclear fuel types that 

might be generated by speculative technologies, such as sodium-cooled, fast-neutron reactors 

or fusion reactors. The GEIS will evaluate the environmental impacts associated with the 

continued storage of commercial spent nuclear fuel, including both low- and high-burnup lowenriched uranium and reasonably foreseeable fuel types, such as uranium-plutonium MOX fuels 

at low and high burnups. 

Comments: (0118-17-11) (0286-102) 

I. Timeframes for GEIS Scenarios 

The NRC received comments on the timeframes for the various GEIS scenarios, including 

comments on when the NRC should assume a repository becomes available and the long 

decay times associated with spent nuclear fuel. The GEIS will specify the timeframes and 

repository availability assumptions for any scenarios analyzed. The NRC will consider these 

comments as it continues to develop the draft GEIS and proposed rule. 

Comments: (0004-4-7) (0004-6-5) (0023-1) (0096-1) (0107-2) (0107-6) (0118-12-2) (0233-2) 

(0244-5) (0244-7) (0246-12) (0263-23) (0263-8) (0264-4) (0265-6) (0269-13) (0270-10) (0272-

13) (0272-14) (0274-6) (0284-10) (0286-12) (0286-121) (0286-13) (0286-16) (0286-61) (0286-

90) (0291-3) (0292-1) (0294-2) (0325-1) 

J. Permanent Disposal 

The NRC received comments that questioned whether disposal is still the national policy for 

spent nuclear fuel or recommended other disposal solutions, such as permanent onsite 

disposal. Some commenters expressed concern that the continued storage facilities would 

become de facto disposal sites. The GEIS will reflect that disposal in a repository continues to 

be the national policy. 

Comments: (0004-9-1) (0107-3) (0118-16-2) (0118-16-3) (0251-1) (0256-1) (0258-1) (0259-1) 

(0265-23) (0273-6) (0300-3) 
- 31 - 

K. Timeframe for Reviewing Waste Confidence 

The NRC received one comment suggesting that perpetual storage could be addressed by 

requiring periodic revisiting of Waste Confidence. As with any NRC action, the Commission 

would consider revisiting and updating the GEIS and rule if it becomes apparent that an update 

is needed. 

Comment: (0244-15) 

L. No-Repository Scenario 

The NRC received comments about the inclusion of a no-repository scenario in the GEIS and 

whether the no-repository scenario could be described as a potential mitigating measure. The 

GEIS will include a no-repository scenario. 

Comments: (0004-16-2) (0004-20-4) (0004-4-1) (0004-4-8) (0037-1) (0037-3) (0107-4) (0118-

12-1) (0118-16-1) (0148-32) (0226-3) (0233-1) (0244-17) (0244-18) (0244-3) (0260-2) (0260-4) 

(0263-11) (0263-12) (0268-3) (0270-9) (0271-10) (0275-23) (0281-13) (0285-18) 

M. Safety 

The NRC received comments that questioned the continued safety of spent nuclear fuel storage 

either due to lack of appropriate technology, societal hurdles, the need for robust studies to 

ensure safe storage, or the length of time spent nuclear fuel needs to be safely stored. As a 

regulatory agency, the NRC does not develop new technologies or direct public policy regarding 

the management of spent nuclear fuel. However, the NRC has regulations and requirements to 

ensure protection of public health and safety and the environment, and is developing the GEIS 

to evaluate the impacts of continued storage. These comments will be considered in the 

development of the GEIS. 

Comments: (0004-4-2) (0033-1) (0048-3) (0069-3) (0073-1) (0118-3-1) (0119-6-3) (0151-1) 

(0154-1) (0160-1) (0162-1) (0183-1) (0195-2) (0208-1) (0218-1) (0219-1) (0275-13) (0277-2) 

(0321-6) (0336-2) 

N. Timeframe to Develop Repositories 

The NRC received comments that questioned whether the GEIS would consider the time 

needed to develop multiple repositories. The GEIS will consider the time necessary to develop 

sufficient repository capacity for a reactor’s spent nuclear fuel, which will include a discussion of 

the statutory repository limit and the potential need for more than one repository. 

Comments: (0118-13-2) (0118-17-9) (0119-10-2) 

O. Scope of Scenarios 

The NRC received comments on the scope of the scenarios that will be considered in the GEIS. 

For example, some of these commenters suggested that the GEIS scenarios consider the 

possible expansion of nuclear power instead of a “no growth” scenario where nuclear power 
- 32 - 

continues to supply about 20 percent of the nation’s electricity needs. The NRC will consider 

these comments as it develops the GEIS. 

Comments: (0107-5) (0286-28) (0286-31) (0286-32) (0286-35) 

P. Relationship Between Continued Storage and Repository 

The NRC received one comment questioning the relationship between continued storage and 

repository design. This relationship will not be assessed in the GEIS, because it is not relevant 

to the analysis that the NRC must conduct to assess the environmental impacts of continued 

storage. Any future repository design would need to account for changes to the spent nuclear 

fuel due to decay and aging. 

Comment: (0271-12) 

B18. Comments Concerning NEPA Process 

A. General Schedule and Public Participation 

The NRC received many comments concerning the Waste Confidence GEIS proposed schedule 

and public participation opportunities. These comments expressed both support for and 

criticism of the NRC's 24-month schedule to complete the GEIS. The Waste Confidence 

rulemaking is a high priority for the Commission; there are resources and energy being put into 

its completion within the 2-year timeframe while ensuring ample public involvement. The staff’s 

schedule for the previous effort was based on fewer resources, fewer staff members, and a 

variety of new issues related specifically to the long-term update, which is not at issue in this 

rulemaking. The current schedule for the GEIS will enable the NRC to conduct the hard look 

required by NEPA and optimize public participation in the process. 

With regard to the duration of the scoping comment period, as noted in a letter dated December 

5, 2012 from NRC Chairman Macfarlane, the 70-day Waste Confidence GEIS scoping period 

was consistent with, or longer than, scoping comment periods for other NRC licensing actions 

(ADAMS Accession No. ML12319A309). Further, there will be another opportunity for public 

comment when the draft GEIS and proposed rule are issued. During the comment period for 

these documents, the NRC plans to hold regional and webcast public meetings to discuss the 

conclusions in the draft GEIS, and solicit public comments on the draft GEIS and proposed rule. 

Comments: (0001-2) (0004-10-1) (0004-12-10) (0004-12-6) (0004-14-2) (0004-14-6) (0004-19-

1) (0004-20-1) (0004-22-1) (0004-22-3) (0004-23-2) (0004-27-6) (0004-7-1) (0004-8-1) (0005-7-

5) (0005-9-2) (0005-9-3) (0009-8) (0010-1) (0011-1) (0011-2) (0012-1) (0012-2) (0013-1) (0013-

2) (0014-1) (0015-1) (0015-2) (0016-1) (0017-1) (0017-2) (0018-1) (0019-1) (0019-3) (0020-1) 

(0028-1) (0029-2) (0029-3) (0035-3) (0038-10) (0041-1) (0041-4) (0043-1) (0045-2) (0050-2) 

(0053-1) (0055-6) (0059-2) (0059-4) (0060-1) (0061-1) (0075-1) (0076-1) (0078-1) (0086-1) 

(0086-2) (0086-5) (0091-5) (0098-1) (0099-1) (0100-1) (0103-1) (0104-1) (0104-3) (0111-1) 

(0114-2) (0118-2-3) (0118-21-1) (0118-23-2) (0118-25-3) (0119-6-1) (0119-6-2) (0119-7-1) 

(0120-1) (0148-2) (0148-3) (0152-3) (0216-1) (0216-2) (0217-1) (0223-3) (0228-2) (0237-5) 

(0242-2) (0242-3) (0247-2) (0252-3) (0263-1) (0263-20) (0264-1) (0265-1) (0268-2) (0269-8) 

(0271-5) (0273-2) (0273-8) (0276-2) (0276-3) (0281-4) (0288-6) (0290-1) (0290-2) (0296-10) 
- 33 - 

(0296-8) (0297-4) (0299-1) (0302-1) (0308-1) (0311-1) (0312-1) (0313-1) (0317-1) (0318-1) 

(0321-14) (0321-15) (0322-1) (0326-2) (0326-3) (0326-5) 

B. Number of and Locations for Public Meetings 

The NRC received many comments about the number and locations of meetings to discuss the 

GEIS and proposed rule. During the comment period for the draft GEIS and proposed rule, the 

NRC plans to hold a number of public meetings across the country to allow stakeholders to 

interact with and hear directly from NRC staff. At least one of these meetings will be webcast 

and teleconferenced, which will allow interested people and organizations to participate in the 

meeting without having to travel. The NRC will consider the suggestions in these comments as 

it develops the public meeting schedule. 

Comments: (0004-12-1) (0004-12-3) (0004-13-3) (0004-14-1) (0004-15-1) (0004-18-7) (0004-

23-3) (0004-25-17) (0004-25-8) (0004-5-5) (0004-7-4) (0005-11-1) (0005-12-1) (0005-17-6) 

(0005-5-1) (0005-7-4) (0014-2) (0016-2) (0019-2) (0020-2) (0029-4) (0043-3) (0049-4) (0059-3) 

(0060-4) (0084-4) (0086-3) (0086-4) (0098-2) (0100-2) (0118-2-4) (0118-20-1) (0118-3-2) 

(0119-6-7) (0119-8-1) (0152-5) (0165-2) (0197-1) (0221-3) (0237-7) (0242-8) (0244-20) (0265-

21) (0268-4) (0273-1) (0274-9) (0281-2) (0286-60) (0290-3) (0291-25) (0296-1) (0296-3) (0296-

4) (0296-9) (0299-2) (0311-4) (0312-2) (0318-2) (0325-8) (0326-4) 

C. Public Outreach 

The NRC received comments about the timing, locations, and form of its public outreach, 

including a comment describing difficulties with accessing the Internet-based meetings that 

were held as part of the scoping process. The NRC will consider these comments as it 

continues to refine its public outreach activities associated with the development of the GEIS. 

For example, in response to the comment outlining the difficulties experienced when searching 

for information on the Waste Confidence Directorate's website, the NRC reorganized the 

website so that a direct link to current public meeting information is available on the homepage 

of the site. 

The NRC strives to conduct its regulatory responsibilities in an open and transparent manner, 

consistent with the NRC Approach to Open Government. The NRC appreciates feedback 

regarding its communications with the public and will consider that feedback moving forward. 

Comments: (0004-12-8) (0114-3) (0118-23-1) (0118-24-1) (0118-24-2) (0118-25-1) (0118-25-2) 

(0118-25-4) (0118-26-1) (0118-27-1) (0118-3-5) (0119-11-2) (0119-12-1) (0119-13-1) (0273-7) 

(0288-7) (0297-1) 

D. Reliance on Existing Data and Documents 

The NRC received comments regarding reliance on existing data and documents in the GEIS. 

As it develops the GEIS, the NRC will actively seek out information sources that may be 

relevant and helpful in the preparation of the GEIS, including previous Waste Confidence 

rulemakings, EAs and impact statements, and technical reports, as appropriate. These 

documents will be clearly referenced or cited in the GEIS, and members of the public will be 

able to comment on the NRC’s decisions regarding existing data and documents during the 

comment period for the draft GEIS. 
- 34 - 

Comments: (0004-10-3) (0004-10-6) (0004-19-2) (0004-20-2) (0004-27-4) (0004-27-5) (0004-7-

2) (0118-13-1) (0237-2) (0237-6) (0246-3) (0263-10) (0263-19) (0263-2) (0264-3) (0274-7) 

(0283-5) (0283-6) (0285-3) (0286-3) (0291-8) (0298-4) (0302-2) (0302-3) (0335-1) 

E. Federal Register Notice on GEIS Scoping Period 

The NRC received many comments about the Federal Register notice announcing the GEIS 

scoping period (77 FR 65137, October 25, 2012, “Consideration of Environmental Impacts of 

Temporary Storage of Spent Fuel After Cessation of Reactor Operation”). These comments 

generally requested that NRC withdraw the Federal Register notice because the notice is legally 

deficient and that the proposed action and alternatives were absent from the notice. These 

comments mirror a number of informal requests to the Commission (i.e., comments not 

submitted through formal comment routes) to withdraw the Waste Confidence scoping notice 

and to extend the public comment period. The Commission also received a letter dated 

November 8, 2012 (ADAMS Accession No. ML12314A345), from Diane Curran, Mindy 

Goldstein, and Geoffrey Fettus, on behalf of 25 organizations and individuals, expressing 

concern about the NRC’s scoping notice. Following receipt of this letter, the Waste Confidence 

Directorate (via WCOutreach@nrc.gov) received approximately 2,300 identical e-mails that 

expressed support for the letter. These e-mails were not considered as formal scoping 

comments, but the issues raised in the e-mails are addressed in this response. 

NRC Chairman Allison Macfarlane responded to the November 8 letter on behalf of the 

Commission (ADAMS Accession No. ML12319A309; December 5, 2012). In her letter, the 

Chairman reaffirmed that the federal action under consideration is an update to the Waste 

Confidence rule. The Chairman also noted that the scoping notice complies with the NRC’s 

regulations and that an extension of the scoping period was not warranted. 

Finally, one comment discussed the content of a Record of Decision. The NRC's Record of 

Decision is not required to be completed until the Commission concludes its final GEIS (10 CFR 

§ 51.102). The NRC's final rule and GEIS will include a Record of Decision that complies with 

the NRC's NEPA requirements. 

Comments : (0004-11-1) (0004-12-2) (0004-12-4) (0004-12-9) (0004-13-1) (0004-13-2) (0004-

18-8) (0004-22-2) (0004-23-1) (0004-25-1) (0004-27-2) (0005-11-2) (0005-12-2) (0005-17-2) 

(0043-2) (0045-1) (0047-1) (0047-2) (0049-1) (0049-2) (0049-3) (0049-5) (0050-1) (0051-1) 

(0058-10) (0058-9) (0060-2) (0060-3) (0083-1) (0083-3) (0083-4) (0085-1) (0085-2) (0085-3) 

(0107-1) (0118-2-1) (0118-2-2) (0118-5-1) (0147-3) (0216-3) (0263-4) (0266-5) (0269-9) (0271-

1) (0271-21) (0271-3) (0271-4) (0271-7) (0271-8) (0273-3) (0275-6) (0296-2) (0298-1) (0298-5) 

(0299-3) (0307-1) (0310-2) (0311-2) (0311-3) (0315-5) (0318-3) (0319-1) (0319-2) (0321-10) 

(0321-12) (0326-1) 

F. Tribal Consultation 

The NRC received comments regarding tribal consultation. The NRC will comply with relevant 

laws, regulations, and Executive Orders (including Executive Order 13175 [65 FR 67249]) to 

ensure that interested tribes are aware of and involved in the development of the GEIS. 

For example, as part of the NRC’s scoping efforts, letters about the scoping process for the 

GEIS were sent to federally recognized tribes that live within 50 miles of a nuclear power plant, 
- 35 - 

to tribes that requested to receive advanced notification of shipments of spent nuclear fuel and 

high-level nuclear waste under 10 CFR Parts 71 and 73, and to tribes that expressed interest in 

the NRC’s Yucca Mountain application activities. The NRC will continue its outreach efforts with 

Native American tribes interested in this rulemaking, encourage their participation, and be 

respectful of tribal sovereignty. 

Comments: (0004-4-6) (0284-12) (0284-8) (0321-18) 

G. Issues Identified by the Court of Appeals for the D.C. Circuit 

The NRC received comments regarding the scope of the GEIS with respect to the issues 

identified by the Court of Appeals for the D.C. Circuit and previous Waste Confidence 

rulemakings. The GEIS will include, but not be limited to, the three issues identified by the 

court. Further, the GEIS will consider the issues discussed in previous Waste Confidence 

rulemakings, but will expand the analysis of those issues as appropriate for a GEIS. The NRC 

will ensure that its analysis complies with the requirements of NEPA. 

Comments: (0004-8-2) (0009-9) (0244-1) (0259-2) (0263-9) (0264-2) (0267-5) (0268-8) (0283-3) 

(0291-4) (0291-5) 

H. Guidance Documents for Development of GEIS 

The NRC received comments regarding which, if any, NRC guidance documents would be used 

to develop the GEIS. The GEIS will follow, to the extent practicable, the applicable guidance in 

NUREG-1748, “Environmental Review Guidance for Licensing Actions Associated with NMSS 

Programs: Final Report” (NRC 2003). This document is available on the NRC website at 

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1748/. 

Comments: (0004-4-3) (0283-1) (0321-19) 

I. Level of Review 

The NRC received comments requesting that the NRC conduct a thorough environmental 

review of spent fuel storage, including impacts at particular NRC-licensed sites. The Waste 

Confidence GEIS will be developed in accordance with NRC’s regulations that implement NEPA 

at 10 CFR Part 51, and will provide an assessment of the environmental impacts of continued 

storage. The GEIS will evaluate these impacts generically, and thus will not evaluate specific 

sites. 

Comments: (0032-1) (0035-1) (0037-4) (0038-1) (0123-1) (0126-1) (0142-1) (0164-1) (0227-1) 

(0232-1) (0237-1) (0284-9) (0286-103) 

J. Site-Specific Analyses 

The NRC received comments requesting that the NRC require a separate site-specific 

environmental analysis before it licenses or relicenses a nuclear power plant. A site-specific 

environmental analysis is required prior to licensing or relicensing for each application received 

by the NRC. The GEIS will be an environmental analysis that looks at the continued storage of 
- 36 - 

spent nuclear fuel on a generic basis. The Waste Confidence rulemaking and supporting GEIS 

will not license or relicense any reactor or spent nuclear fuel storage facility. 

Comments: (0152-2) (0166-1) (0170-1) (0172-2) (0178-1) (0184-1) (0191-1) 

K. Content and Format 

The NRC received a comment requesting that the NRC provide a detailed discussion of the 

comments and the basis for the NRC’s final determination regarding the scope of the GEIS. 

The draft GEIS will reflect the NRC’s determinations regarding the scope of the GEIS. 

Members of the public will be able to comment on the draft GEIS, and the NRC will provide 

detailed responses to those comments as part of the final GEIS. The scope of the final GEIS 

could change from the draft as a result of public comments. 

Comment: (0275-22) 

L. Authority for Development of a GEIS 

The NRC received a comment requesting citations to the authority that allows for the 

development of a GEIS. The courts have supported a generic evaluation of continued storage 

since the late 1970s (Minnesota v. NRC, 602 F.2d 412) (D.C. Cir. 1979), and the Court of 

Appeals for the D.C. Circuit recently noted that a generic assessment was an acceptable way to 

evaluate the environmental impacts of continued storage (New York v. NRC, 681 F.3d 471) 

(D.C. Cir. 2012). Examples of other NRC GEISs include nuclear power plant decommissioning 

(NUREG-0586, NRC 2002), nuclear power plant license renewal (NUREG-1437, NRC 2009a), 

and uranium recovery in-situ leach facility licensing (NUREG-1910, NRC 2009b). 

Comment: (0246-2) 

M. Lessons Learned on Previous Waste Confidence Efforts 

The NRC received a comment suggesting NRC conduct a lessons learned analysis from 

previous Waste Confidence efforts. The NRC will consider past Waste Confidence experience 

in the development of the GEIS and proposed rule. 

Comment: (0260-1) 

N. Availability of Information 

The NRC received many comments suggesting that adequate data are not available, significant 

uncertainties exist, or additional research is necessary on various issues, including MOX fuel 

and high-burnup spent fuel, before a Waste Confidence GEIS can be developed. The NRC 

believes there are numerous sources of the requisite technical data and information available to 

successfully complete the GEIS while meeting NEPA requirements. 

The staff will adopt or incorporate by reference all or part of existing EISs, as appropriate. 

There are numerous other technical documents and reports on pertinent issues that can be 

used to support the necessary analyses in the Waste Confidence GEIS. 
- 37 - 

In preparing the GEIS, the NRC is mindful of the CEQ’s “Guidance on Improving the Process for 

Preparing Efficient and Timely Reviews Under NEPA” (CEQ 2012), which encourages (i) 

straightforward and concise reviews of documentation that are proportionate to potential 

impacts and effectively convey the relevant considerations to the public and decision-makers in 

a timely manner while rigorously addressing the issue presented and (ii) coordination of 

appropriate existing documents and studies, which may be adopted and incorporated by 

reference. This guidance can be found at the CEQ's website: 

http://www.whitehouse.gov/sites/default/files/microsites/ceq/improving_nepa_efficiencies_06mar

2012.pdf. The NRC will rely on accurate and high quality information to ensure the Waste 

Confidence GEIS contains a thorough and rigorous environmental impact analysis. 

Comments: (0004-6-8) (0265-24) (0265-4) (0280-1) (0280-2) (0286-2) (0286-4) (0286-64) 

(0286-66) (0286-67) (0286-7) (0286-70) (0286-76) (0286-78) (0286-79) (0286-82) (0286-89) 

(0298-2) (0322-3) (0322-8) 

The NRC received a comment requesting that research efforts evaluating transportation impacts 

be integrated with aging management programs. The NRC will consider a variety of information 

sources to support the GEIS. 

Comment: (0004-9-2) 

O. Mitigation Alternatives 

The NRC received comments about its proposed methodology for considering mitigation 

alternatives. The Waste Confidence GEIS will evaluate environmental impacts and discuss 

mitigation that could reduce impacts to resources affected by continued storage of spent nuclear 

fuel. 

Comments: (0275-15) (0284-7) (0286-8) 

P. Scope of the GEIS 

The NRC received a comment suggesting the scope of the Waste Confidence GEIS should be 

narrowly bounded. The GEIS will address the deficiencies identified by the recent decision by 

the Court of Appeals (New York v. NRC, 681 F.3d 471) (D.C. Cir. 2012). The NRC will be 

considering a variety of information sources to support the analyses in the GEIS. As applicable, 

this can include spent fuel storage and transportation regulatory programs, including available 

information from or about research and development efforts underway currently or that would be 

conducted in the future by the NRC, DOE, and the Electric Power Research Institute, and 

current information about aging management programs. The GEIS will only consider impacts 

resulting from actions and activities applicable to continued storage of spent nuclear fuel. 

Comment: (0259-3) 

The NRC received comments suggesting that the proposed action had a broader scope than 

described by the NRC. In particular, commenters requested that the scope include the 

cessation of all spent nuclear fuel generation and analysis of stopping future spent fuel 

generation in light of significant future uncertainty. While the GEIS will consider an indefinite 

storage scenario, the NRC does not agree with the commenters’ description of the proposed 
- 38 - 

action. As Chairman Macfarlane noted in the December 5, 2012 letter to the commenter and 

others (ADAMS Accession No. ML12319A309), the federal action is the update to the Waste 

Confidence rule. As noted in the same letter, one alternative to the proposed action is to not 

update the rule and to analyze these impacts on a site-specific basis. The NRC is considering 

whether additional alternatives would be appropriate for consideration in the GEIS based upon 

the feedback it has received during the scoping comment period. 

Comments: (0271-6) (0275-5) 

Q. National Historic Preservation Act 

The NRC received a comment requesting that the NRC comply with Section 106 of the National 

Historic Preservation Act (NHPA). The NRC will comply with the requirements of Section 106 of 

the NHPA through implementation of its NEPA requirements in 10 CFR Part 51 by considering 

these issues in the GEIS. Potential impacts to historic and cultural resources will be discussed 

in the GEIS. However, the Waste Confidence rulemaking does not identify specific sites for 

NRC licensing actions that would trigger the identification of historic properties and other steps 

in the Section 106 process. These activities would occur during site-specific licensing actions. 

Comments: (0284-2) (0284-3) 

R. Relationship to Previous Long-Term Waste Confidence Effort 

The NRC received comments responding to its issuance of a December 2011 pre-scoping 

document, “Draft Report for Comment: Background and Preliminary Assumptions for an 

Environmental Impact Statement—Long-Term Waste Confidence Update” (NRC 2011a). This 

document relates to a separate initiative to look at spent fuel storage for more than the 60 years 

after the end of licensed life for operation considered in the 2010 Waste Confidence rulemaking 

(i.e., the “Long-Term Waste Confidence Update”). This is a separate project from the current 

effort to prepare a Waste Confidence GEIS and update the Waste Confidence rule. The longterm effort has been deferred until the NRC completes the current effort to prepare a GEIS and 

update the Waste Confidence rule. Comments received on the 2011 pre-scoping document 

were reviewed by the NRC staff to assess whether they are relevant to the current Waste 

Confidence update. Those comments, which were in response to a different, though related, 

effort, are not within the scope of this analysis and have not been captured in this scoping 

summary report. A summary of the comments can be found in Section A12 of this report, and a 

complete list of commenters on the pre-scoping document can be found in Section E. 

Comments: (0005-9-1) (0259-7) (0321-20) 

S. Coordination with Other Agencies 

The NRC received two comments that identified the U.S. Navy as a resource for dealing with 

long-term storage of spent nuclear fuel. In developing the GEIS, the NRC will follow the 

Commission’s direction to “coordinate and take appropriate advantage of existing documents 

and studies.” This may include information from other federal agencies and government 

sources. 

Comments: (0003-2) (0254-1) 
- 39 - 

B19. Comments Concerning Rulemaking Process 

A. Proposed Action 

The NRC received comments concerning the description of the proposed action that was 

published in the Federal Register. The proposed NRC action is a revision to the Waste 

Confidence rule (10 CFR § 51.23). The proposed revision to the rule will adopt into the NRC’s 

regulations the generic assessment in the GEIS of the environmental impacts associated with 

the continued storage of spent nuclear fuel beyond the licensed life of a reactor and prior to 

ultimate disposal. The Waste Confidence rule is not a licensing action. It does not authorize 

the initial or continued operation of any nuclear power plant and does not authorize storage of 

spent nuclear fuel. Therefore, the licensing of specific reactors or storage facilities is not the 

purpose of this rulemaking or the proposed action. A separate NRC action is required before a 

reactor is licensed and before fuel can be stored after the expiration of a reactor’s license at a 

specific site. The environmental analysis accompanying each of these actions to license or 

relicense a nuclear power plant would examine site-specific, no-action alternatives. 

Comments: (0270-7) (0271-2) (0321-11) 

B. Definition of Spent Nuclear Fuel 

The NRC received comments concerning the use of the term “spent nuclear fuel.” The NRC 

defines spent nuclear fuel (or spent fuel) as “fuel that has been withdrawn from a nuclear 

reactor following irradiation, the constituent elements of which have not been separated by 

reprocessing," according to 10 CFR § 2.1105(b). The NRC will use the term “spent nuclear fuel” 

or “spent fuel” throughout the GEIS and the Federal Register notice for the rule. 

Comments: (0281-12) (0288-1) 

C. Scoping Comments 

The NRC received a comment asking whether there will be a comment period on this scoping 

summary report. This scoping summary report provides the scope for the forthcoming GEIS, as 

informed by public comments. The next opportunity for public comment will be when the NRC 

solicits input on the draft GEIS and proposed rule. The Waste Confidence GEIS will consider 

the environmental impacts of the continued storage of spent nuclear fuel for various timeframes, 

and the NRC will clearly define those timeframes as part of its analysis. The GEIS will define 

any technical terms that are used to support its analysis. 

Comment: (0118-4-1) 

D. Use of the Five Findings 

The NRC received comments concerning the historical Waste Confidence decision and the 

“Five Findings.” The NRC will consider these comments as it prepares the Federal Register

notice for the proposed rule, which will also address the Waste Confidence Decision. 

Comments: (0263-21) (0263-3) (0270-8) 
- 40 - 

E. Document Availability 

The NRC received comments expressing concern about the availability of documents that will 

be used to support the GEIS and proposed rule. The NRC strives to conduct its regulatory 

responsibilities in an open and transparent manner, consistent with the NRC Approach to Open 

Government. The Waste Confidence GEIS and rule, if finalized, will be supported by a 

comprehensive, publicly available docket of supporting and informing materials. To the extent 

possible under existing laws and regulations, the NRC will disclose the documents that provide 

the basis for the GEIS and the rule. The NRC does not expect to rely on classified or sensitive 

documents in the GEIS, but must follow federal and NRC document requirements if it does. 

One comment suggests making non-NRC documents relevant to the Waste Confidence GEIS 

and rulemaking available on the NRC's Waste Confidence website 

(http://www.nrc.gov/waste/spent-fuel-storage/wcd.html). The NRC will consider its 

implementation. 

Comments: (0148-1) (0275-21) (0283-4) 

F. Hearing Request 

The NRC received comments requesting that the NRC use an adjudicatory hearing process for 

this rulemaking. The NRC does not agree that it is appropriate to convene an adjudicatory 

hearing for this rulemaking, nor does the NRC believe that the 10 CFR Part 2, Subpart L 

procedures are appropriate for this rulemaking. The NRC staff believes that the normal NEPA 

and rulemaking processes, including the scoping process and this scoping summary report, the 

comment response for the draft GEIS, and the notice-and-comment rulemaking process, allow 

for the ample public comment opportunities as well as the efficiencies the Commission required. 

Comments: (0237-8) (0275-20) 

G. Description of the Proposed Action 

The NRC received a comment disagreeing with the NRC’s description of the proposed action, 

instead suggesting that the NRC should consider whether or not to allow nuclear power plants 

to continue to operate, given the absence of a disposal facility. The NRC disagrees with this 

characterization. The current Waste Confidence update will not result in the authorization to 

operate or construct any particular facility, or to generate nuclear waste. The Waste Confidence 

GEIS will resolve one piece of the NEPA analysis for reactor licensing and spent fuel storage 

facility licensing proceedings (i.e., storage of spent nuclear fuel beyond the licensed life of a 

reactor prior to disposal in a repository). The proposed action is the issuance of a final rule. 

One alternative is to not issue the rule and to consider these impacts on a case-by-case basis. 

The NRC is considering the many comments it received on possible alternatives to the Waste 

Confidence rulemaking. These alternatives will be described and analyzed in the GEIS, which 

will be available for public review and comment later this year. 

Comment: (0275-1) 

 
- 41 - 

H. Major Federal Action 

The NRC received a comment that it has misunderstood the nature of the recent court opinion 

with respect to the nature of the major federal action for which the GEIS is being prepared. The 

NRC does not agree with the comment, nor with the commenter’s interpretation of the court’s 

opinion. The language cited by the commenter refers to Waste Confidence as a major federal 

action, noting Waste Confidence's role in individual licensing proceedings. However, the court 

neither found that Waste Confidence is a licensing action, nor that it authorizes the storage of 

spent nuclear fuel. Instead, the court noted that the Commission’s approach to resolving 

environmental issues has been endorsed both by the U.S. Supreme Court and the D.C. Circuit 

Court of Appeals (New York v. NRC, 681 F.3d 471, 480) (D.C. Cir. 2012). 

Comment: (0275-7) 

I. Public Participation and Site-Specific Concerns 

The NRC received a comment asking how interested parties can raise site-specific concerns 

about high-density spent fuel pools. The GEIS will include a generic analysis of risks 

associated with the continued storage of spent nuclear fuel, including storage at spent fuel 

pools. Interested parties can raise concerns during the comment period associated with the 

GEIS. 

Comment: (0004-5-4) 

J. General Rulemaking Support 

The NRC received comments supporting the NRC scoping effort and schedule, assessment of 

the environmental impacts of extended spent fuel storage (including the “no repository” 

scenario), and utilization of a geologic repository as the disposal method. The comments do not 

provide any specific information related to the environmental effects of continued storage of 

spent nuclear fuel and will not be evaluated in the GEIS. 

Comments: (0004-27-1) (0059-1) (0226-4) (0294-5) 

K. General Rulemaking Opposition 

The NRC received comments expressing general opposition to the Waste Confidence rule and 

rulemaking process, including requests for Waste Confidence to be abolished. While the 

comments are useful for the NRC to understand public opinion about the rulemaking, the 

comments provide no information regarding the scope of the Waste Confidence environmental 

review and will not be evaluated. 

Comments: (0048-1) (0115-2) (0121-3) (0124-2) (0127-2) (0128-2) (0128-3) (0129-2) (0145-3) 

(0148-39) (0152-1) (0157-2) (0161-2) (0165-1) (0166-2) (0172-1) (0178-2) (0236-2) (0247-1) 

(0262-4) (0269-11) (0290-4) (0305-1) (0321-2) 

 
- 42 - 

B20. Comments that are Out of Scope 

A. Fuel Cycle 

The NRC received comments suggesting that the GEIS consider the entire nuclear fuel cycle, 

including uranium mining and milling, fuel fabrication, reactor operation, and enrichment 

facilities. The focus of this GEIS is a generic assessment of the environmental impacts of 

continued storage. Assessing the environmental and health impacts associated with the entire 

uranium fuel cycle or with halting generation of additional radioactive waste is outside the scope 

of the analysis and will not be considered in the GEIS, although it is considered in other NRC 

analyses, including licensing actions and other generic analyses. 

Comments: (0004-13-10) (0004-13-4) (0004-13-5) (0004-13-6) (0075-5) (0090-1) (0090-4) 

(0090-5) (0119-5-1) (0220-1) (0263-15) (0271-22) (0275-19) (0298-3) 

The NRC received comments related to spent nuclear fuel disposal. Spent nuclear fuel disposal 

is outside the scope of the Waste Confidence analysis, which will consider the environmental 

impacts of continued storage prior to ultimate disposal. The development of a national 

repository, the licensing of Yucca Mountain or another repository site, environmental impacts 

associated with disposal in a repository, funding issues, recycling, and other waste disposal 

strategies are outside the scope of this GEIS. 

Comments: (0246-11) (0269-12) (0276-1) (0286-122) (0286-14) (0286-18) (0286-77) (0286-91) 

(0322-5) 

The NRC received comments on whether reprocessing, and high level waste derived from 

reprocessing, should be considered in the GEIS. The GEIS will not address the environmental 

impacts of construction, operation, and decommissioning of reprocessing facilities, including 

continued storage of high level waste derived from reprocessing, because there are no 

operating reprocessing facilities in the United States. In addition, any commercial high level 

waste is currently being managed by the Department of Energy. 

Comments: (0004-14-10) (0118-18-1) (0119-10-3) (0148-35) (0148-6) (0269-18) (0273-13) 

(0285-15) (0285-19) (0286-21) (0286-94) (0294-3) (0314-3) (0336-5) 

The NRC received a comment asking about the decommissioning process for spent fuel pools. 

The decommissioning of spent fuel pools will be assessed as part of the NRC’s review of 

decommissioning activities at a reactor site. A description of decommissioning activities can be 

found in the Final Generic Environmental Impact Statement on Decommissioning of Nuclear 

Facilities (NUREG-0586, NRC 2002). This comment is outside the scope of the GEIS, which 

analyzes the impacts of continued storage of spent nuclear fuel. 

Comment: (0096-4) 

B. Waste 

The NRC received a comment concerning disposal of GTCC low-level waste in a high-level 

waste repository. The environmental impacts associated with disposal of GTCC low-level waste 

are currently being assessed by the DOE, for example in its “Draft Environmental Impact 
- 43 - 

Statement for the Disposal of Greater-Than-Class C (GTCC) Low-Level Radioactive Waste 

(LLRW) and GTCC-Like Waste” (DOE 2011). Assessing the environmental impacts associated 

with disposal of GTCC low-level waste is outside the scope of analysis for the Waste 

Confidence GEIS and will not be considered. 

Comment: (0118-17-10) 

The NRC received comments about spent nuclear fuel from foreign countries being shipped to 

the United States for treatment and disposal. The United States, through the DOE, has taken 

back research reactor fuel generated in various foreign countries through the Foreign Research 

Reactor Spent Nuclear Fuel Acceptance Program. The goal of this program is to eliminate 

inventories of highly enriched uranium by returning research reactor spent nuclear fuel to the 

country where the fuel was originally enriched. The continued storage of spent nuclear fuel 

generated at research reactors, either in the United States or abroad, is outside the scope of the 

GEIS and will not be considered further. 

Comments: (0118-15-1) (0148-33) (0148-36) (0285-6) 

The NRC received a comment requesting that additional environmental reviews be conducted to 

address the entire range of nuclear wastes generated throughout the nuclear fuel cycle and 

generated by sources other than nuclear power reactors, including wastes from enrichment 

facilities and weapons production. The focus of the Waste Confidence GEIS will be a generic 

assessment of the environmental impacts associated with the continued storage of spent 

nuclear fuel generated by nuclear power reactors. Assessing the environmental and health 

impacts associated with nuclear waste generated by uranium fuel cycle facilities, reactor 

operation, research reactors, or weapons production is outside the scope of the analysis and 

will not be considered. 

Comment: (0262-9) 

The NRC received comments about the West Valley site. The waste streams at the West 

Valley site, which are reprocessed wastes that have been vitrified and will be managed and 

disposed of by the DOE under the West Valley Demonstration Project Act, will not be 

considered in the Waste Confidence GEIS. Thus, wastes at the West Valley site are outside the 

scope of the Waste Confidence GEIS. 

Comments: (0119-4-1) (0219-2) (0296-22) 

C. Site-Specific 

The NRC received several comments about site-specific issues at individual plants. These 

comments refer to site-specific licensing and license renewal issues, as well as a range of 

safety and environmental concerns, including natural hazards, at individual sites. The GEIS will 

be limited to a generic analysis of the environmental impacts of continued storage. Comments 

about site-specific concerns are outside the scope of the Waste Confidence GEIS. 

Comments: (0004-18-4) (0004-5-2) (0005-18-1) (0007-1) (0008-1) (0009-1) (0088-1) (0104-2) 

(0118-19-1) (0118-2-6) (0130-1) (0148-14) (0222-1) (0225-1) (0274-1) (0291-7) (0296-17) 

(0296-18) (0330-1) 
- 44 - 

The NRC received comments concerning operating license renewal at particular nuclear power 

plants. These comments express opposition to renewing operating licenses for existing nuclear 

power plants and are outside the scope of this analysis, which concerns the environmental 

impacts from continued storage of spent nuclear fuel. 

Comments: (0062-3) (0068-3) (0072-4) (0221-1) (0277-9) 

The NRC received comments about contamination at the Hanford Site in Washington State. 

The Hanford Site is not within scope of the Waste Confidence GEIS, because it is a DOE facility 

that is not regulated by the NRC. 

Comments: (0159-1) (0252-1) 

The NRC received a comment recommending that Idaho National Laboratory should not be 

considered as a site for consolidated storage. Site identification for away-from-reactor storage 

is not within the scope of the Waste Confidence GEIS, which will not select sites or grant 

licenses for future away-from-reactor storage. 

Comment: (0214-1) 

The NRC received comments concerning the operation and license renewal of Indian Point 

Nuclear Power Plant Units 2 and 3, as well as the relationship between this Waste Confidence 

analysis and that license renewal. The licensing or relicensing of any specific power plant or 

reactor technology is outside the scope of the Waste Confidence GEIS, which concerns the 

environmental impacts of continued storage of spent nuclear fuel. The Commission has stated 

that it will not issue licenses dependent upon Waste Confidence until the court’s remand has 

been addressed, and this is true for the ongoing Indian Point license renewal proceeding. 

Comments: (0001-5) (0026-2) (0030-3) (0031-1) (0034-1) (0036-1) (0088-2) (0108-2) (0229-1) 

The NRC received comments concerning ongoing issues at the San Onofre Nuclear Generating 

Station. The current operating status of any specific power plant is outside the scope of the 

Waste Confidence GEIS, which concerns the environmental impacts of continued storage of 

spent nuclear fuel; therefore, these comments will not be evaluated further. 

Comments: (0005-6-1) (0005-6-2) (0203-1) 

The NRC received a comment about the operation and relicensing of the Diablo Canyon 

Nuclear Power Plant Units 1 and 2. The current operating status of any specific power plant will 

not be considered in the Waste Confidence GEIS, which is a generic analysis of the 

environmental impacts of the continued storage of spent nuclear fuel; therefore, these 

comments will not be evaluated further. 

Comment: (0284-1) 

The NRC received a comment about the potential licensing of a third reactor at the North Anna 

Power Station. Site-specific safety and environmental evaluations are conducted in individual 

combined license application reviews. The licensing of any specific nuclear power plant is 
- 45 - 

outside the scope of the Waste Confidence GEIS, which is a generic analysis of the 

environmental impacts of the continued storage of spent nuclear fuel; therefore, this comment 

will not be evaluated further. 

Comment: (0005-3-3) 

D. NRC Oversight 

The NRC received comments expressing concern over the integrity, transparency, or credibility 

of the NRC as a regulator of the nuclear industry. Some comments question the NRC's 

enforcement of existing regulations, including implementation of security and monitoring 

requirements to prevent radiological accidents. The NRC is an independent agency and was 

established in 1975 to ensure the safe use of radioactive materials for beneficial civilian 

purposes while protecting people and the environment. 

The NRC strives to conduct its regulatory responsibilities in an open and transparent manner, 

consistent with the NRC Approach to Open Government. Because these comments do not 

provide information related to the environmental review of continued storage of spent nuclear 

fuel, they will not be evaluated further. 

Comments: (0001-1) (0057-1) (0114-1) (0118-20-2) (0149-1) (0220-2) (0231-3) (0243-2) (0262-

10) (0277-10) (0290-7) (0290-8) (0314-2) (0316-2) (0336-6) 

E. Energy Alternatives 

The NRC received comments about alternative energy sources. These comments express 

general support of energy alternatives, including renewable energy sources. The alternatives 

analysis is an important aspect of NEPA, and energy alternatives are addressed in site-specific 

license renewal and combined license environmental reviews. Site-specific energy alternative 

concerns are outside of the scope for the Waste Confidence GEIS and will not be evaluated. 

Comments: (0002-1) (0003-3) (0003-5) (0021-3) (0039-1) (0049-9) (0057-2) (0070-3) (0079-1) 

(0110-1) (0119-11-4) (0119-13-2) (0124-3) (0134-2) (0135-1) (0155-1) (0181-1) (0194-4) (0213-

1) (0213-5) (0213-6) (0227-2) (0255-1) (0258-4) (0262-1) (0269-16) (0269-2) (0274-3) (0274-4) 

(0297-2) (0303-2) 

F. Emergency Planning 

The NRC received comments addressing emergency preparedness concerns, including sitespecific evacuation planning. The purpose of the Waste Confidence GEIS is to analyze the 

generic environmental impacts of continued storage. Comments pertaining to emergency 

preparedness are outside of the scope for the Waste Confidence GEIS and will not be 

evaluated. In relation to emergency planning, commenters also expressed concerns about 

accidents involving spent fuel storage; as noted previously in this report, the environmental 

impacts from accidents will be evaluated in the GEIS. 

Comments: (0004-23-7) (0056-1) (0056-3) (0106-1) (0119-11-1) (0119-14-1) (0231-2) (0246-5) 

(0269-4) (0291-1) (0291-15) (0291-26) 
- 46 - 

G. Miscellaneous 

1. Experimental Fuel Cladding Materials 

Two comments suggested that experimental cladding materials, such as silicon carbide and 

ceramic, be included in the scope of the GEIS. Experimental cladding materials are considered 

speculative and will not be addressed in the GEIS. The analysis of continued storage of spent 

nuclear fuel will include cladding materials that are presently in use in U.S. commercial reactors. 

Comments: (0286-101) (0286-69) 

2. Spent Fuel Storage Alternatives 

The NRC received comments that suggested novel or unexplored ways to address the spent 

nuclear fuel problem. The GEIS will not consider these undeveloped methods, because its 

scope is limited to the current state of technology. As new technologies are developed, the 

NRC will consider whether updates to this analysis are necessary to consider these 

developments. 

Comments: (0054-1) (0054-2) (0122-1) (0163-1) (0163-3) (0163-6) (0163-7) (0179-1) (0188-1) 

(0295-5) (0309-1) 

3. Mark I and II Reactor Designs 

The NRC received comments about boiling water reactor designs, including the General Electric 

Mark I and Mark II designs. The GEIS will not analyze the environmental impacts associated 

with licensing or relicensing nuclear reactors. The GEIS will evaluate the environmental impacts 

of the continued storage of spent nuclear fuel, including analyses of accidents. The purpose of 

the GEIS is to disclose the environmental impacts of continued storage of spent nuclear fuel. 

Comments: (0118-7-1) (0118-7-2) (0242-1) (0250-1) (0281-6) 

4. Fukushima Orders 

The NRC received comments concerning the Order Modifying Licenses with Regard to Reliable 

Spent Fuel Pool Instrumentation (EA-12-051) (NRC 2012d). These comments are outside the 

scope of this analysis, which is an update to the Waste Confidence rule. NRC actions following 

the accident in Japan can be found at http://www.nrc.gov/reactors/operating/opsexperience/japan/japan-meeting-briefing.html. The GEIS will contain appropriate discussion of 

spent fuel storage in spent fuel pools for continued storage, including impacts from accidents. 

Comments: (0148-10) (0148-11) (0148-16) 

5. Moving Spent Nuclear Fuel Away From Reactors 

The NRC received a comment recommending that the NRC require moving spent fuel away 

from operating reactors to prevent possible impacts on operating reactors. The environmental 

and health impacts of design basis accidents, including those that involve spent fuel handling, 

are evaluated during the initial licensing process, and the ability of the plant to withstand these 
- 47 - 

accidents is demonstrated to be acceptable before issuance of an operating license. The NRC 

continues to evaluate new information as it becomes available through the ongoing reactor 

oversight process. Should new information become available indicating a safety concern for an 

operating reactor, such as for spent nuclear fuel stored nearby, the NRC would evaluate that 

issue through a separate regulatory process such as the Generic Issues Program, and take 

whatever action is necessary to protect public health and safety. As a result, the potential 

impacts of spent nuclear fuel on an operating reactor are outside the scope of this GEIS and will 

not be evaluated further. 

Comment: (0129-3) 

6. Collaboration with Other Agencies and Experts Regarding Security

The NRC received comments recommending that the NRC engage other government agencies 

or independent experts to aid the NRC in its site security and security assessments. The NRC 

works collaboratively with other government agencies to fulfill its statutory mission to protect the 

public health and safety and provide for common defense and security. However, the NRC 

does not defer any of its statutory obligations to other agencies. The Atomic Energy Act of 1954 

grants the NRC authority to implement a domestic safeguards program. Recommendations that 

the NRC work collaboratively with other agencies to develop and implement site security and 

security assessments are outside the scope of the GEIS. 

Comments: (0003-4) (0273-11) (0285-4)

7. Reasonable Assurance 

The NRC received comments requesting that the terms “reasonable assurance” and “adequate 

protection” be formally defined. These comments are outside the scope of the Waste 

Confidence analysis, which concerns a generic evaluation of the environmental impacts of the 

continued storage of spent nuclear fuel, not NRC safety standards. The term “adequate 

protection” is not defined in the Atomic Energy Act of 1954, as amended; it is a subjective, yet 

mandatory standard applicable to NRC licensing criteria, rather than to environmental analyses. 

The environmental analysis relies on the established licensing criteria in developing an impact 

analysis, but the GEIS will not explicitly define the terms “adequate protection” and “reasonable 

assurance.” 

Comments: (0004-25-2) (0296-23) 

8. Congressional Interactions 

The NRC received a comment regarding the relationship between the NRC and Congress. The 

NRC is an independent federal regulatory agency created by Congress and is statutorily 

obligated to keep Congress fully and currently informed about the agency’s activities through 

the Office of Congressional Affairs. The NRC has kept Congress informed of the Waste 

Confidence activities (e.g., Commission Order, formation of Directorate, publication of 

documents, public meetings) and will continue to keep Congress updated as the GEIS is 

developed. 

Comment: (0277-3) 
- 48 - 

9. Legislative Changes 

The NRC received comments about legislative changes in favor of particular spent fuel storage 

strategies. Legislative changes are beyond the scope of the Waste Confidence GEIS, which 

concerns the environmental impacts of the continued storage of spent fuel; these changes will 

not be considered. 

Comments: (0118-26-2) (0148-34) (0323-14) 

10. Regulatory Framework for Spent Fuel Management 

The NRC received a comment about the regulatory status of commercial spent nuclear fuel that 

requested an evaluation of the current regulatory framework. While the overarching regulatory 

framework for managing spent nuclear fuel may be described in the GEIS, an evaluation of the 

existing framework is outside the scope of the Waste Confidence GEIS. 

Comment: (0246-10) 

11. Blue Ribbon Commission Organizational Recommendations 

The NRC received comments recommending a new or different organization to address nuclear 

waste following the report of the Blue Ribbon Commission on America’s Nuclear Future (BRC 

2012). Two commenters point out that the Blue Ribbon Commission recommended the creation 

of a new organization to implement a nuclear waste management program. At this time, the 

NRC is the only federal agency appointed to regulate the long-term storage of spent nuclear fuel 

and high-level waste. Because these comments are not within the scope of the Waste 

Confidence GEIS, they will not be considered further. 

Comments: (0233-3) (0282-5) (0294-1) 

12. Repository Policy 

The NRC received comments concerning implementation of the Nuclear Waste Policy Act and 

impediments to the development of a permanent repository for spent nuclear fuel. Because 

policy related to development of a national repository is outside the scope of the Waste 

Confidence GEIS, the comments will not be considered further. 

Comments: (0038-7) (0055-2) (0174-1) (0174-2) (0213-3) (0226-2) (0244-21) (0244-22) (0262-

2) (0268-1) (0268-5) (0268-6) (0268-7) (0278-1) (0280-8) (0282-2) (0282-3) (0282-4) (0282-7) 

(0292-2) (0292-3) (0320-1) (0321-1) 

13. Evaluating Repository Impacts 

The NRC received comments about final disposal of spent nuclear fuel. Several comments 

stated that the GEIS needs to consider environmental impacts or safety of a repository, 

including the effects of spent nuclear fuel degradation due to extended storage. The effects of 

spent fuel degradation will be considered as part of the Waste Confidence GEIS. However, 
- 49 - 

assessing the impacts associated with geological disposal of spent fuel in a repository is outside 

the scope of the Waste Confidence GEIS and will not be considered. 

Comments: (0225-2) (0265-8) (0265-9) (0280-3) (0286-74) (0296-5) (0300-2) 

14. Repository Development 

The NRC received comments expressing support or interest in development of a repository as a 

permanent storage or disposal solution. The purpose of the Waste Confidence GEIS is to 

evaluate the potential impacts of continued storage. The GEIS will not assess the impacts 

associated with the licensing, construction, or operations of a repository. The environmental 

impacts of a repository will be analyzed as part of the site-specific licensing proceeding for a 

repository. Because development of a repository will be considered in a separate proceeding, 

this analysis is outside the scope of the Waste Confidence GEIS and will not be considered 

further. 

Comments: (0004-8-3) (0125-3) (0148-5) (0158-4) (0190-1) (0209-1) (0276-4) (0323-13) 

15. Environmental Justice in Repository Siting 

The NRC received a comment about environmental justice issues at Yucca Mountain. Because 

this comment does not pertain to the environmental impacts of continued storage of spent 

nuclear fuel, the comment will not be considered further. 

Comment: (0118-17-4) 

16. Reactor License Renewal Procedures 

The NRC received one comment on updates to the NRC’s procedures for reactor license 

renewals. License renewal activities are outside the scope of the GEIS and are assessed by 

the NRC in separate, site-specific safety and environmental reviews. A site-specific 

environmental review (resulting in a supplemental EIS) is conducted for license renewal 

applications. Information on the NRC’s license renewal process can be found at the NRC’s 

website: http://www.nrc.gov/reactors/operating/licensing/renewal.html. 

Comment: (0272-3) 

17. Licensing Delays 

 

The NRC received a comment expressing concern about delays in licensing nuclear reactors 

while the NRC responds to the court remand. This comment does not address issues within the 

scope of the Waste Confidence GEIS, and so it will not be considered further. 

Comment: (0005-2-3) 

18. Ongoing Proceedings 

The NRC received a comment concerning ongoing licensing proceedings and this rulemaking. 

This comment is outside the scope of the Waste Confidence analysis, which concerns the 
- 50 - 

impacts from the continued storage of spent fuel, not NRC adjudications or adjudicatory policy. 

In Commission Order CLI-12-16 (NRC 2012a) the Commission stated that “in recognition of our 

duties under the law, we will not issue licenses dependent upon the Waste Confidence Decision 

or the Temporary Storage Rule until the court’s remand is appropriately addressed. This 

determination extends just to final license issuance; all licensing reviews and proceedings 

should continue to move forward.” Continuing in a footnote, the Commission stated “that it is in 

the public interest for adjudications to proceed, except for contentions associated with waste 

confidence issues.” 

Comment: (0223-2) 

19. The 10 CFR § 2.206 Process 

The NRC received a comment about the 10 CFR § 2.206 petition process. This regulation 

permits any person to file a request to institute a proceeding to, among other things, modify, 

suspend, or revoke an NRC license. Waste Confidence is not a licensing proceeding. Because 

this comment is outside the scope of this analysis, which generically concerns an analysis of the 

environmental impacts of continued spent fuel storage, it will not be considered further. 

Comment: (0118-11-1) 

20. Request to Amend Adjudicatory Procedure Regulations 

The NRC received a comment requesting that the Commission establish a new procedure by 

which the public would have an opportunity to raise site-specific impacts of continued storage 

before the ASLB. The GEIS will generically analyze the environmental impacts of continued 

storage. The GEIS and Waste Confidence rule will identify those impacts that cannot be 

analyzed generically and therefore must be analyzed on a site-specific basis. NRC 

adjudications are governed by current NRC regulations, principally in 10 CFR Part 2. Therefore, 

this request to amend or create new adjudicatory proceeding regulations is outside the scope of 

the GEIS. 

Comment: (0275-17) 

21. Federal Funding of Monitoring 

The NRC received one comment requesting that funds be dedicated to local and state 

governments to independently monitor spent fuel storage sites. This issue is outside the scope 

of the environmental impacts of continued storage; therefore, the GEIS will not address funding 

for independent monitoring. 

Comment: (0004-14-9) 

22. Costs Associated with Nuclear Power Production 

The NRC received comments requesting that the GEIS address general costs associated with 

nuclear power production, including subsidies. One comment also raised concerns about the 

costs of nuclear weapon technology production. These issues are outside the scope of the 
- 51 - 

environmental impacts of continued storage; therefore, the GEIS will not address the costs 

associated with nuclear power or nuclear weapon production. 

Comments: (0079-2) (0269-19) (0269-6) 

23. Methane Hydrates 

The NRC received one comment that refers to a release of methane from methane hydrates in 

the oceans that could cause a worldwide explosion. The postulated fast release of methane 

hydrates is outside the scope of the GEIS and will not be considered further. 

Comments: (0009-5) 

24. Opposition to Nuclear Power 

The NRC received comments expressing general opposition to nuclear power, including calls to 

cease all nuclear reactor licensing and to decommission all operating reactors. These 

comments did not address the scope of GEIS, which will evaluate the environmental impacts of 

continued storage. These comments are outside the scope of the GEIS. 

Comments: (0025-1) (0048-2) (0055-3) (0070-2) (0089-2) (0092-2) (0093-1) (0094-1) (0095-1) 

(0105-1) (0109-1) (0118-13-3) (0119-11-3) (0144-1) (0146-1) (0158-2) (0171-1) (0173-1) (0185-

1) (0195-3) (0205-1) (0206-1) (0212-1) (0213-2) (0224-1) (0228-3) (0230-1) (0261-1) (0306-1) 

25. Support for Nuclear Power 

The NRC received comments expressing support for nuclear power in the context of preventing 

global warming. The purpose of the Waste Confidence GEIS is to disclose the generic 

environmental impacts of continued spent fuel storage. These comments are outside the scope 

of this GEIS. 

Comments: (0005-2-1) (0005-2-2) (0005-4-1) 

 
- 52 - 

C. References 

10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Rules of Practice for 

Domestic Licensing Proceedings and Issuance of Orders.” Available at 

http://www.nrc.gov/reading-rm/doc-collections/cfr/part002/. 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” Available at 

http://www.nrc.gov/reading-rm/doc-collections/cfr/part051/. 

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

Transportation of Radioactive Material.” Available at http://www.nrc.gov/reading-rm/doccollections/cfr/part071/. 

10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, “Physical Protection of 

Plants and Materials.” Available at http://www.nrc.gov/reading-rm/doc-collections/cfr/part073/. 

51 FR 15618. April 25, 1986. “National Environmental Policy Act Regulations; Incomplete or 

Unavailable Information.” Federal Register. Council on Environmental Quality, Executive Office 

of the President. 

65 FR 67249. November 9, 2000. “Executive Order 13175 of November 6, 2000, Consultation 

and Coordination with Indian Tribal Governments.” Federal Register. Office of the President. 

74 FR 66589. December 16, 2009. “Draft Technical Basis for Rulemaking Revising Security 

Requirements for Facilities Storing SNF and HLW; Notice of Availability and Solicitation of 

Public Comments.” Federal Register. U.S. Nuclear Regulatory Commission. 

75 FR 81037. December 23, 2010. “Waste Confidence Decision Update.” Federal Register. 

U.S. Nuclear Regulatory Commission. 

77 FR 65137. October 25, 2012. “Consideration of Environmental Impacts of Temporary 

Storage of Spent Fuel After Cessation of Reactor Operation.” Federal Register. U.S. Nuclear 

Regulatory Commission. 

77 FR 74788. December 18, 2012. “Long-Term Cooling and Unattended Water Makeup of 

Spent Fuel Pools.” Federal Register. U.S. Nuclear Regulatory Commission. 

Atomic Energy Act of 1954, as amended. 42 U.S.C. 2011 et seq.

Blue Ribbon Commission on America’s Nuclear Future (BRC). 2012. Blue Ribbon Commission 

on America’s Nuclear Future Report to the Secretary of Energy. U.S. Department of Energy, 

Washington, DC. Accession No. ML12073A433. 

Council on Environmental Quality (CEQ). 2012. Improving the Process for Preparing Efficient 

and Timely Environmental Reviews under the National Environmental Policy Act. March 6, 

2012. Washington, DC. Available at Available at 77 FR 14473 and 

http://www.whitehouse.gov/sites/default/files/microsites/ceq/improving_nepa_efficiencies_06mar

2012.pdf. 
- 53 - 

Minnesota v. NRC, 602 F.2d 412 (D.C. Cir. 1979). 

National Environmental Policy Act of 1969 (NEPA), as amended. 42 U.S.C. 4321 et seq. 

National Historic Preservation Act (NHPA). 16 U.S.C. 470 et seq. 

New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012). Available at ADAMS Accession No. 

ML12191A407. 

Nuclear Waste Policy Act of 1982 (NWPA). 42 U.S.C. 10101 et seq.

Shaw/AREVA MOX Services, LLC. 2010. Mixed Oxide Fuel Fabrication Facility License 

Application. Aiken, South Carolina. Accession No. ML101040742. 

U.S. Department of Energy (DOE). 2002. Final Environmental Impact Statement for a Geologic 

Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca 

Mount, Nye County, Nevada. DOE/EIS-0250. Washington, DC. ADAMS Accession Nos. 

ML032690321 and ML081750191. 

U.S. Department of Energy (DOE). 2011. Draft Environmental Impact Statement for the 

Disposal of Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and GTCC-LikeWaste. DOE/EIS-0375-D. Washington, DC. Available at 

http://energy.gov/nepa/downloads/eis-0375-draft-environmental-impact-statement. 

U.S. Nuclear Regulatory Commission (NRC). 2002. Final Generic Environmental Impact 

Statement on Decommissioning of Nuclear Facilities. NUREG-0586, Supplement 1, Vols. 1 and 

2. Washington, DC. Available at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr0586/. 

U.S. Nuclear Regulatory Commission (NRC). 2003. Environmental Review Guidance for 

Licensing Actions Associated with NMSS Programs: Final Report. NUREG-1748. Washington, 

DC. Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1748/. 

U.S. Nuclear Regulatory Commission (NRC). 2009a. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Draft Report for Comment. NUREG-1437, Vols. 1 and 

2. Washington, DC. Available at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1437/r1/index.html. 

U.S. Nuclear Regulatory Commission (NRC). 2009b. Generic Environmental Impact Statement 

for In-Situ Leach Uranium Milling Facilities. NUREG-1910, Vols. 1 and 2. Washington, DC. 

Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1910/. 

U.S. Nuclear Regulatory Commission (NRC). 2011a. Draft Report for Comment, Background 

and Preliminary Assumptions for an Environmental Impact Statement—Long-Term Waste 

Confidence Update. Accession No. ML11340A141. 

U.S. Nuclear Regulatory Commission (NRC). 2011b. “Policy Issue Information—SECY-11-

0029—Plan for the Long-Term Update to the Waste Confidence Rule and Integration with the 

Extended Storage and Transportation Initiative.” SECY-11-0029, Washington, DC. Accession 

No. ML110330445. 
- 54 - 

U.S. Nuclear Regulatory Commission (NRC). 2012a. “Commission Memorandum and Order 

(CLI-12-16).” CLI-12-16, Washington, DC. Accession No. ML12220A100. 

U.S. Nuclear Regulatory Commission (NRC). 2012b. “Enclosure to SECY-12-0132—Licensing 

Actions Affected by Waste Confidence Remand.” SECY-12-0132, Washington, DC. Accession 

No. ML12276A038. 

U.S. Nuclear Regulatory Commission (NRC). 2012c. “Staff Requirements—COMSECY-12-

0016—Approach for Addressing Policy Issues Resulting from Court Decision to Vacate Waste 

Confidence Decision and Rule.” SRM-COMSECY-12-0016, Washington, DC. Accession No. 

ML12250A032. 

U.S. Nuclear Regulatory Commission (NRC). 2012d. “Order to Modify Licenses with Regard to 

Reliable Spent Fuel Pool Instrumentation.” EA-12-051, Washington, DC. Accession No. 

ML12054A679. 

West Valley Demonstration Project Act (WVDPA). 42 U.S.C. 2021a. 

 
- 55 - 

D. List of Commenters on the Scope of the Waste Confidence GEIS 

Diane Curran (Harmon, Curran, Spielberg & Eisenberg, LLP) submitted two comment 

documents (ADAMS Accession Nos. ML13007A441 and ML13017A404) on behalf of the 

following organizations and individuals: Mindy Goldstein (Turner Environmental Law Clinic), 

Arjun Makhijani (Institute for Energy and Environmental Research), Gordon R. Thompson 

(Institute for Resource and Security Studies), Phillip Musegaas (Riverkeeper), Alliance for 

Nuclear Accountability, Beyond Nuclear, Blue Ridge Environmental Defense League, Center for 

a Sustainable Coast, Citizens Allied for Safe Energy, Citizens Environmental Alliance, Don’t 

Waste Michigan, Ecology Party of Florida, Friends of the Earth, Georgia Women’s Action for 

New Directions, Hudson River Sloop Clearwater, Missouri Coalition for the Environment, NC 

WARN, Nevada Nuclear Waste Task Force, New England Coalition, Nuclear Information and 

Resource Service, Nuclear Watch South, Physicians for Social Responsibility, Public Citizen, 

Riverkeeper, San Luis Obispo Mothers for Peace, SEED Coalition, Sierra Club Nuclear Free 

Campaign, and Southern Alliance for Clean Energy. For administrative reasons, Ms. Curran is 

listed as the sole author of the comments in these two documents, but the NRC here notes the 

additional signatories to these comment documents. 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Anonymous ML12324A375 0001

Anonymous ML13018A405 0146

Anonymous ML13022A222 0115

Anonymous ML13022A223 0266

Anonymous ML12324A375 0007 

Anonymous ML12324A319 0113

Abbott, Dana ML13022A222 0115

Adams, Grace ML12324A381 0003

Adams, Grace ML13028A031 0254

Agnew, David Cape Downwinders ML12355A187 0119-6

Agnew, David Cape Downwinders ML13028A019 0242

Aguilera, Marco ML13022A222 0115

Albertini, John ML12331A278 0319

Alcon, Sylvia ML13022A558 0178

Alexander, Charles ML13018A409 0150

Alexander, Kathleen ML13022A222 0115

Alger, Dwight ML12331A278 0319

Allen, Melissa ML13022A222 0115

Amel, Dean ML13022A222 0115

Anderson, Johanna ML12324A321 0029

Anderson, Johanna ML13028A035 0257

Anderson, Johanna ML13030A357 0287
- 56 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Anderson, Peter ML12331A278 0319

Anderson, Stevie ML13022A222 0115

Andreas, Sonja MN Peace Group ML12331A278 0319

Andreas, Sonja MN Peace Group ML12324A281 0014

Andrews, Richard ML13030A028 0262

Angelus, Joshua ML12331A278 0319

Angst, Sara ML13058A029 0115

Armstrong, Robert F. ML13022A502 0201

Arnon, Daniela ML13022A557 0177

Atkinson, Kim ML12331A278 0319

Attaguile, Faith ML13018A427 0166

Azarovitz, Janet ML12342A277 0089

Baeckstrom, Chris ML13022A222 0115

Bahr, Richard Sierra College ML13023A395 0180

Baier, Mary Ann ML13022A222 0115

Baier, Mary Ann ML13028A007 0326

Bailey, Lee ML12331A278 0319

Bailin, Jonathan ML12331A278 0319

Barczak, Sara Southern Alliance for Clean Energy ML12331A347 0004-12

Baron, James ML12331A278 0319

Barrett, Lake Sustainable Fuel Cycle Task Force 

Science Panel ML13030A023 0280

Bartholomew, Alice ML12324A348 0099

Bartholomew, Alice ML12334A394 0071

Bartolacelli, Richard ML13022A222 0115

Bateman, Guy ML13022A222 0115

Beavis, Margaret ML12331A278 0319

Behling, Steve ML12325A058 0054

Bell, Michael ML13028A004 0226

Benes, Michelle ML13022A222 0115

Benmosche, 

Shoshanna ML12331A278 0319

Bennett, Paul ML13022A222 0115

Berger, Dian ML12324A350 0100

Bergh, Darcy ML12331A278 0319

Berman, Gary ML13022A222 0115

Bernard, Janice ML12331A278 0319

Bernard, John ML12324A352 0120

Bernstein, Laura ML12331A278 0319

Bertha, Bertha ML13022A222 0115
- 57 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Beverly, Jessica E. ML12331A278 0319

Bevill, Bernard Arkansas Department of Health ML13007A400 0294

Biddle, Lynn ML12331A278 0319

Biddle, Lynn ML12325A051 0050

Birnie, Pat Women's International League for 

Peace and Freedom ML12334A381 0059

Birnie, Patricia ML13015A308 0253

Birnie, Patricia T. GE Stakeholders’ Alliance ML13011A083 0323

Bishop, Damon ML13022A222 0115

Blakely, Naiomi ML13022A498 0115

Blee, David S. United States Nuclear Infrastructure 

Council ML13007A357 0276

Blevins, Katherine ML13022A222 0115

Block, Gary ML13022A222 0115

Blue, Donna ML12331A278 0319

Blumenthal, Bob ML12331A278 0319

Bosold, Patrick Iowa Sierra Club ML12334A398 0077

Bosold, Patrick MN Peace Group ML12324A346 0098

Bosold, Patrick ML12325A012 0043

Bottomley, Pat ML13022A222 0115

Bradbeer, Wilma ML12324A359 0035

Brailsford, Beatrice Snake River Alliance ML13007A356 0288

Brancato, Deborah Riverkeeper ML12340A150 0086

Branham, Rebecca ML13018A322 0131

Bratcher, Deborah ML13022A222 0115

Brimm, Martha ML13022A222 0115

Brock, Matthew Massachusetts Office of Attorney 

General ML13011A084 0275

Bromm, Susan E. U.S. Environmental Protection Agency ML13028A469 0325

Brooks, Michele ML13022A563 0183

Brown, Beth ML13022A222 0115

Brown, Deb ML13022A496 0198

Brown, Roger ML12331A278 0319

Bruce, Buffalo ML13022A222 0115

Buckner, Marian ML13018A204 0126

Buenzle, Tom ML13022A222 0115

Burke, Barbara ML13022A222 0115

Burns, Alan ML13022A222 0115

Burpo, Leslie ML13022A222 0115

Burton, Bruce ML12331A347 0004-8
- 58 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Burton, Vic ML13022A505 0326

Butler, Edward ML12324A297 0001

Butler, Elizabeth ML12331A278 0319

Byrne, James ML12331A278 0319

C, John ML13022A511 0187

Calendine, Georgeann ML13018A415 0154

Callahan, Mike Decommissioning Plant Coalition ML12331A347 0004-9

Callahan, Mike Decommissioning Plant Coalition ML13010A126 0259

Calter, Thomas J. Massachusetts State Representative ML13007A406 0299

Camhi, Gai ML13023A390 0212

Cappelletti, Regina ML13022A222 0115

Carberry, Mike ML12331A278 0319

Carberry, Mike ML13022A222 0115

Carey, Deborah ML12331A278 0319

Carrigan, Milton ML13022A222 0115

Cash, Joy Women Occupy ML13022A506 0203

Caswell, Richard ML13022A222 0115

Cavalier, Corey ML13022A222 0115

Chapman, Robin ML13022A555 0175

Cherwink, Rob ML13022A222 0115

Chess, Deborah ML12324A318 0112

Chischilly, Jane ML12324A373 0042

Christman, Dave ML12331A278 0319

Clark, Carolyn ML13022A222 0115

Clark, Kenneth ML12334A387 0064

Clausing, Mary ML13022A222 0115

Clements, Tom Alliance for Nuclear Accountability ML13007A354 0301

Clucas, Donald ML13022A222 0115

Cobb, Sandra ML13022A491 0216

Cobb, Sandra M. ML12331A278 0319

Cochran, Moncrieff ML12340A152 0080

Cockerill, Marc ML13022A222 0115

Cohen, Judy ML13022A222 0115

Coleman, Chrystal ML13018A422 0161

Collecchia, Geri ML12324A277 0010

Collecchia, Geri ML12334A388 0065

Collins, Carol ML13022A222 0115

Collins, Fred Northern Chumash Tribal Council ML13010A118 0284

Combes, Steven B. ML12331A278 0319
- 59 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Cooper, Susan ML13028A016 0240

Copi, Margaret ML12331A278 0319

Courtright, Caroline ML12331A278 0319

Craig, Anne ML12356A231 0290

Craig, Anne ML12324A391 0103

Craig, Anne ML13022A222 0115

Craig, Carol ML13022A222 0115

Cramer, Pamela ML13018A403 0144

Crockett, Margaret ML13022A554 0174

Crowley, Loretta ML13022A561 0181

Cunningham, Jim ML12331A278 0319

Cunningham, Kristine NC Sierra Club ML12324A392 0104

Cunningham, Kristine Sierra Club North Carolina-Ashville ML13028A010 0234

Curlette, Diane ML13022A222 0115

Curran, Diane Harmon, Curran, Spielberg & 

Eisenberg, LLP ML13007A441 0286

Curran, Diane Harmon, Curran, Spielberg & 

Eisenberg, LLP ML13017A404 0322

Curran, Diane Harmon, Curran, Spielberg & 

Eisenberg, LLP ML12340A149 0085

Curtis, Marni ML12331A278 0319

D'Arrigo, Diane Nuclear Information Resource Service ML12355A187 0119-4

D'Arrigo, Diane Nuclear Information Resource Service ML12355A187 0119-8

D'Arrigo, Diane Nuclear Information Resource Service ML13030A358 0285

Davies, Phyllis ML13022A222 0115

Davis, Diane G. ML12331A278 0319

Davis, Randall ML13022A222 0115

De Cecco, Jorge ML13022A222 0115

De Falla, Susanna Sierra Club ML13022A494 0196

Decker, Michael Sierra Club ML13018A324 0133

DeMarsh, Julienne ML13022A222 0115

Demorest, Carolyn ML12331A278 0319

Denneen, Bill ML13022A516 0192

Derbigny, Rodney ML12334A397 0074

DeStefano, Linda ML12331A278 0319

Deutsch, James ML13023A398 0220

Dickinson, Lee National Park Service ML13028A011 0235

Didrichsen, Susan ML12324A367 0039

Diederichs, Barbara ML12324A376 0032

Dilling, Brock ML12331A278 0319
- 60 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

DiMatteo, Richard ML12331A278 0319

Dimitri, Mr. and Mrs. 

William ML13022A222 0115

Doucet, Lisha ML13022A222 0115

Drey, Kay Beyond Nuclear ML13007A407 0300

Dubois, Gwen L. Chesapeake Physicians for Social 

Responsibility ML12332A227 0058

Dunivant, Terre ML13022A553 0173

Earle, Ben ML12331A278 0319

Eichelberger, Don ML13022A222 0115

Eilenberg, Alisa ML12334A384 0061

Eisenstark, Sarita ML12324A324 0027

Elliot, Ed ML13022A222 0115

Enebo, Karin ML12328A011 0055

Espinosa, Sally ML13022A222 0115

Estes, Douglas ML13022A222 0115

Esteve, Gregory ML12331A278 0319

Evans, Dinda ML12319A468 0008

Evans, Dinda ML13022A222 0115

Evans, Michael W. ML12324A366 0001

Evans, Patricia Riverkeeper/Clearwater ML12324A317 0111

Fairhurst, Charles Sustainable Fuel Cycle Task Force ML13030A023 0280

Falk, Melba ML13022A222 0115

Falkner, Carla ML13022A495 0197

Faris, Janice and Larry ML12331A278 0319

Farrington, Susan Sierra Club, Riverkeeper ML12324A357 0033

Fast, Wendy ML12324A380 0023

Fast, Wendy ML13028A020 0243

Fazzari, Angie ML12331A278 0319

Feldman, Jane ML13022A222 0115

Ferrara, Amy ML12324A310 0109

Fettus, Geoffrey Natural Resources Defense Council, 

Inc. ML13017A404 0322

Fettus, Geoffrey Natural Resources Defense Council, 

Inc. ML12340A149 0085

Fettus, Geoffrey Natural Resources Defense Council, 

Inc. ML13010A145 0271

Filler, Matthew ML13023A404 0225

Fisher, Allison ML13022A223 0266

Fiske, Nancy ML12331A278 0319
- 61 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Flanagan, Lynn ML12324A322 0030

Fleetham, Chelsea ML12324A363 0037

Flowers, Bobbie ML12324A302 0001

Flowers, Bobbie ML13022A222 0115

Foley, Brian ML13022A222 0115

Forbes, Jane ML13022A222 0115

Forbes, June ML12331A278 0319

Forbes, Melinda Mothers for Peace ML13022A566 0186

Forlie, Kai Mikkel ML12325A017 0048

Foskett, MaryAnna ML13022A222 0115

Foster, Tracy Beyond Nuclear ML13028A032 0255

Fouche, David ML13022A222 0115

Fowler, Joanna Brackenhollow Stables ML13018A401 0142

Frankfurter, Aryeh ML13022A222 0115

Frantin, Lillia Pilgrim Anti Nuclear Action/Cape Cod ML123380143 0094

Frederick, Vicki ML12331A278 0319

Fredrickson, Amy ML12324A394 0107

French, Dominique Nuclear Information Resource Service ML12331A347 0004-13

Fronce, Linnea M. ML13022A222 0115

Fuchs, Katherine Alliance for Nuclear Accountability ML12331A347 0004-18

Fuchs, Katherine Alliance for Nuclear Accountability ML13030A020 0281

Gale, Maradel ML12331A278 0319

Gale, Maradel ML13022A223 0266

Garner, Lowell ML12324A306 0026

Gasperoni, John ML12331A278 0319

Geary, B. Citizen Action for Safe Energy ML13028A022 0247

Geise, Mark M. ML13022A510 0326

Gellert, Sally Jane MN Peace Group ML12324A342 0019

George, Edward ML12331A278 0319

Gibble, Joia ML13022A222 0115

Gilbert, Valerie ML12324A395 0001

Gilva, Stephen ML13022A222 0115

Ginsberg, Ellen Nuclear Energy Institute ML12331A347 0004-7

Ginsberg, Ellen Nuclear Energy Institute ML13010A124 0263

Giral, Joe ML13022A551 0172

Glass, Peter M. Xcel Energy ML13010A132 0292

Goldfarb, Carole ML13018A397 0138

Goldin, Martha ML13022A222 0115

Goldman, Steve ML12331A278 0319
- 62 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Goldstein, Mindy Turner Environmental Law Clinic ML12340A149 0085

Golich, Conrad ML12331A278 0309

Goodell, Barbara ML13023A397 0115

Gosnell, Lisa ML13022A222 0115

Gould, Schuyler ML12331A278 0308

Goze, Yunjoo ML12324A365 0038

Graham, Roger ML13028A025 0255

Grajeda, Monique ML13022A565 0185

Graves, Caryn ML12331A278 0319

Graves, N. ML13022A222 0115

Gray, Erica ML12331A353 0005-3

Greensfelder, Jeanie ML13022A550 0171

Grenard, Mike Hayduke MN Peace Group ML12324A343 0020

Groot, Henriette Mothers for Peace ML13022A507 0204

Gugino, Martin ML13023A396 0219

Gupton, William ML13022A222 0115

Haasch, Jane E. ML12324A299 0078

Haasch, Jane E. ML12325A060 0079

Hackner, Paul ML12331A278 0319

Hadovsky, Linda ML13022A222 0115

Halevy, Libbe ML12331A353 0005-6

Halizak, Kimberly Anne ML13022A222 0115

Hall, Dennis ML12331A278 0319

Hall, Silvia ML13022A222 0115

Halligan, Mary A. ML12331A278 0319

Halstead, Robert State of Nevada Agency for Nuclear 

Projects ML13010A120 0265

Hamilton, Helen ML12331A278 0319

Hamrick, Steve ML12331A347 0004-19

Handelsman, Robert ML13018A399 0140

Hanes, Fenna Pilgrim Coalition ML13028A026 0250

Hanley-Hyde, Joan ML12331A278 0319

Hanna, Helen N. ML12331A278 0319

Hannah, Rober ML13022A222 0115

Hansen, Jan ML13022A222 0115

Hanson, Art ML12324A304 0025

Hanson, Art ML13022A222 0115

Hanson, Natalie ML12324A304 0025

Hanson, Natalie ML13022A222 0115
- 63 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Hargrove, Chris ML13022A222 0115

Harkins, Lynne ML13022A222 0115

Harlan, Thomas City of Red Wing, Minnesota ML13010A131 0291

Harris, Deborah W. ML13023A384 0207

Hartman, Randall ML13018A419 0158

Haschke, Becky ML13022A222 0115

Hasselbrink, Bob ML12331A278 0319

Hasselgren, Joan ML13018A319 0128

Hatfield, Barry ML12331A278 0319

Hatley, Earl LEAD Agency ML13028A027 0251

Haughney, Charles ML13030A019 0282

Hauck, Molly ML13022A222 0115

Hazynski, Chris ML13018A402 0143

Headrick, Gary San Clemente Green ML13018A398 0139

Helmstetter, Chris ML12331A278 0319

Hendin, Judith ML13022A222 0115

Henry, Beth ML13028A009 0231

Hill, Edwin ML13010A128 0267

Hill, Michael ML13022A222 0115

Hodgkins, Yvonne ML12331A278 0319

Hoffman, Ace Nuke Free North County California ML13007A358 0279

Hoffman, David ML12325A015 0046

Hofford, William ML12331A278 0319

Holmes, Andre ML13058A061 0218

Holt, Robert ML12331A278 0319

Holzberg, Steven ML12331A278 0319

Homer, Deanna ML13028A036 0258

Hoodwin, Marcia ML12320A361 0313

Hoodwin, Marcia ML12324A384 0105

Horn, Stewart ML12331A347 0004-26

Horowitz, Shel ML12324A320 0028

Horvat, Sabolch ML13022A222 0115

Howard, Gloria J. ML13022A223 0121

Howard, Gloria J. ML13022A222 0115

Howard, Gordon Sierra Club ML12331A278 0304

Howard, Gordon Sierra Club ML13022A556 0176

Hudson, Marcella ML12331A278 0319

Hughes, Kevin ML13022A222 0115

Hurzeler, Philip ML12331A278 0319
- 64 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Hutchings, William ML13022A222 0115

Hynes, Patricia ML12331A278 0319

Ingram, Gwen ML12320A361 0317

Irwin, John ML12331A278 0319

Israel, Marcy ML13022A512 0188

Iversen, Gerald ML13022A222 0115

Iwane, Cathy ML12331A353 0005-14

Iwane, Cathy ML12331A353 0005-18

Jamil, Dhiaa Duke Energy Corporation ML13010A127 0264

Janusko, Robert and 

Donna ML12331A278 0319

Jaworski, Mary ML12355A174 0118-18

Jeffrey, Monroe Edwin ML12331A278 0319

Jeffrey, Monroe Edwin ML12324A282 0016

Jenkins, David ML13022A222 0115

Jennings, Sid ML13018A416 0155

Jessler, Darynne ML12334A385 0062

Johaningsmeir, Mark ML12331A278 0319

Johnson, Abigail Eureka County Nuclear Waste 

Program ML13007A404 0298

Johnson, Alaina ML12324A316 0110

Johnson, Alaina ML13023A403 0224

Johnson, Ron Prairie Island Indian Community ML12331A347 0004-4

Jones, Robert ML13022A222 0115

Jones, Virginia ML13018A412 0153

Jorgensen, Andrea ML13022A222 0115

Joseph, Randy ML13022A222 0115

Jurek, James ML13022A222 0115

Kammerer, Greg ML12334A390 0067

Kamps, Kevin Beyond Nuclear ML12331A347 0004-11

Kamps, Kevin Beyond Nuclear ML12331A353 0005-5

Kamps, Kevin Beyond Nuclear ML12331A353 0005-7

Kamps, Kevin Beyond Nuclear ML12331A353 0005-9

Kamps, Kevin Beyond Nuclear ML12355A174 0118-17

Kamps, Kevin Beyond Nuclear ML12355A174 0118-2

Kamps, Kevin Beyond Nuclear ML12355A174 0118-25

Kamps, Kevin Beyond Nuclear ML12355A174 0118-8

Kamps, Kevin Beyond Nuclear ML12355A174 0118-9

Kamps, Kevin Beyond Nuclear ML13060A240 0332

Kamps, Kevin Beyond Nuclear ML13060A240 0333
- 65 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Kamps, Kevin Beyond Nuclear ML13060A240 0334

Kamps, Kevin Beyond Nuclear ML13060A240 0335

Kamps, Kevin Beyond Nuclear ML13023A405 0326

Kamps, Kevin Beyond Nuclear ML13030A021 0329

Kamps, Kevin Beyond Nuclear ML13030A022 0328

Kamps, Kevin Beyond Nuclear ML13030A025 0327

Kamps, Kevin Beyond Nuclear ML13032A565 0331

Kamps, Kevin Beyond Nuclear ML13037A298 0330

Karpen, Leah ML12356A232 0293

Katz, David ML13022A222 0115

Kelly, Karen A. ML12331A278 0319

Kennedy, David ML13028A018 0326

Kenyon, Deborah ML13022A222 0115

Kerr, Beverly Blue Ridge Environmental Defense 

League ML12347A190 0090

Kerr, Julius ML12355A174 0118-10

Kerr, Julius ML12355A174 0118-20

Kerr, Julius ML12355A187 0119-11

Kerr, Julius ML12355A187 0119-13

Kerr, Julius ML12355A187 0119-9

Kersting, John ML12324A372 0041

Khalsa, Mha Atma S. ML12331A278 0319

Kiralla, Michael ML13022A222 0115

Kirk, John ML12324A351 0101

Kitman-Trimmer, 

Lorraine ML13022A222 0115

Klein, Roberta ML12348A035 0095

Kline, Susan ML13023A399 0221

Knipp, Donna ML13022A499 0326

Knol, Patricia ML13022A222 0115

Knox, Eric United States Nuclear Infrastructure 

Council ML13007A357 0276

Koessel, Karl ML12331A278 0319

Kohl, Sybil ML13022A222 0115

Kohler, Joseph ML13028A021 0246

Koivisto, Ellen and 

Gene Thompson ML12331A278 0319

Kotch, Brant ML13022A222 0115

Kovitz, Johanna ML12331A278 0319

Kraft, Dave Nuclear Energy Information Service ML13018A418 0157
- 66 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Kranzdorf, Richard ML13022A549 0170

Kriesel, Robert ML13023A386 0209

Kruszynski, Yasiu ML13022A503 0326

Kuehn, Richard Sierra Club ML13022A514 0190

Kukovich, Kenneth M. ML12335A008 0092

Kulp, Judy ML12331A278 0303

Kunkel, Christopher ML13022A222 0115

Kurtz, Sandra Bellefonte Efficiency & Sustainability 

Team ML13028A034 0256

Kutcher, Celia ML13022A222 0115

Laambeth, Larry ML12331A278 0319

Lacey, L. Darrell Nye County Nuclear Waste Repository 

Project Office ML13010A121 0244

Laing, Josephine ML13028A008 0230

Lambert, Gwen ML12320A361 0318

Lambert, Gwen ML12331A278 0319

Lambert, Gwen ML12354A128 0289

Lampert, Mary Pilgrim Watch ML12355A174 0118-11

Lampert, Mary Pilgrim Watch ML12355A174 0118-15

Lampert, Mary Pilgrim Watch ML12355A174 0118-26

Lampert, Mary Pilgrim Watch ML12355A174 0118-7

Lampert, Mary Pilgrim Watch ML12349A010 0148

Landau, Doug ML12324A370 0040

Lane, Gary ML12325A014 0045

Lang, Michael ML13022A222 0115

Lanski, Christopher ML13022A222 0115

Laramee, Eve ML12331A353 0005-12

Laramee, Eve ML12331A353 0005-17

Laramee, Eve ML12325A018 0049

Larkin, Gail ML13022A222 0115

Larson, Dennis ML13007A401 0295

Larson, Jean ML13022A222 0115

Laurie, Annie ML13022A222 0115

Lawton-Singer, Cynthia ML12320A361 0316

Lazzarini, Howard ML13022A222 0115

Lee, Catherine ML12331A278 0319

Leichtling, Don ML13018A424 0163

Lemon, Patricia Selectboard, Town of Warwick ML13028A023 0248

Lenz, Andrew ML13018A320 0130

Leonardi, Michael Toledo Coalition ML12331A353 0005-15
- 67 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Lesser, Gerson T. ML12331A278 0319

Lester, Janet ML13022A222 0115

Levin, John ML13022A222 0115

Levine, Gregg ML12355A174 0118-22

Levine, Gregg ML12355A187 0119-10

Levine, Gregg ML12355A187 0119-12

Levine, JR ML12324A393 0002

Levey, Laura ML12324A385 0001

Lewis, Marvin ML12355A174 0118-14

Lewis, Marvin ML12355A174 0118-21

Lewis, Marvin ML13058A031 0223

Lewis, Marvin ML123250525 0009

Lewis, Marvin ML12332A225 0056

Lewis, Marvin ML12334A401 0075

Lewis, Marvin ML12340A151 0087

Lewis, Marvin ML12348A034 0091

Lewis, Marvin ML13023A402 0217

Lieberman, Andrea ML12331A353 0005-8

Lieberman, Sharon and 

Jim ML12331A278 0319

Lippman, Roger ML12331A278 0319

Lish, Christopher ML12331A278 0319

Lish, Christopher ML13028A033 0266

Lochbaum, David ML13010A123 0260

Lorwin, Lisa ML13022A222 0115

Lukas, James ML13022A222 0115

Lynch, Janette ML13022A222 0115

M, Teresa ML13018A202 0124

Mac Krell, Thomas ML13018A205 0127

MacDonald, Joan ML12331A278 0310

MacWaters, Chris ML12334A392 0069

Mahowald, Philip R. Prairie Island Indian Community ML13010A132 0292

Mahowald, Philip R. Prairie Island Indian Community ML13017A008 0321

Mainland, Edward ML13018A400 0141

Maiorca, Michelle ML12324A296 0106

Makhijani, Arjun ML12331A347 0004-6

Malina, Matt NYC H2O ML12324A374 0001

Mammarella, James ML12331A278 0319

Maness, Mitchell ML13023A385 0208
- 68 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

March, Leslie ML13018A411 0152

Marcus, Jack Davis ML13022A222 0115

Margos, J.F. ML13022A222 0115

Mariotte, Michael Nuclear Information and Resource 

Service ML13022A223 0266

Martin, Brad ML13022A222 0115

Martinez, Catherine Sierra Club ML13018A396 0137

Matsuda, Thomas ML12331A278 0319

Matsuda, Thomas ML12334A386 0063

Matsuda, Thomas ML13022A500 0326

Maurer, William PANA ML123380151 0080

McCall, Charles ML13022A222 0115

McCollough-Howard, 

Celeste

Women's International League for 

Peace and Freedom ML13028A028 0252

McCollum, Brian ML13022A222 0115

McComb, Melinda ML12325A016 0047

McCormick, Bob ML12331A278 0319

McCue, J.G. ML12331A278 0319

McDonough, Susan ML13022A222 0115

Meacham, Thomas ML12331A278 0319

Meadow, Norman Maryland Conservation Council ML12331A353 0005-2

Meadow, Norman Maryland Conservation Council ML12331A353 0005-4

Milcarek, Thomas ML13022A509 0206

Mohan, Debi ML12325A013 0044

Monaster, Susan ML12331A278 0319

Monroe, Victoria ML13018A200 0122

Monsees, David ML13023A394 0214

Morello, Phyl ML13022A222 0115

Morris, Daniel ML13022A222 0115

Morrison, George J. ML12324A355 0031

Mouradian, Judy ML12331A278 0319

Moyer, Heather ML13022A222 0115

Moyer, Phoebe ML13022A508 0205

Mueller, Kirstin ML13022A222 0115

Murtha, William ML13028A005 0227

Naples, Jean Marie ML12335A301 0319

Naples, Jean Marie ML12340A145 0083

Neiman, Laura ML12324A303 0001

Neland, Vicki Beyond Nuclear ML12334A396 0073

Nelson, Scott D. ML12331A278 0319
- 69 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Nichols, John ML12331A278 0319

Nichols, John ML12340A027 0312

Nichols, John ML123380141 0093

Nicholson, Larry Florida Power and Light ML13007A399 0302

Niles, Ken Western Interstate Energy Board ML13010A122 0270

Nord, Jill ML13022A547 0168

North, D. Warner ML13030A026 0278

North, D. Warner Sustainable Fuel Cycle Task Force ML13030A023 0280

O'Connell, Brian National Association of Regulatory 

Commissioners ML13010A125 0233

O'Leary, David ML13022A222 0115

O'Neill, Kevin ML12324A375 0007

O'Neill, Kevin ML12319A467 0097

Oberlin, Carl ML13022A222 0115

Oconnell, Daniel ML13022A222 0115

Oehler, Susan ML13022A222 0115

Olsen, Corey E. ML12331A278 0319

Olson, Mary Southeast Office of Nuclear 

Information and Resource Service ML12331A347 0004-16

Olson, Mary Southeast Office of Nuclear 

Information and Resource Service ML12355A187 0119-5

Ostrer, Allison ML12331A278 0319

Ower, Douglas ML13028A017 0241

Page, Nicholas ML13022A222 0115

Pagoulatos, Alexis ML12331A278 0319

Palmer, R. Brent ML13022A222 0115

Pasquale, Elizabeth ML12324A358 0034

Pate, Ann ML12331A278 0319

Patrie, Lewis WNC Physicians for Social 

Responsibility ML13028A014 0238

Payton, Renee ML13022A222 0115

Peirce, Susan ML13022A222 0115

Pelham, Christopher ML12331A278 0319

Pelizzari, Roger ML12331A278 0319

Pelizzari, Roger ML12324A279 0012

Perkins, Bob ML12331A278 0319

Pfaelzer, Morgan ML13022A222 0115

Philbrook, Pati ML12331A278 0319

Phillips, Stuart ML12331A278 0319

Phillips, Stuart ML12325A052 0051
- 70 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Piarulli, Josephine ML12331A278 0319

Pick, Anna ML12331A278 0319

Pino, Dolores C. ML13022A222 0115

Pirch, Charlotte ML12320A361 0315

Poole, Jesse ML12342A278 0088

Portszline, Scott Three Mile Island Alert ML12331A347 0004-24

Poulson, Judi Fairmont MN Peace Group ML12324A280 0013

Poulson, Judi ML12331A278 0319

Poulson, Judi ML12340A146 0083

Poulson, Judi ML13022A497 0199

Preston, Lynne ML12331A278 0319

Priestly, Meredith ML13022A222 0115

Prior, Barbara ML13022A222 0115

Prola, Jim and Diana ML13022A222 0115

Pruitt, Steve and Alicia ML13018A410 0151

Puca, Rob ML12324A315 0001

Puett, David ML13018A203 0125

Pyburn, Susan ML13022A501 0200

Rafacz, Bernard ML13022A222 0115

Rattner, Ron ML13022A222 0115

Rea, Paul ML13018A395 0136

Reel, Joseph ML13022A222 0115

Reischke, Ysan ML13022A222 0115

Renn, Melissa ML13018A326 0135

Repka, David ML12331A347 0004-20

Reynolds-Sparks, Darla ML13028A024 0249

Ribnick, Lawrence ML13022A222 0115

Richards, Jay ML12324A278 0011

Richardson, Don ML12331A278 0306

Richkus, John ML12331A278 0319

Richkus, John ML12324A347 0001

Rigby, Cheri ML13022A222 0115

Riggs, George ML13028A006 0229

Riley, Christine L. ML12320A361 0314

Rivers, Alicia Sierra Club ML12355A187 0119-14

Roane, Christine ML12331A278 0319

Roane, Christine ML12324A323 0015

Roberts, James ML13022A559 0179

Robertson, Kenneth ML13022A222 0115
- 71 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Robinson, Julie ML13022A222 0115

Rogers, Karen ML12331A278 0319

Roland, Jelica ML12331A278 0319

Roseboom Jr., Eugene 

H. ML13017A109 0320

Roseboom Jr., Eugene 

H. Sustainable Fuel Cycle Task Force ML13030A023 0280

Rosen, Kay ML13022A222 0115

Roskos, Laura Women's International League for 

Peace and Freedom, US Section ML13011A085 0277

Roth, Erik ML12331A278 0319

Rupar, Randyl ML13022A222 0115

Rusch, Joann Mothers for Peace/Sierra Club ML13022A564 0184

Ryan, Sarah ML13022A222 0115

S., Erin ML13022A222 0115

Safer, Don Tennessee Environmental Council ML12355A174 0118-16

Safer, Don Tennessee Environmental Council ML12355A174 0118-24

Safer, Don Tennessee Environmental Council ML12355A174 0118-3

Saftler, Michael ACTelluride ML13018A423 0162

Salazar, Joe ML12331A278 0319

Salazar, Joe ML12340A147 0083

Sanders, Marshall ML13022A492 0195

Savett, Adam ML13022A490 0215

Schlamm, Rhoda ML12324A305 0108

Schmotzer, Michael ML13018A201 0123

Schor, Mary ML12331A278 0319

Schuchart, Lawrence ML12331A278 0319

Schwartz, Eric Hagerstown Community College ML13018A323 0132

Schweiss, Kraig and 

Valerie ML13022A222 0115

Scott, Barbara ML13022A515 0191

Scott, Cathy ML13028A012 0236

Seeley, Rick ML12331A278 0319

Selquist, Donna ML12334A393 0070

Selquist, Donna ML13022A493 0194

Sembrowich, Nita ML12331A278 0319

Settanni, Anne ML13022A222 0115

Seyfried, Mike ML13022A222 0115

Shaffer, Matthew ML13022A222 0115

Shafnisky, Luke ML13022A222 0115
- 72 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Shakarian, Jana ML12324A361 0036

Shapiro, Susan Indian Point Energy Coalition ML13007A402 0296

Shapiro, Susan ML12331A347 0004-25

Shaw, Sally ML12331A278 0307

Shaw, Sally ML12331A278 0319

Shaw, Sally ML13018A406 0147

Shea, Kelly ML13022A222 0115

Sheehan, Margaret Pilgrim Coalition ML12331A347 0004-23

Sheehan, Margaret Pilgrim Coalition ML12355A174 0118-19

Shepard, Larry U.S. EPA, Region 7 ML12355A174 0118-6

Sheridan, Paul MN Peace Group ML12324A340 0017

Sheridan, Paul MN Peace Group ML12334A391 0068

Sheridan, Paul MN Peace Group ML13022A223 0266

Shields, Lane ML13009A341 0319

Shifrin, Allen ML13022A222 0115

Shomer, Forest ML12331A278 0319

Shoop, Pamela ML12331A353 0005-13

Shuput, Steve ML12334A395 0072

Silberg, Jay Pillsbury Winthrop Shaw Pittman ML12331A347 0004-27

Silbey, Marilena ML12331A278 0319

Silver, Barrett Riverkeeper ML111111111 0222

Silver, Ron ML12331A278 0319

Silverman, Don Morgan, Lewis & Brockius ML12331A347 0004-10

Simmerman, Scott ML12331A278 0305

Simmons, Carole ML13022A222 0115

Simmons, Ymani ML13022A222 0115

Sipos, John State of New York ML12331A347 0004-5

Sipos, John State of New York ML13007A398 0275

Skrzynecki, Richard ML13022A222 0115

Slade, Matt ML13022A222 0115

Slezak-Fritz, Joan ML13018A404 0145

Slotnick, Lauryn ML13023A387 0210

Small, Sally ML12331A278 0319

Smith, Mike MN Peace Group ML12324A341 0018

Smith, Wiley ML13022A222 0115

Sorensen, Laura SAFE Carolinas ML13010A135 0274

Sorensen, Laura ML12355A187 0119-7

Sorensen, Ole ML13028A029 0261

Sorgen, Phoebe Fukushima Response Bay Area ML12334A403 0076
- 73 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Sorrell, William H. State of Vermont ML13007A398 0275

Sparks, Jeanne ML13022A222 0115

ssf, Edmund ML12331A278 0319

Stadnik, George ML13022A222 0115

Stanley, Edh ML13022A488 0193

Star, Priscilla ML12331A353 0005-11

Stavely, Jary ML13022A222 0115

Stein, Julia ML13022A222 0115

Steiner, Danny ML12332A226 0057

Stone, Lisa ML13022A222 0115

Straw, Sara ML13018A408 0149

Strawn, Michael ML13022A222 0115

Strickland, Christine ML12331A353 0005-10

Strickland, Christine ML12331A353 0005-16

Struble, Dan ML13022A222 0115

Suter, Lindsay ML12331A278 0319

Swanson, Jane San Luis Obispo Mothers for Peace ML12324A298 0114

Swyers, Matthew ML12331A278 0319

Swyers, Matthew ML12334A389 0066

Szokolai, Maria ML13022A222 0115

Tache, Jan ML12331A278 0319

Talbot, James ML12331A278 0319

Tallent, Yvonne ML13022A222 0115

Taylor, Wallace Sierra Club ML13023A391 0213

Taylor, Wendi Sierra Club ML13018A421 0160

Tepper, Carol ML13022A222 0115

Thomas, Ruth Environmentalists, Inc. ML12331A347 0004-17

Thomas, Ruth Environmentalists, Inc. ML13028A013 0237

Tibbits, Kathy ML13007A403 0297

Tignanelli, Doreen ML12324A344 0001

Tokuda, Tlaloc ML12331A278 0319

Torres, Madge ML13022A546 0167

Trager, Jami ML13022A222 0115

Treichel, Judy Nuclear Waste Task Force ML12331A347 0004-22

Unger, Art ML12325A054 0053

Unknown, Ralph ML13022A222 0115

Vale, Karen ML12340A148 0084

Valentine, Jennifer ML12319A466 0001

Valtri Burgess, Vivian ML13022A513 0189
- 74 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Van Stone, Carolina ML12331A278 0319

VanWicklen, Betty J. ML13018A321 0129

Varekamp, Patrick ML12325A011 0001

Vaughan, Leila ML13022A222 0115

Voeller, Estelle ML12331A278 0319

Vollmer, Terry ML12331A278 0319

von Christierson, Peter ML13018A420 0159

Vora, Davina ML13022A222 0115

Wachob, William ML12331A278 0319

Waddell, W. Duane ML13022A562 0182

Wakefield, Marie ML13023A388 0326

Wallace, Don ML12331A278 0319

Wallace, Martin Saner Living Neighborhood 

Association ML13028A164 0228

Walters, Catherine ML13022A222 0115

Warren, Barbara Citizens Environmental Coalition ML13010A130 0269

Warren, Barbara Physicians for Social Responsibility ML12355A174 0118-13

Warren, Barbara Physicians for Social Responsibility ML12355A174 0118-4

Warren, Barbara Physicians for Social Responsibility ML13018A325 0134

Warren, Richard C. ML12331A278 0319

Warshauer, Meira Environmentalists, Inc. ML13028A037 0336

Watts, Elizabeth ML13022A222 0115

Weart, Wendell Sustainable Fuel Cycle Task Force ML13030A023 0280

Weber, Nicole ML13023A401 0232

Wedow, Nancy ML13022A222 0115

Weiner, Ruth ML13030A023 0280

Weisenmiller, Robert B. California Energy Commission ML13010A133 0272

Weisman, David Alliance for Nuclear Responsibility ML12331A347 0004-15

Wentland, Mary ML13018A425 0164

Whitefield, Anne NC Warn ML13028A015 0239

Wilder, Laura ML12331A278 0319

Wildermuth, Gordon ML13022A222 0115

Wildwind, Landry ML12331A278 0319

Wiley, JiYoung Louisiana Department of 

Environmental Quality ML12348A036 0096

Williams, Curt ML12325A053 0052

Williams, Terry J. ML13022A222 0115

Wilvert, Cal ML13022A563 0183

Wilvert, Rosemary ML13022A548 0169

Winholtz, Betty ML12331A278 0319
- 75 - 

Commenter Affiliation (if stated) ADAMS Accession # Correspondence 

ID

Winholtz, Betty ML12334A383 0060

Winograd, Isaac Sustainable Fuel Cycle Task Force ML13030A023 0280

Wolf, Rachel ML12331A278 0319

Wollman, Michael ML13022A504 0202

Wolski, Mike ML13022A222 0115

Wong, Houston ML13022A222 0115

Wood, Richard ML13023A389 0211

Woodcock, Charlene ML13022A222 0115

Wright, David A. Nuclear Waste Strategy Coalition ML13010A129 0268

Wynne, Diane ML13022A222 0115

Yeatts, Jordan ML13018A417 0156

York, Jennifer ML12321A324 0311

Young, Nancy ML13022A222 0115

Zalcman, Barry ML13030A017 0283

Zamek, Jill ML13022A222 0115

Zeller, Lou Blue Ridge Environmental Defense 

League ML12331A347 0004-14

Zeller, Lou Blue Ridge Environmental Defense 

League ML12355A174 0118-12

Zeller, Lou Blue Ridge Environmental Defense 

League ML12355A174 0118-23

Zeller, Lou Blue Ridge Environmental Defense 

League ML12355A174 0118-27

Zeller, Lou Blue Ridge Environmental Defense 

League ML12355A174 0118-5

Zeller, Lou Blue Ridge Environmental Defense 

League ML13007A359 0273

Zerzan, Paula ML13022A222 0115

Zigmund, Sean ML12324A379 0021

Zimmerman, Warren ML13018A426 0165

Zmolek, Mike ML12331A278 0319

Zucker, Lee ML12331A278 0319
- 76 - 

E. List of Commenters on the December 2011 Draft Report, 

“Background and Preliminary Assumptions for an Environmental 

Impact Statement—Long-Term Waste Confidence Update” 

Commenter Name Commenter Affiliation Comment 

Date 

ADAMS 

Accession 

Number 

Alex Cole 26-Feb-12 ML12059A619 

Allison Ostrer 24-Feb-12 ML12059A504 

Anna A. Pick 24-Feb-12 ML12059A282 

Art Hanson 25-Feb-12 ML12059A617 

Aurora & Raul Insurriago 28-Feb-12 ML12061A010 

Barbara Byron, Ken Niles Western Interstate Energy Board 

(WIEB) High-Level Waste Committee 17-Feb-12 ML12052A044 

Beatrice Brailsford Snake River Alliance 17-Feb-12 ML12052A051 

Bernard Bevill Arkansas Department of Health, 

Radiation Control Section 16-Feb-12 ML12048A281 

Berton Moldow 24-Feb-12 ML12059A503 

Beth Anne Boardman 30-Jan-12 ML12033A003 

Bettina Barbier 24-Feb-12 ML12059A522 

Bill Brown 24-Feb-12 ML12058A557 

Brian O'Connell National Association of Regulatory 

Utility Commissioners (NARUC) 16-Feb-12 ML12048A305 

Brian O'Connell National Association of Regulatory 

Utility Commissioners (NARUC) 22-Feb-12 ML12055A124 

Byron L. Davis, Ph.D. 

Center for High Performance 

Computing, Univ. of Utah, Staff 

Consultant for Stat. & Rsch Method 

24-Feb-12 ML12058A560 

Carroll E. Arkema 24-Feb-12 ML12059A494 

Caryn Graves 24-Feb-12 ML12058A545 

Charles Brobst 24-Feb-12 ML12059A498 

Charles Fairhurst, D. 

Warner North, Ruth 

Weiner, Isaac Winograd, 

Wendell Weart, Eugene H. 

Roseboom Jr. 

Sustainable Fuel Cycle Task Force 17-Feb-12 ML12052A053 

Charlotte Sumrow-Pirch 24-Feb-12 ML12059A557 

Christine M. Roane 24-Feb-12 ML12059A010 
- 77 - 

Commenter Name Commenter Affiliation Comment 

Date 

ADAMS 

Accession 

Number 

Crystal Rose Starheart 25-Feb-12 ML12059A613 

Crystal Rose Starheart 25-Feb-12 ML12059A614 

Dan Danziger 24-Feb-12 ML12058A406 

Daniel Shively 27-Feb-12 ML12059A627 

Daral Reynolds-Sparks 25-Feb-12 ML12059A599 

Darlene St. Martin 24-Feb-12 ML12059A525 

Dave P. & Louise S. 

Ransom 24-Feb-12 ML12058A547 

David A. Wright Nuclear Waste Strategy Coalition 

(NWSC) 17-Feb-12 ML12052A046 

David Greene 27-Feb-12 ML12059A628 

David Houseman 25-Feb-12 ML12059A595 

David Weisman Alliance for Nuclear Responsibility 25-Jan-12 ML12026A047 

Diane Curran, Geoffrey 

Fettus 

Blue Ridge Environmental Defense 

League (BREDL), the Institute for 

Energy and Environmental Research 

(IEER), Natural Resources Defense 

Council (NRDC), Riverkeeper, and 

Southern Alliance for Clean Energy 

(SACE) 

17-Feb-12 ML12052A047 

Diane D’Arrigo, Moe 

Headington, Judy Treichel, 

Charles Utley, Don Safer, 

Pam Moffit, Tom 

Clements, Paula Gotsch 

Alliance for Nuclear Accountability; 

Blue Ridge Environmental Defense 

League; Episcopal Peace Fellowship 

(Chicago); Grandmothers, Mothers 

and More for Energy Safety (NJ); 

Nevada Nuclear Waste Task Force; 

Nuclear Information and Resource 

Service; Stand Up Save Lives (IL); 

Tennessee Environmental Council 

16-Feb-12 ML12047A007 

Dolores A. Pieper 28-Feb-12 ML12061A013 

Donna Gilmore 26-Jan-12 ML12027A206 

Doris Fulton 26-Feb-12 ML12059A621 

Douglas Gerleman 26-Feb-12 ML12059A624 

Dr. Darrell D. Davisson, 

Ph.D. 24-Feb-12 ML12059A578 

Dr. Mha Atma S. Khalsa 24-Feb-12 ML12059A497 

Dr. William H. Whitaker 26-Feb-12 ML12059A622 

Elena Day 24-Feb-12 ML12059A002 
- 78 - 

Commenter Name Commenter Affiliation Comment 

Date 

ADAMS 

Accession 

Number 

Elizabeth Butler 24-Feb-12 ML12058A561 

Eric Morris 28-Feb-12 ML12061A011 

Gail Payne 24-Feb-12 ML12058A392 

Gary Lane 6-Jan-12 ML12010A142 

Gene Stone Residents Organized For a Safe 

Environment (ROSE), CA 24-Jan-12 ML12026A043 

Gerard F. Gaudin 24-Feb-12 ML12059A003 

Gerson T. Lesser, M.D. 24-Feb-12 ML12059A527 

Grant R. Shafer 29-Feb-12 ML12061A016 

Greg Sutherland 24-Feb-12 ML12059A553 

Gwen Lambert 25-Feb-12 ML12059A594 

Hendrica Regez 24-Feb-12 ML12058A540 

J.A. Gresham Westinghouse 17-Feb-12 ML12048A873 

J.J. Saecker 24-Feb-12 ML12059A271 

James Concannon 16-Jan-12 ML12017A125 

James M. Nordlund 25-Feb-12 ML12059A593 

Jan Tache 24-Feb-12 ML12058A544 

Jayne Hamilton 24-Feb-12 ML12059A276 

Jeanie Johnson 24-Feb-12 ML12059A499 

Jeffrey M. Skov 17-Feb-12 ML12052A045 

Jennifer M. Weishaar 28-Feb-12 ML12061A012 

Jerry Weiser 4-Jan-12 ML12010A144 

Jim Bell 24-Feb-12 ML12058A558 

Joe Salazar 24-Feb-12 ML12059A575 

Joel Kay 24-Feb-12 ML12059A555 

John H. Kessler Electric Power Research Institute 

(EPRI) 17-Feb-12 ML12052A050 

John M. Ackerman, M.D. 25-Feb-12 ML12059A607 

John Ventre 24-Feb-12 ML12059A523 

John Viacrucis 24-Feb-12 ML12059A524 
- 79 - 

Commenter Name Commenter Affiliation Comment 

Date 

ADAMS 

Accession 

Number 

Jonathan Bailin, Ph.D. 25-Feb-12 ML12059A616 

Joyce & Ronald Mason 24-Feb-12 ML12059A560 

Joyce Frohn 24-Feb-12 ML12059A280 

JT 24-Jan-12 ML12026A044 

Judith E. Klein 25-Feb-12 ML12059A604 

Kaitlin Nichols 24-Feb-12 ML12059A520 

Karry Muzzey 27-Feb-12 ML12059A626 

Kathe Garbrick 24-Feb-12 ML12059A006 

Kathleen Ward 25-Jan-12 ML12026A045 

Kenneth J. Gunther 24-Feb-12 ML12059A004 

Kiwibob Glanzman 25-Feb-12 ML12059A611 

Laura Bernstein 24-Feb-12 ML12059A278 

Laurence Kirby 25-Feb-12 ML12059A601 

Lawrence Turk, R.N. 29-Feb-12 ML12061A015 

Lee Baily, Ph.D. 24-Feb-12 ML12058A541 

Leslie Limberg 24-Feb-12 ML12058A542 

Leslie Limberg 24-Feb-12 ML12058A559 

Leslie Tawnamaia 24-Feb-12 ML12058A546 

Lewis Darrell Lacy Nye County Nevada Waste Repository 

Project Office 16-Feb-12 ML12048A326 

Lewis McGregor 24-Feb-12 ML12059A275 

Linda & Lewis Paleias 25-Feb-12 ML12059A600 

Lisa Gosnell 24-Feb-12 ML12058A539 

Lisa R. Janairo 

Council of State Governments 

Midwestern Radioactive Materials 

Transportation Committee 

16-Feb-12 ML12048A270 

Lynn Wilbur 24-Feb-12 ML12058A405 

M. Kelly Sutton, M.D. 24-Feb-12 ML12059A576 

M. Ross Adams 26-Feb-12 ML12059A623 

Marcy Vaj 24-Feb-12 ML12059A279 
- 80 - 

Commenter Name Commenter Affiliation Comment 

Date 

ADAMS 

Accession 

Number 

Margaret Dunn 26-Feb-12 ML12059A620 

Marie Wakefield 24-Feb-12 ML12059A551 

Mark Hayduke 24-Feb-12 ML12059A561 

Mark Kwasny 4-Jan-12 ML12010A149 

Marthea Rountree Environmental Protection Agency 15-Feb-12 ML12047A005 

Mary Neland 24-Feb-12 ML12059A573 

Maura Derey 27-Feb-12 ML12059A629 

Michael S. Callahan Decommissioning Plant Coalition 16-Feb-12 ML12052A063 

Michele Johnson, M.D. 24-Feb-12 ML12059A521 

Mike Smith 24-Feb-12 ML12059A272 

Millicent Sims 24-Feb-12 ML12059A574 

Mo Sandel 24-Feb-12 ML12058A538 

Monroe Edwin Jeffrey 24-Feb-12 ML12058A543 

Naomi Zuckerman 24-Feb-12 ML12059A559 

Nita Sembrowich 24-Feb-12 ML12059A495 

Pati Philbrook 24-Feb-12 ML12059A501 

Patricia Jerrells 25-Feb-12 ML12059A608 

Patricia Moore 24-Feb-12 ML12058A399 

Patricia Orlinski 24-Feb-12 ML12059A580 

Patrick Bosold 24-Feb-12 ML12059A526 

Paul Franzmann 24-Feb-12 ML12059A577 

Paul Roden 24-Feb-12 ML12059A005 

Paula Hendrick 25-Feb-12 ML12059A597 

Peter Broderson 25-Feb-12 ML12059A596 

Philip R. Mahowald Prairie Island Indian Community 17-Feb-12 ML12048A867 

R. Fay 25-Feb-12 ML12059A615 

Randall Hartman 24-Feb-12 ML12059A009 

Randall Webb 24-Feb-12 ML12059A582 
- 81 - 

Commenter Name Commenter Affiliation Comment 

Date 

ADAMS 

Accession 

Number 

Rebecca Tippens 24-Feb-12 ML12059A277 

Robert J. Halstead State of Nevada Agency for Nuclear 

Projects 17-Feb-12 ML12052A040 

Robert Kenny & Julia 

Glover 24-Feb-12 ML12059A562 

Robert Mihaly 25-Feb-12 ML12059A591 

Rod McCullum Nuclear Energy Institute 16-Feb-12 ML12048A295 

Ron Smith 24-Feb-12 ML12058A556 

Ronald S.Katz 24-Feb-12 ML12059A554 

Sandra Cobb 24-Feb-12 ML12059A493 

Sandra J. Bader 24-Feb-12 ML12059A502 

Sandy Sanders 24-Feb-12 ML12059A001 

Sarah Preston Tiers 24-Feb-12 ML12059A496 

Sarah Woodside Gallagher 24-Feb-12 ML12059A000 

Scott Nass, M.D., M.P.A. 25-Feb-12 ML12059A590 

Seth Carr 24-Feb-12 ML12058A409 

Shari Horne 25-Jan-12 ML12026A046 

Sharon & Jim Lieberman 25-Feb-12 ML12059A605 

Shellee Davis 24-Feb-12 ML12059A274 

Sidney Keener, P.E. URS 4-Jan-12 ML12010A146 

Steve Behling 11-Jan-12 ML12012A002 

Steve Michaelson 5-Jan-12 ML12010A143 

Steve Netherby 27-Jan-12 ML12027A207 

Steve Roddy 25-Feb-12 ML12059A609 

Susan Peirce 25-Feb-12 ML12059A606 

Sybil Schlesinger 25-Feb-12 ML12059A598 

Tabor Browder 26-Feb-12 ML12059A618 

Terry Ellen Robinson 24-Feb-12 ML12059A518 

Theodore Wilcox, PhD 24-Feb-12 ML12059A007 

Thomas Lindeman 25-Feb-12 ML12059A603 
- 82 - 

Commenter Name Commenter Affiliation Comment 

Date 

ADAMS 

Accession 

Number 

Thomas Paulson 25-Feb-12 ML12059A610 

Tim Leighton 24-Feb-12 ML12058A537 

Tim Steorts 25-Feb-12 ML12059A612 

Tom Carsner 24-Feb-12 ML12059A581 

Tom Clements Alliance for Nuclear Accountability 10-Feb-12 ML12045A096 

Tom Liberatore 28-Feb-12 ML12061A014 

V.E. Perkins, Ph.D. 24-Feb-12 ML12059A556 

Vernon Huffman 23-Dec-11 ML12010A151 

Vernon Huffman 30-Dec-11 ML12010A150 

Veronica Hayes 24-Feb-12 ML12059A273 

Wallace L. Taylor Iowa Chapter of the Sierra Club 13-Feb-12 ML12045A141 

Wendy Fast 24-Feb-12 ML12059A517 

Will Yeager 25-Feb-12 ML12059A583 

William D. Rizer 24-Feb-12 ML12059A008 

William Saenz 26-Feb-12 ML12059A625 

William Wilgus 24-Feb-12 ML12059A550