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The working materials in the NRDC Document Bank are listed in reverse chronological order. For additional policy materials including reports and issue papers, see the Issues section of the main NRDC site.

NRDC’s Perspectives on the Economics of Small Modular Reactors

Power point presentation of NRDC’s perspectives on the economics of small modular reactors (SMR). Presented at the Secretary of Energy Advisory Board SMR Subcommittee Meeting on May 30, 2012.

NRDC's Amicus Response in Support of Friends of the Earth

The Natural Resources Defense Council submitted this amicus response in support of the Opening Brief and Petition to Intervene and Request for Hearing filed by Friends of the Earth on January 11th, 2013 pursuant to the December 20th, 2012 Scheduling Order established by the Atomic Safety & Licensing Board.

An Evaluation of the NRC Response to the Fukushima Nuclear Accident

On Aug. 7th, 2012, the Nuclear Regulatory Commission (NRC) invited Nuclear Program Director Christopher Paine to present NRDC’s views on the Commission’s regulatory response to date to the lessons of the March 2011 multi-unit nuclear accident at the Fukushima Daichi nuclear power station in Japan.

Post-Fukushima Hardened Vents with High-Capacity Filters for BWR Mark Is and Mark IIs

This report comments on the various safety benefits of installing high-capacity filters in addition to hardened vents for Boiling Water Reactor (BWR) Mark I and II containments. The U.S. Nuclear Regulatory Commission is expected to discuss the issue of filtered venting systems and whether thy should be required as part of the March 2012 Commission order requiring reliable hardened vents.

Nuclear Safety Deferred: The U.S. Nuclear Regulatory Commission's Inadequate Response to the Lessons of the Fukushima Dai-ichi Nuclear Accident

Closing in on the one-year anniversary of the largest nuclear accident since the 1986 Chernobyl disaster, many people are reflecting on the events of last year's Fukushima Dai-ichi disaster. Those in the United States may wonder: Has anything changed here? What have we learned from Fukushima, and is the U.S. nuclear industry safer than it was a year ago? Should Americans be confident in our nuclear regulators? And how has the situation progressed in Japan since March 2011? What has been the impact of the Fukushima catastrophe on the global nuclear industry?

NRDC Intervenes in the Limerick Nuclear Plant Operating License Renewal Application, Citing Obsolete Accident Mitigation Study

NRDC filed petitions with the U.S. Nuclear Regulatory Commission (NRC) to become interveners in Exelon Generation Company’s application to renew the operating license for the Limerick Generating Station, located 30 miles northwest of Philadelphia. Due to an inappropriate exemption received from the Nuclear Regulatory Commission (NRC), Exelon seeks to re-license Limerick to operate until the middle of this century without updating safety studies that date back to the 1980s. The NRDC petitions contend that Exelon’s license renewal application is deficient because it relies on outdated and insufficient safety and risk information and fails to fully consider the alternatives to re-licensing Limerick as required by the National Environmental Policy Act (NEPA).

Global Implications of the Fukushima Disaster for Nuclear Power

This paper was written by Thomas B. Cochran and Matthew McKinzie and delivered by Cochran and the World Federation of Scientists’ International Seminars on Planetary Emergencies at the Ettore Majorana Centre in Erice, Sicily, held from August 19-25, 2011.

NRDC comments on the NRC Near-Term task force recommendations

NRDC’s written comments filed on September 2, 2011 on the Nuclear Regulatory Commission (NRC) Near-Term task force recommendations being considered for implementation ‘without unnecessary delay.’” (Please Note): NRDC Nuclear Program Director Christopher Paine provided extended oral comments on this same subject matter at a Commission staff dialogue conducted with external stakeholders at NRC headquarters on August 31, 2011)

NRDC's petitions to the NRC in response to the Near-Term Task Force's 90 Day Report on the Lessons from Fukushima

In July 2011 the NRDC Nuclear Program submitted to the Nuclear Regulatory Commission (NRC) twelve 10 CFR 2.206 petitions for immediate agency action and six 10 CFR 2.802 petitions for rulemaking that track the nuclear safety recommendations in the NRC Task Force's recently-released 90 day report on the lessons from the Fukushima Daiichi disaster. The 10 CFR 2.206 petitions ask the Commission to directly issue orders to nuclear power plant license holders on specific reactor safety upgrades. And the 10 CFR 2.802 rulemaking petitions request the NRC to commence a public process to alter specific rules that govern the nuclear industry's safety requirements.

Prior to our petitions, the New York Times recently discussed the NRC's Near Term Task Force Review and also provided an explanation of the different processes that we have invoked.

Here are brief descriptions of the specific petitions we filed.

    10 CFR 2.206 Petitions

  • nuc_11081201a.pdf 2.1 Order licensees to reevaluate the seismic and flooding hazards at their sites against current NRC requirements and guidance, and if necessary, update the design basis and SSCs important to safety to protect against the updated hazards.[p.30]
  • nuc_11081201b.pdf 2.3 Order licensees to perform seismic and flood protection walkdowns to identify and address plant-specific vulnerabilities and verify the adequacy of monitoring and maintenance for protection features such as watertight barriers and seals in the interim period until longer term actions are completed to update the design basis for external events. [p.30]
  • nuc_11081201c.pdf 4.2 Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.[p.39]
  • nuc_11081201d.pdf 5.1 Order licensees to include a reliable hardened vent in BWR Mark I and Mark II containments. [p.41]
  • nuc_11081201e.pdf 7.1 Order licensees to provide sufficient safety-related instrumentation, able to withstand design-basis natural phenomena, to monitor key spent fuel pool parameters (i.e., water level, temperature, and area radiation levels) from the control room.[p.46]
  • nuc_11081201f.pdf 7.2 Order licensees to provide safety-related ac electrical power for the spent fuel pool makeup system.[p.46]
  • nuc_11081201g.pdf 7.3 Order licensees to revise their technical specifications to address requirements to have one train of onsite emergency electrical power operable for spent fuel pool makeup and spent fuel pool instrumentation when there is irradiated fuel in the spent fuel pool, regardless of the operational mode of the reactor. [p.46]
  • nuc_11081201h.pdf 7.4 Order licensees to have an installed seismically qualified means to spray water into the spent fuel pools, including an easily accessible connection to supply the water (e.g., using a portable pump or pumper truck) at grade outside the building.[p.46]
  • nuc_11081201i.pdf 8.1 Order licensees to modify the EOP technical guidelines (required by Supplement 1, “Requirements for Emergency Response Capability,” to NUREG-0737, issued January 1983 (GL 82-33), to (1) include EOPs, SAMGs, and EDMGs in an integrated manner, (2) specify clear command and control strategies for their implementation, and (3) stipulate appropriate qualification and training for those who make decisions during emergencies.[p. 49]
  • nuc_11081201j.pdf 8.3 Order licensees to modify each plant’s technical specifications to conform to the above changes.[p.50]
  • nuc_11081201k.pdf 9.3 Order licensees to do the following until rulemaking is complete:<br><br><ul><li>Determine and implement the required staff to fill all necessary positions for responding to a multiunit event. <li>Add guidance to the emergency plan that documents how to perform a multiunit dose assessment (including releases from spent fuel pools) using the licensee's site-specific dose assessment software and approach.<li>Conduct periodic training and exercises for multiunit and prolonged SBO scenarios. Practice (simulate) the identification and acquisition of offsite resources, to the extent possible.<li>Ensure that EP equipment and facilities are sufficient for dealing with multiunit and prolonged SBO scenarios. <li>Provide a means to power communications equipment needed to communicate onsite (e.g., radios for response teams and between facilities) and offsite (e.g., cellular telephones, satellite telephones) during a prolonged SBO.<li>Maintain ERDS capability throughout the accident.[p.57]</ul>
  • nuc_11081201l.pdf 9.4 Order licensees to complete the ERDS modernization initiative by June 2012 to ensure multiunit site monitoring capability.[p.57]<br><br><b>10 CFR 2.802 Rulemaking Petitions</b>
  • nuc_11081201m.pdf 2.2 Petition for Rulemaking to require licensees to confirm seismic hazards every 10 years and address any new and significant information
  • nuc_11081201n.pdf 4.1 Petition for Rulemaking to revise 10 CFR §50.63
  • nuc_11081201o.pdf 7.75 Petition for Rulemaking to require licensees to improve spent nuclear fuel pool safety
  • nuc_11081201p.pdf 8.4 Petition for Rulemaking to require realistic training on Severe Accident Mitigation Guidelines
  • nuc_11081201q.pdf 9.1 Petition for Rulemaking to require emergency preparedness (EP) for multiunit events
  • nuc_11081201r.pdf 9.2 Petition for Rulemaking to require emergency preparedness (EP) enhancements for prolonged station blackouts

NRDC et al letter to Nuclear Regulatory Commission RE: the NRC's response to the Fukushima disaster

This letter to Commissioners Ostendorff, Magwood, and Svinicki of the Nuclear Regulatory Commission about the NRC's response to the Fukushima disaster was sent May 9, 2011 and signed by the Natural Resources Defense Council, Physicians for Social Responsibility, Public Citizen, Nuclear Information and Resource Service, Project on Governmetn Oversight, Riverkeeper, Inc., and Pilgrim Watch.

Who Ensures that a Nuclear Agency is Actually Carrying Out its Mission to Protect the Public

This is a summary of a presentation by Christopher E. Paine made at the International Workshop on Nuclear Energy Safety: Improving Safety in the Aftermath of the Fukushima Crisis, Beijing, China, June 29-30, 2011.

The Fukushima Nuclear Disaster Implications for Nuclear Power Safety [in China]

This presentation was made by Thomas B. Cochran and Matthew G. McKinzie at the International Workshop on Nuclear Energy Safety: Improving Safety in the Aftermath of the Fukushima Crisis, Beijing, China, June 29-30, 2011

The collective effective dose resulting from radiation emitted during the first weeks of the Fukushima Daiichi Nuclear Accident

This study prepared by Matthew McKinzie, Ph.D. and Thomas B. Cochran, Ph.D., April 10, 2011, was submitted as an attachment with Dr. Cochran’s written statement to the Joint Hearings of the Subcommittee on Clean Air and Nuclear Safety and the Committee on Environment and Public Works, April 12, 2011.

Letter from NRDC President Frances Beinecke to President Barack Obama Following the Nuclear Crisis at the Fukushima Nuclear Plant in Japan

Letter from NRDC President Frances Beinecke to President Barack Obama following the nuclear crisis at the Fukushima nuclear plant in Japan. On behalf of NRDC's members, Frances Beinecke strongly endorses President Obama's call for a comprehensive review of nuclear reactor safety in the United States, and further calls on President Obama to add an independent review of key safety issues for nuclear power plants to reduce the chance of a nuclear incident occurring in this country.

A letter sent on March 8, 2011 from NRDC to the U.S. Nuclear Regulatory Commission.

Comments submitted by the NRDC on the American Physical Society’s (APS) Petition to the NRC to require a proliferation analysis during the licensing process.

Waste Confidence Petition for Review

On February 17, 2011, NRDC filed a petition for review with the United States Court of Appeals for the DC Circuit challenging the Nuclear Regulatory Commission's "Waste Confidence" and "Temporary Storage Rules."

An Alternative LMFBR Program (as revised)

Thomas B. Cochran, "An Alternative LMFBR Program (as revised)," (Washington, DC: Natural Resources Defense Council, February 28, 1977).

The Black Sea Experiment

Thomas B. Cochran presented this paper at "From Reykjavik to New START: Science and Diplomacy for Nuclear Security in the 21st Century," an event sponsored by the National Academy of Sciences Committee on International Security and Arms Control and the U.S. Institute of Peace Center for Innovation for Science, Diplomacy, and Peacebuilding, Washington, DC, January 19, 2011.

Nuclear Program Director Christopher Paine's comments to the National Academy of Sciences (NAS) regarding Inertial Fusion Energy (IFE) systems

Nuclear Program Director Christopher Paine recently participated in the public comment process of the National Academy of Sciences (NAS) committee system – a process NRDC litigation helped create in 1997 – regarding:

(1) The composition and charge of a new NAS committee to review scientific and technical prospects for development of Inertial Fusion Energy (IFE) systems [document submitted December 8, 2010] and

(2) The record of previous NAS attempts to evaluate the National Nuclear Security Administration’s ongoing and very costly attempt to demonstrate “lab-scale” fusion ignition in a facility the size of three football fields – the $5 billion plus National Ignition Facility (NIF) [in person testimony, Washington, D.C., December 16].

  • nuc_11010602a.pdf Comments of Christopher Paine, Nuclear Program Director, Natural Resources Defense Council, regarding National Academy of Sciences Review Committee PIN: DEPS-BPA-10-03, "Prospects for Inertial Confinement Fusion Energy Systems," and its provisional membership
  • nuc_11010602b.pdf Public Comments of Christopher E. Paine Nuclear Program Director, Natural Resources Defense Council To the First Meeting of the Provisional NAS Committee on "Prospects for Inertial Confinement Fusion Energy Systems"

Independent Laser Fusion Expert Reviews Status of National Ignition Facility (NIF)

At the request of NRDC, Dr. Stephen Bodner, former head of the laser fusion program at the U.S. Naval Research Laboratory, reviews the scientific and technical obstacles that still confront the $5 billion plus effort to ignite fusion fuel using a massive laser assembled over the last 13 years to support the US nuclear weapons program. 

In an accompanying document titled "Background on the NIF Controversy and Inertial Confinement Fusion", Nuclear Program Director Christopher Paine provides some essential technical and historical background on the Department of Energy’s massive ignition laser, and NRDC's longstanding opposition to the false pretenses under which the facility was sold to Congress and pushed prematurely into construction.

  • nuc_11010601a.pdf An Assessment of the National Ignition Facility, by Dr. Stephen E. Bodner
  • nuc_11010601b.pdf Background on the NIF Controversy and Inertial Confinement Fusion

Uranium Mining in Virginia: Opening the Door to a Host of Problems

A presentation by Geoffrey H. Fettus before the Committee on Uranium Mining in Virginia, National Academy of Sciences, Washington, DC, November 16, 2010.

Sustainable Development and Energy Options

Presentation on nuclear power and other types of energy by Dean Abrahamson, NRDC Trustee and Professor Emeritus  of Public Affairs and Planning at the University of Minnesota, October, 2010.

Statement before the Department of Energy’s Blue Ribbon Commission on America’s Nuclear Future

Statement by Christopher Paine before the Department of Energy’s Blue Ribbon Commission on America’s Nuclear Future on October 12, 2010 analyzing the economics of the nuclear fuel cycle as well as its environmental, social, and geopolitical effects

Comments submitted by the NRDC on the Draft Environmental Impact Statement for the Proposed GE-Hitachi Global Laser Enrichment LLC Facility in Wilmington, NC.

A letter sent August 18, 2010 from NRDC to the U.S. Nuclear Regulatory Commission.

Comments submitted by the NRDC to the National Academy of Sciences on the balance and composition of the Provisional Committee for the Study of Uranium Mining in Virginia.

Letter sent August 18, 2010 from NRDC to Dr. David Feary.

Statement Before the Department of Energy's Blue Ribbon Commission on America's Nuclear Future, Washington, DC, May 25, 2010

Statement by Thomas B. Cochran before the Department of Energy's Blue Ribbon Commission on May 25, 2010 on how the nation should proceed in managing and disposing of spent nuclear fuel (SNF) and radioactive high level waste (HLW).

From Counterforce to Minimal Deterrence: A New Nuclear Policy on the Path Toward Eliminating Nuclear Weapons

Robert S. Norris, Hans M. Kristensen, and Ivan Oelrich, From Counterforce to Minimal Deterrence: A New Nuclear Policy on the Path Toward Eliminating Nuclear Weapons, Occasional Paper No. 7 (Washington, DC: Federation of American Scientists/Natural Resources Defense Council, April 2009)

NRDC Takes the Nonproliferation Campaign to Moscow

Presentation delivered by Christopher Paine, NRDC Nuclear Program Director, on ratification of the Comprehensive Nuclear Test Ban Treaty (CTBT), and Thomas Cochran, Nuclear Program Senior Scientist, on preventing the weaponization of uranium enrichment programs around the world. Presentations delivered at the 2010 Moscow Nonproliferation Conference, held from March 4-6.

  • nuc_10040801a.pdf Christopher Paine on ratification of the Comprehensive Nuclear Test Ban Treaty (CTBT)
  • nuc_10040801b.pdf Thomas Cochran on preventing the weaponization of uranium enrichment programs around the world

"Environmental, Safety, and Economic Implications of Nuclear Power," a paper delivered at the California Energy Commission’s (CEC) Energy Report

Thomas B. Cochran, “Environmental, Safety, and Economic Implications of Nuclear Power,” a paper delivered at the California Energy Commission’s (CEC) Energy Report: Nuclear Power, 2007 Workshops, Sacramento, CA, June 28, 2007.

Presentation: Economics of Plutonium Recycle

A presentation delivered on December 11, 2009 at Johns Hopkins University by Thomas B. Cochran, Ph.D., Senior Scientist at the Natural Resources Defense Council, arguing against reprocessing spent uranium and plutonium, and instead continuing the current open fuel cycle system in the United States.

Review of the book "Inventing Los Alamos: The Growth of an Atomic Community"

Robert S. Norris reviewed the book, “Inventing Los Alamos: The Growth of an Atomic Community,” by Jon Hunner in the Journal of Cold War Studies, Volume 11, No. 4 (200): pp. 149-151.

International Regulation of Uranium Fuel Cycle Facilities

In this draft discussion paper NRDC proposes a major new supplement to current IAEA safeguards requirements for uranium enrichment (and later other nuclear fuel cycle activities) in order to strengthening international controls over the nuclear fuel facilities.

International Management of Uranium Enrichment

A paper by Thomas B. Cochran and Christopher E. Paine to be presented at the International Meeting onNuclear Energy and Proliferation in the Middle East, Amman, Jordan, June 22-24, 2009.

Comments of Thomas B. Cochran to questions from the Committee on Energy and Natural Resources

Comments of Thomas B. Cochran to questions from the Committee on Energy and Natural Resources "Questions for the Record", United States Senate, Washington, DC, Re: "Nuclear Energy Developments" Washington, DC, March 18, 2009.

Transforming the U.S. Strategic Posture and Weapons Complex for Transition to a Nuclear Weapons-Free World

NRDC is a member of the Nuclear Weapons Complex Consolidation Policy (NWCC) Network, a collaboration of six national and regional groups. This NWCC study provides the roadmap for a large and swift reduction in the nation's nuclear weapons and the sprawling government complex that develops and produces them. The study outlines the case for a tenfold reduction in the nation's active nuclear weapons stockpile, to 500 deployed nuclear warheads by 2015, supported by a weapons complex reduced from the current eight sites in seven states to just three sites in two states, Texas and New Mexico.

A Manhattan Project for Climate Change?

A presentation to the National Academies' Committee on Science, Engineering and Public Policy (COSEPUP) by Robert S. Norris, September 5, 2008.

Complaint Filed Against a Nuclear Weapons Production Facility in Kansas City, Missouri

Complaint filed by a coalition of environmental and peace organizations asked a federal court in Washington, D.C. to set aside plans for a new nuclear weapons plant and direct the agencies to prepare a new environmental analysis of site-cleanup and relocation alternatives for the existing Kansas City Plant (KCP).The lawsuit was filed in response to a joint refusal by the General Services Administration (GSA) and the Department of Energy's National Nuclear Security Administration (NNSA) to consider the significant environmental impacts of moving a critical nuclear weapon production facility to a new location.

Statement of Thomas B. Cochran, Senior Scientist, on The Utility of Advanced Spectroscopic Portal Monitors for Interdicting WMD

Statement before the Committee on Homeland Security and Governmental Affairs, United States Senate Washington, D.C., September 25, 2008.

Statement on the Environmental, Safety and Economic Implications of Nuclear Power and Its Role in Mitigating Climate Change

Statement of Thomas B. Cochran, Senior Scientist, NRDC's Nuclear Program before the Energy and Environment Committee of the Science and Technology Committee of the House of Representatives, April 23, 2008.

NRDC's Petition for Rulemaking to Ban Future Civil Use of Highly Enriched Uranium

NRDC has filed a petition with the U.S. Nuclear Regulatory Commission (NRC) to establish a date after which it would stop licensing or authorizing the export of highly enriched uranium for civil purposes.

Toward True Security

Ten steps the next president should take to transform U.S. nuclear weapons policy.

A Nontechnical Guide to Groundwater Modeling With Specific Reference to the U.S. Department of Energy's Hanford Site

A  report addressing groundwater modeling in the U.S. Department of Energy's nuclear weapons complex that will permit community organizations to more effectively oversee and understand DOE environmental cleanup actions.

NRDC Comments on the Scope of the National Nuclear Security Administration's Complex 2030 Supplemental Programmatic Environmental Impact Statement

Letter to the U.S. Department of Energy, January 17, 2007.

NRDC Comments on the Energy Department's Notice of Intent to Prepare a Programmatic Environmental Impact Statement for the Global Nuclear Energy Partnership

Letter to the Office of Nuclear Energy, Science and Technology, April 11, 2007.

Letter from NRDC Regarding a NNSA-GSA Proposal for a New Kansas City Plant

Letter to NNSA regarding its plans to construct a new facility for non-nuclear component procurement and manufacturing operations in Missouri which violates NEPA, May 21, 2007.

NRDC Comments on Dominion Power's Request to Construct Two New Reactors at Its North Anna, VA Nuclear Power Plant

Letter to Mr. Jack Cushing, Environmental Project Manager for North Anna ESP Site Application, U.S. Nuclear Regulatory Commission, September 8, 2006.

Reissuance of VPDES Permit VA0052451 North Anna Power Station Units 1 and 2

Comments of Christopher Paine, NRDC Nuclear Program Director, on the reissuance of VPDES permit VA0052451 North Anna Power Station Units 1 and 2, July 18, 2007.

NRDC Nuclear Program Response to April 19, 2007 Recommendations of the National Commission on Energy Policy on Nuclear Power

NCEP's recommendations would put the public's health and safety at risk by suggesting that Congress undermine existing standards for disposal of highly toxic nuclear waste.

What is the Size of Khushab II?

Analysis regarding new nuclear reactor Pakistan is constructing to produce plutonium for weapons.

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