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The NRC’s Generic Environmental Impact Statement & What We Can Do About It

The NRC’s Generic Environmental Impact Statement & What We Can Do About It. Why is the NRC proposing a “Generic” EIS?. NRC anticipates 20-30 new ISL projects or ISL re-starts in the next few years NRC does not have the staff to do comprehensive site-specific reviews

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The NRC’s Generic Environmental Impact Statement & What We Can Do About It

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  1. The NRC’s Generic Environmental Impact Statement & What We Can Do About It

  2. Why is the NRC proposing a “Generic” EIS? • NRC anticipates 20-30 new ISL projects or ISL re-starts in the next few years • NRC does not have the staff to do comprehensive site-specific reviews • Companies are pressuring NRC to speed up the process •  NRC wants to streamline NEPA process through a “common” document http://www.nrc.gov/materials/fuel-cycle-fac/licensing/geis.html

  3. http://www.nrc.gov/info-finder/materials/uranium/

  4. Important Dates for GEIS • NOI for GEIS published July 24, 2007 • Scoping period extended until Nov. 30 • 3 public meetings held in entire area • Draft released July 28, 2008 • Public comment period ends Oct. 7 • Scoping meetings held in eastern Wyo, NM, NE and SD (none in Western Wyo) • Final anticipated June 2009 • Gov Dave wants Jan 2009

  5. Geographic Areas Covered by GEIS • Eastern Wyoming: Powder River Basin • Western Wyoming: Gas Hills Uranium District, Northern Sweetwater County • Black Hills projects: far NE Wyoming (Crook and Weston Counties), South Dakota, Nebraska (including Crow Buttes) • New Mexico: west central, including some tribal lands

  6. Geographic Areas Not included • Agreement States: Colorado, Utah, Texas • Areas where strip mines or other non-NRC licensed uranium projects will occur • Areas where companies have not expressed interest in applying for a license (e.g. early exploratory projects)

  7. Broad Problems with GEIS • What is really “common” about ISL? • No analysis of cumulative impacts of either the programmatic decision or individual projects • No discussion of past actions that could increase impacts (e.g. past mines) • No (or very little) tribal consultation • No real agency-to-agency consultation • Potential to limit site-specific analysis and public involvement

  8. More Problems with GEIS • Insufficient and inaccurate information in a whole host of issues – water, air, land, socio-economics • No real mention of past history of company compliance (or lack thereof) and NRC’s ability to monitor and enforce • No enforceable mitigation measures • No mention of ISL rulemaking

  9. Other Concerns with NRC’s NEPA process • Parsing off of impacts by stage of the project: construction, operation, restoration • Categorization of impacts: “small” “moderate” “large”  what is significant? • Arbitrary determinations of significance • Forgone conclusion that site-specific documents will be EAs • No alternatives analysis

  10. So what can we do about it? • Organize, organize, organize! • Local opposition is critical • Local media exposure is critical • Coalition-building • Regional cooperation & information-sharing • Legal challenges • Congressional oversight? Opposition from governors and state legislators?

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