Recently, we asked our supporters to send comments to the Nuclear Regulatory Commission (NRC) in order to prevent a very bad decision, with serious implications for environmental and climate justice. The NRC is proposing to create regulatory shortcuts for building what it labels small-scale “advanced” nuclear reactors (ANRs) – including issuing a generic environmental impact statement.
There are several reasons why this is a terrible idea. Among other things, the NRC has no experience regulating so-called “advanced” nuclear reactors. There have been no non-light-water reactors in operation in the U.S. since the 1980s. Only three were ever built, two of which were built in the 1960s—before the NRC was even created. In other words, the NRC shouldn’t give an easy environmental pass to reactors it doesn’t have experience regulating. The NRC’s lack of experience in regulating such a wide variety of possible reactor designs requires rigorous study and experience.
There are also dozens of potential types of such reactors, which makes creating a generic environmental impact statement about them nothing less than fiction. There is no such thing as a “generic” ANR, so there shouldn’t be a generic environmental impact statement to cover them all. Shortcutting the regulatory process is a recipe for nuclear safety problems that simply can’t be allowed.
Another important reason ties deeply with the recent protests we’ve seen against police violence and institutionalized racism: Small-scale ANRs will have significant environmental justice impacts. At every stage of the nuclear fuel cycle, polluting facilities and activities have been located disproportionately on indigenous peoples’ lands and in African American, Latinx, and other communities of color. There is no reason to expect that to change with ANRs.
But perhaps the most important reason to deny a generic environmental impact statement to ANRs is their impact on climate change—or rather, their lack of impact. The nuclear industry and their allies have spent considerable time and effort painting nuclear power as an emissions-free energy source. This is simply not true. The fact is that, when you take into consideration the entire fuel chain, nuclear energy is a net producer of greenhouse gases.
As a “low-carbon” energy source, nuclear is falling far behind other sources of energy, including renewables. That’s not us saying this: The relatively pro-nuclear International Energy Agency (IEA) says that nuclear is not on track for meeting its share of decarbonization under the IEA’s Sustainable Development Scenario. Even light water small modular reactors (SMRs), much touted by the industry and their allies, look much less promising on closer examination. As a relatively pro-nuclear team of researchers from Carnegie Mellon University concluded in a 2018 paper in the Proceedings of the National Academy of Sciences:
Because light water SMRs incur both this economic premium and the considerable regulatory burden associated with any nuclear reactor, we do not see a clear path forward for the United States to deploy sufficient numbers of SMRs in the electric power sector to make a significant contribution to greenhouse gas mitigation by the middle of this century.
In short, nuclear energy, whether it’s produced with old-fashioned light-water reactors or with newer ANRs, is no solution to our climate crisis. It costs too much and takes too long to scale up in order to meet our need to rapidly decarbonize the economy. The money that is being wasted propping up an unsustainable and polluting industry could be put to better use by investing in renewable energy and efficiency. It’s what the American people want, after all. The NRC should remember that its job is to protect the public’s health and safety, not pushing the interests of the nuclear industry, and apply the same review standards to ANRs that it would to any other kind of reactor. After all, if nuclear reactors can’t pass a thorough and rigorous safety review, then they shouldn’t be built to begin with.