When you think about who is going to be hit the hardest by pollution, whether it’s conventional air water and soil pollution or climate change, it is very often low-income communities and communities of color. The undercutting of these kinds of protections is going to have a disproportionate impact on these very same communities.
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Department of Energy and Related Commissions
frustrating is that these costs to a large extent are due to the agencies being overly prescriptive rather than outcomes-focused and fall on well-known and understood LWR reactor technologies.
New Policies
While refocusing its regulatory efforts on new reactor technologies, the NRC should also continue to ensure the security of radiological sources and mitigate cybersecurity risks across the industry. Applications for Combined Operating Licenses (COLs) and design certifications that rely on light-water technology should generally be completed within two years. Early Site Permits should generally be issued within one year for construction on or adjacent to an existing reactor site. Additionally, the NRC should:
• Expedite the review and approval of license extensions of existing reactors, which will require the NRC to streamline and focus its NEPA review process.
• Set clear radiation exposure and protection standards by eliminating ALARA (“as low as reasonably achievable”) as a regulatory principle and setting clear standards according to radiological risk and dose rather than arbitrary objectives.
• Work with Congress to reform its funding approach so that licensee fees are generally required for activities that are specific toa regulated entity, with other agency costs being provided through normal appropriations.
Budget
In FY 2022, the NRC was required to recover approximately 85 percent of its $887.7 million budget through licensee fees.** The Nuclear Energy Innovation and Modernization Act requires the NRC to recover nearly all of its costs through fees. These reforms would likely not cost additional money but could rebalance the fee-versus-appropriations calculation.
AUTHOR’S NOTE: The preparation of this chapter was the work of many individuals. All contributors to this chapter are listed at the front of this volume, but | wish to give special thanks to Brent Bennett, Willis Bixby, Travis Fisher, Ben Lieberman, Brian McCormack, Tom Pyle, Mark Robeck, Daniel Simmons, Jack Spencer, Katie Tubb, and David Walsh. Though informed by many, the author alone assumes responsibility for the content of this chapter, and no views expressed herein should be attributed to any particular individual.