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Union of Concerned Scientists Comments on the Energy Department’s Draft Global Nuclear Energy Partnership Programmatic Environmental Impact Statement

The Union of Concerned Scientists (UCS) opposes the Department of Energy's preference, as stated in the GNEP DPEIS, to "close the nuclear fuel cycle," that is, to change the U.S. strategy for disposal of commercial spent nuclear fuel from direct emplacement in a geologic repository to reprocessing and separation of fissile materials for fabrication into new reactor fuel. UCS opposes spent fuel reprocessing for reasons of security, safety and cost, as expressed in detail in its comments on the scope of the GNEP DPEIS and other publications, including the 2007 report Nuclear Power in a Warming World (NPWW), which is described and referenced in Chapter 1 of the DPEIS.

A review of the GNEP DPEIS indicates that the document provides no new or compelling data or analysis to support DOE's "preference" for closing the fuel cycle. The technical analysis is of extremely poor quality and is riddled with unsupported assumptions, misleading comparisons and major omissions. The fact that DOE expresses its preference without selecting a specific strategy for closing the fuel cycle makes it appear that this process is fully in sync with DOE's standard "decide, announce, defend" mode. DOE is not in a position to express a preference for the closed fuel cycle unless it can point to a scenario that clearly demonstrates that its goals can be met and that effectively responds to the technical arguments against such a preference.

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