Additional sample talking points you can use to write your own public comments

[See Beyond Nuclear's comments, as submitted to DOE on 1/23/17, in .doc format (with functional URLs embedded) and in .pdf format (embedded URLs do not work).]

Additional sample talking points you can use to write your own public comments:

1. As Tom "Smitty" Smith of Public Citizen's Texas office has said, "Texans do not consent to the risky plan to store high-level radioactive waste at private sites on an open pad above ground in Texas. Another company near Hobbs, New Mexico -- less than 50 miles away -- is expected to file an application to open a storage site that would accept the rest of the nation's high-level nuclear waste. These twin 'storage sites' likely would create a de facto high-level national waste sacrifice zone. This proposal invites disaster because the private owners will be cutting costs at every turn to maximize profits. If there was radioactive contamination our land, air, water, and human health could be harmed for millennia." (emphasis added; see press release here)

2. Private permanent parking lot dumps are high-risk, not only radiologically but also to U.S. taxpayers' pocketboots. As Kevin Kamps of Beyond Nuclear has said: "By requiring a permanent deep geological repository to be operating before centralized interim storage [whether private or federal government owned/operated], Congress wanted to prevent the very real danger of a de facto permanent parking lot dump -- a high-level radioactive waste storage site that would be designed for the short-term but be there forever. WCS, for example, is a cynical shell game and taxpayers are sure to lose. Congress was right that liability for the costs for storing commercial irradiated nuclear fuel belong with the generators and should not be shifted onto the backs of the American public." (see press release)

3. Regarding the transportation costs and risks of centralized interim storage (whether private or federal government owned/operated):

As Diane D'Arrigo, radioactive waste project director at Nuclear Information and Resource Service, has said, "Moving irradiated nuclear fuel over roads, rails, and waterways to a supposedly temporary site puts us all at risk and creates only the illusion of a solution."

And as Karen Hadden, executive director of the Texas-based SEED (Sustainable Energy & Economic Development) Coalition, has said, "Due to risks of radioactive contamination from leaks or accidents or potential terrorist actions, nuclear waste should only be moved once, and only when a deep underground permanent repository is in place that could safely isolate the dangerous waste for the million years [see immediately below] that it will remain hazardous." (see the press release)

In fact, a coalition of environmental groups, including NRDC, NIRS, Nevada Nuclear Waste Task Force, Citizen Action Coalition of Indiana, and Public Citizen, won a major court victory on July 9, 2004, which ordered EPA back to the drawing board on its proposed Yucca Mountain high-level radioactive waste dump regulatory cut-off at 10,000 years post waste burial. In 2008, EPA's revised regulations acknowledged a one million year hazard associated with irradiated nuclear fuel and high-level radioactive waste. (Truth be told, there are radioactive poisons in high-level radioactive waste that will remain hazardous far longer than even a million years. Iodine-129, as but one example, has a 15.4 million year half-life. This means it will remain hazardous for 157 to 314 million years!)

4. As the lead proposals for centralized interim storage (de facto permanent parking lot dumps) are private initiatives (in fact, there are no proposed federal government owned/operated parking lot dumps), all of the public comments submitted to DOE during its so-called "consent-based siting" public comment period in 2016 still apply. (The lead private initiative is by Waste Control Specialists, LLC in Andrews County, West Texas, followed by the Eddy-Lea [Counties] Energy Alliance in Hobbs, New Mexico (less than 50 miles from WCS); AFCI in Loving County, TX; and Culberson County, TX. Note that not only WCS, but also AFCI, have close connections to Trump's pick for Energy Secretary, former TX governor Rick Perry, representing a blatant conflict of interest and ethical violation.) Comments submitted by environmental, public interest, and other NGOs can and should be submitted again during this current comment period (especially considering the fact that DOE largely to entirely ignored these comments when it issued its draft and final reports on defining "consent-based siting"!). See those comments by the following groups, and use them to write your own: several sets of comprehensive Beyond Nuclear comments, covering various subject matter, including Environmental Justice; Beyond Nuclear's Top 10 List, as well as its more detailed 2-page, and even more detailed 13-page, versions of sample comments;  Alliance for Nuclear Accountability (ANA); Fairewinds Energy Education; Institute for Energy and Environmental Research (IEER); Natural Resources Defense Council (NRDC); Nuclear Information and Resource Service (NIRS); Public Citizen; and a collection of comments from groups such as SEED Coalition, NAWO, Pilgrim Watch, and others.