Expert witness declaration by Robert Alvarez in the WCS/ISP CISF proceeding

Robert Alvarez, Associate Fellow at the Institute for Policy Studies, Adjunct Professor at Johns Hopkins University, and former senior policy adviser to the Secretary of Energy and deputy assistant secretary for national security and the environment at the U.S. Department of Energy from 1993 to 1999, prepared an expert witness declaration on behalf of a seven-group grassroots environmental coalition opposing the Waste Control Specialists/Interim Storage Partners centralized interim storage facility for 40,000 metric tons of commercial irradiated nuclear fuel targeted at Andrews County, Texas. The expert witness declaration is entitled "Comments on the Application for a License for a Consolidated Interim Spent Fuel Storage Facility by Waste Control Specialists LLC (Docket No. 72-1050)," which includes the following subject matter: Failure to Accurately Address Life-Cycle Costs; High Burnup Spent Nuclear Fuel; and Repackaging for Disposal.

Terry Lodge, Toledo-based counsel for the environmental coalition, filed this expert witness declaration on Nov. 13, 2018, as part of the overall legal intervention.