Beyond Nuclear's comments to DOE on so-called "Consent-Based Siting" or radioactive waste dumps

Environmental coalition members from the Crabshell Alliance, Sierra Club Nuclear-Free Campaign, NIRS, PSR, NEIS, and Public Citizen "just say NO!" at the NRC HQ nuke waste con game public comment meeting on 11/14/13 in Rockville, MD. Photo credit David Martin and Erica Grey.Beyond Nuclear submitted six sets of comments to the U.S. Department of Energy (DOE), by the July 31st deadline, re: "Consent-Based Siting" for so-called "centralized interim storage sites" (de facto permanent parking lot dumps), as well as permanent burial dumps (such as long targeted at Yucca Mountain, Nevada), for high-level radioactive waste/irradiated nuclear fuel.

The first set comprised Beyond Nuclear's "Top Ten List" of "We Do NOT Consent!" talking points.

The second set comprised Beyond Nuclear's two-page version of the "We Do NOT Consent!" talking points, providing more detail.

The third set comprised Beyond Nuclear's 13-page version of the "We Do NOT Consent!" talking points, providing yet more detail.

The fourth set, a 10-page document, protested the very illegitimacy of the DOE's entire "Consent-Based Siting" defintion-setting proceeding. Specifically, the Blue Ribbon Commission on America's Nuclear Future (which, ironically enough, Energy Secretary Moniz was a commission member of, and several DOE officials in charge of "Consent-Based Siting" were lead staff members of) highly recommended that DOE no longer remain in charge of irradiated nuclear fuel management, or policy setting. This was due to the countless failures, and betrayals of the public's trust, over many years and even decades, perpetrated by DOE. And yet, DOE initiated and conducted the "Consent-Based Siting" proceeding, and appears determined to simply continue on, setting high-level radioactive waste management policies, despite the Blue Ribbon Commission's strong recommendation to the contrary.

The fifth set, a 10-page document, is entitled STOP RADIOACTIVE RACISM! It chronicles decades of DOE, U.S. Nuclear Regulatory Commission (NRC), and nuclear power industry attemps to dump high-level radioactive waste on Native American reservations, lands, and communities across the U.S. It protests DOE's ongoing environmental injustice, even during this so-called "Consent-Based Siting" proceeding. But one example is DOE's decision to invite the infamous DOE Nuclear Waste Negotiator from the 1980s to 1990s, David Leroy, to participate on the panel at the Boise, Idaho public meeting. Two attachments accompanied this set of comments: President Barack Obama's March 2009 Women's History Month proclamation, honoring Grace Thorpe for blocking radioactive waste dumps targeted at Native American communities; and "Radioactive Racism: The History of Targeting Native American Communities with High-Level Atomic Waste Dumps," a six-page, fully referenced backgrounder prepared by NIRS and Public Citizen on June 14, 2005.

The sixth set comprised the submission of two documents for the record. Both documents came out of the same event, Citizen Awareness Network's (CAN) "People's Summit on High-Level Radioactive Waste," held at Wesleyan University in Middletown, CT from April 12-14, 2002. The first document, entitled "Indigenous Anti-Nuclear Statement: Yucca Mountain and Private Fuel Storage at Skull Valley," was prepared for the event. The second document, "Principles for Safeguarding Nuclear Waste at Reactors," although promulgated in September 2006 (and later updated in March 2010), nonetheless had its origins at this same 2002 CAN event. Dr. Arjun Makhijani of IEER coined the phrase "Hardened On-Site Storage" (HOSS) at the 2002 event; the 2006 Principles (updated in 2010) hammered out, in writing, the HOSS principles, which have since been endorsed by hundreds of environmental organizations, representing all 50 states.

In addition to the written submissions above, Beyond Nuclear attended multiple DOE "Consent-Based Siting" meetings across the country, and provided additional verbal comments there.

Beyond Nuclear attended DOE's Jan. 20th "Kick-Off" meeting in Washington, D.C., firing off numerous questions there (incredibly enough, and very tellingly, DOE did not provide an oral public comment opportunity at this "Kick-Off" meeting for a seven month long public comment proceeding!).

Beyond Nuclear also attended DOE's March 29th meeting in Chicago, as reported by Kari Lydersen in Midwest Energy News.

(See comprehensive coverage, in multiple Beyond Nuclear website posts, about the Chicago meeting at the Radioactive Waste section, between the dates March 18 and March 31, 2016.)

And Beyond Nuclear also attended DOE's meeting in Boston, MA, on June 2nd, as reported by Amy Goodman on Democracy Now!. There, Beyond Nuclear pointed out that it is disingenuous that the U.S. federal government and nuclear industry are now seeking public consent to dispose of high-level radioactive waste, when they never sought consent for the generation of nuclear waste in any of the operational licensing and license extension proceedings.

In fact, when the DOE was conducting its aborted 1986 crystalline rock repository search in New England, 130 town meetings in New Hampshire took up the issue in warrant articles.  Of those town meetings in the Granite State, 100 town meetings adopted the common language "to oppose the burial, storage, transportation and production of high-level nuclear waste" in the state of New Hampshire. (New Hampshire was targeted for a national high-level radioactive waste dumpsite -- seven historic towns faced extinction, as documented in this 2007 Beyond Nuclear backgrounder.)