Beyond Nuclear’s Top Ten List for Comments to DOE re: Irradiated Nuclear Fuel (High-Level Radioactive Waste)

1. Stop making it. The only truly safe, sound, just solution for the radioactive waste problem, is to not make it in the first place. Electricity can be supplied by clean, safe, affordable renewable sources, such as wind and solar, and demand decreased significantly by efficiency, rather than generating radioactive waste via dirty, dangerous, and expensive nuclear power.
2. Expedite the transfer of irradiated nuclear fuel from densely-packed “wet” storage pools into Hardened On-Site Storage (HOSS) dry casks.
3. Store irradiated nuclear fuel in HOSS dry casks, as safely and securely as possible, as close to the point of generation as possible, in a monitored, inspectable, retrievable manner.
4. Given the unavoidable risks of high-level radioactive waste truck, train, and/or barge shipments on roads, rails, and/or waterways (Mobile Chernobyls, Dirty Bombs on Wheels, Floating Fukushimas), transport irradiated nuclear fuel only once, such as straight to a (suitable, acceptable, just) geological repository, not to so-called centralized interim storage (de facto permanent parking lot dumps, such as those currently targeted at Waste Control Specialists, LLC in Andrews County, west Texas; at Eddy-Lea Counties, near the Waste Isolation Pilot Plant in southeast New Mexico; Native American reservations; nuclear power plants, such as Exelon's Dresden in Morris, IL; etc.).
5. Geological repositories must be scientifically suitable (capable of isolating the hazardous high-level radioactive waste from the living environment forevermore), socially acceptable (genuinely consent-based), and environmentally just. Note that no such suitable/acceptable/just geologic repository has yet been found, in more than half a century of looking. DOE has admitted it can’t open any repository (even an unsuitable/unacceptable/unjust one) till 2048 at the earliest, more than a century after Enrico Fermi, in 1942, generated the first high-level radioactive waste, in the world’s first reactor, as part of the Manhattan Project to build atomic bombs; and more than 90 years years after the first “civilian” atomic reactor began generating waste at Shippingport, PA.
6. Do not reprocess (extract fissile plutonium and/or uranium from) irradiated nuclear fuel. Not only would this risk nuclear weapons proliferation, and be astronomically expensive; it would also very likely cause environmental ruin downwind and downstream of wherever it is carried out, as has been shown at such places as Hanford Nuclear Reservation in Washington; Savannah River Site, South Carolina; West Valley, New York; Sellafield, England; La Hague, France; Kyshtym, Russia; etc.
7. Preserve and maintain “wet” storage pools – albeit emptied of irradiated nuclear fuel -- as an emergency back up location for cask-to-cask HOSS transfers, when old HOSS casks deteriorate toward failure, and need to be replaced with brand new HOSS casks. That is, do not dismantle pools as part of nuclear power plant decommissioning post-reactor shutdown.
8. Carefully pass information about storing irradiated nuclear fuel as safely as possible, as close to the point of generation as possible, from one generation to the next, à la the concept of “Rolling Stewardship” described by the Canadian Coalition for Nuclear Responsibility.
9. Address the shortfall in funding for forevermore storage of high-level radioactive waste. Dr. Mark Cooper of Vermont Law School has estimated the first 200 years of commercial irradiated nuclear fuel storage (assuming just a single repository, although at least two will be required!) will cost $210 to $350 billion, even though there is only some tens of billions of dollars remaining in the now-terminated Nuclear Waste Fund, collected from nuclear power ratepayers.
10. Environmental justice, in keeping with Bill Clinton's 1994 Executive Order 12898, demands that Native American communities and lands, as well as those of other low income and/or people of color communities, never again be targeted for high-level radioactive waste parking lot dumps or permanent burial sites, a shameful form of radioactive racism dating back decades in the U.S.
    

Speak now (before the July 31 deadline for public comments), or forever hold your peace, regarding Mobile Chernobyls through a town near you...de facto permanent parking lot dumps for high-level radioactive waste...and permanent burial dumps for high-level radioactive waste on scientifically unsuitable, socially unacceptable, and/or environmentally unjust (radioactively racist) locations!

Also see Beyond Nuclear's two-page and 13-page versions of the "We Do NOT Consent!" talking points, for more detail.

SAMPLE COMMENTS TO DOE ON "CONSENT" for 11:59pm Eastern, Sunday, July 31st public comment deadline

Mary Olson, Director of NIRS Southeast Office, has compiled this collection of sample comments you can use to write your own, for submission to the U.S. Department of Energy (DOE) by its 11:59pm Eastern deadline for public comments regarding so-called "Consent-Based Siting" of centralized interim storage (de facto permanent parking lot dumps), permanent burial sites, and the Mobile Chernobyl truck, train, barge shipments on the roads, rails, and waterways through most states it would take to move the waste there:

Joel Masser shared the following two ideas:

---consent must be defined in terms of a fully informed electorate and a vote of the people;

---siting must ensure environmental justice by complying with Executive Order 12898 and
the Department of Energy's own formal environmental justice policy.

The SEED Coalition in Texas (the Sustainable Energy and Economic Development Coalition, a lead group fighting the parking lot dump targeted at Waste Control Specialists, LLC in Andrews County, West Texas, on the New Mexico border) prepared the following comments, viewable here at this link.

The North American Water Office (long-time watchdogs on Minnesota's atomic reactors, and on-site radioactive waste storage, at Monticello and Prairie Island) submitted these comments to DOE after the meeting in Minneapolis.

Pilgrim Watch in Massachusetts prepared these comments for the meeting in Boston.

Two sets of sample comments, not attributed to a particular author, are posted here: set #1; set #2.

In addition to Mary Olson at NIRS's compilation, the following comments have been circulated by their authors, to help others prepare their own comments by the deadline:

---Concerned Citizens for Nuclear Safety in Santa Fe, NM, presented these comments to DOE at the "Consent-Based Siting" meeting in Sacramento, CA on April 26th (ironically timed, being the 30th anniversary of the beginning of the Chernobyl nuclear catastrophically);

ANA submits comments to DOE on "Consent-Based Siting" of radioactive waste dumps

The Alliance for Nuclear Accountability (ANA), a network of organizations and leaders seeking a nuclear-free future that safeguards our communities and environment, has filed comments with the U.S. Department of Energy (DOE), regarding its "Consent-Based Siting" proceeding for opening centralized interim storage sites and permanent burial sites for high-level radioactive waste and irradiated nuclear fuel.

Beyond Nuclear has been a member organzation of the ANA network, since Beyond Nuclear was founded in 2007. ANA is a coalition of some three-dozen watchdog groups, many from communities living in the shadows of DOE nuclear weapons complex facilities. Some of those facilities -- such as Waste Isolation Pilot Plant (WIPP) -- are already permanent burial dumps for radioactive wastes (in WIPP's case, plutonium contaminated wastes from the weapons complex).

The WIPP area -- Eddy and Lea counties, New Mexico -- is also being targeted for consolidated interim storage for commercial irradiated nuclear fuel (a.k.a. a de facto permanent parking lot dump). ANA member groups CCNS (Concerned Citzens for Nuclear Safety), Nuclear Watch New Mexico, and SRIC (Southwest Research and Information Center) watch-dog nuclear issues in New Mexico; SRIC has watch-dogged WIPP specifically for decades.

Waste Control Specialists, LLC (WCS) in Andrews County, West Texas, just across the border from New Mexico, is also targeted for a parking lot dump. WCS is already a national dumpsite for a large variety of so-called "low" level radioactive wastes. It is located directly adjacent to, or even above, the Ogallala Aquifer, which provides vital irrigation and drinking water to numerous states on the Great Plains, from Texas to South Dakota. Because of this, several Texas state environmental officials resigned in protest over the original opening of this risky dump.

Numerous other DOE nuclear weapons complex sites may also be on the target list for parking lot dumps, including the Savannah River Site (SRS) in South Carolina. SRS has long "served" as a "long-term" storage site for highly radioactive wastes, some of which are being permanently abandoned in underground storage tanks, which is almost guaranteed to cause radioactive ruin of the Savannah River, and perhaps even the Tuscaloosa Aquifer, over time. A number of ANA member groups watch-dog SRS, including: Georgia WAND (Women's Action for New Directions); Nuclear Watch South; and SRS Watch.

The situation is very similar at Idaho National Lab (INL), putting at dire risk the Snake River, and the Snake River Aquifer. The Snake River Alliance is the ANA member group that has long watch-dogged INL.

HEAL (Healthy Environment Alliance) Utah led -- along with traditional Skull Valley Goshutes tribal members Margene Bullcreek and Sammy Blackbear -- the successful grassroots environmental justice effort to fend off a parking lot dump for commercial high-level radioactive waste, targeted at the tiny Indian reservation west of Salt Lake City, a decade ago.

Yet other ANA member groups have been forced to deal with actual dumping of radioactive wastes, or the attempted dumping of such waste, without their consent. This includes PRESS (Portsmouth/Piketon Residents for Environmental Safety and Security), targeted for a centralized interim storage site and reprocessing facility under the George W. Bush administration's Global Nuclear Energy Partnership a decade ago.

It also includes Oak Ridge Environmental Peace Alliance, central to the effort to fend off a "Monitored Retrievable Storage" (MRS) site for commercial irradiated nuclear fuel in decades past.

It also includes Heart of America Northwest, and Hanford Challenge, which watch-dog the worst radioactively contaminated site in the Western Hemisphere, the Hanford Nuclear (Weapons) Reservation, which "hosts" many millions of gallons of high-level radioactive liquid wastes, in leaking storage tanks.

And still other ANA member groups, such as PSR (Physicians for Social Responsibility) Kansas City, PeaceWorks Kansas City, and Rocky Mountain Peace & Justice Center, given their geographic location along major "Mobile Chernobyl" shipping routes for high-level radioactive waste transports, have played vital roles in calling attention to, and fending off any unnecessary rush into, those risks, for a long time.

This listing, unfortunately, is far from exhaustive.

Public Citizen action alert: Nuclear dump in your community?

After four decades of failing to find a place to dump our nation’s lethal nuclear waste, the federal government is trying a new approach:

Consent.

The U.S. Department of Energy (DOE) is designing a new process called “consent-based siting” for developing nuclear waste facilities that would require a state and local community to agree to stockpile our radioactive waste.

And the DOE is asking the public to weigh in on the process.

That’s right — instead of forcing a radioactive waste facility on a state or community against its will, which is the current U.S. policy, the DOE is attempting to adopt a process that is more adaptive, flexible and open to public input and scrutiny.

Public Citizen has identified 10 principles that the DOE should build into its design to achieve and maintain fair and just consent-based siting.

View our 10 Criteria for Community Consent, then urge the DOE to incorporate them into its design.

We have an obligation to future generations to find a safe, permanent solution for managing nuclear materials they had no part in creating.

However, a community or state should not unwillingly have to bear this responsibility.

That’s why a fundamental change in the government’s approach to public engagement, consultation and consent in managing lethal waste is necessary.

This is an opportunity.

Don’t let the government waste it.

Thank you,

Allison Fisher
Public Citizen’s Climate and Energy Program

Action Alert: Minneapolis, MN DOE "Consent-Based Siting" public meeting, Thurs., July 21st

The U.S. Department of Energy (DOE) will hold its final "Consent-Based Siting" public comment meeting in Minneapolis, MN on Thursday, July 21st. This is the ninth of nine such meetings held across the U.S. this year.

The meetings come in the context of DOE seeking "consent" for rushed centralized interim storage* (de facto permanent parking lot dumps) for high-level radioactive waste, by as early as 2021. It's important we turn folks out, both in person, as well as via the Webcast.

Whether it's the long-targeted Yucca Mountain, Nevada dumpsite, or a parking lot dump, the high-risk Mobile Chernobyl shipments launched, through most states, would be unprecedented in number.

Please see below for sample talking points you can use to prepare your own. Also see DOE's mtg. announcement, as well as backgrounders and maps we've prepared or assembled, re: transport risks, whether by road, rail, and/or waterway. Finally, a backgrounder shedding light on/asking important questions about the risk that Minnesota could be targeted once again, as it was in the 1980s, for a national high-level radioactive waste dumpsite.

Thanks!

---Kevin Kamps, Radioactive Waste Watchdog, Beyond Nuclear
(240) 462-3216

*While "consent-based siting" for permanent geologic repositories (dumpsites) is also on the agenda, DOE predicts a national dumpsite won't open till 2048. However, parking lot dumps are scheduled for as early as 2021, meaning the groundwork is already being laid now. Also, this public comment proceeding will lay the groundwork for permanent geologic repository site searches to come, including the potential targeting of MN in the future. 

"We do NOT CONSENT!" Sample talking points you can use to prepare your own, to DOE, opposing the Yucca dump, parking lot dumps, and Mobile Chernobyls

Beyond Nuclear has prepared sample talking points, entitled WE DO NOT CONSENT!, that you can use to prepare your own public comments, for submission to the U.S. Department of Energy (DOE), in opposition to high-risk, high-level radioactive waste shipments (by road, rail, and/or waterway) to Yucca Mountain, Nevada, as well as to "centralized interim storage sites" (de facto permanent parking lot dumps).

Full length (13-page) version: Beyond Nuclear's WE DO NOT CONSENT! sample talking points are available in PDF format (as well as Word format, with live URL links, at our Website).

Short summary (2-page) version: PDF format (and Word format, with live URL links, at our Website).

Beyond Nuclear has also prepared an even shorter version of sample talking points, a one-page, Top 10 List, of comments to make to DOE: PDF format; and posted online (with live URL links).

Please feel free to use one or more of the sample talking points (verbatim, or adapted to your own words) to prepare your own public comments, and then submit them to DOE by its July 31, 2016 deadline. Express your strong opposition to the Yucca dump, to parking lot dumps, and to Mobile Chernobyls/Floating Fukushimas/Dirty Bombs on Wheels! Also speak out against non-consent based targeting of such states as MN down the road in the future. And please, spread the word.