UCS Infographic: Safer Storage for Nuclear Waste

The Union of Concerned Scientists (UCS) has released an Infographic entitled "Safer Storage for Nuclear Waste," stating "Nuclear waste is piling up in our backyard—and it's not stored as safely as it could be."

While UCS refers to on-site dry cask storage as a "safer alternative" to densely-packed pools, Beyond Nuclear calls for safety upgrades to go one step further: HARDENED on-site dry cask storage. In fact, UCS itself has endorsed Hardened On-Site Storage (HOSS), as have hundreds of environmental groups representing all 50 states.

While HOSS may be the least bad interim measure for commercial irradiated nuclear fuel that already exists (some 70,000 metrc tons in the U.S.), Beyond Nuclear strives to permanently shutdown atomic reactors, to prevent the generation of any more radioactive waste. The only real safe, sound solution for high-level radioactive waste is to not generate it in the first place!

Government shutdown undermines NRC's nuke waste con game

North Anna watchdog Erica Grey, and Diane D'Arrigo of NIRS, unfurl a banner at NRC's first Nuke Waste Con Game meeting, held Oct. 1st in the NRC Commissioners conference room at NRC HQ in Rockville, MD. Photo by Beyond Nuclear's Kevin Kamps.The current federal government shutdown belies the U.S. Nuclear Regulatory Commission's (NRC) "Nuclear Waste Confidence." NRC holds that high-level radioactive waste (HLRW) can be stored safely, soundly, and securely, not just during atomic reactor operations, but for 60 years post-shutdown, 160 years, or even forevermore. NRC's false confidence applies not only at the reactor sites where the HLRW was generated in the first place, but also at away-from-reactor, so-called centralized or consolidated interim storage sites, what critics have dubbed de facto permanent parking lot dumps.

One of NRC's overly optimistic assumptions is that institutional memory, and societal control, will continue forevemore into the future. NRC's assumption ignores the fact, as pointed out by environmental coalition expert witness Dr. Arjun Makhijani, President of Institute for Energy and Environmental Research, that the oldest of human institutions, such as the Catholic Church, are but two millenia old. He also pointed out that North America has experienced major disruptive and violent societal events, such as the War of 1812, and the Civil War, within the past 150 to 200 years. This begs the question, might future, violent societal upheavals put the storage of HLRW at risk in the next century or two to come, not to mention further out in time? After all, even the U.S. Environmental Protection Agency (EPA) was forced to admit, under a hard-won court order by an environmental coalition, that HLRWs remain hazardous for a million years. Actually, that's an under estimate. The radioactive poison Iodine-129, for example, has a half-life of 15.7 million years, which means its hazardous persistance lasts at least 157 million years, and perhaps even 314 million years (10 to 20 half-lives).

One of NRC's most far-fetched assumptions is that the HLRW dry cask storage systems, structures, and components can and will be entirely replaced once per century. In order to do this, unprecedented, unproven Dry Transfer Systems (DTS) will have to be built. Every hundred years, NRC assumes the inner canisters, dry casks, dry cask pads, and DTSs will be replaced, safely and smoothly, forevermore into the future, with no cut off point, if a deep geologic repository is never opened. However, NRC does not estimate the price tag for doing such replacements forevermore, nor identify where that funding will come from.

As part of its court-ordered Environmental Impact Statement (EIS), NRC had committed to hold some two-dozen public comment meetings across the U.S. Beyond Nuclear attended the very first one, at NRC HQ in Rockville, MD, on October 1st, and testified. Beyond Nuclear had planned on participating at a number of other meetings as well, including Toledo on Oct. 15th, Chicago on Oct. 24th, Orlando on Nov. 6th, and NRC HQ again on Nov. 14th. Beyond Nuclear had pre-registered to provide oral comments at each of these meetings, as requested by NRC. Now, NRC has either postponed, or outright canceled (it's not clear yet) all those, as well as all the rest, of its public comment meetings. Many hundreds of concerned citizens and environmental group representatives had planned on attending these meetings. Now travel arrangements have to be postponed or cancelled, including having to deal with airline tickets that are no longer needed.

NRC cannot assure institutional control even today, as shown, ironically, by the cancellation of long-planned public comment meetings about its "Nuclear Waste Confidence," or nuke waste con game (see photo, above left, taken at the Oct. 1st meeting).

So what can be done? Written comments are still being accepted by NRC. The current deadline is Nov. 27th. You can submit written comments via webform, email, snail mail, or fax. It is essential that NRC receive large numbers of quality, heartfelt public comments.

Beyond Nuclear has prepared sample comments, as has NIRS. At a press conference last week, D.C. attorney Diane Curran, and experts Dr. Gordon Thompson (President of Institute for Resource and Security Studies) and Bob Alvarez (Senior Scholar, Institute for Policy Studies), have also provided insights into the risks of HLRW storage pool fires, which NRC is currently ignoring. Curran and the experts are preparing sample comments, on behalf of an environmental coalition comprised of two dozen groups, including Beyond Nuclear, so watch for those in weeks ahead.

Update on October 17, 2013 by admin

Today, NRC's Nuclear Waste Confidence Directorate spokesperson, Sarah Lopas, has confirmed in an email to NIRS that the Chelmsford, MA, Tarrytown, NY, Charlotte, NC, Orlando, FL, and Rockville, MD public comment meetings, scheduled between Oct. 28th and Nov. 14th, are again "a go" now that the federal government is no longer shutdown. If you plan to attend these public comment meetings, NRC requests that you pre-register if you plan to make oral public comments. Only the NRC HQ public comment meeting in Rockville, MD on Nov. 14th will provide webcast coverage and the option of phoning in to make oral public comment; the other public comment meetings must be attend in-person.

Sarah Lopas also indicated that the public meetings previously scheduled between Oct. 7th and 24th for CA, MN, OH, IL -- all postponed due to the government shutdown -- will now be rescheduled, at the same previously announced locations. The new dates and times will be announced at a later point by NRC, perhaps as early as next week.

The NRC Nuclear Waste Confidence Diretorate plans to extend the public comment deadline beyond Nov. 27th, provided the NRC Commission approves the extension. The new deadline will be announced by NRC at a later point, likely next week.

NRC's announcements re: rescheduled public comment meetings and the new deadline for written public comments will likely crystallize next week. NRC will communicate these updates via its website, as well as via emailed announcements, as well as the publication of revised Federal Register notices. As soon as Beyond Nuclear obtains these updates, we too will publicize them.

In the meantime, please continue to submit your public comments to NRC via email, webform, fax, or snail mail.

You can submit as many public comments as you want, between now and the final public comment deadline.

Sample comments, which you can use to help you write your own, have been provided by Beyond Nuclear and NIRS.

At a press conference on Oct. 2nd, D.C. attorney Diane Curran, and experts Dr. Gordon Thompson (President of Institute for Resource and Security Studies) and Bob Alvarez (Senior Scholar, Institute for Policy Studies), also provided insights into the risks of high-level radioactive waste storage pool fires, which NRC is currently ignoring. Curran and the experts are preparing sample comments, on behalf of an environmental coalition comprised of two dozen groups, including Beyond Nuclear, so watch for those in weeks ahead, as well.

Resolutions, legislators, and petition signatures against Canadian Great Lakes radioactive waste dump!

MI State Rep. Sarah Roberts (D-St. Clair), and Sen. Hoon-Yung Hopgood (D-Taylor), spoke to local press along the shores of Lake Huron at Macpherson Park in Kincardine, Ontario, Canada. Photo credit Kincardine Times.The number of resolutions against the Canadian Great Lakes radioactive waste dump is growing significantly, as Michigan legislators, State Senator Hoon-Yung Hopgood (D-Taylor) and State Representative Sarah Roberts (D-St. Clair), traveled to Kincardine, Ontario to testify in person before the Joint Review Panel (JRP) against the proposed dump on the Lake Huron shore. (see photo, left)

Sen. Hopgood and Rep. Roberts joined 31 Canadian and U.S. environmental and public interest groups, including Beyond Nuclear, in a Request for Ruling sent to the JRP today, asking for clarification on whether or not highly radioactive wastes would also be dumped at the DGR (Deep Geologic Repository, what critics have sarcastically dubbed the DUD, for Deep Underground Dump). This Request for Ruling follows a previous, similar one asking for clarification on decommissioning wastes, which alone could double the dump's capacity from 200,000 cubic meters of operational and refurbishment "low" and "intermediate" level radioactive waste, to 400,000 cubic meters altogether.

Sen. Hopgood and Rep. Roberts put out a press release about the Request for Ruling on highly radioactive wastes.

The Stop the Great Lakes Nuclear Dump petition has added a thousand signatures in the past week alone, approaching nearly 36,000. If you haven't signed it, please do, and spread the word to everyone you know!

How to pre-register to make oral comments at NRC Nuke Waste Con Game public meetings

Following are NRC's pre-registration instructions:

REGISTRATION:

Persons interested in providing oral comments at upcoming NRC public comment meetings are encouraged to register no later than 3 days prior to the meeting in question; however, registration will be accepted at the meetings, as well. Please note that individual oral comments may be limited by the time available, depending on the number of persons who register.

NRC will accept written comments any time during the meeting [as well as anytime until the final public comment deadline on Nov. 27th via such means as email, web form, snail mail, and fax].

Registration by Telephone to Make Oral Comments at the 11 Remaining Public Meetings:

To register for and request to provide oral comments at NRC public meetings, please call 301-287-9392. [Note that NRC is requiring oral comments to be made in-person at the 10 field meetings left across the country. Only the November 14th public comment meeting to be held at NRC HQ in Rockville, Maryland will allow oral comments to be made by teleconference; that Nov. 14th meeting will also be viewable online via webcast.]

Voicemail is available for calls received after hours or if no one is available to take your call directly. Please clearly state your name, affiliation or organization if appropriate, and request for accessibility accommodations if necessary. Also, please indicate whether you would like to provide oral comments. Registration will be confirmed by phone.

Registration by Email:

Please send your name, affiliation or organization if appropriate, and request for accessibility accommodations if necessary, to WCRegistration@nrc.gov. Also, please indicate whether you would like to provide oral comments. Registration will be confirmed by email.

To attend the open house and/or meeting at NRC headquarters [on Nov. 14th] in person, please provide your full name as it appears on a government-issued photo ID, which you must present upon entering the NRC facility. Directions to the NRC and parking information will be sent to you upon registration.

To provide comments by telephone during the webcast [on Nov. 14th only], dial 1-888-603-9749 and provide passcode 5132332. An operator will assist you. Speaking priority will be given to those who have registered in advance. Individual oral comments may be limited by the time available, depending on the number of persons who register.

NRC Nuke Waste Con Game meetings underway, public comments needed

[Please see Update below. NRC has announced the postponement, and perhaps even cancellation, of the public comment meetings in California next week, due to the federal government shutdown. NRC has indicated that in the days ahead, it will also announce the fate of other upcoming meetings, such as near Toledo, and in Minnesota. Please note that written comments can and should still be submitted by the various ways described below.]

Beyond Nuclear provided oral public comments at the first U.S. Nuclear Regulatory Commission (NRC) meeting -- on October 1st at NRC's headquarters in Rockville, Maryland -- regarding the agency's court-ordered "Nuclear Waste Confidence" draft Generic Environmental Impact Statement (DGEIS). The public comment period lasts until November 27th.

North Anna nuclear power plant watchdog Erica Grey and Diane D'Arrigo of NIRS unfurl a "STOP THE NUKE CON JOB" banner at the NRC public comment meeting on October 1st.You can use Beyond Nuclear's oral testimony on October 1st as a model to help prepare your own oral or written public comments. Beyond Nuclear has prepared additional sample comments, or "talking points," that you can use to prepare your own as well.

Nuclear Information and Resource Service (NIRS) has also prepared talking points you can use to prepare your own comments, and has provided other preparatory materials for taking part in the public comment meetings.

A press conference on Oct. 2nd featuring environmental coalition attorney Diane Curran of Washington, DC, Dr. Gordon Thompson of the Institute for Resource and Security Studies, and Bob Alvarez of Institute for Policy Studies also provides deep insights on the potentially catastrophic risks of HLRW pool fires that can be used to fashion public comments. Thompson and Alvarez co-authored a study in 2003 with now-NRC Chairwoman, Allison Macfarlane, warning about such risks, and calling for the transfer of irradiated nuclear fuel out of densely-packed pools into dry cask storage as a top national security priority.

You can submit written public comments anytime from now until November 27th, via email, web form, snail mail, fax, or hand delivery.

You can make public comments orally at any of the 11 remaining public hearings across the country. The next one is on October 3rd in the Denver area. To make oral comments at these field meetings across the U.S., you must attend in person. No webinar access, nor teleconference opportunity, is being provided by NRC at these field meetings.

The final scheduled NRC public meeting is on November 14th, again at the agency's Rockville, MD HQ. The Nov. 14th meeting will allow oral comments made via telephone conference call bridge line; the meeting will also be viewable via webcast.

NRC urges those wishing to make oral public comments to pre-register.

While the Oct. 3rd Denver meeting is confirmed as happening, NRC has indicated that all future meetings depend on an end to the current government shutdown. If the government shutdown continues, the future meetings may be postponed or even cancelled.

This should not be. As David Blee of the U.S. Nuclear Infrastructure Council -- a nuclear industry lobbyist representing a trade group -- commented at the Oct. 1st meeting, industry licensees provide some 90% of NRC's budget, so why should a federal government shutdown affect the agency's public meetings in any significant way?

Several public commenters noted the irony of NRC's conclusion that on-site or away-from-reactor storage of irradiated nuclear fuel forevermore will be safe, sound, and secure based on the absurd assumption that "institutional control" will be maintained indefinitely into the future. How can NRC make such an assumption for centuries or even millenia into the future, when the U.S. government is currently shutdown?!

A large number of quality public comments are vitally needed during this public comment period. The June 8, 2012 court victory against NRC's bogus Nuke Waste Con Game has already forced the NRC Commission to suspend finalization of proposed new reactor license applications, as well as degraded old reactor license extensions, for at least two years, until the GEIS is finalized and a Record of Decision (ROD) is issued. Some three dozen environmental groups have cited this court-ordered NEPA (National Environmental Policy Act) proceeding in some two dozen reactor licensing proceedings. For example, Beyond Nuclear has cited this legal victory to block the finalization of an old reactor license extension rubberstamp by NRC at Davis-Besse, Ohio, as well as a proposed new reactor operating license at Fermi 3, Michigan.

Previously, the NRC admitted it would take seven years to carry out such a GEIS. NRC is clearly racing through this GEIS proceeding, under industry pressure to resume rubberstamping reactor operating licenses as soon as possible. In fact, at the Oct. 1st meeting, several Nuclear Energy Institute lobbyists called for such an expedited finalization of this draft GEIS, ASAP.

If you can make it, please consider attending any of 10 remaining field meetings across the country, and making oral public comment. And bring friends with you!

If you can't attend a meeting in person, please attend the final meeting on Nov. 14th via teleconference (or webinar), and make your oral comment via the phone bridge.

Or submit your written comments via email, web form, snail mail, or fax before the Nov. 27th deadline.

Please spread the word! Thank you.

Update on October 4, 2013 by admin

This just in from NRC on Friday morning, Oct. 4th:

Greetings,

Thank you for registering for an upcoming waste confidence public meeting.

Due to the lack of an appropriation and the government shutdown, the Waste Confidence Directorate regrets to inform you that we will not be able to hold the two public meetings that were scheduled for next week (San Luis Obispo, California on 10/7; Carlsbad, California, on 10/9).  At this time the other meetings now scheduled for future dates are subject to being postponed if the shutdown continues.

When full operations are restored, the Waste Confidence Directorate will send status e-mails, post details on the waste confidence website regarding future meetings and work to determine the best path forward for continuing public participation in the waste confidence rulemaking.  This will include consideration of when we can reschedule these meetings, consistent with our commitment to optimize public participation in the process.

Thank you,

Staff of the Nuclear Regulatory Commission
Waste Confidence Directorate