Beyond Nuclear's testimony at NRC Nuke Waste Con Game draft GEIS public comment meeting in Rockville, MD on Oct. 1st

Beyond Nuclear's Kevin Kamps delivered the following testimony during the U.S. Nuclear Regulatory Commission's (NRC) public comment meeting regarding its "Nuclear Waste Confidence" draft Generic Environmental Impact Statement (GEIS) held at the agency's headquarters in Rockville, Maryland on October 1st:

"Good day. My name is Kevin Kamps. I serve as Radioactive Waste Watchdog at Beyond Nuclear, a national environmental watchdog on the nuclear power industry.

The National Environmental Policy Act (NEPA) requires consideration of all reasonably foreseeable environmental impacts of a proposed action -- from cradle to grave. The question that must be answered in an atomic reactor licensing decision is: if you look all the way, to the end of the reactor's life, including decommissioning, spent nuclear fuel/irradiated nuclear fuel/high-level radioactive waste storage, and disposal, is having that source of electricity generation -- nuclear power -- worth all the environmental and economic costs, risks, and impacts that will then inevitably ensue?

As soon as NRC licenses a reactor, the generation/creation of irradiated nuclear fuel and all its related costs, risks, and impacts will then follow. The NRC effectively assumes licensing, and goes on from there to look at the impacts of irradiated nuclear fuel storage, although it does a very poor, woefully inadequate, and, in my opinion, legally insufficiency and violative job of that!

But the whole point of the Environmental Impact Statement is to allow an informed decision regarding whether to license the reactor in the first place, that is, to allow the generation of irradiated nuclear fuel. NRC does not even attempt to answer that question.

What is the cost of storing irradiated nuclear fuel for any period of time, let alone forevermore? NRC does not even ask that question, let alone answer it, in this draft GEIS.

Is having a new or extended reactor operating license worth all the costs, risks, and impacts of storing irradiated nuclear fuel? The answer to that question is a resounding "NO"!

Have mitigation measures for these costs, risks, and impacts been explored in this GEIS? Again, they have not.

NRC's draft GEIS is completely devoid of such issues. Thus, the draft GEIS makes a mockery of NEPA, as well as the federal appeals court ruling in New York versus NRC.

We have a mountain of commercial high-level radioactive waste 56 years high, and we don't even know what to do with the first cupful. It's time to stop making it!

For that which already exists -- some 70,000 metric tons worth in the U.S. -- hundreds of environmental groups representing all 50 states have called on NRC for over a decade to require hardened on-site storage (HOSS). HOSS would empty the densely packed storage pools, vulnerable to leaks and catastrophic fires, into quality dry cask storage, that is designed and built to last not decades, but centuries, without leaking its deadly contents into the environment. HOSS would also be designed and built with fortifications against attacks, and safeguards against accidents, including such basic measures as monitors to track heat, pressure, and radioactivity, none of which are currently required. Although HOSS is but an interim measure, it should be mandated as a national security priority of the highest order. We join with NRC Chairwoman Allison Macfarlane, who, along with a team of authors, published a study in 2003 warning about the potentially catastrophic risks of storage pool fires, and calling for the wastes to be transferred to dry cask storage on an expedited basis.

A growing list of radioactive leaks from HLRW storage pools have already occurred in the U.S. This has taken place at the following NRC-licensed facilities: Dresden, IL; Hatch, GA; BWX Technologies, VA; Indian Point 1 & 2, NY; Salem 1, NJ; Connecticut Yankee; and Davis-Besse, OH. A pool leak has also occurred at a U.S. Department of Energy licensed facility, the High Flux Beam Reactor at Brookhaven National Lab on Long Island, NY.

Regarding the risk of pool fires, we need only look at Fukushima Daiichi Unit 4 in Japan. That reactor building was badly damaged by the hydrogen explosion that took place there. The HLRW storage pool is now open-air. Another bad quake could topple the entire building, including the storage pool. If the cooling water is lost, some hundreds of tons of HLRW could then catch on fire in a short period of time. The catastrophic release of hazardous radioactivity directly into the environment would dwarf what has occurred up to this point since March 11, 2011.

I am thankful for this opportunity to make public comments. Beyond Nuclear will follow up with extensive written comments before the November 27th deadline, as well."

Public comments needed at NRC Nuke Waste Con Game meeting, Denver, Oct. 3

Thursday, October 3

Denver, Colorado Crowne Plaza Denver International Airport Convention Center 15500 East 40th Ave Denver, CO  80239

Open House 6:00-7:00 p.m. MDT Meeting 7:00-10:00 p.m. MDT

The U.S. Nuclear Regulatory Commission (NRC) is holding a public comment meeting in Denver on October 3rd regarding its court-ordered "Nuclear Waste Confidence" draft Generic Environmental Impact Statement.

Beyond Nuclear posted an action alert last week:

http://www.beyondnuclear.org/radioactive-waste-whatsnew/2013/9/26/nrc-nuke-waste-con-game-public-comment-meetings-begin-next-w.html

It contains links to sample public comments, that folks can use to write their own.

It also contains information on pre-registering to speak, which NRC urges public commenters to do in advance.

Thanks for spreading the word in the Denver area!

Please note, this NRC Denver field meeting will not have webinar or teleconference capability. To take part or make oral comments, folks have to attend in person.

The Nov. 14th NRC HQ public comment meeting in Rockville, MD will be the next -- and last -- time that folks can make comments by phone, or watch online. However, written comments can be submitted anytime between now and the end of the public comment period on Nov. 27th, via email, webform, snail mail, fax, or hand-delivery. See the action alert link above for more information.

State of MI legislators speak out against Great Lakes radioactive waste dump in Ontario

As reported by CTV, Michigan State Senator Hoon-Yung Hopgood and Representative Sarah Roberts spoke out today in Kincardine, Ontario against Ontario Power Generation's proposal to bury radioactive wastes along the Lake Huron shore.

Hopgood's resolution against the DGR (for Deep Geologic Repository, or DUD, for Deep Underground Dump) passed the Michigan State Senate unanimously. Roberts has introduced a companion resolution in the MI State House of Representatives.

Hopgood and Roberts testified today before Canada's federal Joint Review Panel hearing concerns about the DUD. The legislators issued a press advisory, as well as an endorsement of a call by 28 U.S. and Canadian environmental groups (including Beyond Nuclear) "Request for Ruling," that the JRP require OPG to come clean on whether or not it intends to double the capacity of the proposed DUD from 200,000 cubic meters of so-called "low" and "intermediate" level radioactive waste from operations and refurbishment at 20 Ontario reactors, by adding another 200,000 tons of L&ILRWs from decommissioning activities over time.

Sen. Hopgood and Rep. Roberts also submitted written testimony. Attached to Sen. Hopgood's written testimony are statements of opposition to the Great Lakes radioactive waste dump provided by: Michigan United Conservation Clubs (with 42,000 members); Michigan Boating Industries Association (comprised of 300 marine businesses); Michigan Charter Boat Association; Michigan Steelhead & Salmon Fishermen's Association (the largest sport fishing organization in the Great Lakes Basin); Michigan Environmental Council (a coalition of more than 70 organizations); and Michigan Clean Water Action (boasting 200,000 members).

Update on October 1, 2013 by admin

The Owen Sun Times/Kincardine News has covered this story.

Number of resolutions growing against Canadian nuclear waste dump on the Great Lakes

As compiled by Stop the Great Lakes Nuclear Dump, more and more resolutions are being passed on both sides of the border in opposition to Ontario Power Generation's (OPG) proposed Deep Geologic Repositories (DGRs), or DUDs (for Deep Underground Dumps).

In addition to these numerous resolutions, as of April 10, 2014, over 53,000 individuals have signed the Stop the Great Lakes Nuclear Dump petition.

Below, please find links to many of these resolutions opposing, or voicing serious concerns, regarding Deep Geological Repositories (DGRs) for burying radioactive wastes in the Great Lakes Watershed:

2006

Great Lakes United

(GLU, disbanded in June 2013, was an environmental coalition comprised of scores of groups from the U.S., Canada, and Native American First Nations)

2008

Macomb County Water Quality Board - (Macomb County, Michigan)

Macomb County Board of Commissioners - (Macomb County, Michigan)

(As of 2012, Macomb County had a population of 847,383);

St. Clair County Water Quality Board - (St. Clair County, Michigan)

(As of 2012, St. Clair County had a population of 160,644);

Marine City - (St. Clair County, Michigan)

(As of 2012, Marine City had a population of 4,174);

City of St. Clair Shores - (Macomb County, Michigan)

(As of 2012, the City of St. Clair Shores had a population of 59,749)

Environmental and public interest group sign-on statement (around 300 organizations, including coalitions, as well as many hundreds of individuals).

2012

The Huron Declaration, Nuclear Labyrinth on the Great Lakes - International Conference held in Huron, Ohio, focused on critical nuclear issues affecting the health of the Great Lakes watershed;

Great Lakes United (re: DGR 1 and 2). GLU also passed a companion RESOLUTION ON THE HUMAN RIGHT TO WATER, inherently incompatible with OPG's proposed DUDs, which resolved: "that Great Lakes United urge the governments of Canada and the United States in national and global trade, to exercise responsible stewardship over this life-giving resource by respecting water as a common good and basic human necessity thereby a human right that cannot be bought and sold, this being ensured through public ownership; and recognize that this human right brings with it the duty to treat water responsibly, and the obligation to ensure all citizens’ human rights are met." (emphasis added)

2013

Michigan State Senate

(The State of Michigan, as of 2012, was home to 9,883,000);

Macomb County Board of Commissioners - (Macomb County, Michigan - 2nd resolution);

Village of Lexington - (Sanilac County, Michigan)

(As of 2010, Lexington had a population of 1,178);

Lynn Township - (St. Clair County, Michigan, one of three townships in St. Clair County that defeated a "low" level radioactive waste dump for 8 states, a little over two decades ago)

(Lynn Twp.'s population is reported as 1,129 to 1,187);

St. Clair County Board of Commissioners - (St. Clair County, Michigan);

Wayne County Board of Commissioners - (Wayne County, Michigan)

(As of 2012, Wayne Co. had a population of 1,792,000);

City of Oregon, Ohio

(As of 2012, Oregon had a population of 20,221);

Friends of the Detroit River;

Lambton County, Ontario

(Lambton Co. currently has a population of 126,199);

City of Sarnia - (Lambton County, Ontario)

(As of 2011, Sarnia, the largest city on Lake Huron, had a population of 72,366);

Greenwood Township - (St. Clair County, Michigan)

(As of 2000, Greenwood Twp. had a population of 1,373);

County of Essex, Ontario

(As of 2011, Essex Co. had a population of 177,891);

Town of Blue Mountains, Ontario

(As of 2011, The Blue Mountains (Town) had a population of 6,453);

Town of Kingsville, Ontario

(As of 2011, Kingsville had a population of 21,362);

Attached to Sen. Hopgood's written testimony to the Joint Review Panel are statements of opposition to the Great Lakes radioactive waste dump provided by: Michigan United Conservation Clubs (with 42,000 members); Michigan Boating Industries Association (comprised of 300 marine businesses); Michigan Charter Boat Association; Michigan Steelhead & Salmon Fishermen's Association (the largest sport fishing organization in the Great Lakes Basin); Michigan Environmental Council (a coalition of more than 70 organizations); and Michigan Clean Water Action (boasting 200,000 members);

Toledo City Council, Ohio

(As of 2012, Toledo had a population of 284,012);

London, Ontario

(As of 2011, London had a population of 366,151);

Great Lakes and St. Lawrence Cities Initiative, May 24th and August 13th. The Great Lakes and St. Lawrence Cities Initiative (GLSLCI) is a binational coalition of mayors and other local officials (in over 100 cities) that works actively with federal, state, and provincial governments to advance the protection and restoration of the Great Lakes and the St. Lawrence River.

Update on October 3, 2013 by admin

City of Wyandotte, Michigan

(As of 2012, Wyandotte had a population of 25,485);

Port Clinton, Ohio (City Council considering passage of a resolution, after its Planning and Development Committee urges it);

City of Mississauga, Ontario

(As of 2011, Mississauga was Canada's 6th largest municipality, with a population of 713,443).

Update on November 21, 2013 by admin

The City of Toronto, Canada's largest city, with a population of 2.79 million, on Nov. 14th

Update on November 22, 2013 by admin

The City of Windsor, Ontario -- just across the Detroit River from Detroit, MI -- has also passed a resolution opposing OPG's DUD! Its population is 215,000.

Update on November 25, 2013 by admin

The City of Kingston, Ontario passed resolution on Nov. 19th opposing OPG's DUD. Kingston, where the St. Lawrence River meets Lake Ontario, has a population of 123,363.

This ever expanding list, above, of 7 counties, and more than a dozen cities, towns, townships, and villages across MI, OH, and ON, represent jurisdictions with a combined population of nearly 17.7 million downstream residents.

Update on November 28, 2013 by admin

The Town of Ajax "By the Lake" (Lake Ontario, that is), just east of Toronto, near the 8-reactor Pickering Nuclear Power Plant, has also passed a resolution against the DUD. Ajax, as of 2011, had a population of 109,600.

This takes the total population of municipalities (cities, towns, townships, counties, villages, etc.) with resolutions against the DUD to around 17.8 million.

Update on December 16, 2013 by admin

The Town of Port Clinton, OH passed a resolution on Dec. 10, 2013. Port Clinton is located within the 10-mile Emergency Planning Zone of FirstEnergy Nuclear's Davis-Besse atomic reactor. Port Clinton has a population of over 6,000.

Update on February 6, 2014 by admin

Our allies at Stop the Great Lakes Nuclear Dump report that the following municipalities have recently adopted resolutions opposing the DGR (or DUD):

Ontario:

City of Sault Ste. Marie;

City of St. Catharines;

Municipality of Chatham-Kent.

Michigan:

City of Eastpointe;

Clinton Township.

Update on March 4, 2014 by admin

City of Milan, MI, in Southeast MI, population 5,836.

NRC Nuke Waste Con Game public comment meetings begin next week

An irradiated nuclear fuel assembly being moved underwater in an indoor storage pool.The U.S. Nuclear Regulatory Commission (NRC) has published information on how you can take part in the very first "Nuclear Waste Confidence" draft Generic Environmental Impact Statement (DGEIS) public comment meeting, to be held on Tuesday, October 1st from 2 to 5 PM Eastern at NRC's Rockville, MD HQ.

While it is not required to pre-register to view the proceedings on the NRC's webcast (as NRC has stated, "It is not necessary to register to view the webcast. Please go to http://video.nrc.gov for connection information), Beyond Nuclear encourages you to testify orally, to provide public comments. Sample public comments can be found here. (You can also submit public comments by various means -- email, internet webform, snail mail, fax, etc. -- anytime between now and Nov. 27th. Here is how you can do so.)

Nuclear Information and Resource Service (NIRS) also has a helpful resources page you can check out in preparation for the upcoming public comment meetings.

If you are in the D.C. area and can attend this first public comment meeting on Oct. 1 in person, great! But if you are not able to come in person, you can still take part by listening in and watching at the webcast, and very importantly, by providing oral public comment over the phone.

Note that this Oct. 1st meeting, and the very last meeting of all on Nov. 14th (again, to be held at NRC's HQ in Rockville, MD), are the only public meetings of the dozen to be held around the country where viewing by webcast and providing oral public comment by phone will be allowed. To take part in the dozen additional public comment meetings across the U.S., you must attend in person (NRC is urging pre-registration for those, too).

In order to provide oral public comments on Oct. 1st (whether in person, or by phone), you must pre-register as soon as possible. Following are NRC's pre-registration instructions:

REGISTRATION:

Persons interested in providing oral comments at the October 1 meeting are encouraged to register no later than 3 days prior to the meeting; however, registration will be accepted at the meeting. 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.

Registration by Telephone:

To register for and request to provide oral comments at the October 1 meeting, whether in-person or by teleconference, please call 301-287-9392.

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 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, 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.

For more information on NRC's Nuke Waste Con Game, please see Beyond Nuclear's weekly email bulletin entry from last week.