Re: "Private Initiatives" (PIs) for de facto permanent high-level radioactive waste parking lot dumps: Sample talking points you can use to write your own comments, and instructions on how to submit them to DOE by Jan. 27 deadline
See DOE questions (in italics), followed by sample talking points you can use to write your own public comments:
As stated in its Request for Information (RFI), the U.S. Department of Energy (DOE) has requested:
In particular, DOE seeks information in the following areas...
1. What key factors should be considered to ensure that PIs, as part of the overall integrated nuclear waste management system, would provide a workable solution for interim storage of spent nuclear fuel and high-level waste?
Since a private centralized interim storage facility could easily become a de facto parking lot dump, or could one day well be targeted not just for storage but also for permanent disposal (such a preference has been expressed in related legislation on Capitol Hill, that the pilot-, and full-scale, centralized interim storage site also be considered for permanent disposal), the following criteria must be met: scientific (geologic, hydrologic, etc.) site suitability; free, fully informed, consent-based siting; environmental justice, not just for current, but also for all future generations.
In addition, since consolidated interim storage would require unprecedented numbers of shipments (by road, rail, and/or waterway) of highly radioactive irradiated nuclear fuel, through many to most states, such "Mobile Chernobyl" risks must be minimized. Long-distance shipments should only happen once, to suitable, consent-based, environmentally just permanent disposal, not to a supposedly interim storage site, from which the wastes will have to move again, multiplying transport risks. Consent should be required for transport corridor communities for such shipments, and transport container safety and security should be guaranteed, requiring significant upgrades to current shipping container integrity standards.
Additional sample talking points you can use to write your own public comments:
1. "Private Initiatives," such as Waste Control Specialists, LLC's scheme to open a de facto permanent parking lot dump for commercial irradiated nuclear fuel (high-level radioactive waste) storage in west Texas, are illegal under the terms of the Nuclear Waste Policy Act, as Amended. [See the letter sent by Diane Curran, legal counsel for an environmental coalition, to the U.S. Nuclear Regulatory Commission; see the coalition's press release; see additional information, including extensive media coverage.] For this reason alone, DOE should cease and desist from pushing it!
2. As Tom "Smitty" Smith of Public Citizen's Texas office has said, "Texans do not consent to the risky plan to store high-level radioactive waste at private sites on an open pad above ground in Texas. Another company near Hobbs, New Mexico -- less than 50 miles away -- is expected to file an application to open a storage site that would accept the rest of the nation's high-level nuclear waste. These twin 'storage sites' likely would create a de facto high-level national waste sacrifice zone. This proposal invites disaster because the private owners will be cutting costs at every turn to maximize profits. If there was radioactive contamination our land, air, water, and human health could be harmed for millenia." (emphasis added; see press release here)
3. Private permanent parking lot dumps are high-risk, not only radiologically but also to U.S. taxpayers' pocketboots. As Kevin Kamps of Beyond Nuclear has said: "By requiring a permanent deep geological repository to be operating before centralized interim storage [whether private or federal government owned/operated], Congress wanted to prevent the very real danger of a de facto permanent parking lot dump -- a high-level radioactive waste storage site that would be designed for the short-term but be there forever. WCS, for example, is a cynical shell game and taxpayers are sure to lose. Congress was right that liability for the costs for storing commercial irradiated nuclear fuel belong with the generators and should not be shifted onto the backs of the American public." (see press release)
4. Regarding the transportation costs and risks of centralized interim storage (whether private or federal government owned/operated):
As Diane D'Arrigo, radioactive waste project director at Nuclear Information and Resource Service, has said, "Moving irradiated nuclear fuel over roads, rails, and waterways to a supposedly temporary site puts us all at risk and creates only the illusion of a solution."
And as Karen Hadden, executive director of the Texas-based SEED (Sustainable Energy & Economic Development) Coalition, has said, "Due to risks of radioactive contamination from leaks or accidents or potential terrorist actions, nuclear waste should only be moved once, and only when a deep underground permanent repository is in place that could safely isolate the dangerous waste for the million years [see immediately below] that it will remain hazardous." (see the press release)
In fact, a coalition of environmental groups, including NRDC, NIRS, Nevada Nuclear Waste Task Force, Citizen Action Coalition of Indiana, and Public Citizen, won a major court victory on July 9, 2004, which ordered EPA back to the drawing board on its proposed Yucca Mountain high-level radioactive waste dump regulatory cut-off at 10,000 years post waste burial. In 2008, EPA's revised regulations acknowledged a one million year hazard associated with irradiated nuclear fuel and high-level radioactive waste. (Truth be told, there are radioactive poisons in high-level radioactive waste that will remain hazardous far longer than even a million years. Iodine-129, as but one example, has a 15.4 million year half-life. This means it will remain hazardous for 154 to 317 million years!)
5. As the lead proposals for centralized interim storage (de facto permanent parking lot dumps) are private initiatives (in fact, there are no proposed federal government owned/operated parking lot dumps), all of the public comments submitted to DOE during its so-called "consent-based siting" public comment period in 2016 still apply. (The lead private initiative is by Waste Control Specialists, LLC in Andrews County, West Texas, followed by the Eddy-Lea [Counties] Energy Alliance in Hobbs, New Mexico (less than 50 miles from WCS); AFCI in Loving County, TX; and Culberson County, TX. Note that not only WCS, but also AFCI, have close connections to Trump's pick for Energy Secretary, former TX governor Rick Perry, representing a blatant conflict of interest and ethical violation.) Comments submitted by environmental, public interest, and other NGOs can and should be submitted again during this current comment period (especially considering the fact that DOE largely to entirely ignored these comments when it issued its draft and final reports on defining "consent-based siting"!). See those comments by the following groups, and use them to write your own: several sets of comprehensive Beyond Nuclear comments, covering various subject matter, including Environmental Justice; Beyond Nuclear's Top 10 List, as well as its more detailed 2-page, and even more detailed 13-page, versions of sample comments; Alliance for Nuclear Accountability (ANA); Fairewinds Energy Education; Institute for Energy and Environmental Research (IEER); Natural Resources Defense Council (NRDC); Nuclear Information and Resource Service (NIRS); Public Citizen; and a collection of comments from groups such as SEED Coalition, NAWO, Pilgrim Watch, and others.
HOW TO SUBMIT YOUR PUBLIC COMMENTS TO DOE BY THE JAN. 27 DEADLINE:
To provide your comments on the Request for Information on Private Inititives, please email privateISF@hq.doe.gov. The comment period ends on January 27, 2017.
In its RFI (Request for Information) posted at its website, DOE provides the following additional details:
RESPONSE PREPARATION AND TRANSMITTAL INSTRUCTIONS
Responses to this RFI are due by January 27, 2017, shall be sent by email to the mailbox PrivateISF@hq.doe.gov and shall include the subject line "Response to RFI on Private Initiatives to Develop Consolidated SNF Storage Facilities”. The responses shall be in Microsoft Word, Microsoft PowerPoint, or Portable Data Format (PDF) readable by Adobe Acrobat software and should be limited to approximately 15 pages.
Also at its posted RFI, DOE lists a dozen areas or questions it would particularly ask the public's comments to address (see pages 2-3).
In its Federal Register Notice, DOE added the following additional ways to submit public comments:
Interested parties are to submit requested information by any of the following methods:
Email: Responses may be provided by email to PrivateISF@hq.doe.gov.
Mail: Responses may be provided by mail to the following address: U.S. Department of Energy, Office of Nuclear Energy, Response to RFI on Private Initiatives to Develop Consolidated SNF Storage Facilities, 1000 Independence Ave. S.W., Washington, DC 20585.
Fax: Responses may be faxed to 202-586-0544. Please include "Response to RFI on Private Initiatives to Develop Consolidated SNF Storage Facilities" on the fax cover page.
Online: Responses will be accepted online at www.regulations.gov.
Instructions: All submissions received are to include "Response to RFI on Private Initiatives to Develop Consolidated SNF Storage Facilities" in the subject of the message. The complete RFI, including the additional instructions, can be found at www.energy.gov/ne/downloads/Private-ISF.
FOR FURTHER INFORMATION CONTACT:
Requests for further information should be sent to Mr. Andrew Griffith via PrivateISF@hq.doe.gov.