Beyond Nuclear's responses, and additional thoughts, to questions from Senate ENR Committee on its "discussion draft" of CIS/Mobile Chernobyl legislation

An infrared photo of a high-level radioactive waste rail shipment. The high temperature of such shipments, however, is the least of our worries. A severe accident, or attack, involving such a shipment could breach the container, leading to disastrous releases of hazardous radioactivityBeyond Nuclear has submitted the following responses, and additional thoughts, to the U.S. Senate's Energy and Natural Resource (ENR) Committee, regarding its list of questions about its proposed "discussion draft" of legislation that would rush centralized interim storage sites into operation. If enacted, this legislation would launch unprecedented numbers of high-level radioactive waste shipments by truck, train, and barge -- a risky radioactive waste shell game on our roads, rails and waterways! (see web site postings below for more detailed information) The Senate ENR Committee had set 5 PM today, Friday, May 24th (close of business on the Memorial Day holiday weekend) as the deadline for responses to its bill, which was unveiled on April 25th, ironically on the eve of the 27th anniversary of the beginning of the Chernobyl nuclear catastrophe.

Be sure to scroll down to the second page, in order to see the Beyond Nuclear Responses to the various questions (#2 to 8).

Executive Summary (referred to as "Question #1"); Response to Question #2; Response to Question #3; Response to Question #4; Response to Question #5; Response to Question #6; Response to Question #7; Response to Question #8; Additional Thoughts.

In addition, Beyond Nuclear signed onto an environmental coalition statement spearheaded by NIRS.

A group of 7 Ph.D.'s also submitted comments. The authors included: Dr. Seth Tuler, a Research Fellow at the Social and Environmental Research Institute in Greenfield, MA who serves on the Board of Directors of Alliance for Nuclear Accountability (ANA; Beyond Nuclear is a proud member group); and Dr. Kristin Shrader-Frechette at Notre Dame University, who wrote the 1993 book Burying Uncertainty: Risk and the Case Against Geological Disposal of Nuclear Waste.

Dave Kraft, Director of Nuclear Energy Information Service of IL, a 32-year-old watchdog group in Chicago, also submitted comments. On the weekend of Dec. 2, 2012, Dave coordinated the conference entitled "A Mountain of Radioactive Waste 70 Years High: Ending the Nuclear Age," at the U. of Chicago were Enrico Fermi fired up the first nuclear chain reaction, generating the world's first cupful of high-level radioactive waste, for which we still have no solution. The conference, which brought together hundreds, was devoted in large part to not only looking back, but countering the present Mobile Chernobyl bill. Beyond Nuclear was a proud co-sponsor of the event, as was Friends of the Earth (which also submitted comments today).

Bob Alvarez, a former senior advisor the the Secretary of Energy, and now a senior scholar at Institute for Policy Studies, also submitted comments. Beyond Nuclear often cites Bob's work on the risk of catastrophic fires in high-level radioactive waste storage pools, including in its comments to the Senate ENR Committee today.

Thanks to everyone who has responded to our action alerts going back weeks and months, urging action be taken to stop this latest Mobile Chernobyl bill dead in its tracks.

U.S. Senators introduce Mobile Chernobyl bill on eve of Chernobyl nuclear catastrophe anniversary

An infrared photo of a high-level radioactive waste rail shipment. The high temperature of such shipments, however, is the least of our worries. A severe accident, or attack, involving such a shipment could breach the container, leading to disastrous releases of hazardous radioactivity

{Directions for Submissions

Please submit comments electronically to: Nwaste_feedback@energy.senate.gov 

Submission due date: Friday, May 24, 2013 at 5:00pm (EST)

The documents attached below can be used as a template for submitting comments.  We request that you submit your comments in the template format, but will accept comments in other formats.  Please feel free to respond to as many or as few of the questions as you like.

Please provide your name and affiliation in the header of your comments.

The committee may post the comments, including any personal identifying information you provide (street or e-mail addresses, or phone numbers) it receives on its website.  If you would like your personal identifying information withheld, please indicate that.

The comment period will close on Friday, May 24, 2013.

Please find the submission documents below [linked here] and the link to the discussion draft, summaries and questions here.}

For the second year in a row, U.S. Senators have introduced the latest Mobile Chernobyl bill on the eve of the Chernobyl nuclear catastrophe anniversary. On April 25, 2013 -- the eve of the 27th anniversary of the beginning of the Chernobyl nuclear catastrophe -- U.S. Senators Ron Wyden (D-OR) and Lisa Murkowski (R-AK), the Chair and Ranking Member of the Energy and Natural Resources Committee, as well as Dianne Feinstein (D-CA) and Lamar Alexander (R-TN), the Chair and Ranking Member of the Appropriations Subcommittee on Energy and Water Development, published a "Discussion Draft" of proposed legislation on high-level radioactive waste management. They issued a press release, one page summary, section-by-section summary, and the full text of the 58-page bill. 

In essence, if enacted, the proposal would launch shipments of high-level radioactive waste onto the roads, rails, and waterways in unprecedented numbers, bound for "consolidated interim storage sites," from which they would have to be removed someday, to permanent dumpsites. Unless, that is, they never are transferred -- which would lead to de facto permanent surface storage, parking lot dumps for high-level radioactive waste.

Last year, on April 26, 2012 -- the actual 26th anniversary of Chernobyl, to the day -- Sens. Feinstein and Alexander led the passage of a Mobile Chernobyl bill through not only their Energy and Water Development Appropriations Subcommittee, but through the full Senate Appropriations Committee. Their bill, however, was never considered by the full Senate last year.

Now, Sens. Feinstein and Alexander have -- simultaneously to the "Discussion Draft" rollout -- proposed alternative legislative language. It would further expedite the shipment of high-level radioactive waste on our roads, rails, and waterways to "consolidated interim storage sites." Their alternative proposal, and its summary, are also available.

As this is a "Discussion Draft" of the proposed bill, the Senators state in their press release:

"The members are seeking comment on the discussion draft and a number of policy and technical questions from experts and stakeholders, including utilities, conservation groups, Blue Ribbon Commission members and others, by May 24."

Perhaps the single most important question involves "linkage" -- or lack thereof -- between "consolidated interim storage sites" and permanent dumpsites. As stated in the Senators' list of "Nuclear Waste Questions":

"Linkage between storage and repository

Should the bill establish a linkage between progress on development of a repository and progress on development of a storage facility?  If so, is the linkage proposed in section 306 of the bill appropriate, too strong, or too loose?  If a linkage is needed, should it be determined as part of the negotiations between the state and federal governments and included in the consent agreement rather than in the bill?"

Currently, as stated in the one page summary section entitled "Linkage Between Storage Facilities and a Repository," there is no linkage:

"The bill authorizes the Administrator [of a newly established Nuclear Waste Administration, outside of the Department of Energy, DOE] to begin siting consolidated storage facilities immediately, and does not set waste volumes [sic] restrictions on storage."

In this regard, the currently proposed legislation is significantly worse than the bill proposed last September by U.S. Sen. Jeff Bingaman (D-NM), the now-retired former chair of the Energy and Natural Resources Committee. Although Bingaman unaccetably "gave away" the first 10,000 tons of irradiated nuclear fuel for "centralized interim storage" as a political compromise (a "pilot" parking lot dump, strongly advocated by Sen. Feinstein, with no strings attached to permanent disposal), his bill would have required linkage between permanent disposal and any further "centralized interim storage." He did this in order to guard against "interim" storage sites -- including one threatened in his own state of New Mexico, at WIPP -- from becoming de facto permanent surface storage, if a geologic repository is never pursued, developed, and operated.

The most likely targets for "consolidated interim storage sites" are at DOE facilities, including the Savannah River Site (SRS) in South Carolina, the Idaho National Lab, and as previously mentioned, the Waste Isolation Pilot Plant (WIPP) in New Mexico. In fact, SRS hopes to reprocess the irradiated nuclear fuel moved there for "consolidated interim storage." This would be not only a serious nuclear weapons proliferation risk, but also a risk of widespread radioactive contamination of the environment downwind and downstream. It would also cost taxpayers and/or ratepayers many tens of billions of dollars.

Other likely targets for "consolidated interim storage sites" are Native American reservations, as well as nuclear power plants themselves. Over the course of decades, scores of Native American reservations have been targeted for high-level radioactive waste parking lot dumps, a shameful history of environmental racism. And, as but one of numerous such examples, Illinois' three-reactor Dresden nuclear power plant, and immediately adjacent General Electric-Morris reprocessing facility, already "host" around 3,000 tons of irradiated nuclear fuel on a single site. There is a high risk that this bill, if enacted, would increase the pressure to import and "consolidate" yet more waste there, as documented in an Oak Ridge study.

Rushing into high-level radioactive waste shipments on the roads, rails, and waterways makes no sense. Risks of Mobile Chernobyls, Dirty Bombs on Wheels, and Floating Fukushimas include severe accidents (high-speed crashes; high-temperature, long-duration fires; underwater submersions; etc.) or even intentional attacks. Such shipments to parking lot dumps would merely launch a radioactive waste shell game, as the wastes would have to be moved again someday, this time to permanent disposal sites. Thus, high-level radioactive waste transport risks would be multiplied, for no good reason.

Hardened On-Site Storage (HOSS) makes a lot more sense than this bad bill. HOSS calls for emptying vulnerable high-level radioactive waste storage pools into on-site dry cask storage, but would require significant upgrades to the safety, security, and environmental protections associated with dry cask storage: safeguards against accidents and natural disasters; concealment, distancing between casks, and fortification against attacks; and quality assurance on cask design and fabrication to ensure they will last not decades, but centuries, without leaking radioactivity into the environment. Nearly 200 environmental groups, representing all 50 states, have endorsed HOSS. They've been calling for it for well over a decade now.

Contact not only Sen. Wyden, but also your own two U.S. Senators, and urge that a strong linkage between "consolidated interim storage" and permanent disposal be re-established in this proposed legislation! Warn them that the risk of de facto permanent parking lot dumps for high-level radioactive waste is unacceptable! Let them know that rushing into Mobile Chernobyl shipments, and playing a radioactive waste shell game on the roads, rails, and waterways, makes no sense and takes unnecessary risks. Urge that Hardened On-Site Storage (HOSS) be required instead, as a common sense interim alternative to this bill's bad ideas.

Contact Sen. Wyden at the Energy and Natural Resources Committee he chairs {per their instructions immediately below, as posted on their website}:

{Directions for Submissions

Please submit comments electronically to: Nwaste_feedback@energy.senate.gov 

Submission due date: Friday, May 24, 2013 at 5:00pm (EST)

The documents attached below can be used as a template for submitting comments.  We request that you submit your comments in the template format, but will accept comments in other formats.  Please feel free to respond to as many or as few of the questions as you like.

Please provide your name and affiliation in the header of your comments.

The committee may post the comments, including any personal identifying information you provide (street or e-mail addresses, or phone numbers) it receives on its website.  If you would like your personal identifying information withheld, please indicate that.

The comment period will close on Friday, May 24, 2013.

Please find the submission documents below [linked here] and the link to the discussion draft, summaries and questions here.}

You can contact your own two U.S. Senators at their websites, or via the U.S. Capitol Switchboard at (202) 224-3121. Urge your Senators to oppose de-linking "consolidated interim storage" and permanent disposal. Urge them to block a rush into Mobile Chernobyl risks merely to play a radioactive waste shell game on the roads, rails, and waterways. Urge them to weigh in with Chairman Wyden and other members of the Senate Energy and Natural Resources Committee, and Energy and Water Development Appropriations Subcommittee.

Update on May 16, 2013 by admin

On May 2nd, at the invitation of Nuclear Energy Information Service (NEIS) in IL, Beyond Nuclear's Kevin Kamps presented via Skype to a "Night with the Experts" gathering at the NEIS office in Chicago on this proposed centralized interim storage and irradiated nuclear fuel transport legislation.

Reporter Kari Lydersen was in attendance, and published an article in Midwest Energy News entitled "Senate plan could make Illinois 'bullseye' for nuclear waste."

Update on May 16, 2013 by admin

ACTION ALERT

 Illinois candidate for national de facto permanent "centralized interim storage" radwaste dump

Greetings All:

Below and attached I provide a letter we just sent off to the Illinois Delegation to Congress and to select members of the Illinois Legislature, as well as the Governor's and AG's office.  It alerts them -- and now you -- to the potential for Illinois to be "selected" as a "voluntary" candidate to site a "centralized interim storage" facility which would store thousands of additional tons of hazardous high-level radioactive waste (HLRW) -- the so-called "spent" fuel rods from reactors.

We are alerting you to this possibility, and to the fact that both Sen. Wyden and his committee, and the Administration seem to be on a "fast track" to get this deal done.  This leaves little time for equivocation:  the question before us is simply -- does your organization favor storing an additional 3,000 to 4,000+ tons of HLRW in Illinois indefinitely (which is what "interim" usually means in Federalese)?

Our organization does not.

Since more than one site is envisioned, even if Illinois does not actually host such a facility, our excellent transportation net will probably see as much as 75% of all HLRW shipments made go into, through, and out of the state.  If we get the site, all arrows point to Illinois. (for more details about this, see the Oak Ridge National Lab report referenced by Kari Lydersen in her article; it's a chunky 17 MB file).

We will be providing you soon with a fact sheet on this issue.  We're happy to come discuss this legislative proposal with your staff and Board.  We will be scheduling a briefing on this proposed legislation within the next month, and would hope your organization could send a representative.  We urge you to provide comments on the webpage provided by Sen Wyden (see the link in the letter below).  And finally, we hope that your organization would oppose this ill-conceived, ineffective and unnecessary plan.  The only good it does is free up more space for the nuclear industry to make even more waste indefinitely.

Feel free to contact us if you have questions, or require additional information or resources.

Stay well, keep on doing,

 --Dave Kraft, Director--


LETTER TO LEGISLATORS AND OFFICIALS:

May 9, 2013

TO:      Illinois governmental contacts

FR:       Dave Kraft, Director

RE:       Illinois candidate for becoming national radioactive waste dumpsite

Greetings All:

I forward to you an article done yesterday, May 8, by journalist Kari Lydersen of  Midwest Energy News of great importance to Illinois:

Senate plan could make Illinois ‘bullseye’ for nuclear waste

http://www.midwestenergynews.com/2013/05/08/senate-plan-could-make-illinois-bullseye-for-nuclear-waste/

The gist of the article is that the new legislation being formulated by Sen. Ron Wyden’s Senate committee makes the likelihood quite high that Illinois will become a candidate to host one of the nation’s first de facto permanent high-level radioactive waste (HLRW) storage sites.

Although the process is planned to be “voluntary,” there is no doubt that the despicable practice of “incentivizing” accepting lasting environmental abuse for temporary jobs will be at play in the call for volunteers, especially in a state (and some would observe, sizeable portions of the Legislature) owned by Exelon Corporation.  Witness what is taking place already around the fracking issue.

The Oak Ridge National Laboratory report referenced by Ms. Lydersen in her article makes this abundantly clear:

“As a totally separate analysis, the consolidated ISFSI site in Illinois is the single optimized2 site for an ISFSI solution when only SNF at orphaned reactors is considered relative to siting a consolidated ISFSI. Base case five-site ISFSI solution showing transport routes to each storage location. Green background depicts ISFSI available siting.”  (p. xviii, ORNL/TM-2012-237 )

Translated into English, the proposed Congressional legislation intends to move HLRW from closed reactors all over the nation like Zion and Dresden-1 to what they call a “centralized interim storage” (CIS) facility, as yet unidentified, designed or constructed.  One or more of these facilities are contemplated; and the HLRW wastes from closed reactors will be given first priority for movement to a CIS.  The Oak Ridge report identified Illinois as THE best candidate site for these wastes from closed reactors, based on location and transportation routes.  Should this occur Illinois could receive an additional 3,000+ tons of HLRW from the currently closed reactors beyond the 8,600 tons we already host; and possibly more, since several reactors have been identified for closure since the 2012 report was done.

We have warned members of the Illinois Delegation to Congress of this possibility for the past two years.  Our warnings were met repeatedly with a  thunderous round of indifference.  Well, now it’s showtime, and there’s no place left to hide.  Officials are going to have to take a public stance on whether they favor the possibility of bringing an additional 3,000+  tons of hazardous spent-reactor fuel to Illinois for “temporary” storage.  With the Federal Government, temporary can mean a very long, long time, as witnessed by the fact that the Federal Government has been trying to site its first HLRW disposal site since 1982.

Sen. Wyden’s office is taking public comments on the proposed draft legislation until May 24^th.  The link for making comments is:

http://www.energy.senate.gov/public/index.cfm/nuclear-waste-bill-feedback

It will now be up to you, our elected officials, to defend Illinois from further radiation abuse.  We ask you to comment on the draft legislation, and let us know your position on this matter.  We are available to answer questions or provide resources to you to help inform your decision.

Thanks for your consideration in this matter.  We eagerly await your response to this letter.

Stay well,

David A. Kraft

Director

For Immediate Release: May 1, 2013

Contact: Keith Chu (Wyden), 202.224.0537

Robert Dillon (Murkowski), 202.224.6977

Committee Launches Webpage for Nuclear Waste Bill Feedback

Washington, D.C. – Today, the Senate Energy and Natural Resources Committee launched a webpage where the public and interested parties can submit comments on a discussion draft of comprehensive nuclear waste management legislation released by a bipartisan group of senators last week.

Senators Dianne Feinstein, D-Calif., and Lamar Alexander, R-Tenn. – the leaders of the Senate Appropriations Subcommittee on Energy and Water Development – and Energy and Natural Resources Committee Chairman Ron Wyden, D-Ore., and Ranking Member Lisa Murkowski, R-Alaska, sponsored the draft bill, which implements recommendations of the Blue Ribbon Commission on America’s Nuclear Future.

The webpage and instructions on how to submit comments on the draft bill can be found on the committee’s website here. The discussion draft, a one-page summary, section-by-section analysis, list of questions, and alternative policy options offered by Senators Alexander and Feinstein can be found here.

###

-- 

David A. Kraft,

Director

NEIS

3411 W. Diversey #16

Chicago, IL  60647

(773)342-7650

neis@neis.orgwww.neis.org

SKYPE address:  davekhamburg

No more Chornobyls!  No more Fukushimas!

Invest  in a nuclear-free world -- today!

Agency warns high-level nuke waste casks deteriorating, already

Nuclear waste storage casks for irradiated reactor fuel assemblies from two Pennsylvania nuclear power plants are showing signs of “premature degradation” after just a few years of storage of the timeless hazard. The Nuclear Regulatory Commission (Information Notice 2013-07) is cautioning operators of all nuclear power plants with the on-site dry cask storage systems that these hazardous material storage canisters are showing signs of deterioration. from “environmental moisture.”  At the Peach Bottom nuclear power plant, water has caused the corrosion of an O-ring seal on the lid of one of the nuclear waste storage casks allowing some of the helium coolant to leak out.  Not good, particularly because this cask was only 10 years old when a low pressure alarm sounded and its supposed to be licensable for up to 100 years. Meanwhile, a nuke waste cask from Three Mile Island Unit 2, the unit that had the nuclear accident in 1979, what fuel didn’t melt was put into dry casks for storage and shipped out to Idaho National Energy Laboratory. Seasonal freezing and ice has caused cracks to form in the concrete outer structure of one of the casks potentially shortening its projected 50 year service life.

Given that the nuclear waste is going to be extremely hazardous for millions of years, the "quality" of these casks suggests that this system is going to fail much sooner than currently credited.

Contact White House and Members of Congress -- urge them to put the brakes on unprecedented, high-risk shipment of LIQUID high-level radioactive waste

An infrared photo of solid irradiated nuclear fuel being shipped by rail. Liquid high-level radioactive waste could have a similar thermal -- as well as radiological -- "signature," if heat-generating radioactive isotopes are retained in the solution.

[Dr. Gordon Edwards has penned a Resolution Against the Transportation of Liquid [High-Level] Radioactive Wastes.

In just a single week, nearly 50 groups -- including Beyond Nuclear -- have endorsed the resolution.

Dr. Edwards welcomes additional organizations to endorse as well. If your group would like to endorse the resolution, please email your full contact information to Dr. Edwards at ccnr@web.ca.]

Unprecedented high-risk shipment of LIQUID high-level radioactive waste approved by Obama White House (April 1 to 5)

Background links on the shipment of LIQUID high-level radioactive waste, containing HEU, from Chalk River, Ontario to SRS, USA (ongoing updates, check back for new entries as time goes on)

Please contact President Obama, your U.S. Senators, and your U.S. Representative, and urge them to stop this unprecedented high-risk shipment of liquid HLRW! You can be patched through to your Members of Congress via the U.S. Congressional Switchboard at: (202) 224-3121. President Obama can be contacted by calling the White House at 202-456-1111, writing him online via the White House web form, or writing him at: President Obama; The White House; 1600 Pennsylvania Avenue NW; Washington, DC 20500.

Beyond Nuclear urged members of the U.S. Senate Energy and Natural Resources Committee to question President Obama's nominee for Energy Secretary, Ernest Moniz, about this issue during his April 9th confirmation hearing.

Update on May 22, 2013 by admin

Dr. Gordon Edwards has penned a Resolution Against the Transportation of Liquid [High-Level] Radioactive Wastes.

In just a single week, nearly 50 groups -- including Beyond Nuclear -- have endorsed the resolution.

Dr. Edwards welcomes additional organizations to endorse as well. If your group would like to endorse the resolution, please email your full contact information to Dr. Edwards at ccnr@web.ca. (The resolution is not for individual signatories at present. However, Dr. Edwards encourages individuals to seek the permission of groups to which they belong -- places of worship, civic organizations, etc. -- to endorse the resolution. And as he encourages below, individuals can also contact their own elected officials.)

As Dr. Edwards has written:

Your support will be crucial in our collective efforts to prevent the transport of 23,000 litres (over 6000 US gallons) of high-level waste in liquid form from Chalk River Laboratories (CRL) in Ottawa to the Savannah River Site (SRS) in South Carolina. (See map [above left] -- but please note that the exact route and timing of the armed shipments will be kept absolutely secret.)

The Age of Nuclear Power is rapidly waning, but the Age of Nuclear Waste is just beginning in earnest. Please contact your elected representatives and alert them to the dangers of political inaction at this critical time.

Steps must be taken to protect the health and safety of people and the environment. Nuclear waste materials must be kept off our roads and waterways. These dangerous materials must be dealt with on-site and kept securely isolated from the environment of living things.

Cheers,

Gordon Edwards, Ph.D., President, Canadian Coalition for Nuclear Responsibility.

http://ccnr.org

Unprecedented, high-risk shipment of liquid high-level radioactive waste approved by Obama White House

An infrared photo of solid irradiated nuclear fuel being shipped by rail. Liquid high-level radioactive waste could have a similar thermal -- as well as radiological -- "signature," if heat-generating radioactive isotopes are retained in the solution.Liquid high-level radioactive waste (HLRW) has never been shipped in North America, according to Dr. Gordon Edwards of the Canadian Coalition for Nuclear Responsibility.

But, thanks to the vigilant watchdogging of the Savannah River Site (SRS) nuclear weapons complex, by FOE's Tom Clements in South Carolina, we now know that the Obama White House has approved a U.S. Department of Energy (DOE) plan to rush such shipments from Chalk River in Ontario, Canada to South Carolina for reprocessing.

As Dr. Edwards' backgrounder (see below) points out, the driving motivation seems to be, not nuclear weapons non-proliferation (as the Obama administration and DOE are trying to claim (the liquid HLRW contains potentially weapons-usable HEU, highly enriched uranium), but rather the Canadian government's attempt to save money, and bother, by paying DOE $60 million to simply take it off their hands, and ship it to SRS. For its part, SRS hopes to keep its dirty, dangerous, and expensive reprocessing capability on life support. The multiple, high-risk shipments could cross the border in the Northeast, New York, and/or Michigan, and cross numerous states before reaching South Carolina.

Please contact President Obama, your U.S. Senators, and your U.S. Representative, and urge them to stop this unprecedented high-risk shipment of liquid HLRW! If your U.S. Senator serves on the Energy and Natural Resources Committee, urge him or her to ask Ernest Moniz about the risks of these proposed shipments during his Senate confirmation hearing for DOE Secretary. If your neither of your Senators serve on the ENR Committee, urge them to urge their colleagues who do to ask the question. You can be patched through to your Members of Congress via the U.S. Congressional Switchboard at: (202) 224-3121.

President Obama can be contacted by calling the White House at 202-456-1111, writing him online via the White House web form, or writing him at: President Obama; The White House; 1600 Pennsylvania Avenue NW; Washington, DC 20500.

BACKGROUND

On April 1, 2013,  Dr. Gordon Edwards of the Canadian Coalition for Nuclear Responsibility wrote the following "Note to everyone concerned about the shipment of high-level liquid radioactive waste from Chalk River [Ontario, Canada] to Savannah River [Site, South Carolina]":

Tom Clements [Friends of the Earth, Columbia, SC] has been notified by telephone today that the US DOE has determined, through a "supplementary analysis" (with no public input) that there is no need for a "supplementary environmental assessment" as requested by Tom some time ago.

Such a supplementary EA would have at least delayed the project for six months or so, while giving the public an opportunity to intervene in this dossier.

Tom was told that the US Government has now approved these shipments -- and that the approval has come from the White House, justified as part of Obama's non-proliferation initiative -- via Laura Holgate, the same woman who was in charge of the weapons-grade-plutonium-into-reactor-fuel (MOX) program previously. (She played an important role in the shipment of weapons-grade plutonium to Chalk River from Los Alamos for testing the use of MOX ("mixed oxide") fuel in CANDU reactors.)

There will be a short notice sent to some press and interested individuals very soon (perhaps even today or tomorrow [April 1 or 2]) that approval for the shipments has been given.  So at this point either the US decision will have to be challenged in court or the Canadian approval process will have to be delayed and opened up if there is to be any chance of public intervention.

It seems clear that the "non-proliferation" goal of repatriating weapons-grade uranium is being subverted for other purposes.

On the US side, the main goal of the Savannah River management is to keep the H-canyon reprocessing facility running -- it has been very difficult for them to get enough business to keep the reprocessing plant running.  On the Canadian side it is cheaper to pay $60 million to send the contents of the FISST tank down to the US than to deal with those wastes on-site.

Important points to bear in mind:

(a) High-level radioactive LIQUID waste has never been transported over public roads and bridges in North America up to now.

(b) The 23,000 litres of high-level radioactive liquid waste that is supposed to be shipped from Chalk River down to Savannah River (almost 2000 km) is all from one tank -- the Fissile Solution Storage Tank (FISST).  But the use of this tank has been discontinued since 2003....

(c) The liquid in the FISST tank is a fiercely radioactive solution of nitric acid containing many fission products including cesium-137 and strontium-90, several transuranic elements including plutonium and americium, and residual amounts of weapons-grade uranium-235.  This material gives off deadly levels of penetrating gamma radiation for centuries and will remain highly radiotoxic for hundreds of millennia, long after the gamma radiation has died down.

(d) The high-level radioactive liquid solution that used to be added to the FISST tank was waste left over from the production of medical isotopes; that same liquid material is still being produced at Chalk River from isotope production, but now the liquid is being solidified by a "cementation" process instead of being stored in a liquid form.

(e) In addition to the FISST tank, there is a "tank farm" at Chalk River containing 13 other tanks of liquid radioactive waste -- and this liquid waste is already being solidified by AECL [Atomic Energy of Canada, Limited] using a process of cementation.

(f) So there are a number of important questions that have not been dealt with:
 
 (1) If Chalk River has been solidifying other liquid wastes and will continue to do so, why are they not solidifying the contents of the FISST tank?

 (2) If, for the last ten years (2003-2013) Chalk River has been solidifying liquid HLW containing HEU, why is DOE content to have AECL store that material onsite but is not content to have AECL continue to store (solidified or not) the liquid contents of the FISST tank?

 (3) Since HEU is weapons-grade material the risk of a criticality accident (a spontaneous chain reaction) will become increasingly worrisome as the liquid in the tank is being "drawn down"; how is this to be analyzed and prevented?

 (4) Since HLW in liquid form is extremely mobile in the environment and since the existing Environmental Assessment documents for shipping HEU-bearing irradiated fuel makes no mention of shipping liquid HLW, how is it possible that a supplementary EIS is not required?

Gordon Edwards.