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NRC nuke waste con game: final written public comment submissions re: DGEIS due 12/20!

Environmental coalition members from the Crabshell Alliance, Sierra Club Nuclear-Free Campaign, NIRS, PSR, NEIS, and Public Citizen "just say NO!" at the NRC HQ nuke waste con game public comment meeting on 11/14 in Rockville, MD. Photo credit David Martin and Erica Grey.

Thanks to all who submitted oral comments to NRC at the call-in on 12/9, the final public meeting re: NRC's bogus nuke waste con game Draft Generic Environmental Impact Statement (DGEIS).

Please continue to submit your public comments to NRC via email, webform, fax, and/or snail mail. You can submit as many public comments as you want, between now and the final public comment deadline (Friday, Dec. 20th).

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

Additional ideas for public comments can be found in the reports back from the field hearings, below. Key comments that need to be made again and again: It's time to stop making high-level radioactive waste! For that which already exists, the environmental consensus is to empty the pools into hardened on-site storage, where appropriate -- requiring a significant upgrade in dry cask storage safety, security, and environmental protection.

Please note that on Thurs., Dec. 19th at 11 AM Eastern, Diane Curran and Mark Cooper, attorney and expert witness, respectively, representing a coalition of dozens of environmental groups, will hold a press conference entitled: EXPERT TO TELL NRC THAT HIDDEN COSTS OF REACTOR WASTE STORAGE & DISPOSAL MAKES NUCLEAR POWER LESS ATTRACTIVE THAN WIND, SOLAR, AND MORE ENERGY EFFICIENCY; Do High Costs of Nuclear Now Make Licensing and Re-Licensing Indefensible in Terms of the Economics?; Comments to NRC From Economist Mark Cooper State Federal Agency Must Consider Full Cost of Nuclear Waste Storage and Disposal.  Cooper serves at the Vermont Law School. Curran serves at Harmon Curran Speilberg + Eisenberg LLP in Washington, D.C. See the Hastings Group's press advisory, with instructions on how to listen-in to the press conference, either live in real time, or to the audio recording afterwards. The Hastings Group has also issued a press release. 


The U.S. Nuclear Regulatory Commission (NRC) Nuclear Waste Confidence Directorate has concluded all of its scheduled public comment meetings on the draft Generic Environmental Impact Statement (GEIS) regarding the agency's "Nuclear Waste Confidence." However, there is still the opportunity to submit written comments at any time up till December 20th.

The GEIS was court-ordered, by the D.C. Circuit Court of Appeals, in June 2012. A coalition of environmental groups (Blue Ridge Environmental Defense League, Riverkeeper, Southern Alliance for Clean Energy, as well as Natural Resources Defense Council) and states (CT, NJ, NY, and VT, as represented by their attorneys general) won the court victory. We owe them all a huge debt for this tremendous environmental victory, which has effectively blocked any finalization of old reactor license extensions, or the granting of new reactor construction and operating licenses, by NRC until it completes the GEIS.


Over 700 public comments (both pro- and con-"Waste Confidence") are accessible for viewing via


Rockville, MD NRC HQ call-in public comment meeting, Dec. 9th (see NRC's transcript, including Kevin Kamps of Beyond Nuclear's testimony at transcript pages 30-34, and again at transcript pages 60-62).

Minnetonka, MN public comment meeting, Dec. 4th

Thanks to John LaForge of Nukewatch Wisconsin for providing this write-up on this meeting.

Severe weather made for a small turn out, so we are very thankful to those brave few who defied the elements to speak truth to power!

"Mr. Burns" hands out chunks of radioactive waste to the public. Photo by Kathy Barnes of Don't Waste MI.Perrysburg, OH public comment meeting, Dec. 2nd

Note that the 12/2 meeting in Toledo marked the 71st year since Enrico Fermi first split the atom in a prototype reactor core, generating the world's first high-level radioactive waste (HLRW) on Dec. 2, 1942, as part of the Manhattan Project. Thus, the mountain of radioactive waste is now 71 years high, and we still don't even know what to do with the first cupful!

Kevin made that point, and others site-specific to Great Lakes reactors, including Palisades in MI and Davis-Besse near Perrysburg, from minute 3:00 to 8:37 on a video recording of the public meeting, filmed by Kathy Barnes of Don't Waste MI (Part 4). Kathy also coordinates the Don't Waste MI Facebook page.

(See the NRC transcript of the meeting, including Kevin Kamps of Beyond Nuclear's comments from pages 41 to 45 of the transcript.)

Kathy's videorecording also captured the street theater before the meeting (Part 1), as well as the public comments themselves (Part 2; Part 3; Part 5; Part 6; Part 7; Part 8; Part 9).

Kathy's still photo (to the left) shows "Mr. Burns" handing out "chunks of radioactive waste" (Atomic Fireball candies) to the public. "Mr. Burns" thanked the public for being such suckers, as the nuclear industry laughed all the way to the bank. He also advised them to quickly encase their chunks of radioactive waste in lead lined boxes, or else they'd be dead in three minutes from gamma radiation exposure. The skit was cooked up in Oak Brook, IL, to counter the Nuclear Energy Institute's handing out of fake uranium pellets, while failing to mention that irradiated uranium fuel pellets are deadly forevermore. The theme of the street theater was "The Emperor's New Clothes." Mr. Burns' wore an x-ray version, inspired by Russell Hoffman's "The Demon HOt Atom" graphic, showing where radioactive poisons lodge, and do their damage, in the human body.

Critics and skeptics of NRC's "Nuclear Waste Confidence" outnumbered supporters and apologists by a count of 35 to 9 -- that is a ration of nearly 4 to 1!

Tom Henry of the Toledo Blade reported on this story.

Evan Davis, host of the radio program "Conscious Voices" at WCRS, community radio in Columbus, OH (102.1/98.3 FM), also reported on this story. His hour-long radio report, entitled "NRC proposes rule change to allow indefinite waste storage," begins with 10 minutes of introduction, progressive event announcements in the listening area, and a special report on coal issues. Then, from the 11:15 to 29:15 minute mark, Lee Blackburn with the Ohio Sierra Club Nuclear-Free Committee discusses NRC's "Nuclear Waste Confidence," followed by Kevin Kamps of Beyond Nuclear from 30:15 to 48:20. The rest of the show features three public comments made at the meeting, by Vic Macks of southeastern MI, Bob Parker of Cleveland, and Mr. Kelly Farris of Put-In-Bay, OH.

Re: the 12/2 Toledo-area meeting, Michael Keegan of Don't Waste MI and the Coalition for a Nuclear-Free Great Lakes put out a press advisory. Its headline was RALLY AGAINST NUCLEAR WASTE CONFIDENCE GAME: ‘THE EMPEROR HAS NO CLOTHES.’

The co-chairs of the Alliance to Halt Fermi 3, Keith Gunter and Carol Izant, also issued a press advisory announcing that representatives from their growing coalition of groups would speak at the 12/2 Perrysburg, OH meeting.

San Luis Obispo, CA, public comment meeting, Nov. 20th

San Luis Obispo Mothers for Peace also provided sample comments in advance of its NRC nuke waste con game public comment meeting, held on 11/20.

Rockville, MD public comment meeting, Nov. 14th

At the Nov. 14th Rockville, MD NRC HQ public comment meeting, Beyond Nuclear's Kevin Kamps joined with numerous colleagues (see photo, above left) to testify.

In the short three minutes allotted for public comment, Kevin set the record straight on false statements the NRC has made in regards to its nuke waste con game policy.

At the Chicago public meeting on Nov. 12th, NRC Nuclear Waste Confidence Directorate Director, Keith McConnell, responded to a question from the audience about the scope of this draft GEIS. McConnell said that it had to do with "on-site" or "at-reactor" storage of irradiated nuclear fuel. Kevin set the record straight, pointing out that there is an entire section of the GEIS document, Chapter 5, about "Environmental Impacts of Away-From-Reactor Storage." This implies high-level radioactive waste (HLRW) transportation as well, a very significant issue that has gotten very short shrift in this draft GEIS.

And of course, the heart of NRC's "Nuclear Waste Confidence" for 30 years now has been the assumption that a deep geologic repository will open someday, somewhere, somehow. The courts, however, have ordered NRC to consider the all-too-real possibility that a repository will never open, leaving HLRW risks at-reactor or away-from-reactor (as at so-called "consolidated" or "centralized interim storage" sites -- parking lot dumps -- the opening of which, by 2021, is a top priority of the Wyden-Feinstein-Murkowski-Alexander "Mobile Chernobyl" bill, S. 1240, in the U.S. Senate, now set for a Senate Energy and Natural Resources Committee vote in December 2013).

See the transcript from the meeting, including Kevin Kamps of Beyond Nuclear's remarks from page 102-107.

Oak Brook, IL public comment meeting, Nov. 12th

See a write-up of the Chicago NRC nuke waste con game, for more ideas on potential comments you can make. See the transcript from this public comment meeting, including Kevin Kamps from Beyond Nuclear's remarks at transcript pages 50 to 54.

Tarrytown, NY public comment meeting, Oct. 30th

Marilyn Elie of Indian Point Safe Energy Coalition (IPSEC) provided Beyond Nuclear with the written statements by IPSEC members, NY AG Schneiderman, and others, from the Oct. 30th NRC public comment mtg. in Tarrytown, NY near Entergy's Indian Point nuclear power plant. Beyond Nuclear has posted these, so you can use them to help prepare your own.

Douglas P. Guarino, the award-winning reporter, wrote an article entitled "Legal Battle Against Rule Crucial To All U.S. Reactor Licenses Rages On" for Global Security Newswire. He quote Janice Dean, Assistant Attorney General of the State of New York, who testified at the Tarrytown, NY meeting.

NRC HQ public comment meeting, Rockville, MD, Oct. 1, 2013:

See the transcript of the meeting, including Kevin Kamps of Beyond Nuclear's testimony at pages 37-41 of the transcript.

NRC video recordings and transcripts from public comment meetings (Oct. 1 to Dec. 9)

Please note that NRC's Nuclear Waste Confidence Directorate has posted the archived webcast, as well as the audio recording, from the very first public comment meeting on Oct. 1 at NRC HQ in Rockville, MD; it has also posted the transcripts from all the public comment meetings held around the country; and it has posted the audio recording from the call-in public comment meeting on Dec. 9th. You can use the presentations made by hundreds of environmentalists and public interest advocates in these sessions to help you prepare your own comments.

Oct. 2nd Curran/Thompson/Alvarez press conference on the catastrophic risks of high-level radioactive waste pool fires

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 potentially catastrophic risks of high-level radioactive waste storage pool fires, which NRC is currently ignoring, despite an explicit court order for NRC to address them in the EIS.

Curran, along with Mindy Goldstein of Turner Environmental Law Clinic at Emory University, are working with a team of experts, including Dave Lochbaum of Union of Concerned Scientists, and Arjun Makhijani of Institute for Energy and Environmental Research, to prepare comments, on behalf of an environmental coalition comprised of two dozen groups, including Beyond Nuclear, to be submitted by the 12/20 deadline.