(The wise cancellation by the Obama administration of the proposal to dump 63,000 metric tons of commercial irradiated nuclear fuel -- and another 7,000 metric tons of DOE high-level radioactive waste -- at Yucca Mountain in Nevada, laid bare the false confidence of NRC in the eventual opening of a repository "when needed" in the U.S. This was a key factor in the D.C. Circuit Court of Appeals' ruling that NRC must prepare an EIS under NEPA regarding the risks of generating and storing irradiated nuclear fuel. The court made explicit that NRC's "mere hope" that a repository will open eventually is not good enough, and ruled that NRC must consider the possibility that a repository will never open. In fact, military wastes have been piling up since 1942, and commercial wastes since 1957, and we still don't even know what to do with the first cupful!)
A special thank you to all those who took action, as urged in Beyond Nuclear's weekly email bulletins, and submitted comments in writing to NRC, or testified orally at public meetings. The final count is not in yet, but it's safe to say many hundreds -- if not thousands -- of high-quality comments were submitted by the Dec. 20th deadline.
In addition to its involvement in environmental coalition efforts, Beyond Nuclear also submitted its own public comments to the U.S. Nuclear Regulatory Commission (NRC) re: its "Nuclear Waste Confidence" Draft Generic Environmental Impact Statement (DGEIS) deadline on Dec. 20th. Beyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, submitted comments, as well as supporting documents (Exhibits: A to E; F to I; and J to O).
Kay Drey, a Beyond Nuclear board of directors member based in St. Louis, MO, also submitted comments. Kay is also the author of the numerous pamphlets listed below, and the inspiration behind the Dec. 2-3, 2012 "Mountain of Radioactive Waste 70 Years High" conference held at the U. of Chicago mentioned below.
Paul Gunter, Director of Beyond Nuclear's Reactor Oversight Project, also submitted comments, telling the inspiring story of "at least 92 of 137 towns adopted identical language 'to oppose the burial, storage, transportation and production of high-level radioactive waste' in New Hampshire" in 1986. In a tremendous grassroots democracy victory, town warrant articles were passed across "the Granite State" -- the month before Chernobyl exploded and 25 years before Fukushima Daiichi melted down -- in opposition to the Department of Energy's proposal to destroy seven historic New Hampshire towns in order to build a national geologic repository for high-level radioactive waste beneath them.
In Nov. 2007, amidst the presidential primary campaign then raging in New Hampshire, Beyond Nuclear published a fact sheet entitled "A New Hampshire High-Level Radioactive Waste Dump?" In the section on "What's at Stake?", Beyond Nuclear reported:
"Several towns, including Hillsborough (frequently spelled Hillsboro), New Hampshire sit atop a large granite formation identified as the “Cardigan Pluton.” The rock body is part of the DOE’s Crystalline Rock Repository Project to site a second national nuclear waste repository. If selected, the populations declining a federal buyout would be subject to relocation and their property seized by eminent domain for the deep geological repository. This dubious distinction persists despite many geological and hydrological flaws in the candidate site including rock fractures, high amounts of rainfall, broad uncertainty about groundwater movement through the rock body and migration of radioactivity from nuclear waste into aquifers for drinking and agricultural irrigation supplies for large populations.
In addition to the environmental impacts, federal confiscation would adversely impact the deep historical significance of the area: the nearby town of Washington, the first town in the U.S. to be named after our first president, just after the Revolutionary War; numerous preserved stone arch masonry bridges; the Franklin Pierce Homestead, the home of the 14th President of the United States; the founding congregation and church of the Seventh Day Adventist denomination are examples. There is also the natural beauty of the area: forested hills, scenic lakes and river-ways. Much of this, along with picturesque, historic towns and villages would cease to exist if a national high-level radioactive waste dump opened in New Hampshire."
In fact, as the Beyond Nuclear backgrounder warned, in the waning days of the George W. Bush administration in late 2008, Energy Secretary Bodman issued a Report on the Need for a Second Repository that indeed listed both New Hampshire and Maine (and most of the rest of the Lower 48) on the target list. (The map on page 12 showed this.)
Re: NRC's nuke waste con game deadline, Kevin also submitted the following additional comments: regarding nuclear industry whistleblower Oscar Shirani's revelations on Holtec dry cask Quality Assurance violations, and NRC dry cask storage inspector Dr. Ross Landsman's support for Shirani; a cover letter and backgrounder on dry cask storage problems; a cover letter, and the Statement of Principles for Safeguarding Nuclear Waste at Reactors, in support of Hardened On-Site Storage (HOSS), signed by hundreds of environmental groups representing all 50 states; a cover letter, and the Beyond Nuclear fact sheet "Catastrophic Risks of GE BWR Mark I High-Level Radioactive Waste Storage Pools"; a cover letter, and Beyond Nuclear pamphlet "Routine Radioactive Releases from U.S. Nuclear Power Plants," as well as a chart, prepared by Russell Hoffman, showing into which particular organs specific radioactive contaminants lodge to cause harm in the human body; a cover letter, packet of materials from "A Mountain of Radioactive Waste 70 Years High" conference, and Beyond Nuclear pamphlet of the same title; a cover letter, and assorted humorous placards, prepared by NEIS for a "nuke waste con game" of "nuclear bingo" at NRC's public comment meeting in Oak Brook, IL; a cover letter, and Beyond Nuclear pamphlets "Dirty, Dangerous, and Expensive," as well as "Nuclear Fuel Reprocessing = Weapons Proliferation"; a cover letter, and sheet prepared by NEIS entitled "It All Boils Down To -- Do We Trust the NRC?".
In addition, Kevin had earlier submitted oral comments at a number of NRC public meetings:
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).
Perrysburg, OH NRC public comment meeting, Dec. 2nd:
Kevin made points site-specific to Great Lakes reactors, including to Palisades in MI and to 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 coordinates the Don't Waste MI Facebook page.)
NRC HQ (Rockville, MD) public comment meeting, Nov. 14th:
Oak Brook, IL public comment meeting, Nov. 12th:
NRC HQ public comment meeting, Rockville, MD, Oct. 1, 2013: