How/where/when to submit comments on NRC's Supplemental EIS on proposed Yucca dump
August 26, 2015
admin

NRC published notification of its Draft Supplemental Environmental Impact Statement (DSEIS) in the Federal Register on Aug. 21. The DSEIS is posted on NRC's website.

Public comments are currently due by Nov. 20 (the deadline had originally been one month earlier, by Oct. 20, but under pressure from the State of Nevada and several environmental groups, including Beyond Nuclear, the NRC, at the Sept. 3rd meeting, announced a one-month extension. However, Beyond Nuclear is still demanding the additional 30-day extension, till Dec. 20. We will keep you posted whether or not we persuade NRC to grant it.).

Per the Fed Reg Notice, comments can be submitted:

via the Federal Rulemaking Web site: Go to http://www.regulations.gov and search for Docket ID NRC-2015-0051;

or, by mailing comments to Cindy Bladey, Office of Administration, Mail Stop: OWFN-12-H08, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Public comments can also be submitted orally at the following-in person NRC meetings:

NRC has stated: "Persons interested in attending or presenting oral comments at any of the public meetings are encouraged to pre-register. Persons may pre-register to attend or present oral comments by calling 301-415-6789 or by emailing YMEIS_Supplement@nrc.gov no later than 3 days prior to the meeting. To provide oral comments, members of the public may also register in person at each meeting."

To obtain further information about this public comment period, the Fed Reg Notice lists as NRC point of contact: Christine Pineda, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; telephone: 301-415-6789; email: YMEIS_Supplement@nrc.gov. (However, to be clear, Ms. Pineda's contact info., such as her email address, is not listed as a way to submit comments.)

Regarding WHAT comments to make, Beyond Nuclear will publish sample talking points ASAP, after having the chance to analyze the draft SEIS. You can use those to write your own. But here is a starter, below. Always specifiy the report number NUREG–2184, as well as the Docket ID NRC-2015-0051, in the subject line of your comments, so they can be routed to the correct docket.

 

SAMPLE COMMENTS [see additional sample "Talking Points," update below]

NRC's DSEIS has absurdly concluded that radioactive releases from the proposed Yucca Mountain high-level radioactive waste dump would be SMALL -- that is, essentially minimal, and harmless -- over the course of a million years into the future.

Actually, if irradiated nuclear fuel is ever buried at Yucca, it would leak massively, into the groundwater, creating a "nuclear sacrifice zone" over a broad region downstream.

This would include hazardous, even deadly, radioactive contamination of the groundwater, currently used for drinking and irrigation water in Nevada's agricultural Amargosa Valley; the Ash Meadows National Wildlife Refuge, Death Valley National Park, as well as the Timbisha Shoshone Indian community inhabiting Death Valley, would also be in harm's way.

The potential for disproportionate impacts on minority or low-income populations is especially high, considering the current lifestyle of the Timbisha Shoshone Indian community, as well as the traditional lifestyle of the Western Shoshone Indian Nation.

The potential for cumulative impacts associated with other past, present, or reasonably foreseeable future actions is very high. After all, the U.S. Atomic Energy Commission, Department of Energy, and military conducted atmospheric nuclear weapons tests in the vicinity of Yucca Mountain from 1951 to 1963. They continued to conduct underground full-scale nuclear weapons tests at the Nevada Test Site (NTS) from 1963 to 1992, many of which leaked radioactivity to the atmosphere and environment, as well as contaminated regional groundwater. Even after 1992, nuclear weapons testing has continued at the NTS, in the form of sub-critical experiments involing plutonium.

Another cumulative impact involves the large-scale transport to, and dumping of so-called "low" level radioactive wastes at, the NTS.

We join with the State of Nevada Agency for Nuclear Projects, several environmental groups, and others in urging NRC to extend the public comment deadline by at least an additional 60 days. We also urge that additional in-person public meetings be scheduled in California (where Yucca's radioactively contaminated groundwater would ultimately surface in springs), as well as elsewhere across the country (given that Yucca's opening would launch the unprecedented, large-scale shipment of risky high-level radioactive waste by truck, train, and barge, through most states. And we urge that all in-person public meetings also include the call-in option, already being provided at other locations, on other dates.


And lastly, WHY to comment? A thousand environmental groups, representing every state in the Union, have joined with the Western Shoshone Indian Nation, as well as the State of Nevada and its U.S. congressional delegation, ever since the "Screw Nevada bill" of 1987, to stop the dangerous Yucca Mountain dump. Now is no time to let up the resistance.

Update on September 1, 2015 by Registered Commenteradmin

Mary Olson at NIRS Southeast has circulated sample "Talking Points" -- the Nevada Nuclear Waste Task Force provided the basis for these talking points.

Update on September 2, 2015 by Registered Commenteradmin

More sample talking points, shared by Mary Olson of NIRS SE, you can use to prepare your own:

HOW does NRC account for the inclusion of High-Burnup Fuel in the Yucca Mt post-closure impact analysis?

If NRC is not factoring High-Burnup fuel as waste, then it is not accurately assessing these factors, all of which impact the post-closure impacts:

Heat load (including over time);

Source Term (ditto);

Mobility of radionuclides in the source-term profile.

If the amount of radioactivity, the type of radioactivity and its contribution to the heat issues are wrong, then the Total System Performance used to project the post-closure outcomes should be corrected and the Draft SEIS tabled until the TSPA is corrected.

FOR MORE ON HIGH-BURNUP WASTE, See Donna Gilmore/Marvin Resnikoff’s fact sheet on High Burnup Fuel:

http://sanonofresafety.org/2014/01/08/high-burnup-fuel-fact-sheet-2/

And Donna’s report on NRC ignoring High Burnup as an issue in nuclear waste transport: (Strong circumstantial evidence that NRC has also ignored High Burnup issues in the matter of Yucca Mt.)

http://sanonofresafety.org/2014/02/21/nrc-ignores-high-burnup-in-spent-fuel-transportation-risk-assessment/

Here is a more “muted” version from NV Nuclear Waste Task Force:

Regarding high burn-up - If there is not the 7,000 MTU [Metric Tons Uranium] of defense waste in the repository it could possibly be made up by adding more commercial waste to fill the 70,000 MTU statutory capacity. Some or all of that 7,000 MTU could be high burn-up which becomes a TSPA problem, because it does not consider high burn-up fuel (above 45 Gwd -- Giga-watt days) in its calculation. This could be an additional contributor to the assertion that the starting point contaminant concentration for the SEIS has no credible technical basis.

Article originally appeared on Beyond Nuclear (http://www.beyondnuclear.org/).
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