Top Ten Overarching Comments, in Summary Form, Submitted to DOE on March 4 by a Coalition of 140 Groups, Opposing Federal CISFs

(1.) The most serious and inevitable risk if the U.S. Department of Energy were to take ownership of commercial highly radioactive nuclear waste before a permanent geologic repository opens: federal Consolidated Interim Storage Facilities would likely become Consolidated Permanent Surface Storage, that is, de facto Above-Ground Permanent Disposal, or Parking Lot Dumps.
****

(2.) Indefinitely long, to permanent, surface storage at federal CISFs would require active features. Loss of institutional control anytime over the next million years would mean the potential for catastrophic releases of hazardous radioactivity into the environment, which would harm people and other living things downwind, downstream, up the food chain, and down the generations, potentially out to great distances, depending on wind- and water-driven flow over long periods of time.
****

(3.) Indefinitely long, to permanent, surface storage at federal CISFs would remain dangerously accessible, risking unintentional/accidental, but nonetheless catastrophic, releases of hazardous ionizing radioactivity, as due to container degradation/failure over time, extreme weather disasters due to climate chaos, etc. However, intentional releases, as due to an act of war, terrorist attack, or sabotage, are also possible. So too is theft/diversion of weapons-usable materials, risking proliferation of nuclear weaponry and/or radiological “dirty bombs.”
****

(4.) Indefinitely long, to permanent, surface storage at federal CISFs would achieve only very short-term effectiveness, at best, compared to the extremely long hazardous persistence of irradiated nuclear fuel and highly radioactive waste.
****

(5.) Indefinitely long, to permanent, surface storage at federal CISFs, would result in
intergenerational inequity, a form of environmental injustice.

****

(6.) Any legal authority for DOE to take title to and liability for commercial irradiated nuclear fuel at a federal CISF, in the absence of a permanent geologic repository, was very limited as to the quantity that could be stored there (just 1,900 metric tons), was for emergency purposes only, and expired more than three decades ago.
****

(7.) Federal CISFs would multiply the highly radioactive waste transportation risks, while accomplishing no increase whatsoever in the safety, security, health, or environmental protection associated with its storage.

****

(8). Nuclear power should be phased out and abolished, so that no more highly radioactive waste will be generated. We need to stop making it in the first place. However for highly radioactive irradiated nuclear fuel (INF) that already exists, hardened on-site storage (HOSS), or hardened near-site storage, is the best interim measure, not CISFs. HOSS, or hardened near-site storage, is the preferred interim alternative, not CISFs.

****

(9.) The continued targeting of CISFs at BIPOC (Black, Indigenous, People of Color) and/or low-income communities, already disproportionately burdened by pollution and hazardous facilities, is a violation of environmental justice principles. DOE, which itself has an infamous history of targeting Native American reservations for CISFs (previously called by other names, such as Monitored Retrievable Storage (MRS) sites, Independent Spent Fuel Storage Installations (ISFSIs), Away From Reactor (AFR) sites, etc.), must cease and desist from such environmentally/radioactively racist practices.
****

(10.) Federal CISFs would be a dangerous dead-end detour on the road to a scientifically/technically, and socially acceptable, repository. Federal CISFs would also constitute a radical reversal of long established U.S. policy, law, regulation, and court precedent, which has held the private owners of commercial irradiated nuclear fuel responsible for its interim storage, while the federal government (that is DOE, using federal taxpayer funds) is responsible for permanent disposal.