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ARTICLE ARCHIVE

Centralized Storage

With the scientifically unsound proposed Yucca Mountain radioactive waste dump now canceled, the danger of "interim" storage threatens. This means that radioactive waste could be "temporarily" parked in open air lots, vulnerable to accident and attack, while a new repository site is sought.

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Tuesday
Mar082022

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

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(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.
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(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.

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(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.

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(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.
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(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.

DateMarch 8, 2022 | Print ArticlePrint Article | |
Friday
Mar042022

Coalition comments to DOE, in defense of Environmental Justice, and opposed to federal CISFs under the ruse of "consent-based siting"

Beyond Nuclear was joined by 139 other organizations, as well as additional individuals, to submit coalition comments to the U.S. Department of Energy by its March 4, 2022 deadline. The coalition did so under protest, as 50+ organizational and individual members of the coalition had requested, in a Feb. 15 letter, that DOE withdraw its Request for Information on "consent-based siting" for federal consolidated interim storage facilities. DOE simply ignored the Feb. 15 letter, neither acknowledging receipt, nor answering it in any way.

See the coalition comments letter, here (as submitted at 3:20pm ET on Friday, March 4, 2022).

(Three additional groups, and one individual, endorsed the comments after that; they were also communicated to DOE ASAP, some before DOE's 5pm ET deadline on March 4, some after.)

Thank you to the 139 other organizations, and additional individuals, who joined Beyond Nuclear in defending environmental justice by endorsing these coalition comments! They are listed below.

DateMarch 4, 2022 | Print ArticlePrint Article | |
Thursday
Feb172022

We Do Not Consent! Coalition Calls for DOE Do-Over

Beyond Nuclear has joined with 50 organizations and individuals, urging the U.S. Department of Energy to re-do its fatally flawed Dec. 1 Request for Information re: "consent-based siting" of federal consolidated interim storage facilities for highly radioactive wastes. Our legal counsel, Diane Curran, submitted the letter on Feb. 15, calling on DOE to withdraw the RFI, and if necessary, to revise and re-publish it. The request featured Native American NGOs and Indigenous-led groups, including CRAFT, IEN, HOPE, MASE, NAWO, NCAC, and NISG. DOE has failed to adequately consult with Native American tribes in a legally required government-to-government manner, especially given DOE's infamously bad past behavior on an issue so critical to environmental justice.

READ MORE
DateFebruary 17, 2022 | Print ArticlePrint Article | |
Tuesday
Feb152022

Order from DC Circuit Court of Appeals sets briefing schedule in DWM, et al. v. NRC

The United States Court of Appeal has issued an Order in the case of Don't Waste Michigan, et al. versus United States Nuclear Regulatory Commission, the federal appeal against NRC's licensing of the Interim Storage Partners, LLC consolidated interim storage facility in Andrews County, Texas, on the New Mexico state line.

The first deadline, for Petitioners' Opening Briefis, is on Friday, March 18, 2020.

This deadline had previously been set for January 20, 2020, but a week prior, the court had suspended the proceeding, in order to address newly filed aspects of the federal appeal.

Parties opposing ISP in this federal appeal in the second highest court in the land include the eponymous Don't Waste Michigan, et al. -- a seven-organization and one-individual national grassroots environmental coalition. Terry Lodge, a Toledo, OH attorney, serves as legal counsel.

Another party opposing ISP is Sierra Club. Cedar Rapids, IA attorney Wally Taylor serves as legal counsel.

Yet another party opposing ISP is Beyond Nuclear. Our legal counsel includes Diane Curran, of Harmon Curran in Washington, D.C., as well as Mindy Goldstein and Geoff Toy of the Turner Environmental Law Clinic at Emory University in Atlanta, GA.

Finally, Fasken Land and Mineral, Ltd. and Permian Basin Land and Royalty Owners also opposes ISP in this case.

DateFebruary 15, 2022 | Print ArticlePrint Article | |
Tuesday
Feb152022

NGO coalition (50+ organizations and individuals) letter to DOE, re: "Request to Withdraw, Revise and Re-Publish Request for Information on Using a Consent-Based Siting Process to Identify Federal Interim Storage Facilities," 86 Fed. Reg. 68,244 (Dec. 1, 2021)

Dear Friends and Colleagues,

Thank you very much to the 50+ organizations and individuals who signed onto this coalition letter, sent yesterday to the U.S. Department of Energy (DOE), requesting a withdrawal/revision/re-publication of its Request for Information re: "consent-based siting" for federal irradiated nuclear fuel (highly radioactive wastes) consolidated interim storage facilities (CISFs). See the full list of signatories, below.
Special thanks to Diane Curran, Beyond Nuclear's legal counsel, for doing the heavy lifting on this letter. Thanks also to all those who helped edit and proofread it. And thanks very much once again to all the groups and individuals who signed on.
Sincerely,
Kevin Kamps, Beyond Nuclear
P.S. In case DOE rejects our request, above, we will still need to meet its current March 4th deadline for public comments. To see coalition comments you can sign your organization onto, and how to do so by the March 4th deadline, see: http://archive.beyondnuclear.org/centralized-storage/2022/2/8/coalition-comment-letter-to-doe-re-consent-based-siting-for.html
Watch for additional email action alerts re: these coalition comments and the March 4th deadline in the days/weeks ahead, and please spread the word to your networks.
Full List of Signatories on 2/15/22 Letter to DOE requesting withdrawal/revision/re-publication of DOE RFI

Organizations

Beyond Nuclear; Cape Downwinders; Citizens Awareness Network; Citizens for Alternatives to Radioactive Dumping; Citizens Resistance at Fermi Two; Coalition for a Nuclear-Free Great Lakes; Concerned Citizens for Nuclear Safety; Council on Intelligent Energy & Conservation Policy; Don’t Waste Arizona; Don't Waste Michigan; Earthkeeper Health Resources; Honor Our Pueblo Existence (H.O.P.E); Hudson River Sloop Clearwater; Indigenous Environmental Network (IEN); Multicultural Alliance for a Safe Environment (member organizations include: Eastern Navajo Diné Against Uranium Mining; Red Water Pond Road Community Association; Laguna-Acoma Coalition for a Safe Environment; Post-71 Uranium Workers Committee; and Bluewater Downstream Valley Alliance); Native Community Action Council; National Nuclear Workers for Justice; Natural Resources Defense Council (NRDC); New England Coalition on Nuclear Pollution; North American Water Office (NAWO); Northeastern New Mexicans United Against Nuclear Waste; Northwatch; Nuclear Energy Information Service; Nuclear Free World Committee of the Dallas Peace and Justice Center; Nuclear Information and Resource Service (NIRS); Nuclear Issues Study Group; Nuclear Watch South; Nukewatch; Oak Ridge Environmental Peace Alliance; Ohio Nuclear Free Network; On Behalf of Planet Earth; Peace Farm; Portsmouth/Piketon Residents for Environmental Safety and Security; Safe Energy Rights Group; San Luis Obispo Mothers for Peace; Snake River Alliance; Southwest Research and Information Center; Sustainable Energy and Economic Development (SEED) Coalition; Vermont Yankee Decommissioning Alliance. 


Individuals:

Lee Blackburn (Ohio); Stephanie Bilenko (Illinois); Carolyn Croom (Texas); Alice M. Evans, Ph.D. (Vermont); Bridget Houston Hyde (Texas); David Rosen, Certified Petroleum Geologist (Texas); Kathleen Russell (Michigan).

DateFebruary 15, 2022 | Print ArticlePrint Article | |
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