Beyond Nuclear meets NRC's "Nuclear Waste Confidence" DGEIS public comment deadline

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 GreA 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 on the historic towns and natural resources that would have been wiped out had the New Hampshire dump gone forward.

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. More.

Environmental coalition meets NRC's "Nuclear Waste Confidence" public comment deadline

Environmental coalition attorney Diane CurranAn environmental coalition of nearly three dozen groups, including Beyond Nuclear, has submitted comments on the U.S. Nuclear Regulatory Commission's (NRC) "Nuclear Waste Confidence" Draft Generic Environmental Impact Statement (DGEIS). The coalition is represented by a team of attorneys, including Diane Curran (photo, left) of Harmon, Curran, Spielberg, and Eisenberg, LLP, Washington, D.C.; Mindy Goldstein, Director, and Jillian Kysor, Fellow, Turner Environmental Law Clinic, Emory University, Atlanta, GA; and Phillip Musegaas, Hudson River Program Director, and Deborah Brancato, Staff Attorney, Riverkeeper, Ossining, NY.

The coalition is also represented by a team of expert witnesses, including Dr. Arjun Makhijani, President, Institute for Energy and Environmental Research, Takoma Park, MD; David Lochbaum, Director, Nuclear Safety Project, Union of Concerned Scientists, Chattanooga, TN; Dr. Gordon Thompson, Executive Director, Institute for Resource and Security Studies, Cambridge, MA; and Dr. Mark Cooper, Senior Research Fellow for Economic Analysis, Institute for Energy and the Environment, Vermont Law School, South Royalton, VT.

The environmental coalition's comments, as well as its expert witnesses' declarations, have been posted on the Southern Alliance for Clean Energy (SACE) website, as well as at the bottom of a press release featuring the work of Dr. Cooper on the economic costs of irradiated nuclear fuel management. The coalition's comment and expert witness declarations are also posted at the NIRS website.

Curran, on behalf of three environmental groups (Blue Ridge Environmental Defense League, Riverkeeper, and SACE), in alliance with Natural Resource Defense Council, as well as four state attorneys general (CT, NJ, NY, and VT) won a landmark legal victory on June 8, 2012. The D.C. Circuit Court of Appeals ruled that NRC had to carry out an environmental impact statement on its "Nuclear Waste Confidence" policy and rule, including the on-site storage risks of irradiated nuclear fuel in pools and dry casks. The Dec. 20th public comment deadline on the DGEIS is a part of that court-ordered process.

"A Christmas Peril": Obama DOE poised to risk $8.3 billion of taxpayer money on Vogtle 3 & 4 nuclear loan guarantee

Street theater performers, activist supporters, and members of the news media in front of DOE HQ on Dec. 11, 2009 protesting nuclear loan guarantees in solidarity with an International Climate Day of ActionIn late November, partners in the Vogtle 3 & 4 new reactor construction project in Georgia announced that they are "almost over the finish line" in negotations with the U.S. Department of Energy (DOE) regarding an $8.3 billion nuclear loan guarantee.

Not only would federal taxpayers back this massive loan guarantee -- they would also provide the loan, via the federal taxpayer-funded U.S. Finance Bank.

Giving the deal the highest possible profile, President Obama himself announced the award in Feb. 2010. However, DOE and proponents like Southern Nuclear have been squabbling ever since, about how much company "skin in the game" would be required to secure the loan guarantee. Documents unearthed thanks to a multi-year court battle waged by Southern Alliance for Clean Energy (SACE) under the Freedom of Information Act showed that a paltry $17 to $52 million were being asked at certain points in time. Despite this, Vogtle 3 & 4's pushers have been very reluctant for nearly four years now to sign on the dotted line.

The Vogtle 3 & 4 nuclear loan guarantee amounts to 15 times more taxpayer money at risk than was lost in the infamous Solyndra solar loan guarantee scandal ($535 million). Only, Vogtle 3 & 4's risk of default is significantly higher than Solyndra's was!

Meanwhile, Vogtle 3 and 4's behind-schedule, over-budget construction proceeds, funded by the gouging of ratepayers under Georgia's Construction Work in Progress (CWIP) charges on electricity bills -- illegal in most states.

In addition, over the past year, DOE has also forked over another $450 million in taxpayer subsidies to the nuclear power industry, in R&D support for "Small Modular Reactors." However, as pointed out by Beyond Nuclear board member Kay Drey of St. Louis, at 200-300 Megawatts-electric, SMRs should not be called "small." Two subsidy installments of around $225 million each have gone to NuScale-Fluor and Babcock & Wilcox-Bechtel, targeting construction at Idaho and the Tennessee Valley Authority, respectively.

On Dec. 11, 2009, Beyond Nuclear teamed up with Public Citizen and other allies like NIRS and FOE for a street theater at DOE HQ in Washington, D.C. entitled "A Christmas Peril." (see photo, above left; thanks to Public Citizen for an excellent video record of the fun event, complete with a soundtrack!) The performance, featuring the Ghosts of Nuclear Power's Past, Present, and Future, warned about and protested against President Obama's and DOE's decision, just a couple of months later, to award the $8.3 billion nuclear loan guarantee for Vogtle 3 & 4. The warning is as relevant as ever, now that Obama's DOE is poised to ink the deal, nearly four long years later.

Contact President Obama and Energy Secretary Moniz. Urge them to cancel the financially risky Vogtle 3 & 4 nuclear loan guarantee, before taxpayers get left holding the bag for many billions of dollars of unpaid loans if and when the project defaults. And urge them to stop subsidizing so-called SMRs -- after a half-century of enjoying the lion's share of taxpayer and ratepayer energy subsidies, nuclear power should at long last either stand on its own two feet in the marketplace, or else crawl into the dust bin of history where it belongs.

Also urge your U.S. Senators and U.S. Representative to block any further subsidies, including loan guarantees, for nuclear power. They can be contacted via the U.S. Capitol Switchboard at (202) 224-3121.

Expert to NRC: Hidden costs of reactor waste storage & disposal make nuclear power less attractive than wind, solar, efficiency

Mark Cooper of Vermont Law SchoolOn Thurs., Dec. 19th at 11 AM Eastern, Diane Curran and Mark Cooper (photo, left), attorney and expert witness, respectively, representing a coalition of dozens of environmental groups, including Beyond Nuclear, 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.

Update on December 27, 2013 by admin

The Hastings Group has put out a press release.

The press release reports: In the NRC filing, Cooper states: “Are the economic costs of at-reactor nuclear waste storage and disposal in a permanent repository large enough to affect the economics of nuclear power and, therefore, should the Nuclear Regulatory Commission consider those costs in its nuclear licensing decisions? The answer is simple and clear–these costs are so large they must be considered. Conservatively estimating these costs, I put the total cost in the range of $210 to $350 billion, in real, undiscounted dollars. That is a figure that is certainly large enough to demand consideration by the Nuclear Regulatory Commission.”'

Cooper goes on to estimate that replacing dry cask storage across the country once per century, as is assumed by the NRC "Nuclear Waste Confidence" DGEIS -- would cost $100 billion per replacement.

NRC nuke waste con game: final written public comment submissions re: DGEIS due Friday, Dec. 20th!

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, at the link 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. More.