ANA Comments on GNEP Programmatic Environmental Impact Statement > Alliance for Nuclear Accountability

ANA Comments on GNEP Programmatic Environmental Impact Statement

published Thursday, May 31, 2007

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Alliance for Nuclear Accountability
A national network of organizations working to address issues of
nuclear weapons production and waste cleanup

May 31, 2007

Mr. Timothy A. Frazier
GNEP PEIS Document Manager,
Office of Nuclear Energy,
U.S. Department of Energy
1000 Independence Avenue, SW,
Washington, DC 20585–0119

Dear Mr. Frazier,

Thank you for the opportunity to provide comments regarding the Department of Energy’s Global Nuclear Energy Partnership (GNEP) Programmatic Environmental Impact Statement (PEIS) No. 0396, in accordance with the provisions of the National Environmental Protection Act (NEPA).

The Alliance for Nuclear Accountability is a network of local, regional and national organizations working collaboratively for 20 years on nuclear weapons policy and waste cleanup issues. We want to register our deep and broad concerns regarding GNEP.

We find no credible evidence provided in the GNEP PEIS to explain how the reprocessing of spent nuclear fuel will solve the problems of nuclear waste management. The plan contains no satisfactory explanation of how long-lived radioactive components of spent nuclear fuel would be rendered benign. GNEP is a hypothetical scheme premised upon as-yet undeveloped technologies. Crucial details need to be worked out and refined over time before a program of this scale can rationally be considered. Rushing ahead with the program and advertising GNEP as the solution to the problem of high-level nuclear waste is poor public policy, as well as dangerous and costly behavior.

Our analysis includes review of previous reprocessing efforts in West Valley, NY, the Savannah River Site, SC, the Idaho National Laboratory, and the Hanford Reservation, WA. It leads us to the conclusion that the proposed production-scale GNEP reprocessing program would be an expensive and dangerous boondoggle, requiring taxpayer support for years to come. Long standing environmental problems at the U.S. sites and at reprocessing facilities in the United Kingdom, France, and Japan show that there are no simple solutions to the waste generated by reprocessing.

The public health of our nation depends on safe and thorough environmental cleanup of existing radioactive contamination. Our public funds and technical expertise are better spent cleaning up the current problems rather than compounding them.

The Alliance for Nuclear Accountability requests that the GNEP PEIS address the following items:

• Comprehensive analysis of all GNEP waste streams, including:
     - Disposition pathways of radionuclides
     - Categories of radioactive and hazardous wastes
     - Storage costs
     - Time periods over which GNEP wastes will threaten human health and the environment
     - Transportation routes and dangers to local populations
     - Quantities and characterizations of waste from GNEP reprocessing facilities and reactors with particular attention to quantities of waste which will still, after reprocessing, require geologic repository.

    • Comprehensive economic analysis of construction, operation, eventual decommissioning, and legacy management costs of GNEP facilities and the resulting waste materials; including disposition and/or remediation of contaminated building materials, soil and groundwater, high-level wastes and any other related matters.

    • Analysis of technical, environmental, and economic failures at past and current reprocessing efforts, including West Valley, NY; Hanford Reservation, WA; the Idaho National Laboratory; Savannah River Site, SC; Morris, IL; Selafield, United Kingdom; La Hague, France; and Rokkasho, Japan, and how the following issues would be addressed:
     - Scientific and technical challenges that remain unsolved in the current GNEP plan, with special attention to the as-yet undisclosed reactor designs
     - Waste disposal problems
     - Accidental and intentional releases of radioactivity into the environment
     - Economic viability and the amount of public subsidy required
     - Operations history and safety records.

    • A thorough and balanced analysis should be provided that considers the public health risks of constructing and operating the spent fuel reprocessing facilities, nuclear reactors, and transportation of nuclear materials.

    • Thorough review and public discussion of the nuclear proliferation risks created by GNEP; namely the spread of nuclear materials and knowledge globally, especially to countries prone to political instability and insecurity.

    • Provide analysis of security at all proposed GNEP facilities, and of ability (or lack thereof) to safeguard against terrorist attack.

    • The statistical likelihood of a catastrophic accident at all GNEP sites (reprocessing facilities, reactors, and other installations) and the financial and physical capacity to respond to an emergency.

    • As a “reasonable alternative,” DOE should provide a full cost/benefit analysis of the redirection of DOE resources to renewable and emerging energy sources; including conservation, increased efficiency, wind power, solar power, and distributed generation. Please include response to the United Kingdom Commission on Sustainable Development’s     2005 report opposing development of nuclear power.

The Alliance for Nuclear Accountability is not convinced that the priorities or technical abilities of the Energy Department have advanced to the degree that a new generation of reprocessing will be less hazardous than the last.

Please acknowledge receipt of these comments, and their inclusion into the GNEP NEPA PEIS official record and send us both hardcopy and electronic versions of any drafts, final statements, and reports.

We will be happy to provide you with any further information regarding these comments.

Sincerely,

Alfred Meyer, Program Director
Alliance for Nuclear Accountability
322 4th Street NE
Washington, DC 20002
202-544-0217
ameyer-at-ananuclear-dot-org

Comments

by "R" Addison, the radionuclides POet on Tuesday, December 11, 2007

one of the "public" exasperations on the issues of wastes from radionuclides is: that the gov't tries to suspend the animation of "stowage" on site but with "remediations' of those isotopes by separation, as the other-Side: pentagon/cIAS of the gov't--morosely more military-Hegemony than is necessitating a democracy--must be incaluably not allowed the privilege in making "safe" those now, pent-Up anxieties of 'accidents at any and all' nuclear-Facilities--those so exasperated by am-241 and pu-240 & ur-239 & ur-236 & th-234!That has been the process-making: decisions, allowing "depleted-Uranium" into a market of aRMAmENTS-SALES to maintain the armor-Metals sales...that which is a munition and an excuse for protective-Armor, which actually can be abrasive to the users of any hand-held weapons w ur-238 "shells" and on up to and including loading AWACs and tanks w munitions--those that must be sold.
The sales-Factor is probably an association of long-Standing interest-Rates which are funds that must be paid on the failed as well as the current "out-Puts: radio-isotopes in nukies"... I find the analogy has not been the "analogous-Debate" in and of peace 'n Justice, or other websites...

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