Comment on Blue Ribbon Commission on America’s Nuclear Future Draft Report to the Secretary of Energy

From: Roma Mauro[SMTP:RMAURO@MD.METROCAST.NET]

Sent: Wednesday, February 29, 2012 5:46:36 PM

To: BRC

Subject: Comment on Blue Ribbon Commission on America’s Nuclear Future Draft Report to the Secretary of Energy

Dear Chairmen Hamilton and Scowcroft, and Members of the Blue Ribbon Commission:

I am part of a community, worldwide, that is deeply committed to preventing exposure of living tissue to random ionizing radiation, particularly exposures that are without informed consent and yield no direct individual benefit. Because of this commitment, I am deeply saddened that the Commission is not clearly and unequivocally making a commitment to the isolation of radioactivity from the industrial operations. Isolation of radioactive materials (and the radiation they emit) from our environment, from the biosphere including the human environment, air, water, food and soil is the only viable goal for a sustainable future. The Commission recommendations not only do not support this goal, they stand in direct opposition to this goal.

It is obvious to anyone who has tried to contain and isolate anything, the less of the stuff to be contained, the better. This is a corollary to the famous "first rule" of getting out of a hole, which is to simply stop digging. In our view the first principle of radioactive waste management is "every curie counts" and the fewer the better. Thus our community works towards ending the production of more highly radioactive waste, irradiated fuel rods, plutonium and the other actinides of course--as quickly as possible.

To be clear: isolation of this waste is not a "distant goal" like a mark on a horizon somewhere. It is an open question, day by day. Is the waste leaking now? Is it in the best possible circumstance to prevent release of radioactivity? How do we know? Are we monitoring it in real time? If these questions are asked and answered on a daily basis, over time we can say "yes, this waste is isolated," or "no, the radioactivity has not been released." Actions that reduce confidence in the answers to these questions must be avoided. Gratuitous transport of the waste (merely to move it), reprocessing, and lack of security must all be avoided.

An example is the wholesale transport of thousands of containers of irradiated fuel. Current regulations define a shipment as an event that may extend "in transit" for up to two years, allowing urban rail yards to be an "interim" unplanned destination. Our community has stood with those along projected transport lines to oppose "Mobile Chernobyl" since we do not think that a radioactive waste "shell game" will support real ongoing isolation.

The centralized, consolidation of interim storage is a worn-out false idea that the Commission has offered yet again. Many assume that an additional storage site would be, by definition, safer or more secure than decentralized, existing sites; this is false. There are several layers to this falsehood.

First, all irradiated fuel is currently at sites licensed by the US Nuclear Regulatory Commission. We believe that this storage should be done better, which would include accelerating the transfer of irradiated fuel out of fuel pools; spreading existing and new containers farther apart; creating earth "berms" between the containers and any road or waterfront; providing real-time monitoring of heat and radiation containers and creating a local oversite group such as those at other nuclear sites (see the Principles for Safeguarding Nuclear Waste at Reactor Sites posted:   http://www.brc.gov/sites/default/files/comments/attachments/hoss_principles_3_23_2010x.pdf).

The whole notion of "centralization" is bankrupt since it will be literally impossible for all the radioactive waste to be centralized or consolidated unless and until the last nuclear power reactor closes. Any new plan will involve sufficient implementation time that within a few years of the beginning of a major nuclear waste shipping campaign there will be as much waste at the existing sites as there is now. Consolidated or centralized storage is simply one more site.

We have a deep concern that radioactive waste is hard to "sell" -- and so once it is put somewhere, it is extremely likely that the waste will stay and the site will be "de facto" permanent. This is less likely to happen at the licensed reactor sites given that there are many of them, and that they belong to large corporations. Since these corporations have benefited from the generation of the waste, and continue to benefit, it is appropriate that they remain part of the dialog until there is a scientifically-based permanent program to isolate the radioactivity for as long as it is a hazard.

If a centralized site IS temporary, then one has made a commitment to move the waste more than once. The assertion there is a lot of experience moving this type of waste is also false. Only a small fraction of highly radioactive irradiated fuel has ever been moved, and other nuclear shipments, such the plutonium to WIPP, are not comparable. Further, there has been a misunderstanding about the radiological impact of a national shipping campaign.

The Department of Energy famously asserted (repeatedly) that there would be no SIGNIFICANT radiological impact from the transportation of radioactive waste to a national repository--without revealing that there would, in fact, be as many as 5 or 6 major radiological catastrophes. A possible scenario includes crushing forces sufficient to break open a container--even a tiny bit, combined with a fire (perhaps diesel fuel) that could loft particles of irradiated fuel, much as the steam at Fukushima is doing. Since the impacts of such events likely would be regional, the Department used the slight-of-hand-phraseology "significant impact" because the radiation doses from these severe accidents, involving off-site release of radioactivity, would be averaged by the DOE over the entire US population. At that scale, those who might suffer cancers, infertility, miscarriage or even death would not 'show up' thus the conclusion that the impact is "not significant" unless, of course, it is your cancer.

Committing to a second (or more) round of transport multiplies these hazards. Further, the containers cannot have sufficient shielding to prevent ambient radiation fields comparable to medical X-rays. A perfect container has the equivalent of 20 chest X-rays an hour (or one every 3 minutes) at the surface. At even 6 feet, the rate is as high as 2 chest X-rays per hour. This is radiation not only to drivers but also to others who may be unwittingly exposed--with no "benefit" to the individual from the exposure to off-set the risk.

The assertion that moving the waste to a "temporary" site could result in multiple moves is illustrated by the Private Fuel Storage situation which was billed as an "intermodal" transfer and storage site for the proposed Yucca Mountain permanent disposal site, and also by the proposed amendments to the Nuclear Waste Policy Act in the 1990's. Both of these proposals would have triggered massive radioactive waste shipping campaigns.

The National Academy of Sciences report "Going the Distance" contains an enormous disclaimer: security is not a factor that can be analyzed; so although the Academy generally described a system it viewed could be safe, it did not hazard an opinion on whether it could be secure. In our view transport of this most deadly of all wastes is neither safe, nor secure. Moving irradiated fuel more than once constitutes "gratuitous" transport, and we are deeply saddened that the Commission has not committed to a decentralized interim storage with hardening of the waste until a permanent program is in place.

 In addition, the Commission has failed the goal of isolation by failing to oppose the industrial activity least likely to deliver ongoing isolation of radioactivity: reprocessing or the misleading term "recycling." The separation of radionuclides from irradiated fuel, under all scenarios and practices, is the direct opposite of isolation. The radioactivity released daily in LaHague France, Sellafield in Scotland, Mayak in Russia (and prospectively at Rokkasho in Japan) is measured in "Chernobyls." Even though much of this is noble gas and chemically "inert," Xenon and Krypton still deliver a radiation dose, and if inhaled, settle in the fat of our bodies where the internalized radiation causes continuous high doses to our tissues. These noble gases decay to radioactive cesium and strontium. The separation of plutonium from the highly radioactive fission products results in such massive release, that if radioactivity were black and oily, these operations would be visible as enormous messes on the scale of the 2010 BP oil spill in the Gulf of Mexico. Thankfully reprocessing is decreasing worldwide due to the un-profitable nature of plutonium.

We recommend rejection of reprocessing as an option for irradiated fuel management in the BRC Final Report, and recommend adequate funding to deal with existing reprocessing wastes. The BRC failed to adequately address the consequences of past irradiated fuel reprocessing in its draft report. Although the committee listened to speakers on the failure and expenses of nation’s only commercial reprocessing venture at West Valley NY, it did not synthesize the information, learn from it or recommend ways to deal with it, which is part of the mission of the BRC. Just six years of reprocessing of commercial (and weapons) irradiated fuel at West Valley, NY  in the 1960s-70s left a $5-$10 Billion nuclear time bomb upstream of the Great Lakes, the Seneca Nation of Indians and US and Canadian residents. The government has provided short-term band-aid fixes and kicked the radioactive can down the road 10 more years before it decides WHETHER to clean up this leaking site.

Another concern is that in the United States it is likely that any plutonium separation would be done after the transfer of title of this most deadly waste to the US taxpayer. No one has been able to give a solid assurance that the National Nuclear Security Administration (owner of other US plutonium) would in fact elect to make civilian fuel with this material which is, in fact, usable in thermo nuclear weapons.

Environmental Justice has been a key portion of the waste policy debate. While the Commission has introduced the idea of "consent" in the siting of a new nuclear site, it has not adequately appraised its responsibility as an advisor to the government that has licensed the generation of this waste. Insofar as a Tribal Nation chooses to build a nuclear waste site, its decision if freely undertaken should be respected. It is, however, incumbent upon this Nation to uphold its principles of protection, precaution and just relations with foreign powers and thereby determine whether the effective EXPORT of our most deadly, enduring, mutagenic wastes to a jurisdiction that represents an Indigenous population is appropriate. It is not.

This perspective about international relations was developed during a long and despicable period of nuclear waste policy in the last century (the 20th) when Native American People and Lands were selectively singled out by the US Department of Energy for radioactive waste storage and disposal. After a long and contentious battle over whether nuclear corporations licensed in the USA should be further licensed to store waste on the Skull Valley Goshute Reservation the Department of the Interior (DOI) said that nuclear waste was "not appropriate economic development" for this tribe. In addition, the decision by the Bureau of Indian Affairs concluded that the “uncertainty concerning when the [Spent Nuclear Fuel] might leave trust land, combined with the Secretary’s practical inability to remove or compel its removal once deposited on the reservation, counsel[s] disapproval of the proposed lease.”

A 21st Century approach would affirm the Tribe's interest in economic development, but bar the "export" of the waste by the USA.  In my view, the Commission in its advisory capacity to the Federal Government should take Native Lands off the table.

As a number of groups pointed out to the Commission earlier this year: "Providing “incentives,” that is, bribes to low-income communities of color to accept highly radioactive waste is a textbook violation of environmental justice principles and will inevitably lead to decades of public and elected official opposition and legal battles that will detract from real solutions."

For all these reasons our community knows that every effort to centralize interim storage of highly radioactive waste in the past (more than 30 tries) has failed and that this bad idea will continue to fail. We have a deep concern that this bad idea is preventing the adoption of better storage where the waste is located now which is our best hope for ensuring isolation of the waste now, and as we go forward, on each and every day.

Please revise your recommendations. If the Blue Ribbon Commission continues to promote the production of more radioactive waste over the commitment to the isolation of the existing waste, certainly this is evidence that such a body, which does not include anyone living in a community where such waste is currently generated or stored, and also no one from the community to which these comments refer, is not capable of truly envisioning a sustainable future.

Sincerely,

Roma Mauro

45849 Nancy Lane

Great Mills, MD 20634