by Ellen Thomas, Disarm/End Wars Issue Committee

DUE JANUARY 2, 2013: PUBLIC COMMENTS TO THE NUCLEAR REGULATORY COMMISSION (NRC) REGARDING ITS “WASTE CONFIDENCE RULE.” YOU CAN HELP BY MAKING PUBLIC COMMENTS ON YOUR OWN AND IN SUPPORT OF THE WILPF POSITION ON THIS ISSUE. SEE BELOW FOR DETAILS.

BACKGROUND: Since enacted in 1984, this Rule accepted, illogically, the idea of on-site storage for at least 120 years of high-level radioactive waste at reactors, stored in indoor wet pools and outdoor dry casks. This faulty premise was rejected by the U.S. Court of Appeals for the District of Columbia Circuit on June 8, 2012, when it ruled in favor of a coalition of states and environmental groups.

The Court Order requires the NRC to prepare a decades-overdue environmental impact statement (EIS), to comply with the National Environmental Policy Act (NEPA), about the risks of on-site high-level radioactive waste storage, with NO NEW OR EXTENDED LICENSES TO BE GIVEN until the decision is made on what to do with the waste.

On October 25, 2012, the NRC published a Notice in the Federal Register giving only until January 2, 2013, for public comments. 

WILPF’s Disarm/End Wars Committee is asking the NRC to stop generating more radioactive waste and not move any radioactive waste from existing sites until a permanent storage solution has been found. 

We ask that the NRC leave the public comment period open until a decision is made, and that the NRC include nuclear experts in the decision-making process that are not part of either the government or the nuclear industry. 

For example, we propose:

David LochbaumUnion of Concerned Scientists

Arjun MakhijaniInstitute for Energy and Environmental Research

Helen CaldicottNuclear Policy Research Institute

Robert AlvarezInstitute for Policy Studies

Dan HirschCommittee to Bridge the Gap

Geoff FettusNatural Resources Defense Council

Ed LymanUnion of Concerned Scientists

plus long-time nuclear activists who live in the vicinity of nuclear facilities, such as:

Diane CurranAttorney

Marvin ReznikoffRadioactive Waste Management Associates

Tom Clements

and founding members of the Alliance for Nuclear Accountability

In your letter, you may have other experts to recommend.  

We expect that what will come of this is an end to an adversarial or hierarchical decision-making process. 

With such an abundance of uncertainties, not only environmental but also economic, caused by actual happenings such as Fukushima and recent evidence of climate change, the communities that are experiencing accidents, leaks, and the overwhelming threat of what could happen and has happened, need to be involved in a solution.  

This takes us beyond the theoretical approach into something that might actually work: cooperative brainstorming.

Please contact the NRC by January 2, 2013. (See footnotes.) We suggest that you explain how you, personally, and your community are affected by nuclear waste policies.

Environmental scoping comments can be submitted using Docket ID NRC-2012-0246:

• electronically at http://www.regulations.gov
• by mail to: Cindy Bladey, Chief; Rules, Announcements, and Directives Branch; Office of Administration; Mail Stop: TWB-05-B01M; U.S. Nuclear Regulatory Commission; Washington, D.C. 20555-0001.
• by fax to: Cindy Bladey/NRC, at (301) 492-3446.
• by upcoming NRC Webinars: Wed., Dec. 5, 1-4pm Eastern (10am-1pm Pacific), or Thurs., Dec. 6, 9pm-Midnight Eastern (6-9pm Pacific). You must pre-register to participate by contacting NRC’s Susan Wittick at Susan.Wittick@nrc.gov or (301) 492-3187.

Helpful links:
 

• Beyond Nuclear has issued a call for comments with sample language you might use.
• NRC Scoping Meetings For New Waste Confidence Directorate EIS

Image credit: WILPF member Frances Crowe http://en.wikipedia.org/wiki/  protesting at Entergy Vermont Yankee, in Vernon, Vt. . Frances, 92, is one of several WILPF members who have  been arrested there for their determined “shut it down” efforts.AP Photo | The Brattleboro Reformer, Zachary P. Stephens,. 8/10/10