The Department of Energy's (DOE) proposed Global Nuclear Energy Partnership (GNEP), a program to restart nuclear waste reprocessing in the United States, poses a threat to local communities and to global security. Instead of pursuing this environmentally destructive, dangerous, and exorbitantly expensive GNEP program, DOE should store nuclear waste at reactor sites and safeguard it from terrorist attack.
The analysis provided in the Draft Programmatic Environmental Impact Statement (PEIS) is appallingly inadequate. Despite its legal mandate to analyze the full socio-economic and environmental impacts of GNEP, this PEIS does not include a complete life cycle cost analysis or fully addressing environmental or nonproliferation impacts. Furthermore, it inadequately addresses the full extent of health impacts from reprocessing.
Ignoring thousands of letters from the public and repeated requests from Congress, DOE has still not provided and this PEIS does not include a total lifecycle cost of GNEP, including all of the reprocessing facilities, fast reactors and fuel fabrication facilities required to fully implement GNEP. This analysis must include clean-up of the reprocessing facilities, as well as decommissioning of fast reactors and fuel fabrication facilities.
No analysis of GNEP's proliferation risks or impacts is provided. Instead, it states that the National Nuclear Security Administration is providing a separate nonproliferation assessment, but fails to provide any clear timetable for its release. For the public to fully assess the impacts of GNEP, a nonproliferation analysis must be included within the PEIS.
The PEIS inaccurately argues that reprocessing reduces the total volume of waste, and therefore, limits long-term health impacts related to disposal. This argument not only ignores recent independent studies that conclude reprocessing does not diminish the volume of waste, but also contradicts a previous section of the report that explicitly states reprocessing will not diminish the need for waste disposal. The Department of Energy must describe how it is going to manage and protect the public and workers from the many radioactive and hazardous waste streams that result from all phases of the GNEP plan. These wastes include, but are not limited to, strontium, cesium, radioactive lanthanides, technetium, uranium, and krypton gas.
Reprocessing is polluting, expensive, and a threat to U.S. national security. DOE should abandon the dangerous GNEP proposal and focus instead on safeguarding nuclear waste at reactor sites.
Sincerely,