ANA Comments for GTCC Scoping Process

ANA staff and colleagues have prepared these scoping comments on the Department of Energy's plans to dispose of Greater-Than-Class-C radioactive waste.

RE: Notice of Intent to Prepare an Environmental Impact Statement for the Disposal of Greater-Than-Class-C Low-Level Radioactive Waste. 72FR140, July 23, 2007, pp. 40135-40139.

Dear Mr. Joyce:

This letter is to provide comments of the Alliance for Nuclear Accountability on the above cited Notice of Intent (NOI).

As the following comments detail, we ask that the scope of the Environmental Impact Statement (EIS) include:

· more specific definition of GTCC and GTCC-like waste and rules and regulations regarding any processes of concentration or dilution of waste materials that would affect it’s classification as GTCC or GTCC-like waste;

· a more complete inventory of known and estimated amounts of Greater-Than-Class-C (GTCC) and GTCC-like wastes, particularly regarding potential waste from new nuclear weapons programs, new nuclear reactors and the proposed reprocessing activities of the Global Nuclear Energy Partnership

· consideration of the alternative of Hardened-On-Site-Storage (HOSS) both conceptually and with specific examples;

· thorough definition of public health and environmental protection standards, monitoring and remediation plans;

· specific information regarding transportation of waste including transportation containers, routes, accident projections and emergency response.

The following sections deal with these topics in greater detail.