On behalf of the Ohio Environmental Council, I respectfully submit these comments on the U.S. Department of Energy’s Programmatic Environmental Impact Statement for the Global Nuclear Energy Partnership (GNEP-PEIS). The OEC is a statewide environmental advocacy group representing over 100 environmental and conservation organizations and thousands of individual members throughout the state of Ohio. OEC’s mission is to advocate for healthy air, land, and water to make Ohio a better place in which to live, work, and play. In light of our mission and our role as a statewide environmental advocate, OEC has some grave concerns with DOE’s decision to consider the Portsmouth Gaseous Diffusion Plant in Piketon, Ohio as a site for GNEP’s nuclear fuel recycling center and/or its advanced recycling reactor.

In response to the DOE’s request for comments on the proposed scope, alternatives and environmental issues to be analyzed by GNEP PEIS, OEC respectfully submits the comments below. OEC requests the DOE take these issues into consideration, and address these questions before moving forward on the GNEP program.

Environmental Issues and other Questions/ Concerns that DOE Must Address

1. Water quality impacts

• With potentially thousands of tons of spent nuclear fuel being shipped to and housed at the proposed facility, the potential for jeopardizing the health of important recreational watercourses and drinking water sources are great. The proposed GNEP facility in Piketon sits atop the Teays Aquifer and is adjacent to streams and creeks that lead to the Scioto River.
• USGS hydrological studies of the site concluded that failure to contain radioactive material would jeopardize these water resources.
• If long term storage is an option for this facility, what are the long-term impacts of housing large quantities of SNF near surface and groundwater drinking and recreation sources?

2. Impacts to flora and fauna of the region

• It is not only the human health and safety that should be a concern. Southern Ohio is the home to a unique collection of plants, some only native to that portion of the state. This region is also home to a number of state and federally recognized threatened and endangered species.

3. Air Quality

• What are the air emissions from this proposed facility, and what will the impact be on the surrounding community?
• Southern Ohio experiences already poor air quality from decades of pulverized coal power plant emissions. While nuclear power plants produce little if any sulfur dioxide, nitrogen oxide, and carbon dioxide compared to fossil fuel burning plants, uranium enrichment process, recycling, as well as the transport of the uranium fuel to the nuclear plant can produce these emissions.
• What will be the cumulative human and environmental health impacts of the facility vis-à-vis air emissions and air quality when the air quality impacts of the nearby coal power plants and other land uses are taken into consideration?

4. Socioeconomic concerns

• This is one of Ohio’s poorest regions, the need for jobs is important, but at what cost? The economic benefits of such a project cannot be seen without a safe, healthy and viable work force. How will DOE secure the safety of its workers and the workers families? What could be the impacts to the workers and the surrounding community if there is a radiological release?
• The DOE must address the economic justice issues inherent in this proposed facility, specifically the disproportionate impact on low-income citizens.
• The DOE should consider whether cleanup and reclamation of the facility for other uses may be more beneficial to the surrounding community.

5. Private Ownership of Nuclear “Recycling Facility”

• If the Piketon facility is allowed to be owned and operated by private companies, will there be, and to what degree will there be, federal government oversight?

6. Does the technology exist?

• Scientists from the Federation of American Scientists and other organizations have analyzed the GNEP program and concluded the necessary technologies do not exist and are not close to development. We have serious concerns with the process of “recycling” nuclear fuel; a process that is still in the research and development stages. The United States cannot afford to base our energy needs on untested and unperfected technology that carries with it the risk for great environmental and human health impacts. This is definitely the case when one looks to the advances in cleaner coal technology, wind, solar, and biomass technology that create energy as well as reduce harmful emissions.

7. Storage

• Is this a short-term storage facility or a long term depository which the citizens of Southern Ohio will be forced to bear the human and environmental risks for an indeterminate time?
• The GNEP proposal calls for storage of spent nuclear fuel to be housed at the GNEP facilities until the Yucca Mountain repository is ready. However, decade long delays with securing that facility and staunch opposition to the utilization of Yucca Mountain have made the reality of a safe depository moot.
• Have the obvious and perhaps devastating homeland security issues been fully and adequately addressed?

o If the Portsmouth Gaseous Diffusion Plant Facility is chosen as the GNEP recycling facility, for example, SNF would be received from commercial nuclear reactors and would be processed at that central location. Terrorists, from both within and without this country would know the route and final destination of massive quantities of highly reactive nuclear waste, making the GNEP facility a major target for disaster.

o Along the same lines, unforeseen acts of nature on or near the facility could cause disastrous health and environmental consequences with the great amount of nuclear fuel and waste housed in that central locale.

8. Transportation of Spent Nuclear Waste

• With the amount of SNF proposed to be trucked into the Portsmouth Gaseous Diffusion Plant in Piketon, Ohio from nuclear facilities in the western United States (and/or around the world) for recycling and storage, how does DOE plan to protect those along the travel route?
• DOE will need to consider the amount of traffic, both in construction of the facility and transportation of the importation of SNF, on the infrastructure of the village of Piketon and Pike County. Outdated and ill-prepared county and township infrastructure (i.e. roads and bridges) could create financial problems for the local government and above all create unsafe conditions for the community.