Dear Ms. Kliczewski:
I write to express my concerns and offer public comment in response to Federal Register Notice 83 FR 50909, "Request for Public Comment on the U.S. Department of Energy Interpretation of High-Level Radioactive Waste", published on October 4, 2018.
As the Notice (83 FR 50909) explains, the Department of Energy (DOE) has proposed changing its interpretation of the definition of "high-level radioactive waste" (HLW). This could lead to more waste being classified as low-level waste, even though the characteristics and properties of the waste has not changed. I am concerned that by redefining the term "high-level nuclear waste" more narrowly, numerous communities across the country will be given the greenlight to ship hazardous, radioactive materials to Nevada without our consent.
Currently, low-level and mixed low-level radioactive waste are disposed of at the Nevada National Security Site (NNSS). DOE's proposed narrow interpretation of HLW has the potential to open the door for new, misclassified high-level waste to be brought to our state. I am strongly opposed to any decision that would allow what is effectively high-level radioactive waste to be transported to Nevada -- whether to NNSS or the proposed Yucca Mountain site.
As I have said numerous times, including to Secretary Perry when he testified before the House Science, Space, and Technology Committee, I strongly oppose storing spent nuclear fuel at Yucca Mountain or anywhere in Nevada. Storage of high-level radioactive waste in Nevada, even if misclassified as low-level waste, threatens Nevada communities and United States national security, particularly given the proximity of Yucca Mountain and the NNSS to Nellis and Creech Air Force Bases, Hawthorne Army Depot, and the Nevada Test and Training Range (NTTR). That is one of many reasons why any reinterpretation of the definition of HLW must not allow additional waste into our state or lead to storage of any waste at Yucca Mountain.
Your notice states that DOE is not making any decisions on the disposal of any particular waste stream, and that these decisions will be made in consultation with appropriate state and local regulators and stakeholders. While I appreciate this nod toward collaboration, this will not change Nevadans' overwhelming and steadfast opposition to becoming the nation's nuclear dumping ground. Nevada has not and will never consent to risking their health and safety for such an endeavor.
DOE's proposed reclassification of significant amounts of HLW as low-level waste is one more affront to Nevadans, who have lived under the constant threat of nuclear waste disposal for nearly four decades. Last month's announcement by DOE approving the storage of up to one metric ton of weapons-grade plutonium at NNSS was a further unacceptable intrusion on our state, and this month's HLW proposal adds insult to injury. Reclassifying high-level waste is yet another fruitless effort to move forward with the reckless plan to turn our state into a radioactive dumping ground.
On this matter and others, I will continue to oppose any proposals that would allow high-level nuclear waste storage in Nevada.
Thank you for your attention to this critical matter.