An open letter, send registered mail, asking for the removal of nuclear waste from West Valley, NY near Cattaraugus Creek.

Green Party of Pennsylvania
P.O. Box 59524
Philadelphia, PA 19102
717-839-2395
[email protected]

Mr. Martin Krentz, DOE Document Manager
West Valley Demonstration Project
U.S. Department of Energy
10282 Rock Springs Road
AC-DOE
West Valley, NY 14171-9979

April 20, 2018

RE: Scoping for DOE/NYSERDA SEIS for Decommissioning and/or Long-Term Stewardship at the West Valley Demonstration Project and WNY Nuclear Service Center

Dear Mr. Krentz:

The Green Party is an international political party founded on ten Key Values. Two of these values are Ecological Wisdom and Future Focus. For this reason, the Green Parties in Canada and the United States, which share a Lake Erie shoreline and are listed below, understand the importance of protecting Lake Erie from radioactive contamination, now and in the future.

Therefore, we are writing to express our strong support for full cleanup of the West Valley nuclear waste site. The site contains vast amounts of radioactive and hazardous waste, which threaten our Great Lakes, public health, economy, and our quality of life. The safest, most responsible, and most cost-effective solution offered in the draft scope is the “Sitewide Removal Option,” which will ensure that all radioactive, hazardous, and mixed waste is removed from site facilities, soil, sediment, and groundwater throughout the site. The other alternatives (close-in-place, no action, and hybrid) are unacceptable, as they fail to protect our Great Lakes, public health, and future generations. The SEIS must focus on “how” to clean up all the waste, not “if”.

It is not possible to secure nuclear waste at West Valley in unlined surface burial grounds, when the site cannot meet current siting standards for even low level radioactive waste. Nuclear waste also should not lie on top of a sole source aquifer. It must be excavated, containerized, secured, and monitored until it can be transferred to permanent disposal sites, as the West Valley Demonstration Project Act requires.

As the U.S. Department of Energy (DOE) and New York State Energy and Research Development Authority (NYSERDA) prepare the Supplemental Environmental Impact Statement (SEIS), our organizations collectively urge you to ensure transparency for the public by providing full access to all of the information, codes, models, and assumptions in a publicly-available, searchable, electronic library.

We urge you to include the following in the scope of the SEIS:

The SEIS Must Consider Impacts to the Great Lakes Ecosystem

The Great Lakes contain 20% of the world’s fresh water, over 90% of the U.S. supply, and provide drinking water to over 40 million people. The Great Lakes generate more than $50 billion in economic activity to the regional economy annually from fishing, wildlife viewing, and tourism.

The West Valley nuclear waste site is located in the Town of Ashford, about 30 miles south and upstream of Buffalo, NY. The site sits in the Great Lakes watershed, with tributaries running through and adjacent to the site. Currently, there is a large plume of contaminated, radioactive groundwater moving off-site into Buttermilk Creek, which flows into Cattaraugus Creek through Zoar Valley and the Seneca Nation into Lake Erie. A major loss of containment of nuclear waste would be a catastrophic failure, leaking high concentrations of radioactive waste into the watershed and then quickly into Lake Erie. What goes into Lake Erie will ultimately travel down the Niagara River and into Lake Ontario, potentially impacting drinking water for the four million New York residents that depend upon the Great Lakes for drinking water. The Great Lakes are also unique in that long-lasting pollutants are
circulated continuously between the atmosphere and the vast watershed. This magnifies the hazard of allowing any amount of long lived radionuclides to contaminate the Great Lakes.

The SEIS should study the adverse impacts of potential radioactive releases into the Great Lakes, expanding the study to include Lake Erie, the Niagara River, Lake Ontario, and St. Lawrence River (using a zero-discount rate, so as to reflect damage in the future for such events). The SEIS must consider impacts to drinking water for millions of people, a multi-billion-dollar fishing, recreation, and tourism industry, millions of jobs that are dependent upon the Great Lakes, wildlife, and economic development along our waterfronts. The SEIS should also consider that a radioactive release threatens recent investments in the Great Lakes and progress to restore the lakes—the federal Great Lakes Restoration Initiative (GLRI) has invested $198 million in 338 projects in New York State alone since 2010, including successful projects to clean up toxic hot spots, reduce polluted runoff, restore critical habitat, and more.

The SEIS Must Consider the Impacts of Climate Change

There is clear scientific evidence that climate change is resulting in an increase in extreme weather events. In the past year the nation has experienced multiple rain events that exceeded 20 inches in 24 hours. The Northeast region has experienced more than a 70% increase in extreme rainfall events—those in the top 1% for amount of rainfall in 24 hours—since 1958. Extreme rainfall events can cause far more erosion than increases in annual rainfall.

Erosion is a powerful and fast-moving force at the West Valley site, as it sits on a geologically young and continuously changing landscape. An extreme weather event in West Valley in August of 2009 demonstrated how quickly the landscape can be altered. In this event, rapidly moving floodwaters scoured the toe of the Buttermilk valley wall, resulting in a large landslide that moved the valley wall 15 feet closer to the State burial grounds. Increased extreme weather events associated with climate change increase the likelihood of erosion, mass wasting and landslides, as well as the potential release of radioactive waste from West Valley into the Great Lakes.

Regrettably, the scoping notice failed to mention climate change as a potential environmental issue for analysis or as having potentially severe adverse impacts. A performance assessment of West Valley’s nuclear waste facilities must address worst case scenarios that address the site’s unique vulnerabilities and potential impacts from extreme weather caused by worsening climate change. Scenarios that cause the loss of containment and the potential for release of radioactive waste into the surrounding environment should be studied. The modelling performed must be capable of capturing multiple extreme weather events rather than just long-term averages.

The SEIS Must Consider Impacts on Public Health for Thousands of Generations

Much of the site is heavily contaminated with dangerous radioactive wastes, many of which will be radioactive for tens of thousands of years, and some for millions of years. There is no safe level of exposure to radioactive waste[i]– every exposure increases the risk of serious adverse health impacts, including cancer, birth defects, neurological effects, and other health damage. Leaving any waste buried onsite, risking a release of dangerous radioactive waste into the surrounding environment and our Great Lakes, threatens public health for thousands of generations to come.

The SEIS Must Consider the Long-Term Cost Benefits of Full Cleanup

The Sitewide Removal Option provides the most cost-effective approach over the long term. An independent, state-funded study released in 2008—The Real Costs of Cleaning Up Nuclear Waste: A Full Cost Accounting of Cleanup Options for the West Valley Nuclear Waste Site—revealed that leaving buried waste at the site is both high risk and expensive, while a waste excavation cleanup presents the least risk to a large population at the lowest cost. Full site cleanup was estimated to cost $9.9 billion (in 1996 dollars) while future costs of remediation of onsite buried waste costs would cost $13 billion, and $27 billion if a catastrophic release of only a small portion of the radioactive waste occurred. While a full exhumation of waste appears costly, the costs associated with a catastrophic release over the long term would be significantly higher. The SEIS must report and assess using a ZERO discount rate. It is essential to not discount future costs as this would skew and minimize the significance of future releases and consequences.

In closing, we strongly support the Sitewide Removal Option to clean up the West Valley site as soon as possible. We can no longer kick the can down the road, passing along this burden to future generations. To do so is irresponsible, dangerous, and costly.

The SEIS must focus on how to clean up all the waste, not if.