Update: The US DOE has unofficially (not published in Federal Register) extended the German waste dumping comment deadline. To be anonymous you will have to send a disposable email, or send it by post with no return address. People should have the right to “vote” anonymously, but the jackboots of nuclear dictatorship have hit the ground. “Comments may be submitted by email to GermanSpentNuclearFuelEA@leidos.com. Direct written comments on the Draft Spent Nuclear Fuel from Germany EA to Tracy Williams, NEPA Compliance Officer, U.S. Department of Energy, P.O. Box B, Aiken, South Carolina 29802. DOE has extended the public comment period in response to several requests. The public comment period now ends March 25, 2016. DOE will consider all comments received via email by 11:59PM Eastern Standard Time or postmarked by that date. Comments submitted after that date and time will be considered to the extent practicable.” http://energy.gov/nepa/ea-1977-acceptance-and-disposition-spent-nuclear-fuel-containing-us-origin-highly-enriched The formal deadline was March 11 at 11.59 pm: http://www.regulations.gov/#!documentDetail;D=DOE_FRDOC_0001-3020

Germany wants to empty 93% of high level nuclear waste from an above ground concrete bunker (Ahaus) and send to it to America to sit out on concrete or gravel, probably under a tarp, for a decade, or longer, before processing-dilution. More will be removed from another comparatively solid facility (Juelich), as well. What a neat trick to get rid of most of their nuclear waste! What great German technology and innovation to just dump on others!



Pandemonium by John Martin

Most likely some will end up buried in Texas, Utah, or elsewhere. Reading the EA it looks like a dilute to deceive scam. It could end up staying in South Carolina, too. Some of the processes proposed and resultant forms appear very dangerous as well.

This may well be a test case. It is a very dangerous precedent to allow the import and processing of foreign commercial waste, and to dilute and bury it in America. It is supposed to be illegal on the German end, and may well be illegal on the US end, as it involves the processing of foreign commercial waste.

Regardless, it is morally wrong. The man who agreed on the US end – Tom D’Agostino – now works for Fluor, the lead operator at Savannah River Site, and the German woman (Annette Schavan) who asked to dump the waste is now German Ambassador to the Vatican, even though she was stripped of her doctorate, for allegedly plagiarizing a dissertation on ethics… no joke!

The Environmental Assessment Alternative, which must be requested, is “No Action Alternative. Under the No Action Alternative, the spent fuel would NOT be transported to the United States for management and disposition…” (Draft EA) The comment deadline is March 11 at 11.59 pm: “Environmental Assessments; Availability, etc.: Acceptance and Disposition of Spent Nuclear Fuel“. http://www.regulations.gov/#!documentDetail;D=DOE_FRDOC_0001-3020

See recent H-Canyon safety problems here: http://www.dnfsb.gov/sites/default/files/Board%20Activities/Reports/Site%20Rep%20Weekly%20Reports/Savannah%20River%20Site/2015/wr_20150306_116.pdf

Draft EA for Comment: http://energy.gov/sites/prod/files/2016/01/f28/Draft%20DOE%20EA%201977_FOR%20PUBLIC.pdf

They have wanted to mislead people by calling it HEU (Highly Enriched Uranium), whereas it WAS HEU and now it is high level nuclear waste! They admit it in a couple of places in the document, such as here:

“DOE dropped from consideration one of the options identified in the Notice of Intent, down blend of the HEU to LEU for reuse as reactor fuel. As pointed out by commenters, the nature and isotopic content of the spent nuclear fuel from Germany makes LEU from down blending this HEU unsuitable for use in commercial reactor fuel” pp.1-8 to 1-9, Draft EA. In short, it’s nuclear waste. The “down blend” may now be to make it dilute enough to classify for land burial. It may include mixing it with DU.

“The shipping campaign from Germany would involve about 30 shipments over approximately a 3.5-year period to transport the 455 CASTOR casks of spent nuclear fuel from Germany; a typical shipment would include 16 casks.” (Draft EA) They are about half the size of the typical US spent fuel casks, so this is equivalent to around 228 US spent fuel casks, which is a lot! More waste will be made through the processing, as well.



Holtec Dry Casks of Spent Nuclear Fuel at Grand Gulf Nuclear Power Station, Missisippi, USA

According to the German government, at Ahaus Transport Cask Storage Facility there are 329 CASTOR® casks. 305 CASTOR® casks are from the THTR/AVR Nuclear Reactors. http://www.bfs.de/EN/topics/nwm/interim-storage/central/ahaus/ Thus, they will get shot of 93% from that facility. The balance are at Juelich.

Ahaus Storage Facility, location exported from Wikipedia.



vs. Savannah River Storage Pad.



This is what they mean when they say storage pad and cover. TRU is Transuranic Waste, like Plutonium and Americium.











The Commercial Waste Facilities in Texas (WCS) and Clive Utah (EnergySolutions) are mentioned as places where diluted waste and/or new waste created through processing may be sent (and buried as seen below).





“Figure 2-4 presents the H-Area Alternative and depicts the three options for processing the dissolver solution through H-Canyon, the Vitrification Option, the LEU Waste Option and the LEU/Thorium Waste Option. This figure shows the principal waste streams generated under each of the three options. Additional wastes, such as casks, canisters, and job control waste are not shown in Figure 2-4, but are identified in the process option descriptions and evaluated in the impacts analysis.“, p. 2-10, Draft EA.

“To meet disposal site requirements for fissile material content, an administrative limit of 900 grams of fissile material per cask would be imposed, meaning that only a portion of the capacity of each cask would be used; the balance of the cask would be filled with clean grout.” (p. 2-16) (Grout is concrete).

The transportation required gives some sense of what may happen to this nuclear waste, depending on options chosen.



Note the DU which may be used for dilution to make the waste appear less radioactive, but DU becomes more radioactive over time due to ingrowth! The EA title is misleading, or possibly a lie, so we blotted out that part to reduce confusion.



The Environmental Assessment author says that people “purported” that the reactors were power reactors, when they were indeed power reactors (i.e. connected to the grid). Notice the “mostly in German” to mislead people. There is IAEA and other documentation in English, as well as German, and other languages.

“Commenters also submitted technical papers, mostly in German, purporting to demonstrate that the AVR and THTR reactors are power reactors.” p. 1-8

According to the IAEA, the THTR-300 (Thorium High-Temperature Reactor) was owned by KERNKRAFTWERK GMBH HOCHTEMPERATUR-KERNKRAFTWERK GMBH. The GMBH means limited liability company (LLC). The First Grid Connection and Commercial Operation were 16 Nov, 1985 and 01 Jun, 1987, respectively. Permanent Shutdown was 29 Sep, 1988. Its “Energy Unavailability Factor” was 58.7 % https://www.iaea.org/PRIS/CountryStatistics/ReactorDetails.aspx?current=92

AVR JUELICH (AVR) HTGR Pebble bed reactor prototype ARBEITSGEMEINSCHAFT VERSUCHSREAKTOR GMBH had its First Grid Connection and Commercial Operation on 17 Dec, 1967 and 19 May, 1969, respectively. Permanent Shutdown Date was 31 Dec, 1988 “Energy Unavailability Factor” was 37.2 %

https://www.iaea.org/PRIS/CountryStatistics/ReactorDetails.aspx?current=114

Thus, Germany is trying to send nuclear waste from its failed Pebble Bed reactors from comparatively sturdy concrete facilities in Germany, across the Atlantic, only to be parked outside or under tarp in the sweltering heat of South Carolina, and probably melted at 1950s H-Canyon, which had criticality safety issues last autumn. While it may be true that the nuclear waste should not be left in Juelich, due to earthquake risk and possible volcano hazard, it can certainly stay in Ahaus and/or the above ground concrete bunker like facility near Gorleben, or anywhere they want in Germany. It is not America’s problem. Furthermore, South Carolina, and especially Charleston, is at risk for large earthquakes. In the past a major earthquake buckled railroad tracks and apparently overturned the trains themselves, as seen in this photo.

Overturned Train in South Carolina From Large Earthquake



The Pebble Bed type of reactor was rejected by the US more than once, due to fuel problems. The Swiss and Germans decided to build them anyway. They failed miserably and caused contamination. The Germans sent the extra fuel to Scotland to be processed at Dounreay, and the waste created by the processing will remain buried in Scotland. Now they want the US to take the old spent nuclear fuel, and not only pollute the US, and make more waste through processing the fuel, but will leave the waste in America!

These were commercial nuclear reactors, which were connected to the grid, although they were not very successful with energy “unavailability factors” of approx. 40% (small AVR) to 60% (larger THTR), according to the IAEA! One had to be bailed out by the German government.

It is illegal for this spent nuclear fuel to be exported from Germany and may be illegal for the US to process spent commercial fuel. Regardless, it is morally wrong and sets a very bad precedent for the import of nuclear waste from foreign countries. This is all the more criminal since the US hasn’t even found a solution for its own nuclear waste.

These two reactors are well-documented, in English, German, and even French, as commercial, and were connected to the grid, not that it really matters in our opinion. Furthermore, the nuclear fuel was highly enriched but is now spent nuclear fuel, so how enriched is it? And, how is enriched uranium more safe sitting outside than in a concrete bunker-like facility? Where was the uranium mined? Germany has mined a lot of uranium. If it was enriched in South Carolina, and possibly mined in the USA, but the energy and research benefits went to Germany, then sending the nuclear waste back also makes the stolen land of America a triple victim. Has anyone asked the Cherokee or other Native tribes, whose names are almost lost in time, if they want their land contaminated by this nuclear waste? How about the non-reservation Cherokee? When will Europe and the world stop seeing America as its dumping ground – first of unwanted people and now of radioactive waste? What sense does it have to steal a land from the Natives only to destroy it, especially at the behest of third parties? By what right? The Cherokee didn’t leave willingly as seen in this 1760 massacre just upriver from the Savannah River site: https://en.wikipedia.org/wiki/Long_Cane_Massacre_Site

What about those Americans who may, or may not, be part American Indian, but who cannot return to their known indigenous homelands, unlike Tom D’Agostino who can get EU citizenship based on an Italian passport. Or, President Obama, who apparently plans to evac to his paternal homeland of Kenya. Shame, shame Mr. Obama. America only gave you and your ancestors good things. Obama’s American ancestors were not enslaved! Why does he hate America so much that he is bringing in foreign nuclear waste from around the world to dump on it? There are many Americans who have been nothing but mistreated by their country, but still love it as their home. Furthermore, they have no other place to go! Why does Obama hate America so much? He’s old enough to have gotten over his mother’s view, as an anthropologist, that all foreign and exotic is good and all American is bad. But, that seems to be his view. So, why’s he even in America? Why did he choose to visit with Queen Elizabeth instead of his paternal village in Kenya?