January 11, 1999

R. B. Heater, Chairman
Technical Committee
NC Low-level Radioactive Waste Management Authority
116 West Jones Street, Suite 2109
Raleigh, NC 27603-8003

Re: Decay In Storage

Dear Mr. Heater:

On behalf of the Blue Ridge Environmental Defense League Board of Directors, I write to oppose the proposal outlined in your letter of December 4, 1998.  While decay in storage is a technique which is used with success by some facilities for short-lived radioactive isotopes, the DIS concept for centralized storage has many of the same flaws as the traditional land disposal facility.

Centralized storage in North Carolina, or any other state, places an unacceptable burden on the citizens of the community where it would be located and an unfair burden on the taxpayers.  In your Executive Summary you state,  “It is unlikely that any private, commercial concern would consider funding the relatively high-risk licensing phase of the project.” (emphasis added). With this statement you have hit the nail squarely on the head regarding the financial risks involved. The financial risks are based on the institutional and regulatory uncertainties of centralized storage as much as the particular method of storage.

Moreover, the risk to public health, safety, and welfare from such a facility have been and remain the primary concern of the Blue Ridge Environmental Defense League since we first raised objections to the Southeast Compact’s centralized low-level radioactive waste project in 1985.

In response to your committee proposal I would pose this question: Would decay in storage be an acceptable technique to Duke Energy and Carolina Power & Light, the major producers of radioactive waste, if the storage was done at each of their reactor sites?  If the committee answers this question yes, than you may have a solution.  If the committee finds the answer is no, then there is a fatal flaw in the proposal and the Authority should consider it no further.

Thank you for the opportunity to provide input on this important matter.  I look forward to your meeting on January 19th.

Sincerely,

Louis Zeller