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Dear Mr. David Levenstein and U.S. Department of Energy.

I would like to comment on the Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement, the Mercury Storage EIS, DOE/EIS-0423D.

Texas is already under assault from toxic mercury from coal burning power plants. They spewed over 11,000 pounds into our air in 2007. Our children are at risk for permanent brain damage from mercury exposure and unfortunately we rank worst in the nation for coal plant emissions. This must change and emissions must be reduced.

Texas needs less mercury, not more. Now the DOE supports Texas as the preferred site for storing up to 11,000 tons of toxic elemental mercury.

Why should Texas be the national dumping ground for stored toxic mercury? I do not support 11,000 tons of toxic mercury coming to our state and proudly say "Don't Mess With Texas."

An artificial 40-year timeframe has been constructed for this storage effort, but the truth is that elemental mercury lasts forever, and someone will have to continually repackage mercury flasks for centuries to come. Can we assured that this will be possible at a site that will take huge amounts of radioactive and hazardous waste? Will it always be accessible?

The option to consider multiple sites was simply written off and not examined in your draft EIS, although it should have been. There are many viable sites under consideration; some that have military security and some that already store mercury. Some of it, including the DOE mercury at the Y- 12 National Security Complex in Tennessee, could stay where it is. There is no reason to ship mercury here from around the country increasing the number of trucks and trains in Texas carrying loads of toxic mercury and increasing risks of a serious accident.

Furthermore, this a grand experiment in risking the mixing toxic and hazardous materials with dangerous radioactive materials all at one site? Why has no cumulative impacts analysis been conducted? The WCS site is licensed to take hazardous waste. Highly radioactive "K-65" weapons waste from Fernald is already onsite and they're licensed to take over 59 million cubic feet of radioactive waste.

Where is there no independent analysis of the groundwater level as opposed to information provided by Waste Control Specialists, the company that would benefit by taking more waste?

The characterization of the site is inadequate and inaccurate. Tornados and earthquakes pose serious risks that need to be further examined. There have been 21 tornados in 42 years. Cars can be lifted and houses lifted off of their foundations by tornados. It is unreasonable to assume that a building not specifically reinforced and designed to withstand a tornado would do so, and there should be requirement for reinforcing the building exterior if a facility is built at this site.  Containers of mercury spread throughout West Texas as a result of a tornado would be a true disaster.

Despite claims to the contrary, groundwater lies beneath trenches adjacent to where the mercury would be stored. Independent analysis of the exact location must be conducted. Relying on WCS studies in inadequate. Three former TCEQ employees quit the agency in protest of licensing the radioactive waste facility due to the inadequacy of the site, including the fact that groundwater is only 14 feet below the bottom of some trenches. Fractures and fissures, in addition to onsite wells, provide pathways through which contamination could spread. Several aquifers are in the region. The Ogallala Aquifer underlies eight states in the wheat and soy-growing region of the US.

The health impacts of mercury inhalation are inaccurately minimized in the EIS. Microbeads of mercury can condense on the storage canisters, increasing the possibility of inhalation. Vapors would be monitored, but what if monitors are not calibrated correctly or are in error? Container flasks can leak and no repackaging plans or container lifespan data have been included in the EIS.

The EPA states the following regarding elemental mercury risks:

"Elemental (metallic) mercury primarily causes health effects when it is breathed as a vapor where it can be absorbed through the lungs. These exposures can occur when elemental mercury is spilled or products that contain elemental mercury break and expose mercury to the air, particularly in warm or poorly-ventilated indoor spaces. The first paragraph on this page lists the factors that determine the severity of the health effects from exposure to mercury <http://www.epa.gov/mercury/effects.htm#content> . Symptoms include these: tremors; emotional changes (e.g., mood swings, irritability, nervousness, excessive shyness); insomnia; neuromuscular changes (such as weakness, muscle atrophy, twitching); headaches; disturbances in sensations; changes in nerve responses; performance deficits on tests of cognitive function. At higher exposures there may be kidney effects, respiratory failure and death. People concerned about their exposure to elemental mercury should consult their physician." (http://www.epa.gov/mercury/effects.htm)

Only the handling area would be air conditioned at the WCS site. With volatilization of mercury a serious problem, the whole building should be required to be kept at a constant low temperature. Geothermal energy might be tapped for such a purpose. In such a hot desert location in Texas, the entire facility should be cooled in order to protect worker health and minimize mercury vapors. Monitors should measure mercury vapors escaping the building and a requirement should be in place to make real-time data available to the public online on an ongoing basis.

Socioeconomic factors should rule out the WCS site. Andrews County is 40% minority and 17% below poverty levels. Environmental justice is not adequately being considered in the EIS. While the area is not heavily populated, people living in the region are not dispensable and the city of Eunice, New Mexico is only 5 miles from the site.

In summary, I strongly oppose sending any toxic mercury to the WCS site in Texas and urge you to immediately reconsider other alternatives and safer sites. The EIS needs to fully analyze the many issues discussed here, conduct independent studies and strengthen requirements for mercury storage. The mercury is going to last forever, not just 40 years, and the possibility that it will remain at a designated site should be more carefully considered in developing the storage requirements, including building design.

Please reply to my comments.

Take Action Fax U.S. Department of Energy Your Comments on Mercury

Take Action
Fax U.S. Department of Energy Your Comments on Mercury