you are right, the nuclear business is more complicated and they take safety more seriously. I saw a big difference between nuclear and Oil & Gas.
However, the comparison is not asinine. The documents and process are the same for good reason. In fact, I remember reading the word "characterization" in the news somewhere about the Consent Order. The exact same word is used in nuclear and it means the exact same thing. Do you know what it means??
Anyway, let's compare nuclear and waste plastic. In the nuclear industry there is this stuff called Tritium. It is a natural by-product of the nuclear fission process and is like water. I think what it is is heavy water with an extra nuclide, and it is unstable (emits nuclides). It is a beta emitter. There are 3 kinds of radiation (gamma, beta, neutron). Heavy water is (I think...) D2O. Deuterium (2) and Oxygen (1). If I remember it right Tritium is D3O.
Anyway, the point is, it can get into a human via ingestion, absorption, or penetration. In layman's terms, if it gets spilled on you, that is BAD. Since it is basically water, and has a half-life of 50000 years, if you get it in you, you have to drink water and go peepee until it no longer is in your system. It can take days..
Now, what about simple acid? If it gets on you it is BAD. Same thing.
In the oil and gas industry, the bad stuff is benzene. Don't know why, just is.
So tell me, how is the government to handle this?
Does it not make sense to have the same documentation structure and process? With the same names? The hazards and preventive measures are different, but that is just content. Each one deserves an EA.
What if the waste plastic has (or could have) acid on it?
Just an example.
I doubt that you could find a flow chart that tells you that the EA is done prior to applying for permits, or that the objective of a BUD is to control environmental damage and that it is not a mechanism of avoidance. There are those that know and those that do not know. There is so much red tape and documentation with the government it is difficult to get a single big picture that shows this process. JBI would have had to consult in an open-minded fashion with the DEC to understand this going in.
Believe me or not.
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