ML18120A108

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Comment (39) of Stephen Gliva on Holtec International HI-STORE Consolidated Interim Storage Facility
ML18120A108
Person / Time
Site: HI-STORE
Issue date: 04/30/2018
From: Gliva S
- No Known Affiliation
To:
Rules, Announcements, and Directives Branch
References
83FR13802 00039, NRC-2018-0052
Download: ML18120A108 (3)


Text

Mobile Chernobyl shipping risks Southeast New Mexico, near the Texas border, has the dubious distinction that every single train car load of high-level radioactive waste will pass through on its way into (and, if it ever leaves, out of} Holtec In,ternationa1/Eddy-Lea [Counties] Energy Alliance (EEEA). But transport impacts, to eventually import more irradiated nuclear fuel than currently exists in the U.S.into southeast New Mexico, will be felt nation-wide. Transporting 100,000 metric tons, or more, of irradiated nuclear fuel to New Mexico makes this proposal even bigger than the highly controversial, unacceptable Yucca Mountain, Nevada permanent burial dump scheme, in terms of transport impacts (limited to 70;000 metric tons under current law). In that sense, when it comes to radioactive waste transportation risks, we all live in New Mexico.

Countless millions of Americans, in most states in the Lower 48, would be put at risk by these highly radioactive, irradiated nuclear fuel shipments by train, truck, and/or barge.

A de facto permanent surface storage "parking lot dump" at Holtec/ELEA in S.E:New Mexico would only increase safety risks. It would not decrease them. It would multiply transport risks, as it would only be temporary (supposedly, even if decades, or centuries, or more, cari be called ('temporary"!). All that highly radioactive waste w.ould have to move again, to a permanent burial site (yet to be.

identified - thaf s a big iF! Yucca is NOT suitable!). And that could be back in the same direction from which it came in the first place; meaning transport corridor communities could see these high risks coming and going!

r Holtec/ELEA's assumption thatthedump at Yucca Mountain, Nevadawilllopen someday, to take the highly radioactive waste away, is fnappropriate. The vast majority of Nevad,ans have expressed their very adamant non-consent for 30+ years now, and still vehemently oppose it. This is reflected by bipartisan resistance by elected officials, at both the state government level, as well as the congressional delegation level, in NV.

Holtec/ELEA's assumption that another permanent burial dump will be opened, by someone, somewhere, someday, somehow, is also inappropriate. After all, the search for a national geologic repository has gone on since the 1950s, but has failed.

And DOE's current estimate for the opening of the U.S.'s first repository is 2048, 31

_ years from now. Exceptthey have no idea where that will be. There is-every likelihood that the 2048 date will slip into the future as well The failed Private Fuel Storage, LLC (PFS) parking lot dump targeted at the Skull Valley Goshutes Indian Reservation in Utah, likewise assumed the Yucca dump would open. They were, of course, incorrect. PFS was based on Holtec casks, just as is the current NM scheme.,

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So PFS' s, Plan B"*was to. '.'return to.sendei:," Hqltec l).c1~ a _similar :Alan,.if cas~.~; show up damaged or,contaminated, in order tQ:protectit~. supposed_ly; :*start clean, ~tay' :.

clean" Centralized-Interim.Storage:FacjlityfCISF'),. or :M,0p.itore,g.Retrie,yable. S,_to,ra:ge (MRS) site; in southeast NM. If 100,000 xnetric;: tops qfi.rl'.ad:i,ated nuclear fuel ~-th~. 1 amount.targeted to go,tb Holtec/ELEA:in sout)least NM>~were, t.o. be... rep.irned to.. /\\

sender'; some decade or century due to the lack ~fa permanent dum,psite; t9 ~end,it*

to, what would that look like in terms of multiplied transport risks?!

MainE;.Yankee was a,PFS:nudeatpow~rjnqustry-consor,ti~m,,rn~Il.lb~r.:M~re than SO rail sized containers of highly radioactivejrr.adiiJtecJ:,nud~c1.r fuel w.ould }:iav~'..

traveled 5,0'0.0Jniles, round trip, from. Maine to Utal)., accomplishjng ab_solutely *.**

nothing, other than exposing millions of people in numerous states to high-ris~

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This garpe of _4igh-risk,.highJ{radioactive WclSt~ m~si~~l ch~irs, or.highly.radioactive waste hot potato, on the.roads (initial Jeg heavy haul trucl< shipments), rails, and waterways (initial \\eg*barge sh.ipme.nts), is µnaC:c:ept~~l~: Jtahiq~*nts to Radioactive,

~u~sI~;nr:ouJ~tte. o.n th~.r,qads, ~aiJl?, and \\-Yeteryv~y~;:Mul_tiply,~g transport.~js~ -~~*r no gooe;l.;r:eason Jswroi;ig, c1nd pla~es nq s,ens~. 1.

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The Hoi'tec~s infamou~, Qu<;1.lity)~.~surc1nc~JQA) failures. and yi9latipns,c1f~ very,,,

significant tQ.. s];iipping risks. Shippil;lg casks would b~ les.~.~apable of wit}:istal).ding.

severe.,aq;,igeuts ( sue: as, high'."speed -crashes:* includingintq*irnmovable _objectsJike bridge aqu.:tm.eµis~ high-te~peratur-r-,.long:dur,~t(~p*_ f\\~~.s~ de,ep,)ong-lastin,i,. ',':. .': underwatt.'I:i~upn,.ersiol).s; drops from 1tall heights; onto unyi.elding_sJirfa~es, such,a:S bri,d.ge four,1ct_atiqns*,or.r,9c:ks clo:WJ:).,l;>el9w;_qr, iome cp~bination of all those), a15.well as intentioD-al.attacks (such as with shaped charges, or anti-tank. weapon systems~* see below)'or other powerful explosions (such as explosive cargoes on passing ** trai:ns, inclµding, J]OVval:l.;1ys,.cru_de oil. '.'Bm;n,b Trp.ins,. a_~Jr:om the ~~~k.ep. oil,fiel~~ in North D.;ik:qt~).

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Add,ingJ~;-th~se ~hipping risks, is.the.pot~ntial f~r barge,shippJ.ents.on *sur;fa~e waters. ShipmentstoHoltec/ELEAin southeast NM are supposed to b.e.. l!mostly rail" i --*which can.also mean many barges (more than n..vo-dozen reactor~. irt'the U.S. lack () direct rail ac::cess,,mea;ni,ng barges. on ~urface w~ters _--:7 t~e Great J,ake,s, river~,. seacoasts~- could he lisedto haul the 1oo';i-ton,'rail;size,d.casks' tothenearest rail. head). Backgrounders -(incl udi~g. ~or~ ct;tpils on th*e high.risk~ J. on th~se.variqµ~' *. _: * ,d _barge ~outes (iqduding in.'apsJ ~er{ori$!nqJiy.wf_i,~~~i{t,q*r.~h'e\\fµc~a_'<l,.U\\np ~~h~m,e/ however, H9ltec/ELEA could just as well involve such barg-~s...

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_... :. ~.. ' '.. ~..... (Howeve~, -~i't1f s~m~th~n~ ~*s* ~iinpl:e* a~'.~'di~h-~d NltC 'r'~bk:~~7~~~~p ~niendni~dt :~: which the shamelessly complicit and colluding agericy\\~ou1d'he'only too'happy fo,, provide the company -- Holtec could apply for, and perhaps even quickly get, permission to truck in smaller-sized, "Legal Weight Truck" (LWT) casks to the s.e NM CISF /MRS. After all, Holtec has bragged in its CISF license application 2

documents SU bmitted to NRC that if would accommodate an}' and,all-cask'models; not.ju.st its owh; at the s:e: NM MRS -site. Any and all would ir.1clude LWT ;sized outer. casks'~hd-iriner canisters:'tohtaihing frradiated.nudear fu.eLThis'mix of.* trairis/barges/heavy hafr}'.tfutks,*art~LWT tasks/canisters, would meari even more Americ-an'comrpunities W6ultfbe exposed to:Mobile Chethobyl risks; as along *;, interstate' highways. ' '.,.;. *. * : : *.,,, ) * :. 1, * :.:; ~. '.!.;:. j. *,* ) ; __.. "Dirty Bomb on Wheels" security risks would abound. This was made clear by the 1test of aii'1inti-tarikmissile:againstah(emptyJ i'rra:::liated nudear fuel* shipping cask at the U.S. Arrriy's*'Abetdeeri Proving Ground'ih-Maryland.*J'he June,19.98-test targeted a German *cASTOR cask While certified for storage""only in the.'.U.S. (the cask nibdel is deployed at the nuclear power plant in Surry, VA), it is '.used for transport in Europe, as in France and Germany. CASTO Rs have relatively thick die cast iron walls, as opposed to much thinner walled steel inner canisters in the U.S. (iS+ 'inches thick CASTO Rs, versus arm.ind O.Sinches thin inner canisters as with* th_e Hoh~C'contafoers!) That is, CASTO Rs are significantly more robust/more ckpabJ~'tdwithsta'nd such an:attack. How~ve'r;ie'ven,tlie CASTOR; the*"Cadillac of. shipping casks'f 'as sbme'haJe 1called'if; was:s'.everely breached :fiy the ahti-tank. missile test at Aberdeen Proving Ground.;A hole as-big around asa*grapefruit or, *' softball was blown clean ~hrough the side of the c;ask wall. Had irradiated nuclear fuel been in'side, the hole 'would *have created the pathway for releas*e of disastrous' ainourits ofhazardous'radioactivity::.. all the-inor~ :sc>; 'ff'an incendia.r}~ a'ttack were.. '.cbmbined'with the*e.xpldsive:attatkffthe zirconium rnefal clacldingon'the-fuel rods in the irradiated n'tkfoa'r fuel' ass*e1hblj\\vere fo be' heated to its ;ignition temperature, the 1 fire could'e'yen becoine-self-feedfog, lik~'highly :radioactive, super-sized 4th of.. Julyspatklers~ lnshort,* shipping containers'were not desigfied'tffwithstand such attack's.'/, ;,_,...,.. _.*,-,.- i .r;'..,- . ',.,.,./' :,_,;,;:.,.

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~ ~. ' :.:. ; Su~ff~ :st'enario 'could unleash disa;strous a:*lllotints of hazardous'radioactivity into*, the environment, hence the label of potential "Dirty Bombs on Wheels;" As San * . Onofre Safety has put it, each Holtec canister holds an equivalent amount of volatile ( able.td escape in a fire}radioa'C'tive *c:esium:.13 7 as was releas:ed by the Chernobyl . nuclear catastrophe.'And as Dr. Marvin Resnikoff of Radfoactive Waste Management Associates has put'it;'a contMnerhol'dfog24 Pressurized'Water'Reador (PWRJ -- irradi~ted nucie;ir fuel assemblies' holds 240 times the long:'liasting radioactivity (in terms !6fradibc;1c:t:ive cesium j's':otbpes' alone} iet alone the hundreds ofadditional

  • hazafdbus: ra"dibad:ive ;isotopes) iel~as.~d'by tfie :Hi'roslhriia' dtorhit:b,~rrib:.-only !

Holtec has Moved oh' from contafriers hdldifl'g*2:f'PWR"'.fasemJ3iie(t'fro_ties: capable of holding 37 assemblies'!*That wb\\ild*thus mean 3tHii-bshima1a'.foniic 'D'6mbs'Worth oflong-lasting radioactivity in each container! Only it's worse than that; as Resnikoffs figure applied to lowJ;mrnup fuel; high burnup fuel, unfortunately coihmdnpla~e-t~d~~}~Jf~~::0i~~t~1to~'.~t~!~e!.. :': -,,:, :-.* 'f, * {,'.' I

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