ML18207B021

Comment (248) E-mail Regarding Holtec-CISF EIS Scoping

ML18207B021
Person / Time
Site:	HI-STORE
Issue date:	07/14/2018
From:	Public Commenter Public Commenter
To:	Division of Fuel Cycle Safety, Safeguards, and Environmental Review
NRC/NMSS/DFCSE
References
83FR13802
Download: ML18207B021 (6)

Text

1 Holtec-CISFEISCEm Resource From:

Susan Armistead <scubasuemd@gmail.com>

Sent:

Saturday, July 14, 2018 11:12 AM To:

Holtec-CISFEIS Resource

Subject:

[External_Sender] Docket ID NRC-2018-0052 Loss of Institutional Control over Surface Storage Sites would eventually prove Catastrophic.

DOE (the U.S. Department of Energy) warned in its Feb. 2002 Final EIS (Environmental Impact Statement) on the proposed Yucca Mountain, Nevada national burial dump for highly radioactive wastes, that loss of institutional control over surface storage sites would eventually prove catastrophic. (Loss of institutional control means societal breakdown, so that maintenance, repair, and replacement of infrastructure and storage containers at Holtec/ELEA would be lost over long enough periods of time - in fact, even basic knowledge of the existence of the facility itself there could be entirely lost/forgotten someday!)

Entropy means that things falls apart, over long enough periods of time. It is the second law of thermodynamics, after all! DOE was focused on this happening at nuclear power plant sites, if irradiated nuclear fuel was abandoned there forever. But the same is true here. DOE used the argument in its Yucca FEIS as a way of pressuring states (and their congressional delegations) to support the proposed Nevada dumpsite, lest such a catastrophe unfold in their own jurisdictions and districts over time. (The prevailing national environmental movement consensus since 2002 has been for Hardened On-Site Storage (HOSS), as close as possible to the point of generation, in order to prevent such radioactive releases at reactor sites. See the Statement of Principles for Safeguarding Nuclear Waste at Reactors, with its list of signatory groups. < http://ieer.org/wp/wp-content/uploads/2010/03/HOSS_PRINCIPLES_3-23-10x.pdf >)

If institutional control is eventually lost at the Holtec International/Eddy-Lea [Counties] Energy Alliance (ELEA) centralized interim storage facility (CISF, or at the Waste Control Specialists, LLC monitored retrievable storage (MRS) site in Andrews County, west Texas, just 38 miles to the southeast of Holtec/ELEA),

the storage containers would eventually fail, and catastrophically release their forever hazardous, highly radioactive waste contents into the living environment. Hazardous and even deadly fallout would then flow with the winds and the waters, downwind and downstream, over greater and greater distances, over an unimaginably long time period. Remember, highly radioactive waste remains hazardous, even deadly, for a million years into the future.

This was acknowledged by the U.S. Environmental Protection Agency (EPA) in 2008, under court order, in its Yucca Mountain dump regulations. (An environmental coalition, joined by the State of Nevada, filed a lawsuit in 2002, objecting to EPAs attempt to cut off regulations at Yucca after just 10,000 years post-burial. The D.C.

Circuit Court of Appeals ruled with the environmental/Nevada coalition in 2004, ordering EPA back to the drawing boards on its Yucca regulations. Four years later, EPA published its million year standard. It is still a significant underestimate of the hazards persistence, however. Iodine-129, an artificial radioactive isotope generated by reactors and present in irradiated nuclear fuel, has a half-life of 15.7 million years. Its hazardous persistence is at least ten times longer, or 157 million years!)

Such impacts could extend to soil, groundwater, surface water, flora and fauna, significant distances downwind and downstream of the Holtec/ELEA site, midway between Carlsbad and Hobbs, NM.

The risks would also persist down the generations, and work their way up the food chain (on top of which humans sit), through processes of bio-concentration, bio-accumulation, and bio-magnification. (At WCS, TX, just 38 miles to the east-southeast of Holtec/ELEA, the immediately adjacent and perhaps even underlying, Ogallala Aquifer would be put similarly at risk. (See the Sacred Trust NM map <

http://sacredtrustnm.org/wpcontent/uploads/2016/02/2015update-ThreatsMap-11x17.pdf > for a clear picture of the lay of the land in s.e. NM and w. TX, and the large number of dirty, dangerous, and hazardous fossil fuel,

2 nuclear, and other facilities are already located there!) The Ogallala can also be considered downwind and downstream. Aquifers directly under or adjacent to WCS could be in direct communication with the Ogallala.

Also, downwind or downstream surface level fallout from WCS could eventually find its way into the Ogallala, through natural flow paths (blowing with the winds, flowing with the rains, deposition onto and into soil, downward flow to aquifers).

The Ogallala, North Americas largest, provides essential drinking and irrigation water for millions in Texas, New Mexico, Oklahoma, Kansas, Colorado, Nebraska, Wyoming, and South Dakota. As the water protectors at the Standing Rock Sioux Tribe reservation say on the Missouri River in North Dakota, Mni Wiconi, Water Is Life. This was made very clear by recent drinking water contamination disasters in Flint, Michigan; Charleston, West Virginia; the Animas River in Colorado, New Mexico and Utah; and Toledo, Ohio.

A radioactive release into or contamination of the Ogallala would be catastrophic, for millions downstream.

And given the more than million-year hazardous persistence associated with irradiated nuclear fuel, it is very possible that leakage of such radioactivity even at Holtec/ELEA, some tens of miles upstream/upwind of the Ogallala, could also impact it, over time, given water and air flows carrying the contamination there eventually!) Making these risks all the worse, NRC (the U.S. Nuclear Regulatory Commission) has allowed a quality assurance (QA) failure crisis to persist in the U.S. nuclear power industry for years and decades. These QA failures extend not only to on-site storage casks at reactors, but also to the shipping casks and away-from-reactor storage casks realm. These QA violations, especially infamous regarding Holtec containers, would risk early failure of casks at Holtec/ELEA, let alone eventual degradation breaches over longer time periods, as due to weathering, erosion, corrosion, etc. of the Holtec/ELEA facility and storage containers, as due to loss of institutional control.

Industry and even NRC whistle-blowers called attention to these QA failure risks 18 long years ago, yet little to nothing has been done to correct them. These revelations had to do directly with Holtec containers. Industry whistle-blower Oscar Shirani questioned the structural integrity of NRC-approved and industry-utilized Holtec storage canisters and casks sitting still, let alone traveling 60 miles per hour or faster on the railways (or on heavy haul trucks, or barges, to get the rail-sized containers to the nearest rail head for transfer onto the train tracks in the first place). Shirani was backed up in his allegations by NRC Midwest Region dry cask storage inspector, Dr. Ross Landsman, who warned The NRC should stop the production of the casks, but they do not have the chutzpah to do it.

This is the kind of thinking that causes space shuttles to hit the ground. See a Summary of Oscar Shiranis Quality Assurance Violations Against Holtec Storage/Transport Casks. <

http://www.beyondnuclear.org/centralizedstorage/2017/4/5/summary-of-oscar-shiranis-allegations-of-quality-assurancev.html > Such QA failures, shoddy design, and shoddy fabrication, of the storage/transport canister and casks, means that their eventual failure, and release of their deadly hazardous highly radioactive waste contents, will only happen all the sooner.

Although Shirani and Landsmans revelations were about Holtec casks (targeted for use at the Eddy-Lea Energy Alliance proposed centralized interim storage site in New Mexico, not far from WCS, TX), NRCs incompetence at best, or even collusion with industry, when it comes to cask QA violations, extends to other cask models and designs, including NAC (Nuclear Assurance Corporation) and Areva (recently renamed Orano) canister and casks to be used at WCS, TX. Although the Holtec/ELEA CISF/MRS site in NM would predominantly use Holtec canisters and casks, the company did brag in its CISF license application documents that its UMAX system could accommodate any and all NRC-certified canister/cask design in the U.S. This would include NAC and Areva canister/cask models, as well. Nuclear Assurance Corporation (NAC) container

- to be used at WCS, TX, and perhaps also at Holtec/ELEA, NM -- QA failures are of specific concern.

3 Last autumn, shoddy welding by NAC led to the bottom literally falling out of an irradiated nuclear fuel assembly transfer caddy, allowing the highly radioactive (and dangerously fragile, in terms of short-and long-term structural integrity, given the exceeding thinness and brittleness of the zirconium cladding on the fuel rods) assembly to strike the bottom of the storage pool at Chalk River Nuclear Labs in Ontario, Canada. Such bad welding calls into question the welds on NAC storage and transport containers as well, such as those potentially to be used at Holtec/ELEA, NM (and certainly to be used at WCS, TX).

At the Davis-Besse atomic reactor on the Great Lakes shoreline near Toledo, Ohio, an Areva design Transnuclear NUHOMS storage cask was loaded with irradiated nuclear fuel, despite local environmental group legal interventions to stop it, after it was revealed the walls of the inner canister holding the highly radioactive irradiated nuclear fuel waste were ground too thin during fabrication, in violation of the designs technical specifications. But violations of tech. specs. for the design and manufacture of casks in the U.S. are as rampant as QA violations. Areva Transnuclear NUHOMS canisters and casks would be used at WCS, TX, and could also be used at Holtec/ELEA, NM.

All this boils down to the risk that de facto permanent abandoned of high-level radioactive waste at the surface, at WCS, could lead sooner rather than later to cask failure, and catastrophic radioactivity release. Such level of detail about specific violations of QA and tech. specs., regarding other cask/canister models (such as EnergySolutions VSC-24s, Ventilated Storage Casks) that could be used at Holtec/ELEA, NM, could also be cited.

NRC, in its so-called Nuclear Waste Confidence Draft Environmental Impact Statement (DEIS), asserted that whether on-site at nuclear power plant sites, or away-from-reactor CISFs (as at Holtec/ELEA, NM; WCS, TX; etc.), the contents from failing dry casks could simply be transferred into brand new replacement casks. But not a single such transfer has ever taken place in the U.S. to date, dating back to the advent of dry cask storage (at the Surry nuclear power plant in Virginia) in the mid 1980s. This, despite the fact that numerous dry casks, as at Palisades nuclear power plant in MI, are acknowledged by industry and/or NRC to be defective (the fourth VSC-24 to be loaded at Palisades in June 1994 was soon thereafter acknowledged by the nuclear utility to have defective welds).

NRC asserted in its Nuke Waste Con Game (as critics dubbed it) DEIS that nonexistent Dry Transfer Systems (DTSs) could be built at some unspecified future date, with no known source of funding, to accomplish this cask-to-cask transfer, when needed. Despite many thousands of public comments expressing concern about such an overly optimistic, science fiction/fantasy paper plan, NRC stood by its Dry Transfer System confidence in its Final EIS (NRCs phrase Nuclear Waste Confidence had to be changed by the agency to the euphemistic Continued Storage of Spent Nuclear Fuel, as critics had effectively changed the phrase to Nuke Waste Con Game!)

Frighteningly, DTSs may be a fantasy plan on which NRC and Holtec/ELEA (and WCS) cannot actually deliver. In that case, abandonment and eventual failure of untended highly radioactive waste storage containers at Holtec/ELEA, and WCS, in the NM/TX borderlands, could well lead to the catastrophic releases of hazardous radioactivity into the environment that DOE warned about as possible at nuclear power plant sites, in its Yucca Mountain Final EIS in Feb. 2002!

The risk that so called interim or temporary (as if 40 years, or many decades longer, could ever be called interim or temporary in the first place!) storage facilities will become de facto permanent surface storage parking lot dumps significantly increases these loss of institutional control dangers. You dont have to take our word for it. Dr. Allison Macfarlane, the NRC Chairman, the agencys top official and spokesman, warned in a note accompanying her Nuclear Waste Confidence vote several years ago, that loss of institutional control is almost guaranteed over a long enough period of time. In this regard, she disagreed with the NRC staff (which had prepared the Nuclear Waste Confidence Draft EIS), as well as her fellow NRC Commissioners, all of whom

4 expressed confidence that institutional control would not be lost, and that such risks need not be worried about.

But such false confidence, or overconfidence, and overly optimistic assurance (a.k.a. technological hubris), flies in the face of history (no matter which society, institutional control is eventually lost, as the society falters and fails), as well as physics (the second law of thermodynamics, things fall apart, entropy increases over time). Dr.

Macfarlane is an internationally regarded natural scientist who has devoted her career to studying and addressing the societal and technical risks of managing highly radioactive wastes.

Nationwide Risks of Shipping Highly Radioactive Nuclear Waste 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.

The Holtecs infamous Quality Assurance (QA) failures and violations are very significant to shipping risks.

Shipping casks would be less capable of withstanding severe accidents (such as high-speed crashes, including into immovable objects, like bridge abutments; high-temperature, long-duration fires; deep, long-lasting underwater submersions; drops from tall heights, onto unyielding surfaces, such as bridge foundations or rocks down below; or some combination of all those), as well as intentional attacks (such as with shaped charges, or anti-tank weapon systems - see below) or other powerful explosions (such as explosive cargoes on passing trains, including, nowadays, crude oil Bomb Trains, as from the Bakken oil fields in North Dakota). See a summary of industry-and Nuclear Regulatory Commissionwhistleblower revelations about Holtec QA violations posted here: http://www.beyondnuclear.org/centralized-storage/2017/4/5/summary-of-oscarshiranis-allegations-of-quality-assurance-v.html Adding to these shipping risks, is the potential for barge shipments on surface waters. Shipments to Holtec/ELEA in s.e. NM are supposed to be "mostly rail" -- which can also mean many barges (more than two-dozen reactors in the U.S. lack direct rail access, meaning barges on surface waters -- the Great Lakes, rivers, seacoasts -- could be used to haul the 100+ ton, rail-sized casks to the nearest rail head). Backgrounders (including more details on the high risks) on these various barge routes (including maps) were originally written for the Yucca dump scheme; however, Holtec/ELEA could just as well involve such barges. DOEs Feb. 2002 Yucca Mountain Final Environmental Impact Statement (FEIS) gives a preview of barge shipments that could well be required to ship high-level radioactive waste to s.e. NM. The following barge shipment routes were proposed under the Yucca Mountain plan:

MD - Chesapeake Bay; VA - James River: DE - Delaware Bay; NJ, NY, CT - Waters Surrounding New York City; MA - Cape Cod Bay, Massachusetts Bay, and Boston Harbor; IL, MI, WI - Lake Michigan; LA, MS -

Mississippi River; TN, AL - Tennessee River; NE, KS, MO - Missouri River;CA - California Coast; FL -

Floridas Atlantic Coastline.

(However, with something as simple as a rushed NRC rubber-stamp amendment - which the shamelessly complicit and colluding agency would be only to happy to 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 documents submitted to NRC that it would accommodate any and all cask models, not just its own, at the s.e. NM MRS site. Any and all would include LWT-sized outer casks and inner canisters containing irradiated nuclear fuel. This mix of trains/barges/heavy haul trucks, and LWT casks/canisters, would mean even more American communities would be exposed to Mobile Chernobyl risks, as along interstate highways. Dirty Bomb on Wheels security risks would abound. This was made clear by the test of an anti-tank missile against an (empty) irradiated nuclear fuel shipping cask at the U.S. Armys Aberdeen Proving Ground in Maryland. The June 1998 test targeted a German CASTOR cask. While certified for storage-only in the U.S. (the cask model is deployed at the nuclear power plant in Surry, VA), it is used for transport in Europe, as in France and Germany. CASTORs have relatively thick die cast iron walls, as opposed to much thinner walled steel inner canisters in the U.S. (15+

inches thick CASTORs, versus around 0.5 inches thin inner canisters as with the Holtec containers!) That is,

5 CASTORs are significantly more robust, more capable to withstand such an attack. However, even the CASTOR, the Cadillac of shipping casks as some have called it, was severely breached by the anti-tank missile test at Aberdeen Proving Ground. A hole as big around as a grapefruit or softball was blown clean through the side of the cask wall. Had irradiated nuclear fuel been inside, the hole would have created the pathway for release of disastrous amounts of hazardous radioactivity - all the more so, if an incendiary attack were combined with the explosive attack. If the zirconium metal cladding on the fuel rods in the irradiated nuclear fuel assembly were to be heated to its ignition temperature, the fire could even become self-feeding, like highly radioactive, super-sized 4th of July sparklers. In short, shipping containers were not designed to withstand such attacks.

Such a scenario could unleash disastrous amounts 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 to escape in a fire) radioactive Cesium-137 as was released by the Chernobyl nuclear catastrophe. And as Dr. Marvin Resnikoff of Radioactive Waste Management Associates has put it, a container holding 24 Pressurized Water Reactor (PWR) irradiated nuclear fuel assemblies holds 240 times the long-lasting radioactivity (in terms of radioactive Cesium isotopes alone, let alone the hundreds of additional hazardous radioactive isotopes) released by the Hiroshima atomic bomb. Only Holtec has moved on from containers holding 24 PWR assemblies, to ones capable of holding 37 assemblies! That would thus mean 37 Hiroshima atomic bombs worth of long-lasting radioactivity in each container! Only its worse than that, as Resnikoffs figure applied to low burnup fuel; high burnup fuel, unfortunately commonplace today, is even more radioactive!

What I would urge at this time is to stop funding any new nuclear power plants and to arrange for the quickest shutdown of all nuclear power plants in this country ASAP. We have tried for 60+ years to manage our nuclear waste safely and have failed at this task completely. We as a species can not afford to continue this charade that anything nuclear is safe for this planet or any of it's inhabitants in our hands!

Then we should fund only dry cask storage safety on site where it is produced. If the worlds nuclear scientists and engineers and containment, metal, cement scientists and engineers work together maybe we as a species will be safe for the near term until a longer term storage solution can be found. Right now there is no safe place on earth with the way we are managing this problem currently.

With the current sea level rise predictions increasing rapidly as more climate science is done, I realize that most of our power plants are at risk for submersion within 20 to 50 years and that this must be taken into account immediately also. But moving all nuclear waste to one spot and leaving it on the surface is insane. We know now that our climate is changing for the worse with more fires, longer droughts, stronger storms of all kinds, more tornadoes, earthquakes and volcanic eruptions are expected in the near future, world wide. If we do not stop this production of nuclear waste immediately it will lead to mass extinction of most all life on earth.

As Einstein said everything on earth changed save the thinking of man with the splitting of the atom.

Thank you for your consideration, Susan C. Armistead, M.D.

Diplomat of the American Board of Internal Medicine Retired 15 North Drive Key Largo, Florida

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