ML18211A473
| ML18211A473 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/30/2018 |
| From: | Public Commenter Public Commenter |
| To: | Division of Fuel Cycle Safety, Safeguards, and Environmental Review |
| NRC/NMSS/DFCSE | |
| References | |
| 83FR13802 | |
| Download: ML18211A473 (6) | |
Text
1 Holtec-CISFEISCEm Resource From:
Mary Beth Brangan <mbbrangan@gmail.com>
Sent:
Monday, July 30, 2018 2:05 AM To:
Holtec-CISFEIS Resource
Subject:
[External_Sender] Docket ID NRC-2018- 0052 RE: Docket ID NRC-2018- 0052; Holtec/ELEA CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico
Dear Nuclear Regulatory Commission Staff:
Reject Holtec Internationals application for a Consolidated Interim Storage Facility (CISF) for high level nuclear waste first because centralized or consolidated interim storage sites are NOT allowed under US federal laws to the extent the Department of Energy and US taxpayers are expected to own and transport the waste. It is an ILLEGAL DUMP.
Environmental Injustice Must Be Addressed We do not consent to the environmental injustice and radioactive racism of yet again targeting low-income communities of color in New Mexico. They have already suffered from being heartlessly exposed to the most hazardous substances ever created from the military. It is unthinkably immoral to now expose them to highly radioactive irradiated nuclear fuel.
Abnormal Subsidence & Uplifting Significance Must Be Analyzed Shipments of waste would be transported through an area shown by a recent study to be abnormally moving.
A March 16, 2018 article in Nature, Association between localized geohazards in West Texas and human activities, recognized by Sentinel-1A/B satellite radar imagery, by Southern Methodist University geophysicists Jin-Woo Kim and Zhong Lu reported literally earth-shaking findings.
https://www.nature.com/articles/s41598-018-23143-6 https://m.phys.org/news/2018-03-radar-images-large-swath-texas.html http://www.texasvox.org/large-swath-texas-oil-patch-heaving-sinking-alarming-rates-wcs-wants-store-high-level-radioactive-waste-nearby/
Their study showed that, in the last two and a half years, large sections of the four Texas counties they studied, spanning a 4000-square-mile area, had sunk or uplifted as much as 40 inches.
"The ground movement we're seeing is not normal. The ground doesn't typically do this without some cause," said co-author Zhong Lu, a recognized global expert in satellite radar imagery research.
"These hazards represent a danger to residents, roads, railroads, levees, dams, and oil and gas pipelines, as well as potential pollution of ground water," Lu declared.
Impacts of this rapid ground movement on waste shipments on rail or highway on the way to or from the Holtec/ELEA site must be analyzed. Impacts to the Holtec/ELEA site integrity itself must be analyzed based on this finding to see if it is also within the area that is subject to this rapid subsidence and upheaval movement.
Railway Accidents Increase Due to Extra Heavy Transport Train Cars Must Be Analyzed As of the last four years, U.S. rail accidents have averaged 12,000 annually, with fatalities of 702 to over
2 800 per year. Extreme weather events are inevitable and have proven to cause more stress on rails, as have the increasing number of heavy oil train cars. Even brand new rail tracks have failed and caused derailments. These specific facts must be analyzed in relation to the weight and number of proposed railway shipments of lethal radioactive waste in the HI-STAR 190 transport cask to the Holtec/ELEA site from all over the country.
Prevention and Mitigation of External Contamination of Transport Shipments Must Be Analyzed Areva (recently renamed Orano) - a key partner in the WCS, TX proposal - at its home base in France, experienced a plague of externally contaminated shipments. A full 25% to 33% of Arevas irradiated nuclear fuel shipments, into its La Hague reprocessing facility, were externally contaminated, for years on end, above permissible levels, in the 1990s. This amounted to many hundreds of individual shipments, contaminated above permissible levels, over the course of several long years. On average, the shipments were giving off radiation dose rates 500 times the permissible level; in one instance, a shipment was emitting radiation 3,300 times the acceptable level. In other words, hundreds - or even thousands -- of chest x-rays worth of gamma radiation, were being emitted. This posed a grave health risk to workers, and innocent bystanders and residents, along the impacted shipping route corridors.
For more info., see the WISE-Paris write up, Transport Special - Plutonium Investigation n°6/7, posted at http://www.wise-paris.org/ under Bulletins.
Externally contaminated shipments have happened in the U.S., as well. Halstead documented this in a report prepared for the Nevada State Agency for Nuclear Projects in 1996 entitled Reported Incidents Involving Spent Nuclear Fuel Shipments, 1949 to Present. 49 surface contamination incidents are documented. This report is posted online at: http://www.state.nv.us/nucwaste/trans/nucinc01.htm The Viability of a System Based on Short Term Profit for Handling 170,000 tons of Lethal Radioactive Waste Lasting Millions of Years Must Be Analyzed The Holtec/ELEA offer to take care of the nations waste is based on expectations of profit. Decisions will be made based on whats best for short-term profit, not primarily safety, resilience and environmental protection. Hanfords sub-contractors lack of progress in handling of leaks is a prime example. Senior safety engineers there have been fired rather than have their recommendations followed that would have solved problems, because they would have taken slightly longer and cost a little more in the short term.
How to prevent this happening with a CIS must be analyzed. The following point is another example of this private corporate attitude that often precludes decisions made in the best interests of the public and environment.
Holtec Must Remove Copyrights And All Redactions in the Environmental Report The ER Cover Page includes a notice that it is a copyrighted intellectual property of Holtec International.
All rights reserved. The notice further states for members of the public to excerpt any part of this document is unlawful without written consent of Holtec International. It is totally inappropriate to include such a statement or to state that we or other members of the public cannot quote any part of the document, as that substantially restricts my/our ability to comment on the ER, which is my/our legal right. NRC must require Holtec to produce an ER that has no such copyright restriction and has no redactions. The scoping comment period must be extended again until such a revised ER is publicly available and there is adequate time for public comment.
The Impacts Of Permanent Storage Must Be Analyzed
3 The Environmental Report (ER) must analyze the impacts of this interim storage becoming a dangerous de facto permanent facility because the waste will likely never be disposed of in a scientifically viable geologic repository using a reliable isolation system. The ER is inadequate and incomplete because it does not analyze the impacts of the spent fuel being left at the Holtec site indefinitely. The NRC must include such an analysis in its draft environmental impact statement (EIS). The clear dangers of a design meant for an extremely short duration, but used indefinitely for an unlimited time must be addressed and analyzed.
The Exact Numbers Must be Provided and Accurately Accounted For Holtec/ELEA has proposed moving 100,000+ metric tons of commercial irradiated nuclear fuel.
Holtec/ELEA cites the figure of 120,000 metric tons. But in fact, multiplying the first phase of 8,680 metric tons of uranium -- as described in NRCs March 30, 2018 Federal Register Notice -- by 20 phases, over 20 years, as Holtec proposes, that would mean not 100,000, nor 120,000, but rather 173,000 metric tons of commercial irradiated nuclear fuel! The application as written is inaccurate and misleading.
More Alternatives Must Be Analyzed Keeping the spent fuel casks in some form of Hardened On Site Storage (HOSS) on the reactor sites, or moved if necessary to the closest viable site from the reactor site must be analyzed. The comparison of the safety and cost impacts of the Holtec CIS compared to keeping the waste safely on site (or moved close by) must be analyzed. The NRC must also include such an analysis in its draft EIS.
The alternative of consolidated storage being done at an existing licensed Independent Spent Fuel Storage Facility (ISFSI) must be analyzed. According to the NRC website, there are 64 reactor sites with general-licensed ISFSIs in various part of the nation. The ER must analyze why one or more of those sites could not provide some or all of the consolidated storage proposed by Holtec. The NRC must also include such an analysis in its draft EIS.
The ER inadequately discusses the transportation Risks The transportation risks are based on a 2-year old document for another facility. The incident-free radiological transportation analysis in this ER tiers from the analysis prepared for the proposed WCS CIS Facility in Andrews County, Texas (WCS 2016). (ER pg. 199) To analyze the transportation risks for this ER, Holtec simply took the WCS report and multiplied by 2.5 times. The transportation risks are based on three sample routes to only three reactor sites, which are supposed to represent all the routes to all the reactor sites. Yet, Holtec proposes to bring ALL of the spent fuel at all of the commercial reactors.
This ER must include transportation routes and the potential impacts of accidents or terrorism incidents on public health and safety along all the routes. The ER states that high-level radioactive waste would be transported for more than 20 years. Even one small accident would be one too many. Terrorist acts involving radioactive waste in a large metropolitan area could have extremely high consequences, which must be analyzed.
The ER is inadequate and incomplete because it does not include an adequate analysis of all transportation routes and modes from all reactors. The ER is inadequate and incomplete because it does not discuss how rail shipments from reactors without rail access would be accomplished and the risks and impacts of such shipments. The NRC draft EIS must also analyze these transportation risks and impacts, if the licensing process continues.
4 Since this is supposedly a storage site and not a disposal site, at some future point the spent fuel will need to be removed and sent to a disposal site, thus doubling the transportation risk stated in this ER. The ER is inadequate and incomplete because it does not include an analysis of such additional transportation routes, risks, and impacts.
To see how unrealistic this assumption of interim storage is, how would the fragile hi burnup fuel assemblies in only 5/8 thick canisters be retrieved and undergo additional transport? This must be analyzed.
Legal Weight Truck Shipments Must Be Analyzed The potential for LWT (Legal Weight Truck) shipments of irradiated nuclear fuel to Holtec/ELEAs CISF in southeast NM must be specifically eliminated or analyzed. Holtec/ELEA states in its license application documents such as the ER (Environmental Report) that it could accommodate any and all NRC-certified casks for shipping and/or storing irradiated nuclear fuel. This would include shipping casks for LWT transport, which can contain only 4 Pressurized Water Reactor (PWR) irradiated nuclear fuel assemblies, as compared to 24 or even 37 PWR assemblies in rail-sized casks on trains, barges, or heavy haul trucks.
If LWT shipments are in fact to be a part of the Holtec/ELEA CISF transport scheme, then communities along interstate highways in most states in the Lower 48 should also be extended public comment meetings.
Barge Shipments Must Be Analyzed We do not consent to radioactive waste barge shipments on the lakes and rivers of this country, the fresh drinking water supply for countless millions, nor on the seacoasts.
The Consequences To An Accident-Exposed Individual Must Be Analyzed Terms like collective dose risk and person-rem are used to ignore the potential impacts to a single individual. The ER even states, Because the risks are for the entire population of individuals along the transportation routes, the risk to any single individual would be small. (Pg. 201) This is not an excuse to not state the impacts and doses to the individual. The ER is inadequate and incomplete.
Cracked And Leaking Casks Must Be Addressed The ER does not analyze exactly how radioactive waste from a cracked and leaking canister would be handled, since there is no wet pool or hot cell at the site. If a cask arriving at the site is cracking or leaked, it might not be allowed to return canisters. Page 214. The ER is inadequate and incomplete because it does not analyze these situations. The NRC draft EIS must include such an analysis.
Risks of Routine Shipments That Are Like Mobile X-ray Machines That Cant Be Turned Off Must Be Analyzed Even routine or incident-free shipments of highly radioactive irradiated nuclear fuel - such as those bound for so-called centralized or consolidated interim storage facilities (CISFs) like Holtec/ELEA, NM or WCS, TX - carry health risks to workers and innocent passers-by, and residents along the shipping routes nation-wide. This is because it would take so much radiation shielding to completely hold in the gamma-and neutron-radiation, being emitted by the highly radioactive waste, that the shipments would be too heavy to move economically. So, NRC has compromised, and allows for or permits, a certain amount of hazardous gamma-and neutron-radiation to stream out of the shipping container, exposing people close enough by to the hazardous radioactivity.
5 More Cumulative Impacts Must Be Analyzed The ER mentions WIPP but does not analyze the cumulative impacts of a radiologic releases from WIPP, URENCO, Waste Control Specialists, and radically increased background radiologic pollution due to oil and gas activity on the proposed CIS site This must be done along with analyzing the impacts of an expanded WIPP, which is reasonably foreseeable. Also, expanded flight tests are being proposed for the area Impacts Of Future Railroads And Electric Lines Must Be Analyzed The railroads and electric lines are not in place, but must be analyzed. Locations of electrical lines, and estimates on electric use must be given. Locations of railroad lines and impacts of railroad construction, including upgrading existing tracks that cannot handle the weight of the HI-STAR 190 transport cask, must be given. The ER is incomplete and inadequate. The NRC draft EIS must analyze these issues, if the licensing process proceeds.
How many of the estimated 135 jobs will go to locals?
The ER estimates 80 construction jobs and 55 permanent operating jobs. How many of these jobs will go to locals? What is the commitment to hire the disproportionally impacted low income and minorities? Is it true that prostitutes were included in the jobs total?
Seismic Impacts On Stored Casks Must Be Stated Although the ER gives a statement on recent seismic activity in the area, there is no analysis of what many 3.0 - 4.0 fracking-induced earthquakes will have on the buried casks. The ER is incomplete and inadequate. The NRC draft EIS must analyze these issues.
Risks of Loss of Institutional Control Must Be Analyzed DOE 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.
Sincerely, Mary Beth Brangan and James Heddle Co-Directors Ecological Options Network, EON Bolinas, CA 94924 www.eon3.org
Federal Register Notice:
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