ML18277A233
| ML18277A233 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 10/04/2018 |
| From: | Bender D - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 83FR44922 00028, NRC-2016-0231 | |
| Download: ML18277A233 (2) | |
Text
PUBLIC SUBMISSION As of: 10/4/18 10:42 AM Received: October 04, 2018 Status: Pending_Post Tracking No. 1k2-95s5-2y65 Comments Due: October 19, 2018 Submission Type: Web Docket: NRC-2016-0231 Waste Control Specialists LLC's Consolidated Interim Spent Fuel Storage Facility Project Comment On: NRC-2016-0231-0187 Interim Storage Partners LLCs Consolidated Interim Spent Fuel Storage Facility Document: NRC-2016-0231-DRAFT-0208 Comment on FR Doc # 2018-19058 Submitter Information Name: Doug Bender Address:
261 Vista del Parque Redondo Beach, 90277 Email: alfabender@verizon.net General Comment Any nuclear storage is hazardous. Experience shows that "interim storage" becomes much longer term, or even de facto permanent due to political opposition to further moves.
In 2008, under court order, the U.S. Environmental Protection Agency acknowledged that commercial irradiated nuclear fuel remains hazardous for a million years into the future. This is actually an underestimate.
Take Iodine-129, as but one example. Its half-life is 15.7 million years. It will remain hazardous for at least ten half-lives, or 157 million years. I-129 is in high-level radioactive waste, too.
A 2013 U.S. Senate bill forerunner to current versions of the legislation in Congress added to the risks of "interim" storage sites becoming de facto permanent parking lot dumps, by stating a preference for co-location of pilot interim storage alongside large-scale, non-priority interim storage, and even the permanent repository (that is, burial dump).
Also, the waiver of any connection or "linkage" between development of centralized interim storage and progress toward opening a repository only increases the risk that stored wastes will simply be allowed to remain in centralized, so-called interim, surface facilities indefinitely into the future. In other words, they could become de facto permanent parking lot dumps.
U.S. Senator Jeff Bingaman (D-NM), Chairman of the Energy and Natural Resources Committee, warned Page 1 of 2 10/04/2018 https://www.fdms.gov/fdms/getcontent?objectId=0900006483794328&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, James Park, Cinthya Cuevas Roman, Jenny Weil COMMENT (28)
PUBLICATION DATE:
9/4/2018 CITATION 83 FR 44922
against this de-linkage in 2012. In fact, the requirement for a permanent disposal repository being opened and operating was, and still is, essential and foundational in the Nuclear Waste Policy Act, as Amended, the benchmark law on commercial irradiated nuclear fuel management. This was, and still is, a safeguard against interim storage sites becoming de facto permanent surface disposal, or parking lot dumps.
Note that linkage requires an operating repository, not just a licensed one, nor just a proposed one by someone, for someday, somewhere, some way. Remarkably, current DOE projections for the opening of a permanent burial dump are by 2048, 31 years from now, although they dont know who, where, or how!
2048 is 106 years after Enrico Fermi generated the first cupful of high-level radioactive waste of the Atomic Age, in his Chicago Pile-1 at the University of Chicago squash court under the football stadium, on Dec. 2, 1942 as part of the Manhattan Project race for the atomic bomb; 2048 is 99 years after the first civilian, or commercial, irradiated nuclear fuel was generated, at the Shippingport atomic reactor near Pittsburgh, PA.
Such remarkable delays in high-level radioactive waste management and disposal are another red flag, warning about WCSs facility becoming a long-term, or even de facto permanent parking lot dump.
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