ML18289A541
| ML18289A541 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 10/09/2018 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/FCSS |
| NRC/NMSS/FCSS | |
| References | |
| 83FR44922 | |
| Download: ML18289A541 (4) | |
Text
1 WCS_CISFEISCEm Resource From:
TB <tbscpbsc@satx.rr.com>
Sent:
Tuesday, October 9, 2018 10:13 PM To:
WCS_CISFEIS Resource
Subject:
[External_Sender] RE: Docket No. 72-1050; NRC-2016-0231 Waste Control Specialists LLCs / ISPs Consolidated Interim Spent Fuel Storage Facility Project May Ma, Office of Administration, Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Email address: WCS_CISF_EIS@nrc.gov RE: Docket No. 72-1050; NRC-2016-0231 Waste Control Specialists LLCs / ISPs Consolidated Interim Spent Fuel Storage Facility Project October 9, 2018
Dear Ms. Ma:
I write for the nearly 3000 members of the Alamo Group of the Lone Star Chapter of the Sierra Club.
Our group does NOT CONSENT to transport of thousands of casks of high level radioactive waste (HLRW), by train and/or truck, through our San Antonio, Texas region. Decades of such transport through major urban and rural areas all around the country poses an unacceptably high risk to the lives of millions of Americans. One accident and canister leak, or one terrorist cask diversion and explosion, would destroy human life throughout this part of Texas. The DOE previously analyzed accident risks for shipping high-level waste to Yucca Mountain and predicted at least one major accident for every 10,000 train shipments. Consolidated storage would involve thousands of radioactive waste shipments that would occur over 20 or more years across much of the United States.
If transport is mainly by truck, 53,000 shipments with 53 accidents were expected. They found that a radiation release could render 42 square miles uninhabitable and cost 9.5 billion dollars to raze and rebuild a one square mile downtown area.
The inadequate WCS EIS should clearly identify transportation routes that would be used across the country. The plan to ship the nations deadly nuclear reactor waste to Texas / New Mexico should be halted immediately due to the risks of radioactive contamination from leaks, accidents or terrorist attacks. Our health, land and aquifers would be threatened. A person exposed up close to the waste would die within a week, and leaks could lead to cancer and genetic damage. Our local health and emergency response systems would be stretched beyond their limits by any such hazardous events.
Low-income minority communities are often concentrated in old inner city areas and a close to rail and highway routes. There is potentially serious environmental injustice in these proposals. The WCS and Holtec proposals also pose risks to low-income minority communities near these proposed sites.
These largely silent people are largely absent from the promotions made by the largely white well to do Andrews Industrial Foundation and comparable Hobbs groups. This issue of environmental injustice must be clearly examined. I personally lived in Midland for 20 years and know the Andrews-Eunice-Hobbs area well.
2 Risks to groundwater and the nearby Ogallala Aquifer must be thoroughly examined. The Ogallala lies beneath eight states, providing drinking water, and water for agriculture, ranching and wildlife.
This area has much greater climatic extremes than most coastal power plant sites. Impacts of temperature extremes, wildfires, flooding, earthquakes, tornadoes, lightning, and shifting ground (as reported in recent Southern Methodist University studies) on radioactive waste casks and canisters exposed to the environment for decades must be studied more thoroughly.
A much better emergency response plan for shipments, and for on site events is critical. Improved monitoring, security and worker protections are needed and the emergency plan should include actions to be taken, not just a notification structure. In this dry area there is already far too much reliance on water for dust and fire control, even without adding 40,000 metric tons of spent fuel rods.
WCS has a troubled financial history over its barely 3 decade existence, during which time its mission has creeped ever farther from its original promise to restrict itself to chemical hazardous waste. The adequacy of financial assurances, and the stability of the new WCS owner, an equity firm that buys and sells companies, and the ties of partner Orano (with a 51%, share) to the French government should be examined thoroughly before such a private company is permitted to take responsibility for 40,000 metric tons of HLRW for 40 years and possibly much longer.
These risks are not only unacceptable, but unnecessary. There is absolutely no reason why consolidated interim storage should be done. This proposal does not solve the real problem, which is that safe permanent storage still needs to be developed. A site for permanent storage MUST be found based on sound science that should be able to isolate this waste from the human and natural environment for over 250,000 years.
That is where all the effort should be placed. Interim storage is an expensive diversion from this true goal, and done only at the behest of the nuclear power industry, eager to offload its liability and NIMBY folks who have benefitted from the electricity derived from nearby nuclear power plants.
Current on site HLRW storage remains the best option. Of course it has taken the federal government far longer than expected to develop safe permanent storage; however, that doesnt make interim storage desirable, safe or cost effective. Every nuclear plant in the country has on site storage, and high level on site security. U.S. nuclear power plants use spent fuel pools to cool the irradiated rods, typically for five years, before theyre transferred to dry casks at existing reactor sites. Most reactors are now licensed to store the waste for 60 years after reactor operation ceases. Security is already in place at these sites and will remain in place for decades to come. When a PERMANENT site is found and developed THEN the material must be moved ONCE to that site, and the risks and costs absorbed.
There will be absolutely zero gain in safety by consolidation, except under the concept of out of sight out of mind, i.e. that it should be stored in the middle of nowhere like West Texas or Eastern New Mexico. Once in interim storage in this location far from the large urban political and financial power centers of the country, there will be ZERO political courage to EVER develop REAL PERMANENT STORAGE and move this material AGAIN, all at HUGE COST. People near WCS and HOLTEC CANNOT consent for their great great grandchildren several generations removed. We in San Antonio do not consent, and CANNOT consent for our grandchildren several generations removed, to have this unnecessary decades long transport of extremely dangerous HLRW through our community.
As we have seen in Fukushima it is easy for planners and politicians to equate small risks with zero risks. They, however, do not bear the brunt of the real impacts when non zero consequences develop.
3 The people placed at risk bear the burden, in lost lives, lost livelihoods, lost property, lost homelands.
These impacts involve more than monetary costs!
We Dont Want It - and We DO Want Public Meetings Texans dont want dangerous high-level radioactive waste, but the NRC has not heard the voices of many concerned Texans. There has not been a single public meeting on the revised application.
Resolutions opposing the radioactive waste plans and transport were passed by Dallas, Bexar, Nueces and Midland counties and our City of San Antonio, yet NRC has failed to host meetings in any of these locations, even for the original application. The NRC has held only one Texas meeting on the project, and that was in Andrews, hundreds of miles from major cities that would be impacted by rail transport of radioactive waste. By contrast, five NRC meetings were held in New Mexico regarding Holtecs proposal there and twenty-four meetings were held for Yucca Mountain, across the country.
This proposal would result in as much transport of radioactive waste across the country, but the public is being given very little opportunity to speak out.
Please extend intervention and public comment deadlines by at least 180 days to allow for public input, and host public meetings in Dallas, Houston, San Antonio, El Paso, Midland and Andrews.
This waste must remain isolated for a million years. Storing it for decades above ground in extreme climate conditions does not lead the nation toward this goal. The NRC should halt review of the WCS license application for Consolidated Interim Storage in Texas, as well as review of the Holtec project proposed for nearby New Mexico. In the interest of our public health and safety both licenses should be denied.
Sincerely, Terry Burns, M.D.
Chair, Alamo Group, Lone Star Chapter, Sierra Club tbscpbsc@satx.rr.com 210.375.4735
Federal Register Notice:
83FR44922 Comment Number:
18532 Mail Envelope Properties (211E10B5-5EB6-4617-8F66-F970D1AC72E1)
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