ML18295A015
| ML18295A015 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 10/19/2018 |
| From: | Michael Lee Promoting Health & Sustainable Energy (PHASE) |
| To: | Office of Administration |
| References | |
| 83FR44922 00060, NRC-2016-0231 | |
| Download: ML18295A015 (2) | |
Text
PUBLIC SUBMISSION As of: 10/22/18 7:33 AM Received: October 19, 2018 Status: Pending_Post Tracking No. 1k2-962r-4qt4 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-0239 Comment on FR Doc # 2018-19058 Submitter Information Name: Michel Lee Submitter's Representative: Michel Lee, Esq.
Organization: Promoting Health and Sustainable Energy (PHASE)
General Comment Promoting Health and Sustainable Energy (PHASE) and the Council on Intelligent Energy & Conservation Policy (CIECP) emphatically urge rejection of the proposal by Waste Control Specialists / Interim Storage Partners to import tens of thousands of tons of high-level radioactive waste from nuclear reactors around the United States for storage in Andrews County, TX for 40 years or longer.
Not only would such a facility expand and expedite unloading of the costs, risks, and liabilities for high level nuclear waste from the nuclear utilities onto the shoulder of the American public, it would open the floodgates to creation of an even larger nuclear waste production and disposition hazard.
It doesnt solve a problem. It creates a new one.
Most egregiously, the scheme incentivizes moral hazard and places at risk the health, safety and security interests of the nation at large. Approval of this scheme, literally, puts America at risk.
We share and here add our voice to those of the many public interest, public health, environmental, and environmental justice groups and individual citizens who have expressed grave concern about the ethics of creating large interim nuclear waste dumps, stressing the toxicity of spent fuel. Permitting the nuclear industry to expose millions of Americans to excess levels of radioactivity along the many routes of transport is morally indefeasible, pure and simple. As experts, including those of the National Academies have noted, women, adolescents, children, girls, pregnant women, infants, and babies in utero are particularly vulnerable to the effects of radioactivity. Families living near transport routes will be exposed to excess radioactivity as a matter of ordinary course. The elevated risk of cancer, developmental disorders, immune system injury, and other radiation dose exposure-linked health effects is likely to be consequential at a population level. Low income populations are likewise vulnerable, as the members of those communities endure elevated levels of toxic exposures overall, suffer greater health impairment, and have less access to care than others in the general population.
SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, James Park, Cinthya Cuevas Roman, Jenny Weil COMMENT (60)
PUBLICATION DATE: 9/4/2018 CITATION 83 FR 44922
In this docket and related proceedings, many public commenters have stressed the grossly unethical nature of turning areas of the American west and southwest into nuclear sacrifice zones. We very much share these concerns.
However, we wish here to place emphasis on the growing risk which would be presented under what strong scientific consensus predicts will be extreme weather and natural disaster conditions. Both frequency and severity of such events are highly likely to grow over the coming years and decades. It should be self evident that relocating massive quantities of extraordinarily hot and radioactive material towards a region experiencing increasing levels of extreme heat, drought, storms with severe winds, and wildfire risk is a stupendously reckless idea.
As a final point, we remind the NRC that the decades of risk involve not only climate-related phenomena, but the danger of terrorism. We are barely past the 17 year anniversary of 9/11, yet the NRC seems to have become oblivious to any risk than involves connection of more than two dots. The 9/11 Commission observed that the 2001 terror attack on the United States revealed four kinds of failures: in imagination, policy, capabilities, and management. Of these failures, the 9/11 Commission stressed imagination as the most important, noting, It is therefore crucial to find a way of routinizing, even bureaucratizing the exercise of imagination.
The failure evident in the entire conceptualization of interim high level nuclear waste sites distal from the points of origin all over the United States exceeds the level of failure of imagination and enters the dimension of willful blindness.
Nineteen men armed with only knives and box cutters were able to transform the instruments of the nation's statistically safest form of transportation into missiles which successfully attacked New York City and the Pentagon. What level of complacency, denial or hubris does it take to ignore the possibility that far more resourced, sophisticated malevolent actors, armed with cyberattack capability and detailed knowledge of our nations deteriorated transportation and gas pipeline infrastructure would not be able to initiate, or at least exploit, the dirty bombs this entire high-level radioactive waste interim storage enterprise would be advancing?