ML18355A220
| ML18355A220 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 11/19/2018 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/FCSS |
| NRC/NMSS/FCSS | |
| References | |
| 83FR44922 | |
| Download: ML18355A220 (5) | |
Text
1 WCS_CISFEISCEm Resource From:
Kevin Kamps <kevin@beyondnuclear.org>
Sent:
Monday, November 19, 2018 11:34 PM To:
WCS_CISFEIS Resource
Subject:
[External_Sender] Docket ID NRC-2016-0231 -- Public Comments to NRC, re: WCS/ISP CISF Environmental Scoping -- PUBLIC COMMENTS PREPARED AND SUBMITTED BY KEVIN KAMPS, RADIOACTIVE WASTE SPECIALIST, BEYOND NUCLEAR, IN OPPOSITION TO THE WCS/ISP APPLICATION...
Kevin Kamps Radioactive Waste Specialist Beyond Nuclear Public Comments to NRC, re: WCS/ISP CISF Environmental Scoping Docket ID NRC-2016-0231 Nov. 19, 2018 Submitted via: WCS_CISF_EIS@nrc.gov PUBLIC COMMENTS PREPARED AND SUBMITTED BY KEVIN KAMPS, RADIOACTIVE WASTE SPECIALIST, BEYOND NUCLEAR, IN OPPOSITION TO THE WCS/ISP APPLICATION TO CONSTRUCT AND OPERATE A CENTRALIZED INTERIM STORAGE FACILITY FOR 40,000 METRIC TONS OF HIGHLY RADIOACTIVE IRRADIATED NUCLEAR FUEL IN ANDREWS COUNTY, TEXAS, IMMEDIATELY ADJACENT TO EUNICE, NEW MEXICO:
Many to most of the comment category subject matter listed below was already submitted by me, to NRC, in the earlier stage of this interrupted environmental scoping proceeding, in early 2017, before WCS requested NRC suspend the proceeding. Please include all of the comments I have previously submitted re: this docket thus far, in 2017, and now these here below, as well as another set, entitled When it comes to highly radioactive waste transportation, we all live in Eunice, New Mexico and Andrews County, Texas! which I submitted earlier this evening on Nov. 19, 2018.
The first set of comments is on the risks of transporting highly radioactive irradiated nuclear fuel, whether by train, truck, or barge, on rails, roads, or waterways. Risks include the release of disastrous amounts of hazardous radioactivity, whether due to severe accidents, or intentional attacks. Severe accidents could include high-speed crashes into immovable objects, like bridge abutments; high-temperature, long-duration fires; long-duration, deep underwater submersions; etc. Intentional attacks, as by anti-tank missiles or shaped charges, could also breach shipping containers, and release their contents into the environment. For these reasons, critics have long called such shipments potential Mobile Chernobyls, Dirty Bombs on Wheels, and Floating Fukushimas. As WCS/ISP has claimed in its license application that NRC-certified LWT (Legal Weight Truck) canister shipments can be accommodated at its CISF, not only rail-sized shipping containers must be worried about, but so too LWT-sized casks, which would travel on interstate highways. Thus, whether by truck, train, or barge, on roads, rails, or waterways, the Mobile Chernobyl risks of WCS/ISPs CISF scheme must be addressed.
A second set of comments addresses another aspect of shipping risks: the risks of so-called routine, or incident-free, shipments nonetheless being like mobile X-ray machines that cant be turned off, a phrase coined by Loren Olson more than 20 years ago. This is due to the gamma-and neutron-radiation being emitted from the highly radioactive irradiated nuclear fuel. To shield it all would require radiation shielding so thick that containers would be extraordinarily expensive to construct, but also so heavy as to be difficult or impossible to move. So NRC has allowed a certain amount of gamma-and neutron-radiation to be emitted. Granted, this radioactivity dissipates quickly with distance. But at two meters
2 (6.6 feet) away from the containers exterior surface, a dose rate of 10 milli-Rem per hour is allowed by NRC. Thats about one to two chest X-rays worth, per hour. At the exterior surface of the container, the allowable dose rate increases dramatically, to 200 milli-Rem per hour - 20 to 40 chest X-rays worth.
Workers, such as truck drivers, locomotive engineers, inspectors, security guards (and, in the case of LWT-sized cask shipments, even toll booth attendants, gas station attendants, rest area attendants, etc.),
who come in very close physical proximity to the shipping container, would be exposed to the highest radiation dose rates. But even innocent passers by, and bystanders, in the general public would also be exposed. This includes those who live close to transport routes, exposed to large numbers of shipments going by over time. Some people, such as pregnant women, should not be exposed to any radiation dose that can be avoided, due to the high risk of harm caused to the fetus in the womb. Of course, shipments externally contaminated with radioactivity would emit even worse radiation dose rates. The State of Nevada Agency for Nuclear Projects, based on federal government data, has documented 49 incidents of accidental surface contamination on highly radioactive irradiated nuclear fuel shipments, between the years of 1949 and 1996. In France, Areva Corporation (formerly called Cogema, and recently renamed Orano) had many hundreds of externally contaminated shipments - a full one-quarter to one-third of all shipments bound for the La Hague reprocessing facility. On average, they emitted 500 times the allowable radiation dose rates; one emitted 3,300 times the allowable dose rate. Allowable does not mean safe. Any exposure to ionizing radioactivity carries a health risk, and these risks accumulate over a lifetime. Areva/Oranos leadership role in the WCS/ISP CISF proposal makes these past skeletons in its closet, in terms of externally contaminated shipments, all the more relevant to this proceeding.
WCS/ISPs proposed CISF would represent a significant fraction of the size of the Yucca Mountain dump scheme in Nevada - 40,000 metric tons, as compared to 70,000 metric tons (only 63,000 metric tons of which would be commercial irradiated nuclear fuel). Thus, the transport risks associated with WCS/ISPs CISF are also very significant in terms of risk, as compared to the highly controversial, high-risk Yucca dump scheme. The WCS/ISP CISF is about 2/3rds the size of the proposed Yucca Mountain, NV dump scheme.
A third set of comments is about the risk of so-called centralized or consolidated "interim" storage facilities becoming de facto permanent, surface storage, parking lot dumps. WCS/ISP has applied for a permit to NRC to store irradiated nuclear fuel in Andrews County, Texas for several decades. But this time period could be extended to a century, or multiple centuries. How even several decades can be called temporary is beyond me, let alone multiple centuries - the United States has only been a country for 242 years! The first U.S. federal government commissioned report on the disposal of highly radioactive irradiated nuclear fuel was published in 1957, the same year as the first so-called civilian atomic reactor began operations in the U.S., at Shippingport, PA. But in 61 years since, a geologic repository has not opened in this country. DOE said five years ago that one could not now be opened till 2048 at the earliest, 30 years from now. Even that date is likely very optimistic. As geologic disposal is so elusive, any claims of interim or temporary storage must be met with deep skepticism. And once 40,000 metric tons of highly radioactive irradiated nuclear fuel is parked at WCS in Andrews County, TX, immediately adjacent to Eunice, NM, there is a good chance it will never leave again. For one thing, it would be one to two members of the U.S. House of Representatives versus most to all others, who would likely say, its fine where its at; likewise in the U.S. Senate, by a vote of at most four, versus all the rest.
A fourth set of comments follows, regarding the risks of loss of institutional control if de facto permanent surface storage parking lot dumps are abandoned, containers fail, and release catastrophic amounts of hazardous radioactivity into the environment. Institutional control is guaranteed to fail over a long enough period of time. No society has lasted, nor can last, forever. In fact, the very oldest human institutions are at most a few to several thousand years old, such as Roman Catholicism, Tibetan Buddhism, and Judaism, to name a few examples. Certain Native American traditional cultural
3 institutions and spiritual practices have also persisted for countless thousands of years. But highly radioactive irradiated nuclear fuel is hazardous for a million years. Longer, actually. Deadly forevermore, in other words. Much longer than homo sapiens sapiens has even been a distinct species. The U.S.
Environmental Protection Agency (EPA) was forced to acknowledge this by court order more than a decade ago. EPA had wanted to cut off regulations at Yucca Mountain, Nevada, the proposed national burial dump, after just 10,000 years. But a coalition of environmental groups, including Citizens Action Coalition of Indiana, Citizen Alert of Nevada, Nevada Nuclear Waste Task Force, NIRS (Nuclear Information and Resource Service), Natural Resources Defense Council, and Public Citizen, as well as the State of Nevada, successfully challenged EPA in court. Even a million years of hazard is a huge underestimate. Artificial Iodine-129, a reactor product, is present in irradiated nuclear fuel. I-129 has a 15.7 million year half-life, and 157 million years, or more, of hazardous persistence. DOE, in its Feb. 2002 Yucca Mountain Final Environmental Impact Statement, warned that irradiated nuclear fuel, abandoned at reactor sites with loss of institutional control, would eventually leak catastrophic amounts of radioactivity into the environment over time, as dry casks containing it failed, as due to corrosion, exposure to the elements, etc. But the same of course would be true at an abandoned centralized or consolidated interim storage facility, such as WCS/ISP want to open in Andrews County, TX, immediately adjacent to Eunice in southeast New Mexico. Up to 40,000 metric tons of highly radioactive waste leaking into the environment from surface storage here, over time, would truly be catastrophic. The forever deadly radioactive wastes would blow with the wind, and flow with the water, harming people and other living things downwind, downstream, up the food chain, and down the generations, forevermore.
Forevermore happens to be the title of a 1986 book by award-winning investigative journalists Barlett and Steele, subtitled Nuclear Waste in America. The book contains a compelling chapter about the Waste Isolation Pilot Plant (WIPP), located relatively close to the targeted ISP/WCS CISF site. WIPP made claims about start clean, stay clean, and the impossibility of leaks over 10,000 years, or even 200,000 years - but it leaked after only 15 years. WCS/ISP have made similar claims about centralized interim storage. So too has Holtec International/Eddy-Lea Energy Alliance, yet another CISF (proposing to store a whopping 173,600 metric tons of irradiated nuclear fuel). Fool me once, shame on you; fool me twice, shame on me.
A fifth set of comments asks, Why Are All These High Risks Being Taken in the First Place?! The answer is, to expedite the transfer of title, and liability, for the highly radioactive irradiated nuclear fuel, from the utilities that generated it (how they made their radioactively filthy forevermore profits), to DOE - which means federal taxpayers - ASAP. Thats not a very good or wise reason to ship 40,000 metric tons of irradiated nuclear fuel to Andrews County, TX for temporary storage. DOE - that is, federal taxpayers -
are already on the hook for permanent disposal of these wastes, an unprecedented subsidy in any industry, which will inevitably cost federal taxpayers $100 billion, and likely significantly more. Actually, DOEs most recent cost estimate for the first 200 years of operations at the proposed Yucca Mountain dump-site was $96.3 billion - an amount that has already topped $100 billion, simply by adjusting the several year old figure to account for inflation. And Dr. Mark Cooper, in his expert witness testimony to NRC during the Continued Storage of Spent Nuclear Fuel EIS proceeding (the latest round of the Nuke Waste Con Game), estimated that the first 200 years of commercial irradiated nuclear fuel management (including two CISFs, one repository, and needed on-site storage in the meantime) would cost $210 to 350 billion, instantly doubling the production cost of nuclear power generated electricity, for this previously unaccounted for externality borne by the public (both ratepayers, as well as taxpayers). But interim storage is supposed to be the utilities responsibility. This open secret - that WCS and ISP are looking to DOE to take title, shoulder all liability if something goes wrong, and to pay all costs, at taxpayer expense - actually makes this NRC licensing proceeding inappropriate, not authorized by law (that is, illegal). Private, away from reactor, centralized storage would be legal, but the utilities would have to retain liability and title - it could only be transferred to DOE at a permanent repository, as the Nuclear Waste Policy Act of 1982, as Amended, directs. Thats why lobbyists from Holtec/ELEA, as well as Waste Control Specialists/Interim Storage Partners, Texas, and other nuclear power and radioactive waste
4 industry lobbyists, are trying to get the law changed, to allow such title and liability transfer to be accelerated by decades, further burdening federal taxpayers with interim storage too, in addition to permanent disposal costs.
Another set of comments is entitled "We Do NOT Consent!" Due to all the risks already mentioned, and many more, that about sums it up -- we do NOT consent!
Thank you for taking my comments into consideration.
Kevin Kamps Radioactive Waste Specialist Beyond Nuclear Takoma Park, Maryland 20912 Cell: (240) 462-3216 kevin@beyondnuclear.org www.beyondnuclear.org Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.
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[External_Sender] Docket ID NRC-2016-0231 -- Public Comments to NRC, re:
WCS/ISP CISF Environmental Scoping -- PUBLIC COMMENTS PREPARED AND SUBMITTED BY KEVIN KAMPS, RADIOACTIVE WASTE SPECIALIST, BEYOND NUCLEAR, IN OPPOSITION TO THE WCS/ISP APPLICATION...
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