ML18355A234
| ML18355A234 | |
| 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: ML18355A234 (4) | |
Text
1 WCS_CISFEISCEm Resource From:
Kevin Kamps <kevin@beyondnuclear.org>
Sent:
Monday, November 19, 2018 11:41 PM To:
WCS_CISFEIS Resource
Subject:
[External_Sender] Docket ID NRC-2016-0231 -- Public Comments to NRC, re: WCS/ISP CISF Environmental Scoping -- Mobile Chernobyl shipping risks 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 Mobile Chernobyl shipping risks Eunice, New Mexico (four miles from WCS, across the TX/NM border) has the dubious distinction that every single train car load of high-level radioactive waste will pass through on its way into (and, if it ever leaves, out of) WCS. But transport impacts, to import more than half the irradiated nuclear fuel in the U.S.
into West Texas, will be felt nation-wide. In that sense, when it comes to radioactive waste transportation, we all live in Eunice, NM.
But a parking lot dump at WCS would only increase safety risks. It would not decrease them. It would multiply transport risks, as it would only be temporary (supposedly). All that highly radioactive waste would have to move again, to a permanent burial site (yet to be identified - thats a big IF!). And that could be back in the same direction from which it came in the first place!
WCSs assumption that the dump at Yucca Mountain, Nevada will open someday, to take the high-level radioactive waste away, is inappropriate. The vast majority of Nevadans has expressed its very adamant non-consent for 30 years now, and still vehemently oppose it. This is reflected by bipartisan resistance by elected officials, at both the state government level, as well as the congressional delegation level.
WCSs assumption that another permanent burial dump will be opened, by someone, somewhere, someday, somehow, is also inappropriate. After all, the search for a national geologic repository has gone on since the 1950s, but has failed. And DOEs current estimate for the opening of the U.S.s first repository is 2048, 31 years from now. Except they have no idea where that will be. There is every likelihood that 2048 date will slip into the future as well.
The failed Private Fuel Storage, LLC parking lot dump targeted at the Skull Valley Goshutes Indian Reservation in Utah, likewise assumed the Yucca dump would open. They were, of course, incorrect.
So PFSs Plan B was to return to sender. If 40,000 metric tons of irradiated nuclear fuel - the same amount targeted to go to WCS, isnt that curious?! - what would that return to sender policy have looked like?
Maine Yankee was a PFS consortium member. More than 50 rail sized containers of irradiated nuclear fuel would have traveled 5,000 miles round trip, accomplishing absolutely nothing, other than exposing millions of people in numerous states to high-risk shipments.
Another version of this is the fact that permanent burial sites could be located right back in the same direction from which the waste came in the first place. In fact, at one time, DOE was targeting two sites in Maine, seven sites in Vermont, and two sites in New Hampshire, for permanent burial dumps. (See Beyond Nuclears backgrounder, re: the NH targets, at:
2 http://static1.1.sqspcdn.com/static/f/356082/24115710/1487366549330/New_Hampshire_dump_fina l+draft.pdf?token=ZDgyvKfq8uxG4HPqWmvVvXBuwmY%3D).
This game of high-risk, high-level radioactive waste musical chairs, or hot potato, on the roads, rails, and waterways, is unacceptable. It amounts to Radioactive Russian roulette. Multiplying transport risks for no good reason is wrong, and makes no sense.
The Nuclear Assurance Corporations Quality Assurance (NAC QA) failures mentioned above are very significant to shipping risks. Shipping casks would be less capable of withstanding severe accidents (such as high-speed crashes, including into immovable objects, like bridge abutments; high-temperature, long-duration fires; deep, long-lasting underwater submersions; drops from tall heights, onto unyielding surfaces, such as bridge foundations; or some combination of all those), as well as intentional attacks (such as with shaped charges, or anti-tank weapon systems - see below) or other powerful explosions (such as explosive cargoes on passing trains, including, nowadays, crude oil Bomb Trains, as from the Bakken oil fields in North Dakota).
Adding to these shipping risks, is the potential for barge shipments on surface waters. WCS is supposed to be "mostly rail" -- which can also mean many barges (26 reactors in the U.S. lack direct rail access, meaning barges on surface waters -- the Great Lakes, rivers, seacoasts -- could be used to haul the 100+
ton, rail-sized casks to the nearest rail head). Backgrounders (including more details on the high risks) on these various barge routes (including maps) were originally written for the Yucca dump scheme; however, WCS could just as well involve such barges.
DOEs Feb. 2002 Yucca Mountain Final Environmental Impact Statement gives a preview of barge shipments that could well be required to ship high-level radioactive waste to WCS, TX. The following barge shipment routes were proposed under the Yucca Mountain plan:
(See NIRS factsheets on barge shipments of deadly high-level radioactive waste on waterways, by state, posted online September 28, 2004):
o MD - Chesapeake Bay
<https://web.archive.org/web/20160331033728/http://www.nirs.org/factsheets/mdbargefacts heet92804.pdf>
o VA - James River
<https://web.archive.org/web/20160331033736/http://www.nirs.org/factsheets/vabargefactsh eet92804.pdf>
o DE - Delaware Bay
<https://web.archive.org/web/20160331032838/http://www.nirs.org/factsheets/debargefacts heet92804.pdf>
o NJ, NY, CT - Waters Surrounding New York City
<https://web.archive.org/web/20160331034044/http://www.nirs.org/factsheets/nybargefacts heet92804.pdf>
o MA - Cape Cod Bay, Massachusetts Bay, and Boston Harbor
<https://web.archive.org/web/20160331020332/http://www.nirs.org/factsheets/mabargefacts heet92804.pdf>
o IL, MI, WI - Lake Michigan
<https://web.archive.org/web/20160327081932/http://www.nirs.org/factsheets/mibargefacts heet92804.pdf>
o LA, MS - Mississippi River
<https://web.archive.org/web/20160331080128/http://www.nirs.org/factsheets/lamsbargefac tsheet92804.pdf>
<https://web.archive.org/web/20160331063817/http://www.nirs.org/factsheets/tnalbargefact sheet92804.pdf>
o NE, KS, MO - Missouri River
3
<https://web.archive.org/web/20160331020303/http://www.nirs.org/factsheets/nemoksbarge factsheet92804.pdf>
o CA - California Coast
<https://web.archive.org/web/20160331030740/http://www.nirs.org/factsheets/cabargefactsh eet92804.pdf>
o FL - Floridas Atlantic Coastline
<https://web.archive.org/web/20160331035101/http://www.nirs.org/factsheets/flbargefactsh eet92804.pdf>
(However, with something as simple as a rushed NRC rubber-stamp amendment, WCS could apply for, and quickly get, permission to truck in smaller-sized, "Legal Weight Truck" (LWT) casks to WCS. This mix of trains/barges and trucks, would mean even more American communities would be exposed to Mobile Chernobyl risks.)
Dirty Bomb on Wheels security risks would abound. This was made clear by the test of an anti-tank missile against an (empty) irradiated nuclear fuel shipping cask at the U.S. Armys Aberdeen Proving Ground in Maryland. The June 1998 test targeted a German CASTOR cask. While certified for storage-only in the U.S. (the cask model is deployed at Surry, VA), it is widely used for transport in Europe. CASTORs have thick die cast iron walls, as opposed to thin walled steel casks in the U.S. That is, CASTORs are significantly more robust, more capable to withstand such an attack. However, even the CASTOR, the Cadillac of shipping casks as some have called it, was severely breached by the anti-tank missile. A hole as big around as a grapefruit or softball was blown clean through the side wall. Had irradiated nuclear fuel been inside, the hole would have created the pathway for release of disastrous amounts of hazardous radioactivity - all the more so, if an incendiary attack were combined with the explosive attack. In short, shipping containers were not designed to withstand such attacks. See:
<https://web.archive.org/web/20150908070611/http://www.nirs.org/factsheets/nirsfctshtdrycaskvul nerable.pdf>.
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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