ML20252A171
| ML20252A171 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/02/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| Caverly J | |
| References | |
| NRC-1033 | |
| Download: ML20252A171 (142) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Public Online Webinar Docket Number:
N/A Location:
Teleconference Date:
September 2, 2020 Work Order No.:
NRC-1033 Pages 1-133 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
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3 PUBLIC ONLINE WEBINAR FOR THE DRAFT ENVIRONMENTAL 4
IMPACT STATEMENT FOR THE PROPOSED HOLTEC HI-STORE 5
CONSOLIDATED INTERIM STORAGE FACILITY 6
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7 WEDNESDAY, 8
SEPTEMBER 2, 2020 9
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10 TELECONFERENCE 11
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12 The Webinar was convened via 13 Teleconference, at 11:00 a.m. EDT, Chip Cameron, 14 facilitating.
15 16 NRC STAFF PRESENT:
17 CHIP CAMERON, Facilitator 18 KEVIN COYNE, Deputy Director, Rulemaking, 19 Environmental and Financial Support, NRC 20 JILL CAVERLY, Environmental Review Project Manager, 21 Environmental Review Branch, NMSS 22 STACEY IMBODEN, Co-Environmental Review Project 23 Manager, Environmental Review Branch, NMSS 24
2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 1
JOSE CUADRADO, Licensing and Safety Review Project 2
Manager, Spent Fuel Licensing Branch, NMSS 3
JOHN McKIRGAN, Chief, Storage and Transportation 4
Licensing Branch, NMSS 5
JESSIE QUINTERO, Acting Branch Chief, Environmental 6
Review and Materials Branch, 7
ANGEL MORENO, Congressional Affairs Officer, Office 8
of Congressional Affairs 9
KELLEE JAMERSON 10 11 ALSO PRESENT:
12 MIRIAM HOLLADAY JUCKETT, Southwest Research 13 Institute 14 MARLA MORALES, Southwest Research Institute 15 16 17 18 19 20 21 22 23 24
3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 C O N T E N T S 1
Page 2
Opening Remarks and Introductions..................4 3
Spanish Introduction and Instructions..............9 4
Welcome by Senior NRC Official Kevin Coyne.........9 5
NRC's Review Process..............................13 6
Safety Review...............................17 7
Environmental Review........................18 8
Overview of Holtec's License Application..........19 9
Public Scoping Comments...........................23 10 NRC's Environmental Review Results................24 11 Information Resources and Ways to Comment.........28 12 Public Comment....................................29 13 Closing Comments.................................132 14 Adjourn..........................................133 15 16 17 18 19 20 21 22 23 24
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P R O C E E D I N G S 1
11:02 a.m.
2 MR. CAMERON: Good morning everyone. My 3
name is Chip Cameron. And I'd like to welcome you to 4
the Nuclear Regulatory Commission meeting to listen 5
to comments from the public on the draft 6
Environmental Impact Statement the NRC has prepared 7
to help the Agency evaluate a license application 8
submitted by Holtec International to build and 9
operate a consolidated interim storage facility in 10 southeastern New Mexico.
11 The EIS is one key part of the NRC 12 evaluation of whether to grant the license. Another 13 key part of the evaluation is a public health and 14 safety review that will be embodied in something 15 called a Safety Evaluation Review.
16 The EIS is done under the authority of 17 the National Environmental Policy Act. The Safety 18 Evaluation Review is done under the authority of the 19 Atomic Energy Act.
20 Now, this is the last scheduled virtual 21 public meeting on the draft EIS. And the NRC staff 22 is looking forward to hearing from you about any 23 issues you disagree with, issues you might agree 24
5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 with, issues that haven't been addressed at all in 1
the EIS, and any supporting documents that you might 2
want to submit to help the NRC in preparing the final 3
Environmental Impact Statement.
4 Now, we have staff in the room here at 5
NRC Headquarters, not only from the Environmental 6
staff, but also from the Technical Safety Evaluation 7
staff. And as you'll hear Jill explain later on, 8
there were some issues that were raised that were 9
quote, out of scope, unquote for the Environmental 10 Impact Statement, because they were going to be 11 covered in the Safety Evaluation Report that the 12 Technical staff is doing.
13 I thought I'd give you a pictorial 14 introduction today of the people with me and on the 15 phone. And we're in a conference room at NRC 16 Headquarters.
17 And it's a horseshoe-shaped table, very 18 appropriate at this time of the year. I'm in the 19 center at the bottom of the horseshoe.
20 Three seats to my right is Jill Caverly.
21 Now Jill is the Project Manager for the preparation 22 of the Environmental Impact Statement. And You're 23 going to hear her summary of the draft EIS in a few 24
6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 minutes.
1 To Jill's right is Jose Cuadrado. Now 2
Jose is the Project Manager for the Health and Safety 3
Review.
4 And you'll also hear from him shortly.
5 He's going to offer assistance to Spanish-speaking 6
members of the public who might be with us today.
7 To Jose's right is Kevin Coyne. Kevin is 8
the Deputy Director of the Division of Rulemaking, 9
Environmental, and Financial Support here at the NRC.
10 His division is responsible for the draft EIS.
11 And to Kevin's right we have John 12 McKirgan. He's at the top of the right part of the 13 horseshoe.
14 And John is the Chief of the Storage and 15 Transportation Branch at NRC. And that's where the 16 Safety Evaluation Report will be produced.
17 Now, going across the top of the 18 horseshoe is Jessie Quintero. She's at the top left 19 of the horseshoe.
20 And Jessie is the Acting Branch Chief of 21 the Environmental Materials Review Branch at the NRC.
22 That's where Jill does her work. And it's in Kevin's 23 division.
24
7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
- Now, we also have some expert 1
environmental scientists who are helping the NRC to 2
prepare the Environmental Impact Statement. And to 3
my immediate left is Marla Morales from the Southwest 4
Research Institute in San Antonio, Texas.
5 On the phone we also have Miriam Juckett.
6 She's the Manager of Environmental Programs at 7
Southwest Research Institute.
8 We have Kellee Jamerson, and Kellee is 9
who helps us with all the technology, including 10 Webex. And we have Angel Moreno. He's from our 11 Office of Congressional Affairs.
12 Stacey Imboden, is Jill Caverly's Co-13 Project Manager on this draft EIS. And he's not here 14 today, because he's having a procedure.
15 Dave McIntyre -- Kellee, can we -- there 16 he is. He'll be back soon. And if any of you in the 17 media need to talk to an NRC contract about media 18 information, there's Dave's contact information.
19 Okay. We're in a virtual setting today, 20 which means we're going to be hearing from you by 21 phone. You can also see the slides on Webex. And 22 Kellee is going to put a slide up on Webex for you.
23 You can also go to the chat box on Webex 24
8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and post a comment if you're having any technical 1
difficulties hearing any of the NRC speakers or 2
anything else.
3 The NRC is not going to finalize this 4
draft EIS or use it in any decision making on the 5
Holtec license application until it evaluates your 6
comment on the draft EIS.
7 Now the NRC's not going to be responding 8
to comments you make tonight. But they will carefully 9
evaluate those in preparing the final EIS.
10 So, as I said, we're in a virtual 11 setting. And we have Olin (phonetic) for our Operator 12 today. And later we'll have Erin, a new Operator, 13 join us.
14 But, they are going to instruct you on 15 how to sign up to speak. How to put you on to talk 16 to the NRC staff.
17 And like the other meetings, this is 18 going to be a first come, first serve to speak. And 19 we're scheduled from 11:00 a.m. Eastern to 2:00 p.m.
20 Eastern.
21 And we have a
little bit more 22 flexibility, I think, today with the length of your 23 comments. But, right now I'm going to ask you to go 24
9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 for, you don't have to go for six or seven minutes.
1 But I'm going to not cut you off at four minutes like 2
we had to do in the past.
3 And we're taking a transcript tonight, as 4
usual. The transcripts from the other virtual 5
meetings will be available. And Jill will tell you 6
about that.
7 But Brandon is our Court Reporter. And 8
he'll be taking the transcript for you. And that 9
will be available in approximately ten days.
10 Okay. So, when Olin or Erin puts you on 11 the phone, please introduce yourself, give an 12 affiliation, if you would like to do so.
13 I'm going to ask Jose to say a few words 14 in Spanish. If anybody needs help with Spanish 15 translation, Jose Cuadrado.
16 MR. CUADRADO: Thank you, Chip. Good 17 morning everyone attending the meeting. My name is 18 Jose Cuadrado.
19 And I'm going to read a brief message in 20 Spanish for any Spanish speaking attendees today to 21 our meeting.
22 (Introduction and directions provided in 23 Spanish) 24
10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CAMERON: Okay, thank you. Thank you 1
very much, Jose. And we're going to go to Kevin Coyne 2
now, who's our Senior NRC Official, to give the public 3
a welcome. Kevin?
4 MR. COYNE: Thanks Chip. Good morning.
5 I'm Kevin Coyne and I'm the Deputy Director for the 6
Division of Rulemaking, Environmental and Financial 7
Support, which is the group responsible for the 8
development of the draft Environmental Impact 9
Statement.
10 The draft Environmental Impact Statement 11 is the result of the NRC staff's evaluation of the 12 environmental impact associated with Holtec 13 International's proposal to construct and operate an 14 interim storage facility. And today, we are asking 15 for your comments on that report.
16 It's important to note that any comments 17 received in this webinar forum are handled in the 18 same manner as those comments received at an in-19 person meeting. Your comments presented here today 20 are recorded and transcribed.
21 Our staff will review and analyze the 22 comments, and update the final EIS report as 23 appropriate. Comments received during this webinar 24
11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 will be made available in a transcript of today's 1
meeting that will be posted to the NRC's Holtec review 2
website shortly after the meeting.
3 The NRC staff in its commitment to 4
openness in this licensing review had planned for 5
five in-person public meetings. Unfortunately, we're 6
sorry that under the current public health emergency, 7
these meetings cannot be held as planned.
8 We are adhering to the New Mexico 9
Governor's guidelines for public gatherings, and are 10 following similar guidance from the State to its own 11 agencies for converting in-person meetings to a 12 virtual format.
13 Our staff is disappointed that we won't 14 be able to meet with you face to face and host open 15 houses prior to the meetings.
16 Over the course of conducting webinars 17 during the public health emergency, we have learned 18 that using video puts an extra burden on our servers 19 and may limit the functionality of the webinar for 20 participants.
21 Therefore, while you will not be able to 22 see us via video, please note that our review team is 23 attending this webinar and are hearing your comments 24
12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and perspectives.
1 Further, the webinar is only being used 2
to share the presentation materials. And these 3
materials are available on the NRC's Holtec 4
application review web page.
5 You can download those materials and 6
review them, or follow along with the presentation 7
over the telephone.
8 There are several recurring remarks at 9
our earlier webinars that I would like to address.
10 The first of those is that the NRC is rushing through 11 the licensing process. The comment period for the 12 draft Environmental Impact Statement has been 13 extended to a total of 180 days. And this provides 14 ample opportunity for people to comment.
15 This meeting is also being held 20 days 16 before the comment closing period to provide 17 additional time to submit comments in writing.
18 If you need any assistance in accessing 19 the application materials, the draft Environmental 20 Impact Statement, or submitting a comment, please 21 contact Jill Caverly for assistance.
22 Secondly, it was our intention to conduct 23 in-person meetings during the public comment period.
24
13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 But as we continue to monitor the public health 1
emergency, the limitations associated with the 2
response to the emergency has made these in-person 3
meetings impossible at this time.
4 Finally, we've received several comments 5
that the NRC is breaking the law by not coming to New 6
Mexico. We take our applications under NEPA very 7
seriously.
8 And NEPA requires federal agencies to 9
provide a 45-day comment period for the draft 10 Environmental Impact Statement. Neither NEPA nor our 11 regulations in 10 CFR, Part 51 require public 12 meetings or in-person meetings.
13 However, the NRC has offered in-person 14 public meetings in the past because it was our 15 practice, not a requirement. We understand that many 16 of the NRC's licensing actions are important to the 17 community, and we like to talk with you about them 18 face to face whenever possible.
19 Again, thank you for your time today, and 20 I'll turn it over to Jill to present the NRC staff's 21 draft Environmental Impact Statement results.
22 MS. CAVERLY: Okay, thanks Kevin. So, 23 good morning. Today I'm here to collect your comments 24
14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 on the NRC's draft Environmental Impact Statement.
1 And the majority of our meeting today 2
will be dedicated to that. And as Chip mentioned, I 3
have this short presentation.
4 I'm going to begin with an overview of 5
the application process, including the differences 6
between the environmental review and the safety 7
review.
8 Next, I'm going to move onto an overview 9
of the application submitted to NRC. I'm then going 10 to summarize the results of the staff's analysis.
11 I'll cover some of the public comments 12 received during the scoping process, and the 13 environmental evaluation and the results.
14 And finally, I'm going to end with 15 information on how you can access the report and make 16 comments on the draft Environmental Impact Statement.
17 So, as I go through my presentation, I 18 will use the term facility and proposed project 19 interchangeably. The abbreviation CISF stands for 20 consolidated interim storage facility.
21 Also, I may interchange the applicant and 22 Holtec, which is short for Holtec International.
23 Environmental Impact Statement will be abbreviated to 24
15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 EIS.
1 And finally, staff and NRC staff will be 2
referring to the staff of the Nuclear Regulatory 3
Commission. Next slide, please. Next slide, please.
4 Okay. So, as we mentioned the purpose of 5
this meeting is to receive your comments on the draft 6
Environmental Impact Statement, or EIS for a 7
consolidated interim storage facility, CISF.
8 And the NRC is requesting that you review 9
the draft EIS document and provide comments that are 10 pertinent to the current licensing action and the 11 draft EIS report. You have access to the report at 12 the NRC's website, where it can be downloaded and 13 read.
14 There are also three ways to comment.
15 Either by mail, website, or by email. Information 16 and methods to comment are going to be summarized at 17 the end of my presentation.
18 As Kevin said, any comments you make in 19 this forum, as well as through the three other methods 20 I just identified, will be recorded and entered into 21 the public docket for this licensing action. Next 22 slide, please.
23 So, we're going to talk a little bit 24
16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 about the review process for a license application 1
for a CISF. Next slide, please.
2 So, this is just to clarify NRC's role.
3 As an independent regulator, the NRC determines 4
whether it is safe to build and operate a storage 5
facility at the proposed site in Lea County, New 6
Mexico.
7 The NRC evaluates an application for a 8
facility and determines if a license can be issued.
9 The NRC does not promote or build nuclear facilities.
10 Also, the NRC doesn't own or operate 11 nuclear facilities. Our mission and our regulations 12 are designed to protect the public, workers, and the 13 environment.
14 Holtec International, or the applicant, 15 has proposed the location for the interim storage 16 facility in its application. So, in its role as a 17 regulator, NRC staff will perform both a safety 18 evaluation and an environmental review on that 19 application. Next slide, please.
20 So, this slide is a familiar looking 21 slide. We often show it in our scoping meetings.
22 But, it's a schematic of the NRC's licensing decision 23 process.
24
17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And it's here to show you that the NRC 1
has concurrent reviews occurring during its 2
evaluation process. You can see from the slide that 3
the process of licensing is based on three 4
foundational activities, the environmental review, 5
the safety review, and the adjudicatory process.
6 The safety review results in a Safety 7
Evaluation Report. And is based on the Atomic Energy 8
Act and regulations in the Code of Federal 9
Regulations. These regulations must be met in order 10 for a license to be granted.
11 The environmental review results in an 12 Environmental Impact Statement. This action is taken 13 because issuing a license is considered a federal 14 action under NEPA, the National Environmental Policy 15 Act. NEPA requires federal agencies to evaluate and 16 disclose environmental impacts of federal actions.
17 And the middle process in this slide is 18 the adjudication process. And that's a legal process 19 used for a dispute. Okay, next slide, please.
20 So to look at the safety side of the 21 review a little bit more. This slide shows you many 22 of the areas of the safety review, which are required 23 by the NRC to assure that a design can be constructed 24
18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and operated while protecting human health.
1 The NRC's safety staff will evaluate the 2
design of the CISF and the characteristics of the 3
construction site to ensure that it will be built and 4
operated safely. That it will be protective, be 5
protected from manmade and natural hazards.
6 And that it will protect the public 7
health and safety. The NRC staff evaluates the 8
physical security practices to assure that the 9
facility is protected from intrusion, theft, and 10 sabotage.
11 The design of structures at the facility 12 is evaluated to verify it's integrity and ability to 13 withstand accidents. Other areas such as financial 14 qualification are reviewed to ensure it meets NRC 15 standards before a facility can be licensed.
16 In addition, the staff will evaluate that 17 the facility is capable of withstanding external 18
- hazards, which include things like extreme 19 temperatures, floods, tornados, and earthquakes.
20 So the safety evaluation determines 21 whether the facility can be constructed and operated 22 to protect human health.
23 And you could say that the safety review 24
19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in part evaluates how the environment will impact the 1
design, and whether that design is capable of 2
providing protection in safely storing spent fuel.
3 All right, next slide, please.
4 So on the other hand, the parallel 5
environmental review evaluates what the project will 6
do to the environment. The environmental review 7
starts with the current environmental conditions as 8
its baseline.
9 In the EIS we call this the affected 10 environment. Each of the resources you see listed 11 here will be evaluated for impacts to that baseline.
12 So using the baseline data, the staff 13 will evaluate the changes or impacts to each of the 14 listed resource areas should the facility be 15 constructed and operate.
16 So that delta or that change to the 17 resource, is evaluated. And that change is called 18 the impact to the resource. And that's what's 19 disclosed in our Environmental Impact Statement.
20 Next slide, please.
21 So in order to quantify the impacts, the 22 NRC uses the definitions of significant levels for 23 environmental impacts, small, moderate, and large.
24
20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And this scale rises based on the 1
destabling influence to the resource. These 2
definitions are from NRC's staff guidance. Next 3
slide, please.
4 Okay. So now we're going to talk a little 5
bit about the details of the application. Next slide, 6
please.
7 The proposed project is located half way 8
between the towns of Carlsbad and Hobbs in New Mexico.
9 Holtec's project includes the storage facility, 10 related buildings and a rail line.
11 A portion of the rail line is shown on 12 the diagram on the right. And is the loop that you 13 see on the east side of the facility.
14 This rail line continues off the diagram 15 to the south. And then turns to the west and 16 continues for approximately five miles to tie into an 17 existing rail line.
18 The area of the rail line not shown on 19 this diagram is on the Bureau of Land Management 20 controlled area, controlled land. So Holtec is 21 seeking a permit for that action to the Bureau of 22 Land Management as a cooperating agency with the NRC 23 on the development of this EIS.
24
21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 In addition, the New Mexico Environment 1
Department worked as a cooperating agency with NRC on 2
surface and groundwater resources for their 3
expertise. Next slide, please.
4 So, on the left side of this slide is an 5
artist rendering of the proposed action. And on the 6
right side is a diagram. It's the same diagram that 7
I showed you on the last slide.
8 The picture on the left is the area 9
circled in red on the diagram on the right, represents 10 the current licensing action, which is to build Phase 11 1 of the spent fuel storage facility.
12 So, if licensed, Holtec would be granted 13 a license to build and store five hundred canisters 14 of spent fuel. The additional support buildings, 15 transfer facilities, and rail line are also included 16 in Phase 1 of the impact analysis.
17 However, Holtec has stated its intention 18 to apply for amendments for up to 20 phases, which is 19 represented by these, the rectangular boxes in the 20 diagram.
21 So, at full build-out for all 20 phases, 22 the area would cover 330 acres. Next slide. Okay.
23 Next slide, please.
24
22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So as I mentioned, the proposed project 1
would be an in-ground, low profile design. On the 2
right is a similar design used for spent fuel to give 3
you some perspective.
4 The proposed project would use a HI-STORE 5
Umax system for the storage of spent fuel. HI-STORE 6
Umax stands for Holtec International Storage Module 7
Underground Maximum Capacity.
8 Each one of these modules will hold one 9
canister of spent fuel. Next slide, please.
10 Okay. So, to give you some perspective, 11 we're looking again at an artist rendering of Phase 12 1 or the proposed licensing action.
13 So, this would include the five hundred 14 canisters of spent fuel stored in the underground 15 system using the Umax canisters. The Umax canister 16 however, is an engineered canister.
17 It's designed to passively cool and store 18 spent fuel for long periods of time. It's constructed 19 from stainless steel, and has been certified by the 20 NRC for storage of spent fuel at power reactor sites.
21 So this means that the manufacturing and 22 the design of the canister is engineered to meet NRC 23 requirements for safety. Those include structural 24
23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 integrity, material integrity, and longevity.
1 The canisters contain spent fuel rods.
2 There's no liquid inside the canisters that could 3
leak into the environment.
4 The thickness and internal 5
characteristics are designed to prevent radioactive 6
material from escaping under normal and accident 7
scenarios. And that's achieved by using redundant 8
welded steel and a robust structural design.
9 The Hi-Store design, which is being 10 proposed in the current license application will 11 store the Umax canisters for an initial license term 12 of 40 years.
13 This means that the NRC is currently 14 evaluating the design for the facility to ensure that 15 the facility meets those requirements. Next slide, 16 please.
17 So, I've added this slide to help clarify 18 how we broke out the project in our analysis. And as 19 I mentioned earlier, the proposed action is Phase 1 20 or five hundred canisters of spent fuel.
21 As stated earlier, the applicant has made 22 it known that it has an intention, its intention to 23 request up to 19 additional phases in license 24
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 amendments. These are referred to in our EIS as the 1
full build-out or Phase 2 through 20.
2 So the staff in its discretion decided to 3
evaluate all 20 phases of the project in its 4
Environmental Impact Statement. It's important to 5
understand the NRC is not licensing all 20 phases.
6 The decision to evaluate all 20 phases 7
was made by NRC staff to provide additional 8
perspective to the environmental impact.
9 Finally, the staff evaluated the project 10 in stages, construction, operation, decommissioning.
11 And that's because each of these stages has unique 12 environmental impacts.
13 So when appropriate, the staff evaluated 14 the maximum impact for combined stages for different 15 phases of a project.
16 So for example, the staff may have 17 evaluated the construction stage for Phase 2 in 18 conjunction with the operation stage of Phase 1, 19 because this would represent the peak impact to a 20 particular resource. Okay, next slide, please.
21 We can just go and cover some of the 22 public scoping comments. Next slide, please.
23 NRC opened the scoping period in March 24
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 2018. And during that time, held one webinar and 1
five in-person meetings.
2 We received 66, almost 67 hundred pieces 3
of correspondence and 39 hundred unique comments.
4 After the scoping period ended, we did review all of 5
those comments and document them, and responded to 6
those.
7 And that scoping report is available on 8
the NRC's docket and website. Next slide, please.
9 So, a lot of the comments we received 10 during the scoping process had to do with 11 transportation, location, geology, the volume of 12 material, water resources, socioeconomic, the EJ, and 13 of course, external events, flood and fire.
14 We also received comments on items like 15 potential flooding, compatibility of the Umax system, 16 design of structural elements, potential for extreme 17 hazards.
18 And now as you can see from the earlier 19 slide, these are out of scope from the environmental 20 review, but our safety reviewers are evaluating the 21 facility for many of these issues. Okay. Next slide, 22 please.
23 So, now we're just going to talk a little 24
26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 bit about the results of the NRC's environmental 1
review and the draft EIS. Next slide, please.
2 So staff evaluated a 40 year licensing 3
term. And the spec -- so, with the assumption that 4
the spent fuel would be removed before any 5
decommissioning stage would begin.
6 The staff impact analy -- evaluation 7
characterized the groundwater at the facility and 8
evaluated storm water overflow or runoff to nearby 9
playas or lakes. Next slide, please.
10 For transportation and accident, the 11 staff evaluated traffic and road degradation from 12 workers and construction vehicles during all stages 13 and phases of the project.
14 Staff evaluated the movement of the 15 entire 20 phases of material, or 10 thousand casks 16 using conservative, representative routes.
17 Radiological doses and health effects to the public 18 and workers along the route were conservatively 19 estimated, and found to be low relative to background 20 radiation and expected baseline cancer risk.
21 Impacts from transportation accidents 22 evaluated doses to first responders, workers, and 23 members of the public. NRC rules require spent fuel 24
27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 transportation canisters to withstand severe accident 1
conditions.
2 So, an assumption of no release during 3
accidents was used during staff's analysis. Previous 4
NRC technical analyses involving spent fuel in 5
canisters support this no release assumption.
6 Land use at the location of the facility 7
was also evaluated by staff. The location of the 8
facility was proposed by the applicant, but the staff 9
evaluated the applicant's site selection process.
10 It also evaluated the land use within a 11 six mile radius of the facility. Next slide, please.
12 So, there's a typo on this slide. And 13 it's the last bullet.
And it should be 14 disproportionately high and adversely affected by, 15 dash. And so on the left side, there's a typo there.
16 So the environmental justice impact 17 evaluated the impact on human health and the 18 environment using well-known guidance from the 19 Council on Environmental
- Quality, the Federal 20 Interagency Working Group on Environmental Justice 21 and NEPA, and NRC's Guidance and Policy Statements.
22 The region of influence for the analysis 23 included 115 block groups, which are geographic areas 24
28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that include between six hundred and three thousand 1
people. And those are within the ten counties that 2
fall either completely or partially within a 50 mile 3
radius of the CISF.
4 So staff identified potentially affected 5
minority and low income populations, and performed 6
the relevant comparisons to the broader geographical 7
regions.
8 Socioeconomic impacts were evaluated 9
based on workers, tax revenues, and resource 10 availability for the community.
11 Tax revenues and economic growth from the 12 proposed project and from the additional workers in 13 the area, were evaluated for impact, including use of 14 public services, schools, housing demands, and that's 15 all due to the increase pop -- the increased 16 population in the region. Next slide, please.
17 Okay. So, the next two slides tabulate 18 the results of the environmental review and the draft 19 EIS. We summarized it as the proposed action of Phase 20 1 or five hundred canisters.
21 And separately, the additional phases 22 that maybe requested in amendments going forward.
23 Those are listed as Phases 2 through 20, or here 24
29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 they're identified as additional Phases.
1 On this slide you can see that most of 2
the impacts are small except for ecology. Next slide, 3
please.
4 So this is a continuation of the summary 5
of the impacts. And here you can also see that most 6
of the impacts are small except for in waste 7
management, they're small to moderate and 8
socioeconomic.
9 And those are -- this is just a summary 10 of the details from the EIS. Okay. Next slide, 11 please.
12 So, this is where you can go to get 13 information.
The draft Environmental Impact 14 Statement is available online.
15 There's also readers' guides that are 16 available in Spanish and English. Those are about 20 17 page summary documents. It's a place to start.
18 And if you want to explore all of the 19 application material, you should go to the NRC's 20 project website. And that has all of the information.
21 That's where the transcripts will be posted. And has 22 all the safety information.
23 I should mention that the transcript from 24
30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the last two meetings will be posted on that website 1
probably by tomorrow. But they're also, they're 2
already available publically on the NRC's ADAMS.
3 So, I think Jose, you -- can you post the 4
number for ADAMS?
5 MR. CUADRADO: Yeah. Sure.
6 MS. CAVERLY: Okay. Okay, so next slide, 7
please. Okay. So how to comment. Today we're 8
recording your comments.
9 We have a court reporter on the line. So 10 we will, it gives us comments in the transcript, and 11 we will evaluate all the comments provided here.
12 You can also make your comments at the 13 Federal Rulemaking Website, Regulations.gov. You can 14 mail the comments to the NRC through regular mail, or 15 you can email comments to Holtec-CISFEIS@nrc.gov.
16 So, the comment period is ending in about 17 20 days. So, we ask that you provide your comments 18 in the next three weeks, two -- three weeks, almost 19 three weeks, so that we can address them in the final 20 EIS.
21 So with that, I think I'm finished. And 22 we can move onto the public comment portion.
23 MR. CAMERON: Great. Thank you very 24
31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 much, Jill.
1 And Olin, we're ready to hear from the 2
public. So, if you could, you could put the first 3
speaker on for us, please?
4 OPERATOR: Thank you. For the question 5
and answer session, I want to give a quick reminder.
6 If you'd like to ask a question, please 7
press star one, unmute your phone, and record your 8
name clearly. Your name is required to introduce 9
your question.
10 If you need to withdraw your question, 11 you may press star two. Again, to ask a question, 12 please press star one.
13 Our first question is going to be coming 14 from Jack Edlow. Mr. Edlow, your line is now open.
15 MR. EDLOW: Thank you very much. And 16 good morning to all. First of all, I would like to 17 say that I support the draft EIS.
18 And I am going to discuss transportation 19 issues since that's my business. I'm involved in the 20 transportation of radioactive cargos worldwide.
21 Now, there are lots of different kinds of 22 hazardous materials in the world. Thousands and 23 thousands of items.
24
32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 They range from Classes 1 through 9. For 1
instance, Class 1 is explosives. Class 2 is gases.
2 A Class 3 is flammable liquids.
3
- Well, Class 7
is for radioactive 4
materials. And in that class there are many forms of 5
radioactive materials as well. Things like empty 6
packages, things like fissile materials, things like 7
natural materials.
8 And of course spent nuclear fuel as well, 9
is one type of radioactive material within the 10 framework of the general hazardous materials.
11 So, there are lots and lots of shipments 12 of hazardous materials. All kinds of things on road, 13 and rail, and air, and sea, and also by pipeline.
14 And there's lots of forms of radioactive 15 material. Many, many, many shipments every day.
16 Millions a year, and most are for radiopharmaceutical 17 use.
18 But, spent nuclear fuel also has a lot of 19 experience. And, I think, based on a lot of the 20 comments I've heard in last calls, I'm not sure it's 21 quite understood how much experience has been 22 obtained in the United States for shipping spent 23 nuclear fuel.
24
33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So in the United States, I'm certainly 1
aware that it's been shipped as far back as 1963, 2
because that's the first year that my father, Sam 3
Edlow, made a shipment, which came from Sweden.
4 It was an Atoms for Peace return shipment 5
from Sweden via the Port of Savannah. And then by 6
rail to the Atomic Energy Commission facility in 7
8 And so since that time, there's been 9
many, many other shipments to reprocessing plants 10 that operated at West Valley, New York, and Morris, 11 Illinois also received many shipments.
12 There were utilities made intra-utility 13 shipments between power plants for a variety of 14 reasons. Many, many, many research reactors at 15 universities all around the country have made 16 shipments back to the Department of Energy.
17 The Navy of course has had a major 18 nuclear program and has moved fuel around coming off 19 their vessels, back to storage and disposal in Idaho.
20 And of course, 40 or 50 research reactors 21 around the world under Atoms for Peace have returned 22 spent nuclear fuel to the United States.
23 Now, internationally there's been lots of 24
34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 other shipments. Japan had large numbers of 1
shipments to France and to England.
2 And within France there were daily 3
shipments. Within the UK there were daily shipments 4
for many years. And you know, other nuclear nations 5
also make spent fuel shipments.
6 So, there have been many thousands of 7
shipments over 60 years. And in the United States 8
now, we probably ship spent nuclear fuel on a weekly 9
basis.
10 Last, in the last two years, Edlow has 11 made approximately 100 shipments. Not always on a 12 weekly basis. Sometimes multiple times in a week.
13 But, there have been large experience here.
14 So, the routes that we use are planned in 15 conjunction with the Department of Transportation, 16 with NRC, and under state guidance as well. So, this 17 is not done without the knowledge and consent of the 18 state, and advice of the state.
19 And of course the states are informed 20 prior to every shipment of spent nuclear fuel. So, 21 they are aware of what's going on.
22 Security is under the guidelines of the 23 Nuclear Regulatory Commission. And security plans 24
35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 exist.
1 They are changed. They are flexible.
2 They have to deal with the various items, and kinds, 3
and situations that occur.
4 So, my summary, I would say, I believe 5
that the transportation of spent nuclear fuel to the 6
proposed Holtec facility can be managed within the 7
United States both safely and securely.
8 And for that reason, I thus, I support 9
the draft EIS. Thank you very much.
10 MR. CAMERON: Thank you, Jack. That was 11 a helpful, a helpful tutorial.
12 And we're going to go onto the next 13 speaker. Olin, who do we have next?
14 OPERATOR: Our next is Cynthia Wheeler.
15 Ms. Wheeler, your line is now open.
16 MS. WHEELER: Hello. Can you hear me?
17 MR. CAMERON: Yes. We can Cynthia.
18 MS. WHEELER: Thank you. My name is 19 Cynthia Wheeler. I am from Santa Fe and grew up in 20 Roswell. I'm again making these comments under 21 protest.
22 The Agency has run them ineptly. There's 23 one thing that's done very effectively though and 24
36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that is to make the public feel that it's talking 1
into a void. Sometimes I imagine NRC staffers 2
listening to the call in their offices while 3
leisurely painting their nails. Now understand that 4
I'm not accusing anyone of doing that, but the point 5
is I'll never know. You've lost my trust.
6 We have detailed many times the 7
following: We don't consent to burying this waste in 8
Our governor and congressional 9
delegation join us in that. The DEIS is amiss in 10 every category it addresses. Most of the impacts are 11 small, only if nothing goes wrong. And I fail to see 12 how the NRC could simply assume that nothing could go 13 wrong.
14 The geology is unstable for this kind of 15 long-term storage. It doesn't protect the Ogallala 16 and other water sources. It will have a negative 17 effect on the economy. No one wants to live near a 18 nuclear waste dump. Cattle and dairy growers, chili 19 and pecan growers, they all have a long history of 20 using this land. One accident will destroy that.
21 Transportation is the greatest hazard in 22 this plan and it is addressed almost not at all. A 23 recent study by a radioactive waste specialist 24
37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 details all the hazards of using rails to move this 1
waste and you should pay close attention to it.
2 To respond to the first speaker just 3
before me, I need to say that Dr. Bob Alvarez, an 4
expert in dealing with nuclear waste systems, has 5
studied the shipment of high-level nuclear waste and 6
unequivocally states that we are not ready for 7
anything on this scale.
8 Holtec is a compromised company with 9
indictments for bribery and lying on applications 10 when asked if it had ever been banned from working 11 with government agencies, which it has. There is 12 some evidence that the bid for this job was arranged 13 so that Holtec was the only company that submitted a 14 bid.
15 And finally there's no compelling reason 16 except to accommodate Holtec for these meetings to be 17 rushed during the pandemic.
18 In response to the speaker at the 19 beginning of the meeting with the NRC, the solution 20 to a pandemic is not to hold the meetings virtually, 21 but to wait to hold the meetings when it is safer.
22 My parents' generation made this waste.
23 They had no idea how to protect us from us and they 24
38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 proceeded with the incredibly foolish idea that 1
future technologies would find a way to store it.
2 One generation should never lay that burden on 3
another. Now my generation is doing the same thing 4
and no one has acknowledged the simple fact that no 5
new technology can change the laws of the physics of 6
radioactive decay occurring on a planet that moves 7
things around over long time scales. And it matters.
8 For example, one of the substances you 9
want to bury here is plutonium-239, half-life of 10 24,000 years. In 10 half-lives, which is about what 11 it takes for most of that substance to be decayed, 12 that's a quarter of a million years. But that's not 13 the end because plutonium decays into uranium-235 14 with a half-life of 700 million years. Ten of those 15 half-lives work out to 7 billion years, and the 16 planet hasn't even existed that long.
17 Now I'm sure you know that because it's 18 your job to know it, but we have to remember geology 19 101 which tells us that the earth is in constant 20 motion over long stretches of time. But if there's 21 one thing you can count on it's that the earth will 22 move, and the continents and oceans that we know have 23 moved dramatically. Lee County in Southeastern New 24
39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Mexico where Holtec wants to bury this waste is an 1
arid desert, but 250,000 years ago it was covered by 2
a shallow sea. No one can adequately explain how 3
deadly and toxic radioactive waste can be securely 4
and safely kept out of the environment we depend on 5
when it lasts so long that the environment will have 6
drastically changed while it's still deadly and 7
toxic.
8 The bottom line is that you don't want 9
inept companies and indifferent agencies handling 10 nuclear waste. I hope those who work at the NRC 11 realize that their job is different from every other 12 job, that the burden that they carry to protect the 13 public from this waste is heavy and that they not 14 forget it. And once again to quote Dr. Jonas Salk 15 who invented the polio vaccine, our greatest 16 responsibility is to be good ancestors. Thank you.
17 MR. CAMERON: Okay. Thank you for 18 joining us again, Cynthia, and for that quote from 19 Dr. Salk.
20 And, Olin, who do we have next?
21 OPERATOR: Our next is Jan Lundgar.
22 Ms. Jan, your line is now open.
23 MS. BOUDART: Is it -- are you talking to 24
40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 me? Is it my line?
1 OPERATOR: Yes, ma'am.
2 MR. CAMERON: I think it is.
3 MS. BOUDART: Oh, it's Boudart. B-O-U-4 D-A-R-T. Jan Boudart. And I would like a very short 5
response to Jack Edlow and to Cynthia Wheeler.
6 The first response to Mr. Edlow is that 7
his -- he deserves congratulations with his company 8
for -- oh, I've got this written down because I wrote 9
it for last time. I got the impression that Edlow 10 Nuclear Transportation Services is self-regulating, 11 and I think he showed that today. This seems to have 12 worked okay which is certainly a wildly improbable 13 exception, so he deserves to be congratulated. With 14 self-regulation commercial enterprises like Boeing 15 and Energy Harbor in --
16 MR. CAMERON: Jan, we seem to have lost 17 you.
18 (No audible response.)
19 MR. CAMERON: Oland, is there something 20 wrong with Jan's line or anything we could do?
21 OPERATOR: Unfortunately her line just 22 disconnected.
23 MR. CAMERON: Okay. Well, we'll see -- if 24
41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 she comes back on, please put her on so we could let 1
her finish her comments, but in the meantime can we 2
go to the next speaker?
3 OPERATOR: Absolutely. We have Elaine 4
Walker.
5 Ms. Walker, your line is open.
6 MS. WALKER: Hello. Is that me?
7 MR. CAMERON: Yes.
8 MS. WALKER: Okay.
9 MR. CAMERON: We hear you.
10 MS. WALKER: It's Kalene. Kalene Walker.
11 Let's see. Regarding the transportation, 12 these are -- never has this quantity of radioactive 13 isotopes been transported in one package. These are 14
-- there's a Chernobyl disaster worth of radiation in 15 each canister.
16 I make this comment with great -- I'm 17 greatly discouraged by the ability of the NRC to -- I 18 don't believe that they can properly manage the 19 nuclear industry, the combination of ISGs. Where 20 they can make Interim Staff Guidance regulation Title 21 X Part 72, Part 71 has been completely stripped of 22 their power through the process of ISGs, exemptions, 23 amendments and the 72.48 process. If you look at 24
42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what's happened at San Onofre with the Holtec system, 1
with Holtec loading the Holtec system, you'll see 2
what we have going on here.
3 I don't have my thoughts together well 4
enough to speak right now, but the NRC has only been 5
analyzing this for 40 years. This is like hundreds 6
of years you should be analyzing. Where is your 7
ability to repackage this stuff? When are you going 8
to require a hot cell? These canisters, they can 9
have leaking helium. There's no contingency plan if 10 a canister drops and the fuel is damaged. There's no 11 facility in the United States capable of handling 12 this.
13 The fact that Holtec is not even thinking 14 that that's a requirement, the whole thing is so 15 egregiously irresponsible. I'm wondering what is the 16 mentality, what is the reason? Do people think that 17 the nuclear waste likes to be stored all clustered 18 together, that all the canisters want to be stored 19 together? Why would you move all of this stuff across 20 the country so it can all be clustered together?
21 There's absolutely no need for such a massive 22 dangerous project. There is -- the lack of 23 responsible oversight on this is egregious and 24
43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 dangerous. Period. Thank you.
1 MR. CAMERON: Thank you, Kalene.
2 Olin, who is next?
3 OPERATOR: We have Rose Gardner.
4 Ms. Gardner, your line is now open.
5 MS. GARDNER: Thank you. I am Rose 6
Gardner from Eunice, New Mexico. I'm with the 7
Alliance for Environmental Strategies. I am making 8
comments under protest today. The Alliance for 9
Environmental Strategies strenuously opposes the 10 Holtec International Project for CIS. The National 11 Waste Policy Act does not allow for this license to 12 be issued to any privately-owned corporation to take 13 the high-level waste from commercial reactors.
14 The failure of the NRC to satisfy the 15 public with these poorly-run and moderated webinars 16 are an example of government waste, as usual.
17 I would like to invoke my friend's name.
18 His name is Noel Marquez. He is from Artesia, New 19 Mexico. He is a co-founder of the Alliance for 20 Environmental Strategies. He is a well-known 21 community artist and activist. He was instrumental 22 in helping pass the Lake Arthur, New Mexico 23 resolution against Holtec.
24
44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The last time I saw Noel speak in public 1
was at the NRC scoping meeting in Carlsbad. He was 2
rudely interrupted by the moderator Chip Cameron. He 3
was not allowed to finish his comments. Fortunately 4
people opted to give him their time so he could finish 5
his comments. Well, folks, he can't speak anymore.
6 He can't speak against Holtec. He is physically 7
unable to do so. So I will speak for him.
8 He opposes this Holtec project and is 9
against the process which targets our Hispanic 10 community with disgraceful and dangerous projects 11 like WIPP, Holtec, Urenco, Waste Control ISP, and 12 others. I would ask that the NRC give one minute of 13 silence and recognize those that are unable to speak 14 and to comment to you today or any day, like my friend 15 Noel. Thank you.
16 MR. CAMERON: Thank you, Rose. Sorry to 17 hear about Noel, and we will gladly give one minute 18 of silence to anybody who is unfortunate to have a 19 physical malady such as Noel. So we're going to start 20 one minute now. And I'll time it and then I'll go 21 back to the operator.
22 (Moment of silence.)
23 MR. CAMERON: Okay. We're back. Thank 24
45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you.
1 Thank you, Rose.
2 And, Olin, who do we have next?
3 OPERATOR: Our next Paul Blanch.
4 Mr. Blanch, your line is now open.
5 MR. BLANCH: Good morning. Can you hear 6
me?
7 MR. CAMERON: Yes. Hi, Paul.
8 MR. BLANCH: Hi. Is that Chip Cameron I 9
hear?
10 MR. CAMERON: That is. That's me. That's 11 correct.
12 MR. BLANCH: God, I haven't seen you for 13 a long time.
14 Anyway, my name is Paul Blanch. I reside 15 in West Hartford, Connecticut. I have more than 50 16 years nuclear experience.
I'm a
registered 17 professional engineer. I am an expert, a system 18 expert for a group, public interest group surrounding 19 the San Onofre Nuclear Power Plant. I have studied 20 extensively not only the regulations, but also the 21 technical details associated with the Holtec UMAX 22 canisters, and I have worked with headquarters, with 23 Andrea Koch and other people.
24
46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We have petitions submitted, FOIA 1
requests submitted. But I thought this was an 2
opportune time to get two of my concerns on the 3
record. And these are concerns that have never been 4
raised before that I am aware of. And this involves 5
not only the environmental impact, but also the 6
safety aspects of the Holtec system design as it may 7
impact the storage in New Mexico. And I've been 8
through this time and time again. I was through it 9
this morning in a report I got that was posted to 10 part of this meeting.
11 And that concern, my first concern is 12 helium. Inside the multipurpose canister, which is 13 half-inch to five-eighth-inch thick stainless steel 14
-- it contains fuel up to somewhere around 37 to 45 15 kilowatts of heat being generated and is surrounded 16 by helium pressure, and that pressure is in the range 17 of anywhere from 45 to 100 pounds depending on the 18 temperature.
19 I have researched -- the concern that 20 many of us have is what is the impact of helium 21 leakage? Helium is used to isolate the fuel, to 22 prevent corrosion, but also it's a heat transfer 23 medium to allow the heat transfer from the fuel to 24
47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the environment. So I ask myself the question what 1
happens if we lose helium pressure?
2 Now this is only five-eighths of an inch 3
thick max. If we remember many years ago where six 4
inches carbon steel hole eroded through the head of 5
a reactor. We know these things age. Being an ex-6 Navy person I'm familiar with the Thresher and the 7
Scorpion. We know those reactor vessels, even though 8
they're six inches thick stainless steel, they have 9
been breached.
10 Now when I go through the licensing 11 documentation, I come upon the most incredible 12 statement that I think I've seen in licensing 13 documents, and I ask myself and I ask the NRC what 14 happens if we lose helium? What happens to the 15 radioactive releases? What happens to the fuel 16 temperature?
17 As I review those documents in many 18 places, including the document that we're talking 19 about today, it says that helium leakage is a non-20 credible event. What this is saying is the NRC 21 somehow has determined that it's impossible for 22 helium to leak out.
23 Now it takes me to Interim Staff Guidance 24
48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 No. 18, which is helium leak rate testing, which only 1
tests the welding at the top of the canister to make 2
sure that weld has high integrity. The fact that the 3
NRC somehow has determined that five-eighth-inch of 4
stainless steel leakage is incredible given the 5
experiences we've had with materials and six-inch 6
reactor vessels and so on and so forth, the fact that 7
is incredible, and they claim that issue is addressed 8
in ISG-18, it is not. The NRC is not being 9
forthcoming in their statements.
10 I have asked Andrea Koch for the basis 11 for the NRC to determine -- and Holtec to determine 12 that this is an incredible event, not possible, not 13 possible in a million years with a million canisters.
14 This is ludicrous from a practical standpoint, from 15 an engineering standpoint and I wouldn't want to be 16 around these when we don't even consider the breach 17 of a canister. Not only that, we don't know what the 18 temperature of the fuel will be and we don't know 19 what the radioactive releases will be; not if, but 20 when these canisters are breached.
21 That is a very, very serious issue. To 22 my knowledge it has never been brought up before. I 23 obviously am pursuing it. This will impact every 24
49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 canister whether it be the UMAX canister or above-1 ground canisters. There is an impact if you lose 2
3 My second issue is a little more subtle 4
and that has to do with the location. If I look back 5
at some of the NRC licensing documents, which I have 6
in front of me on my computer, has to do with natural 7
gas pipeline hazard risk determination. This is a 8
study that is done by -- let me get it here 9
-- Framatone ANP. I have a document number. I don't 10 have the ML number. But basically -- and I have a 11 lot of experience with gas lines in the proximity of 12 nuclear facilities.
13 What this study states -- and this is 14 discussed also in the application. But this study 15 states here; and I'll gladly provide the NRC with a 16 copy of it, that a 16-inch gas line located 1.8 miles 17 away from a nuclear enrichment facility, which is a 18 low radioactive material containment, is 19 unacceptable. Now we have many gas lines where this 20 new facility is being proposed, and there are some 21 analysis within the FSAR and Environmental Impact 22 Statement.
23 But there is no explanation as to why we 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 have an NRC approved study that says it's 1
unacceptable and all of a sudden because of the need 2
it becomes acceptable. It's just incredible to me.
3 And we've had a recent Inspector General report on 4
this gas line issue. It was issued in February of 5
this year. And now the NRC has put out false 6
information, to me.
7 So those are my two comments and I'd like 8
to have them formally considered. I will continue 9
working with headquarters in Region IV on those 10 issues, but I want this issue on the table. And again 11 I am a professional engineer and Chip Cameron and I 12 have known one another and have a mutual respect for 13 one another, and I'm sure that Chip will assure that 14 we get a resolution to this. Thank you very much.
15 MR. CAMERON: Thank you. Thank you, 16 Paul. And I just want to just affirm that mutual 17 respect. And thank you for those specifics. And if 18 there's some documents that you could submit on this 19 to the NRC, that would be great. And I hope you're 20 well.
21 MR. BLANCH: I am very well. I've never 22 been better, Chip.
23 MR. CAMERON: Fantastic. Fantastic.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Olin, who is our next speaker?
1 OPERATOR: We have Barbara Warren.
2 Ms. Warren, your line is now open.
3 MS. WARREN: Good afternoon. My name is 4
Barbara Warren. I'm a registered nurse with a 5
master's degree in environmental health science and 6
Executive Director of Citizens' Environmental 7
Coalition, which is based in the State of New York.
8 Our organization and our members are very concerned 9
about the weak plans for consolidated interim storage 10 as well as the fact that required transportation has 11 not been adequately studied.
12 Today I want to discuss a particular 13 topic. We will be providing detailed comments later 14 on before the 22nd, but today I want to discuss 15 entropy.
16 NRC has concluded that there will 17 primarily be small impacts associated with the Holtec 18 CIS proposal. The law of entropy or the second law 19 of thermodynamics along with the first of 20 thermodynamics comprised the most fundamental laws of 21 physics. Entropy is the subject of the second law 22 and energy is the subject of the first law and their 23 relationship are fundamental to an understanding not 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 just of physics but of life. The law of entropy tells 1
us that disorder always increases. It tells us that 2
anything and everything will always move from order 3
to disorder.
4 Significant energy is required as a 5
result to maintain the order that is absolutely 6
necessary to prevent the dispersal of long-lived 7
radionuclides into the environment and into human 8
beings.
Human and organizational
- failings, 9
inadequate budgets and other priorities always limit 10 our collective ability to successfully contain 11 radioactivity and prevent public exposure. Effects 12 on future generations are an example of 13 intergenerational injustice.
14 As a nation we have failed at achieving 15 the required isolation and are paying the price at 16 many nuclear facilities around the country. WIPP, 17 Hanford and Savannah River are just a few of the 18 hundreds of sites that collective need thousands of 19 years of work just to temporarily contain and limit 20 the dangerous disorder that the law of entropy 21 guarantees at these sites.
22 We are all facing a new threat from the 23 current proposals for interim storage of spent 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 nuclear fuel, one of the most hazardous substances on 1
earth according to the U.S. Government Accountability 2
Office. Unfortunately NRC has thus far demonstrated 3
that will only offer weak requirements and oversight 4
of a very dangerous and potentially catastrophic plan 5
for large quantities of spent nuclear fuel. We are 6
collectively very afraid. Thank you.
7 MR. CAMERON: Okay. Thank you, Barbara.
8 Very interesting about entropy. Thank you for 9
bringing that up.
10 And, Olin, can you put the next speaker 11 on, please?
12 OPERATOR: Absolutely. Michelle Lee.
13 Ms. Lee, your line is now open.
14 MS. LEE: Am I now being heard?
15 MR. CAMERON: Yes.
16 MS. LEE: Okay. Great. So I'd like to 17 just talk briefly on a personal level and then bounce 18 off some of the notes that Paul Blanch raised. And 19 I'm glad he gave me the intro there.
20 But on the personal level, I really never 21 paid attention to nuclear as an issue even after I 22 was in the Soviet Union four years after Chernobyl 23 and spoke to people there. Now that might have given 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 me pause, but I had such confidence in the American 1
regulatory system.
2 I spent my first decade professionally as 3
a litigator and did Pentagon procurement fraud cases, 4
so I have very deep understanding of the frailties of 5
human beings and what you -- is nicely called the 6
human factor. And as astonishing as it always was to 7
me that corporations would engage in deceit and fraud 8
and neglect when it came to the lives of American 9
service men and women, I still believed very much 10 that the regulatory system in this country was 11 robust.
12 I then went for an advanced degree and 13 became an investigator. After 9/11 I took a three-14 month leave of absence to work on issues relating to 15 Indian Point and never went back because; and that's 16 the only reason, because my absolute astonishment of 17 how abysmal the regulatory scheme is and frankly how 18 influenced the NRC is.
19 And when I talk about influence, I'm 20 really talking about the political appointee level, 21 but that percolates down to every single level of the 22 NRC. And it's not an issue of -- it's something we've 23 seen in many, many other areas, but the difference is 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 when you're talking about nuclear power and nuclear 1
waste, the consequences of undue influence are 2
drastic and potentially catastrophic.
3 There are I know -- I have spoken to many 4
people over the years at the NRC. There are many of 5
you who are working as hard as you can to protect the 6
public and to press against the pressure that you're 7
getting from the industry. I am going to implore you 8
to press harder. Do it internally, but press harder 9
because this whole scheme of nuclear waste 10 transportation and storage in states that are full of 11 gas pipelines and other gas/fossil infrastructure, as 12 well as how being incredibly vulnerable to wildfire, 13 heat wave, drought -- it's absolute sheer insanity.
14 Going to the second point and to build 15 upon more of what Paul said, over the years looking 16 and going -- I went very much in depth into the 17 background literature involving this Holtec site in 18 New Mexico. Much of what the NRC relies upon is 19 outdated. It's outdated standards. It's ASME 20 guidelines that were around decades ago.
21 You're not taking into consideration 22 climate reality.
You're not taking into 23 consideration particularly the climate reality in New 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Mexico and Texas with this enormous amount of extra 1
heat, the potential for dust storms, potential for 2
out-of-control wildfires, the potential for first 3
responders to not be able to mitigate an event. And 4
of course those kinds of risks are attendant all over 5
the country in the transportation scheme which is 6
variable -- a wide variety of weather events, a wide 7
variety of natural disasters and the idea that this 8
massive transportation of material that can 9
absolutely wipe out the vitality of a large region 10 overnight.
11 And again, I go back to my experience in 12 the Soviet Union after Chernobyl. The ability that 13
-- that that risk is not taken into consideration, 14 all the unknowns are not taken into consideration, 15 that future terrorists is not being taken into 16 consideration, that human error, gross human error 17 and frailty is not taken into consideration I find 18 astonishing and I again beg those of you within the 19 Agency to not allow this to happen. Do whatever you 20 can. Press -- push back. Thank you.
21 MR. CAMERON: Okay. Thank you. Thank 22 you, Michelle. Thank you for that encouragement.
23 And, Olin, can we go to the next speaker, 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 please?
1 OPERATOR: Absolutely. We have Jan 2
Boudart.
3 The line is now open.
4 MR. CAMERON: Oh, good.
5 MS. BOUDART: Hi.
6 MR. CAMERON: Welcome back, Jan. Welcome 7
back.
8 MS. BOUDART: Thank you. I don't know 9
where I dropped out. I very enthusiastically gave my 10 report and then realized that I was no longer being 11 heard. And is there any possibility that the person 12 who is doing the recording could let me know where I 13 dropped out?
14 MS. CAVERLY: Can we do it from the start 15 again?
16 MR. CAMERON: Well, you know what, in 17 order to have some context here, you didn't -- you 18 weren't on very long when you dropped off, so, Jan, 19 would you mind just go from the start and take your 20 time and then we'll get the whole coherent piece in.
21 Okay?
22 MS. BOUDART: Okay. So I'm trying to 23 reconstruct it. I was making a comment on Section 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 3.12.3, the radiation protection standards in the 1
IES. And I jumped -- I had something to quote from 2
that part of the IES, but I was afraid it would take 3
me too long if I tried to quote everything. So I 4
jumped to line 14 on page 3-97, Exposures to Radiation 5
Present an Additional Risk of Cancer or a Severe 6
Hereditary Effect. And I added -- that is a quote.
7 And my own part is or heart, lung, kidney, stomach, 8
intestine, cataract, arthritis, hearing loss, nerve 9
damage, capillary damage, et cetera. The failure to 10 acknowledge other than cancer diseases is a major 11 omission from this section.
12 And then on line 15 of the same page, I'm 13 quoting, the annual dose limit of the International 14 Atomic Energy Agency as well as the NRC set to protect 15 members of the public from the harmful effects of 16 radiation is one millisievert, which is 100 millirem, 17 period. The additional risk of fatal cancer 18 associated with a dose of one millisievert calculated 19 using the scientific methods of the International 20 Commission on Radiological Protection.
21 And I interrupted that sentence with my 22 own response, which is this is the biggest testimony 23 that we should stop making rad waste and this project 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 is designed to justify our not ceasing to produce 1
spent fuel.
2 My response to Mr. Edlow, because that 3
was -- I missed Paul's -- most of Paul's, which I'm 4
very sorry about, but I'll pick it up in the 5
transcript. I had a response to Edlow and Wheeler 6
today. More information on the ICRP protection 7
analysis should be given. The ICRP from 2007 is 8
referenced, but I looked up the ICRP from 2000 and 9
found much material including what I was looking for, 10 but a major omission of internal dose.
11 Internal dose is a problem rarely treated 12 and much more serious consideration than external 13 dose. Internal dose is measured by monitoring the 14 body itself and is often given in a different unit, 15 the becquerel per kilogram body weight, a reference 16 to other diseases and references to non-reference man 17 individuals like fetuses and pregnant women. And I 18 got this from the ICRP, quote, reference animals and 19 plants.
20 So they don't mention reference man, but 21 there was this quotation on page 56: Quote, the 22 strongest statistical evidence for the induction of 23 these non-cancer effects at affected doses of the 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 order of one sievert derived from the most recent 1
mortality analysis of the Japanese atomic bomb 2
survivors followed after 1968. And there's a 3
reference.
That study has strengthened the 4
statistical evidence for an association with dose 5
particularly for heart disease, stroke, digestive 6
disorders and respiratory disease.
7 A few lines later we get this: Quote, it 8
is also unclear what forms of cellular and tissue 9
mechanisms might underlie such a diverse set of non-10 cancer disorders. While recognizing the potential 11 importance of the observation of non-cancer diseases, 12 the Commission; and I guess that's the ICRP, judges 13 that the data available do not allow for their 14 inclusion in the estimation of detriment following 15 low-radiation doses less than about 100 16 millisieverts.
17 A millisievert is one one-thousandth of 18 a sievert, and 100 of those is one-tenth of a sievert.
19 This agrees with the conclusion of UNSCEAR of 2008 20 which found little evidence of any excess risk below 21 one gray. End of quote.
22 Okay. Do you want to look up their new 23 unit and try to visualize the relationship between a 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 gray and a sievert, a millirem or a millisievert? My 1
point -- I've done this. I've tried to figure this 2
out and it is really an imbroglio to try to go into 3
these units and decide what the heck they're talking 4
about.
5 My point, the nature of the EIS is so dry 6
it is devoid of real caring about the subject who 7
will be given low-dose, long-lasting radiation. I 8
feel this way about Mr. Edlow of Edlow Nuclear 9
Transportation Services' testimony from August 26th.
10 He emphasized the success of his company, the lack of 11 accidents and the NRC has adequately -- and said the 12 NRC has adequately addressed the transportation 13 issue. There was no acknowledgement of the effects 14 of low-level, long-term radiation.
15 In addition, I got the impression that 16 Edlow Nuclear Transportation Services is self-17 regulating. This seems to have worked okay, which is 18 certainly a wildly improbable exception, so he 19 deserves to be congratulated with self-regulation of 20 commercial enterprises through Boeing, Energy Harbor 21 in Ohio, Exelon in Illinois or any nuclear utility.
22 Even Mr.
Edlow's company with its wonderful 23 reputation will change hands at some point with 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 unknown results for self-regulation.
1 So my basic point -- well, let's see.
2 The ICRP 2000 applying a linear no-threshold dose 3
response assumption is on the order of one in 20,000.
4 Oh, here's what I wanted to day. This 5
-- they say that one in 20,000 people will get a 6
cancer, and 500 of those will get a fatal cancer.
7 Now I'm assuming that they're talking 8
about reference man. If you take this reference man 9
at that time and place and you take 10 -- you take 10 little boys at the same time and place, for every two 11 reference man who gets a cancer, five of those little 12 boys will get a cancer. I had this wrong the last 13 time I testified, and I do apologize. I had doubled 14 it.
15 But for two reference men getting a 16 cancer five little boys will get a cancer. And for 17 two reference men getting a cancer 10 little girls 18 will get a cancer. Nobody knows the number of 19 stillbirths or fetuses born with hereditary problems 20 or just problems in their own little bodies. These 21 things are not really measurable, but we know they 22 are a lot. So this small increase in lifetime risk 23 can be compared to the baseline lifetime risk of one 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in three for anyone developing cancer and one in five 1
for anyone developing a fatal cancer.
2 Okay. Let's see. I think that's about 3
all I have to say about the inadequacy of Section 4
3.12.3. And of course my basic point, and I think 5
everybody who is looking at this understands we have 6
to stop making high-level radioactive waste. We have 7
to stop making spent fuel because the interim storage 8
facility in New Mexico is a method where we can get 9
it out of sight and continue making it. We need a 10 different solution that includes the end of the 11 production of spent fuel.
12 Are you still hearing me?
13 MR. CAMERON: Yes, Jan. And I just want 14 to thank you for all of that very complicated 15
-- explaining what seems very complicated. But thank 16 you for coming back on and talking to us. And we're 17 going to go --
18 MS. BOUDART: Before I go I want to thank 19 you for letting me back on. I just didn't -- I did 20 this whole thing and then I realized nobody could 21 hear me. So anyway, I'm very glad that you let me do 22 it. Thank you.
23 MR. CAMERON: Thank you.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Olin?
1 OPERATOR: Our next caller is going to be 2
Ed Hughes.
3 MR. HUGHES: Hello? Can you hear me?
4 MR. CAMERON: Yes.
5 MR. HUGHES: Good morning. Well, it's 6
still morning here. I guess it's afternoon there.
7 I want to -- I have spoken at each one of 8
these -- this is the fourth of a series of -- I've 9
made comments, different comments at each one. I 10 have -- I want to make a comment basically addressed 11
-- that has been addressed by the New Mexico 12 Environmental Department. I'm quoting a letter, 13 parts of a letter, May 18th, 2020. This is actually 14 through the National Nuclear Security Administration.
15 It's not the Nuclear Regulatory Commission. But it's 16 from James Kenney, Cabinet Secretary of the New 17 Mexico Environmental Department.
18 But parts of this letter, it's talking 19 about the Environmental Impact Statement for a 20 statement of pit production. That's not this topic 21 of today, but this letter very much addresses the 22 Environmental Impact Statement there and I know the 23 Environmental Department made some of the same 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 comments concerning the EIS we're speaking about 1
today.
2 First of all I would like to say I just 3
wholeheartedly support the comments that have been 4
made thus far concerning opposition and problems with 5
the EIS. These are issues that have been discussed 6
among many of us to various degrees and I really 7
appreciate those who have come on and very adroitly 8
addressed these things thus -- so far today.
9 As far as the transportation issue which 10 is supposedly out of scope by the slides that were 11 shown this -- earlier, that's very much part of this 12 environment -- possible impacts and I -- there's 13 nothing in the scope that is being proposed by Holtec 14 that's ever been done about any nuclear materials. I 15 heard the -- everything else has been much, much 16 smaller, a much smaller scale. This is just orders 17 or magnitude.
18 But I want to go to this letter from the 19 Environmental Department, point 4. If there's given 20 a disproportionate burden of public health and 21 environmental risk that the State of New Mexico bears 22 related to nuclear energy and weapons programs. This 23 is being addressed -- this is somewhat historical, 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 but it very much pertains to what we're talking about.
1 Goes onto say: Uranium mining and 2
- milling, legacy contamination at national 3
laboratories, disposal of Defense waste at WIPP and 4
the proposed indefinite storage of commercial spent 5
nuclear fuel has long created risks to public health 6
and the environment in the State of New Mexico that 7
are disproportionate greater than such risks to the 8
general population of the United States. And I think 9
that this proposal just magnifies the risk that is 10 being put upon the state.
11 Part of this, there was -- in the slides 12 that were shown it was shown that the -- as far as 13 socioeconomics that there was low risk, all that sort 14 of -- stating that it's low doesn't make it so, but 15 health risks are part of that. And part of that has 16 to do with the demographic data.
17 I want to -- in the United States 18 Hispanic or Latino populations average about 18 19 percent; in New Mexico, 49 percent. American Indian 20 in the United States about 1.3 percent; in New Mexico, 21 10.9 percent. Persons in poverty 11.8 percent; New 22 Mexico 19.5 percent, almost 20 percent. There is a 23 process that goes on that's called pollution shopping 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and it has to do with agencies or people who have 1
high polluting industries or products such as 2
-- nuclear waste is probably the most deadly -- and 3
go to areas that are high demographics and 4
populations such as Latino or Indian or persons in 5
poverty. They think they're more vulnerable, which 6
in fact they are, to these kinds of things. And 7
that's part of what's going on here in Southeastern 8
9 And I want to go on -- talk about draft 10
-- the letter goes on to talk about failure to 11 demonstrate that the proposed action will achieve 12 environmental justice for the high percentage of 13 minority and low-income populations in the State of 14 New Mexico.
They've already suffered 15 disproportionately high adverse human health and 16 environmental effects of the U.S. Department of 17 Energy programs.
18 Environmental justice deficiencies in 19 the Draft EIS. And this pertains to this EIS as well.
20 Failure to identify and evaluate the cumulative 21 history of adverse human health and environmental 22 effects on New Mexico's vulnerable populations.
23 And with that I want to go all the way 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 back to the Trinity site. It was -- it has been 1
documented that after the Trinity test in New Mexico 2
that death in the womb and infant mortality had a 3
very significant increase for the following year or 4
two. And that's not even talking about the impacts 5
of mining and all of the other things that have been 6
going on in New Mexico since that time.
7 There's also a failure to evaluate 8
release scenarios from the proposed action such as 9
transportation or storage that might adversely affect 10 vulnerable populations in New Mexico. Just from the 11 fact that this Environmental Impact Statement only 12 evaluated, quote, normal operation, which had no 13
-- nothing about cask failure or transportation 14 issues or human error, as has been so very well 15 brought up, makes this a laughable document in my 16 opinion.
17 To go on, there's also repeated yet 18 unsubstantiated assertions that cumulative 19 environmental impacts from the proposed action would 20 be either not notable or not expected. Saying that 21 that is the case does not make it true. And I think 22 that has already been pointed up today as well as in 23 earlier times that this action is ludicrous. This 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
-- what is being proposed is ludicrous.
1 I recently retired after 40-plus years in 2
the Federal Government and I know from my experience 3
that bureaucracies as such have no conscience. And 4
it's been stated at the very beginning of this that 5
there's already been -- the comment period has 6
already been extended once or twice or three times, 7
which clearly shows that this is purely 8
administrative. It can be extended again. It can be 9
put off until this 10
-- and to say that the COVID thing we're under right 11 now just kind of overrides any other consideration, 12 it's going to be very short is ludicrous.
13 Administratively you certainly -- the 14 Nuclear Regulatory Commission certainly has the 15 authority and the power to extend this comment period 16 as far as needed until we're past this crisis, until 17 we can have the in-person meetings, until we can do 18 the things that are -- that have been earlier agreed 19 to by NRC and have since been set aside.
20 So again I speak in opposition to what's 21 happening. This -- we have been pulled into this 22 game and it seems that it was stacked against us in 23 a very real way, those that oppose this.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I just want to say too that it's been 1
mentioned -- I've been to not only the scoping hearing 2
a couple years ago, but been listening in on these 3
current hearings as well. I've talked about the 4
-- just the thing that New Mexico needs to do this 5
just out of supporting and out of just being a good 6
state.
You know, we have paid our dues 7
in New Mexico. We have -- as has been stated by this 8
letter from the Environmental Impact Department, New 9
Mexicans; and I'm a third generation New Mexican and 10 my wife and I were both born and raised in New Mexico 11
-- we have paid our dues, more so, disproportionately 12 high than the rest of the country. So I think the 13 idea that the rest of the country, every other state 14 is adamant in getting rid of this waste, why in world 15 should we take the risk?
16 And how do you justify New Mexicans 17 taking the risk of all of this coming to New Mexico 18 on a, quote, interim storage, which Rick Perry when 19 he was Secretary of Energy said it's quite likely 20 going to be permanent storage, not built to the 21 specifications of Yucca Mountain, but an at-surface 22 interim storage, who is actual -- according to 23 Holtec's guarantee the casks themselves are only 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 guaranteed for 25 years, and yet we're licensing for 1
40 and has -- we could go on and on, but this whole 2
process is extremely, extremely immoral in my 3
opinion.
4 And while bureaucrat -- the bureaucracy 5
doesn't have a conscience, I'm assuming as has been 6
spoken earlier by Jan, that many of you within the 7
NRC very much do. Push back. This needs to be 8
stopped by A real Environmental Impact Statement that 9
takes in all of the risks including that of failure 10 of many kinds needs to be analyzed. Thank you.
11 MR. CAMERON: Okay. Thank you very much, 12 Ed. And I hope you can submit that letter that you 13 mentioned from the New Mexico Environmental 14 Department to the NRC as part of --
15 MR. HUGHES: I'd be glad --
16 MR. CAMERON: -- your comments. Okay.
17 Thank you.
18 Olin, who do we have next?
19 OPERATOR: Next caller is Kevin Kamps.
20 Mr. Camps, your line is open.
21 MR. KAMPS: Thank you. Can you hear me?
22 MR. CAMERON: Yes, we can.
23 MR. KAMPS: Thanks. This is Kevin Camps, 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 radioactive waste specialist at Beyond Nuclear and 1
Board of Directors member with Don't Waste Michigan, 2
and I am commenting on something that took place in 3
the last of these public comment webinar call-in 4
sessions. It was on August 26th, 2020. A commenter 5
named Nick Maxwell of We the Fourth in Hobbs, New 6
Mexico, who is a long-time Holtec CISF opponent, and 7
ELEA watchdog, raised an allegation of bribery 8
associated with this scheme, bribery and kickback.
9 Before allowing Nick Maxwell a second 10 opportunity to submit verbal public comments towards 11 the very end of the hours-long session, NRC meeting 12 facilitator Chip Cameron warned Maxwell that he and 13 presumably the rest of the assembled NRC staff did 14 not want to hear any more about bribery allegations.
15 As a Federal Government official Chip 16 Cameron had no right to censor Nick Maxwell's free 17 speech. This not only violated Nick Maxwell's First 18 Amendment free speech rights, but it also violated 19 Nick's rights under the National Environmental Policy 20 Act to submit any public comments regarding the 21 Holtec ELEA CISF scheme that he chose to make.
22 After all, Nick Maxwell's allegations of 23 bribery are bolstered by dozens of articles in the 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 media over the past couple years. And of course it 1
goes without saying the NRC's flippant lack of 2
concern about Holtec's and allegedly also ELEA's 3
penchant for engaging in bribery and kickback schemes 4
is shocking and outrageous.
5 After all, how can NRC fulfill its 6
mandate to protect public health, safety and the 7
environment when it looks the other way as its own 8
licensees engage in such serious criminal wrongdoing 9
as bribery and kickback schemes, not to mention 10 providing false information; that is, lying under 11 oath as has taken place in New Jersey by Holtec's CEO 12 Krishna Singh?
13 How can a company that behaves in this 14 way be entrusted with the storage and transportation 15 of forever-deadly, highly radioactive commercial 16 irradiated nuclear fuel and greater than Class C, so-17 called low-level radioactive waste?
18 Incredibly despite Beyond Nuclear's and 19 Mining Awareness' raising of these issues of Holtec's 20 penchant for engaging in bribery and kickback schemes 21 in their July 2018 public comments during NRC's 22 environmental scoping phase regarding this CISF, and 23 despite the extensive media coverage from 2019 to 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 2020, the words bribe and bribery do not even appear 1
in the 488-page NRC Holtec CISF Draft EIS published 2
by NRC in March 2020, but again the Agency is behaving 3
as if the bribery conviction in which Holtec was 4
involved and additional allegations of Holtec 5
attempting bribery and kickback schemes simply never 6
took place.
7 And so to clarify for the record what I'm 8
referring to, back in 2018 during environmental 9
scoping myself as well as Mining Awareness documented 10 a conviction for bribery in Alabama at the Tennessee 11 Valley Authority's Browns Ferry Nuclear Power Plant 12 in which Holtec's CEO Krishna Singh was implicated.
13 And then as I mentioned when Krishna Singh then 14 applied for a $260 million tax break in New Jersey, 15 the money used to build Holtec's current headquarters 16 for fabrication of the very containers that would be 17 used in this particular scheme, that has all been 18 well-documented by major media coverage.
19 Despite raising these allegations the 20 U.S. Nuclear Regulatory Commission then delivered an 21 early Christmas present to Holtec International on 22 December 20th of 2018. NRC decided that, quote, NRC 23 regulations do not specifically address bribery, end 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 quote. The shocking statement came after an NRC 1
official investigation that lasted nearly five 2
months, and the closure letter was barely a page long.
3 Are concerned citizens and watchdog 4
groups like ours supposed to activate the U.S.
5 Department of Justice to investigate these bribery 6
allegations since NRC has flippantly washed its hands 7
of the matter? NRC has done this despite Holtec's 8
involvement in a bribery scheme that led to a 9
conviction. NRC is behaving like that bribery 10 conviction never took place.
11 Specifically Holtec's CEO Krishna Singh 12 attempted to bribe industry -- in addition Holtec's 13 CEO Krishna Singh also attempted to bribe industry 14 whistleblower Oscar Shirani of Commonwealth Edison, 15 Exelon, as well as NRC's own dry cask storage 16 inspector Dr. Ross Landsman into silence regarding 17 widespread serious quality assurance violations in 18 the design and fabrication of Holtec containers for 19 high-level radioactive waste storage and transport 20 used extensively throughout the U.S. power industry, 21 nuclear power industry.
22 So in the Alabama affair Holtec was 23 eventually fined $2 million and received a 60-day 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 disbarment for doing business with the Tennessee 1
Valley Authority, and that disbarment was the very 2
subject matter of the Krishna Singh then lied about 3
under oath when he applied for that massive New Jersey 4
tax break.
5 And so I will be submitting for this 6
record the 20 news articles that document all this.
7 And what it boils down to is that NRC in its own 8
regulations has corporate character and corporate 9
integrity regulations that would also apply not only 10 to Holtec International, but to its CEO Krishna 11 Singh. And it is my conclusion that NRC is 12 essentially waiving these regulation requirements in 13 allowing this applicant to get this far in this 14 proceeding. Thank you.
15 MR. CAMERON: Okay. Thank you, Kevin. I 16 think the facts will show that I gave Mr. Maxwell six 17 minutes of uninterrupted time to talk about bribery, 18 racketeering and whatever, and because we had extra 19 time I allowed people to come back on again. And all 20 I was saying to Mr. Maxwell was we've heard enough 21 about racketeering and bribery. Do you have anything 22 else? And that is on the transcript.
23 And, Olin, who's next?
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. KAMPS: I disagree with your analysis 1
there, Chip.
2 OPERATOR: We have Becky Halpin.
3 Ms. Halpin, your line is open.
4 MS. HALPIN: Thank you. Can you hear me?
5 MR. CAMERON: Yes.
6 MS. HALPIN: Great. Hello and good 7
morning. I'm Becky Halpin and I would certainly hope 8
that people would be able to talk as much as they 9
want to about any topic including bribery. Thank 10 you.
11 I also protest the unjust format of this 12 meeting requiring access to the Internet and phone 13 connection at the same time. This requirement makes 14 it impossible for many people who might want to 15 participate to be heard. Voices are being silenced.
16 I would also like to note that robust 17 virtual meeting platforms are widely available and 18 used all around the world. If the NRC cannot figure 19 out how to acquire and use a platform that would give 20 video access to the Commissioners without stressing 21 their server makes me wonder how they are equipped to 22 manage this highly technical review process. And I 23 think that's a very fair observation in today's day 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and the way that we all handle business today. It's 1
an easy thing to do.
2 True and appropriate public hearings need 3
to be held in person when the COVID crisis is passed.
4 It constitutes abuse of regulatory power to certify 5
something as safe that is obviously and blatantly 6
extremely dangerous. The risk to population centers 7
all across the nation as this highly radioactive 8
material is transported in these five-eighth-inch 9
thick flimsy containers is astronomical should any 10 accident or incident occur.
11 There is likely a 100 percent probability 12 that an accident or incident will occur that spills 13 this radioactivity into a community over the many 14 years and thousands of trips these dangerous 15 materials will make through our cities. Given the 16 inadequate state of our rail lines to transport these 17 overweight railcars carrying this radioactive 18 material and the large number of rail accidents we 19 currently see every year, we have a clear recipe for 20 radiologic disaster.
21 The world is awash in weapons of war such 22 as shoulder-fired rockets that could easily pierce or 23 explode these transportation containers. There is a 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 large and very active black market for shoulder-fired 1
rockets. Additionally ammunition from legally-2 acquired rifles and weapons could pierce these 3
containers.
4 It is irresponsible not to assume from 5
the get-go from the very outset that these 6
transportation containers would become every 7
terrorist's dream. These containers, these canisters 8
on railcars would be especially inviting terrorist 9
targets when the canister is moving through or parked 10 in urban population centers, in a port, next to a 11 military installation or close to critical 12 infrastructure of any sort.
Radioactive 13 contamination of an entire city is not just possible, 14 but probable under the naive and dismissive planning 15 put forth in this application.
Saying that 16 something is safe in no way renders it so.
17 Transportation of this material across the country in 18 these thin inadequate and easily identifiable 19 canisters is an offering to the gods of chaos. This 20 deadly radioactive material should stay where it has 21 been generated until there is a plan to entomb it in 22 an appropriate facility for the millennium that it 23 will be radioactive. We should not be dragging it 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 across our nation endangering millions of people in 1
the process until we have a final solution.
2 Dumping this dangerous waste in the 3
desert in containers that will deteriorate and leak 4
radiation with no effective plan other than in 25 or 5
40 years or so we'll think of something is a testament 6
to how desperately nuclear plant operators want to 7
just get rid of this stuff regardless of the fact 8
that there is no safe place to put it. There is no 9
plan to park this waste anywhere but here in the 10 desert in New Mexico and across state lines in Texas.
11 This permit is not really for temporary 12 storage and should be denied. Thank you very much.
13 MR. CAMERON: Okay. Thank you, Becky.
14 Olin, can we go to the next person?
15 OPERATOR: We have Patricia Marida.
16 I apologize if I mispronounced the name, but, 17 Patricia, your line is open.
18 MS. MARIDA: Hi. Can you hear me?
19 MR. CAMERON: Yes, we can hear you, 20 Patricia. And we did get your last name correct, 21 Margarita?
22 MS. MARIDA: I say Marida.
23 MR. CAMERON: Okay.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MS. MARIDA: I'm for Columbus, Ohio, and 1
I just want to say that I'm submitting the comments 2
under protest because we can't verify that the NRC 3
decision makers are receiving them. And I want to 4
say that you need to include New Mexico's 5
congressional delegation or staff so that they can 6
verify the validity of the hearing format. And the 7
comment period should be extended until after the 8
COVID emergency has ended and it's safe to have mass 9
gatherings, and then they should be conducted in 10 person in several locations in New Mexico like it was 11 originally promised by the Nuclear Regulatory 12 Commission. And then I want to say that there's no 13 compelling reason for these meetings to be rushed.
14 And they -- this waste needs to stay 15 where it is and be stored much more safely right now 16 where it is. Moving it is just all kinds of problems 17 and trouble. It's insanity warmed over. The idea of 18 an interim and centralized is unnecessary and 19 dangerous. So either the waste must be moved again 20 or it is a permanent site. So those aren't viable 21 choices.
Moving the waste for no reason 22 with the inevitable accidents would take decades and 23 overload 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
-- of course you've heard enough -- I think should 1
have heard a lot about the nation's D-plus rated 2
infrastructure, rated in 2017 by the American Society 3
of Civil Engineers. And I think it's gone downhill 4
since then. And it's been stated by numerous 5
authorities that it's absolutely unsatisfactory, the 6
-- our nation's infrastructure system. So mostly 7
-- it was mostly below standard.
8 And then I just want to add in conclusion 9
that the influence of the industry and of Holtec's 10
-- and the money that they are making and the money 11 they are willing to spread around in order to 12 influence decision making is very concerning to me.
13 So that's 14
-- I wanted to conclude my statement by saying that.
15 MR. CAMERON: Okay. Thank you for 16 joining us, Patricia, for those comments.
17 Olin, who is next?
18 OPERATOR: We have Lon Bonald.
19 Mr. Bonald, your line is open.
20 MR. BURNAM: Can you hear me?
21 MR. CAMERON: Yes, we can, Lon.
22 MR. BURNAM: Okay. Just for the record 23 the name is Lon Burnam, B-U-R-N-A-M, and I am 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 participating today, Chip, under protest. I finally 1
buckled down and recognized that I had an ethical and 2
moral responsibility to represent the Lone Star 3
Chapter of the Sierra Club in these fraudulent 4
proceedings, but you know, we've been around the horn 5
enough to know that in the first place it's not even 6
a legal request.
7 In the second place to be dismissive of 8
the fact that they are under any number of areas of 9
scrutiny because of their illegal activities and to 10 be dismissive of this concern is just absurd to me.
11 And then in third place to artificially 12 bifurcate this project and pretend that it doesn't 13 have a negative impact on Texas is simply the most 14 egregious attack on the whole Environmental Impact 15 Statement I've seen in a long time.
16 And, Chip, as you well know I was in the 17 Texas legislature for 18 years, so I saw a lot of 18 egregious attacks on process and I saw a lot of 19 agencies that -- performing and behaving as if they 20 were captains of the industry. And of course I've 21 long ago begun to assume that that's the case with 22 the NRC.
23 But on a point of process I want to point 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 out not that I'm authorized to speak on behalf of the 1
League of Women Voters, but this whole fast-track 2
streamlined inappropriate approach to citizen 3
participation is an insult to the democratic 4
processes that this country has come to expect. And 5
from the Sierra Club's standpoint this division of 6
environmental concerns should and will be challenged 7
in the courts. I agree with every previous speaker 8
and their comments that they had to be -- had to make, 9
but on behalf of the Lone Star Chapter of the Sierra 10 Club, frankly, I spent enough time wasting my breath 11 with you guys. I'll submit my letter in writing.
12 MR. CAMERON: Okay. Good, Lon. We'll 13 look forward to that writing and it's nice to see 14 that you're still on the job, too. So thank you.
15 Olin, do we have another speaker?
16 OPERATOR: We do. Patty Hughes, your 17 line is now open.
18 MS. HUGHES: Thank you. Can you hear me?
19 Hello?
20 MR. CAMERON: Yes.
21 MS. HUGHES: Okay.
22 MR. CAMERON: Yes, we can hear you.
23 MS. HUGHES: First of all, I'm making my 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 comments under protest for the reasons that you've 1
been hearing.
2 One of your officials said at the 3
beginning of the meeting that the NRC had a commitment 4
to openness, and I just want to make the observation 5
if you had input from a state's national delegation 6
and person after person giving you reasons why in New 7
Mexico webinars are not adequate. This process is 8
not open, so your commitment to openness is at best 9
inadequate.
10 At the first webinar that we've had in 11 these last two weeks an NRC official signaled that 12 despite the protest about the webinars that you would 13 not be impacted by our concerns and announced at the 14 end of that meeting that you would proceed with the 15 webinars. So I think at that point we saw the writing 16 on the wall and saw it as disrespectful.
17 I have a question: How is it that this 18 facility is called interim when as other speakers 19 have said, even the Secretary of Energy says that 20 it's not?
21 You say that -- to another point you say 22 that you will ensure that the Holtec facility will be 23 built and operated safely, but you are ignoring data 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 from a New Mexico Environment Department that you 1
called earlier a cooperating agency. That is in exact 2
conflict with your assertions that you made in the 3
EIS concerning the existence of standing water and 4
groundwater at the Holtec site.
5 My question is -- well, actually a state 6
official told me that your own data shows that there 7
is shallow groundwater at this site. Do New Mexico 8
citizens have to wait for an accident or our 9
Environment Department to be proved right?
10 Next you assert that the socioeconomic 11 impact is small to moderate, and it's moderate due to 12 positive impact on the economy. Again, information 13 that you have gotten -- the expert on the New Mexico 14 economy is our governor. I would ask you to read her 15 letter which doesn't agree with you that is again in 16 exact conflict with the statement that you made. So 17 our governor doesn't agree that the socioeconomic 18 impacts of this would be small to moderate. Neither 19 would the governors of South Carolina, Illinois or 20 any other state agree that the impacts would be small 21 to moderate. It's not that impacts are small. It's 22 because in your eyes New Mexico and its citizens are 23 small. And you are the ones who have made that clear.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Lastly, does the NRC have any internal 1
checks for -- or standards for when they have so 2
disproportionately burdened a state with the nation's 3
nuclear waste that they have broken it?
4 And in my opinion, my husband and I went 5
through an ordeal three years ago where the DOE tried 6
to drill a bore hole on a ranch adjoining our ranch.
7 We saw our property values go to zero. We saw the 8
banks react. We saw families who had been there for 9
five and six generations see that if that happened 10 that they would have to pull up stakes and go 11 somewhere else. Our experience was that storing 12 high-level nuclear waste was not economic 13 development. It was economic replacement of a 14 sustained economy with the most polluting economy on 15 the face of the earth.
Unfortunately Eddy-Lea 16 Alliance has purported to speak for New Mexico when 17 they sent -- telling the world that New Mexico wants 18 its waste. Obviously that isn't true.
19 An earlier caller asked why move the 20 waste? The answer to that is that there's national 21 pressure to get it out of other states. And a DOE 22 contractor told us on the bore hole project in a 23 public meeting in Clovis, New Mexico, that New Mexico 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 has a target on its back that has been perpetuated by 1
the Department of Energy, by the NRC and by private 2
companies that think that we're a viable site for 3
-- to be eternally polluted.
4 I would urge you rather than -- this is 5
the fourth time I've seen this slide presentation.
6 At least two of your slides are in direct conflict 7
with statements that you have received from the State 8
of New Mexico. I would ask you to consider that most 9
expert testimony -- and when you describe the impacts 10 to us, you describe them in a truthful manner. Thank 11 you.
12 MR. CAMERON: Okay. Thank you, Patty.
13 And, Olin, we're going to go to the next 14 speaker.
15 OPERATOR: Michael Keegan.
16 Michael, your line is now open.
17 MR. KEEGAN: Thank you. Can you hear me?
18 MR. CAMERON: Yes, we can hear you, 19 Michael.
20 MR. KEEGAN: Thank you. I'd like to 21 discuss the pedigree of the environmental report and 22 the DEIS, and ultimately the final EIS.
23 We go back to the GNEP program and the 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 work done there in the 2007-2008 era, being done by 1
Tetra Tech, the parent company, who's been heavily 2
implicated in fraudulent schemes and falsification of 3
documentation at Hunters Point and Treasure Island.
4 A 2.206 petition was brought forward and a multitude 5
of documents were placed into the record showing from 6
top to bottom Tetra Tech falsification criminality, 7
people-went-to-prison-kind of situation. And yet 8
there the parent company has a spinoff which 9
developed the GNEP environmental review report, so on 10 and so forth. And so here comes Holtec a decade later 11 and picks up and utilizes those GNEP reports and 12 employs them in their environmental review.
13 So the pedigree of the environmental 14 review, environmental report, the DEIS and the EIS I 15 call into question because criminality was involved 16 way back when. And so I -- it speaks of collusion 17 and racketeering between agency and a proposal 18 proponent, Holtec. So really an investigation needs 19 to be done there.
20 I'm in the Detroit area and I'm very much 21 concerned about transportation. And there have been 22 no public hearings, no public education put forth on 23 this and yet we would be very much impacted because 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 we're on the roads.
1 As I review the record I see these 2
multiple amendments, modifications being made to the 3
casks that are going to be used. Everything is very 4
fragile in that when it comes to the crucial 5
information needed it's withheld. All these pieces 6
are supposed to fit together. What I believe is 7
needed is a
programmatic Environmental Impact 8
Statement process because there are -- so many moving 9
pieces that go into place are initiated by the Holtec 10 proposal. And so do not do it piecemeal. We need to 11 know from top to bottom in every which way so a 12 programmatic Environmental Impact Statement is called 13 for.
14 I have concerns about foreign nuclear 15 waste coming into the U.S. A hundred and seventy-16 three megatons -- hundred and seventy-three thousand; 17 I'm sorry, metric tons are designated for Holtec. Is 18 there going to be foreign nuclear waste coming in?
19 Is Canadian nuclear waste going to be coming in? Why 20 is the NRC reviewing Canadian cask systems? Why is 21 that of our interest? Why is the DOE And the NRC 22 engaged in mock exercises that come from Europe of 23 freighter, barge, how have you, rail to mid-section 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Denver area and call that a successful mock operation 1
of transfer of spent nuclear fuel?
2 I have concerns about foreign ownership.
3 I have concerns about disclosure of a private company 4
at -- LLCs at every level. We don't know. You're 5
dealing with what I believe to be a criminal operation 6
and you are aiding and abetting the situation. That 7
would be a racketeering. So please put the brakes on 8
this.
9 Reflecting on the gentleman's comments on 10 a moral obligation to speak out, I certainly feel a 11 moral obligation to speak out and I want public 12 hearings in Detroit area, in Chicago area, in New 13 York area. Everyone's going to be impacted. So 14 please bring us into the conversation. Thank you.
15 I'm with Don't Waste Michigan. Michael Keegan.
16 MR. CAMERON: Okay. Thank you and thank 17 Don't Waste Michigan. Thank you, Michael.
18 And, Olin, can we go to the next speaker, 19 please?
20 OPERATOR: Absolutely. We have Bruce 21 Montgomery.
22 Mr. Montgomery, your line is now open.
23 MR. MONTGOMERY: Yes, thank you, Oland.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I appreciate the opportunity to speak.
1 My name is Bruce Montgomery. I am the 2
Director of the Used Fuel and Decommissioning of the 3
Nuclear Energy Institute and we represent over 300 4
members, companies, universities, laboratories both 5
in the U.S. and abroad involved in the nuclear 6
enterprise.
7 My personal experience is over 40 years 8
in the nuclear industry. I've been the chief engineer 9
at a couple of different nuclear power plants that 10 have been operating in excess of 40 years, providing 11 electricity to their communities.
12 Now I've heard a lot of discussion around 13 rushed discussions or meetings, or public review for 14 the Draft EIS. I don't think there's anything that's 15 rushed about this. The opportunities have been 16 extended at least a couple of times. I believe that 17 the number of webinars offered the public an 18 opportunity to comment on this has been probably more 19 than I've ever seen before for similar activities.
20 I would like to speak in support of the 21 NRC in issuing this EIS in final form. We speak in 22 favor of the consolidated interim storage that Holtec 23 is requesting a license for. We think that this is 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 an eloquent and proper solution for commercial 1
interim storage of used fuel.
2 My personal experience includes 3
independent spent fuel storage facility installation, 4
design, construction and operation at a couple of 5
different nuclear power plants. The one I'm most 6
familiar with is the one that's located in Maryland 7
on the Calvert Cliffs site. It's been operating for 8
over 26 years. It's a very innocuous thing to look 9
at it. It incorporates the same types of designs 10 that we'll be seeing -- as we have seen across the 11 country including the one that's proposed for the 12 Holtec site in New Mexico.
13 But I think that today's discussion of 14 the three webinars that I have participated has been 15 a most fulsome discussion of the things that are 16 directly relevant to the environmental effects that 17 interim storage would pose to the folks and the 18 environment around the proposed site in New Mexico.
19 I'm especially encouraged that folks are paying 20 attention, that there have been some good discussions 21 around the socioeconomic impacts of the site.
22 I think those reports that have been 23 mentioned during the course of these discussions 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 submitted to the NRC will be taken into consideration 1
adequately by the NRC reviewers.
2 I think that with regard to the safety 3
discussions that have been held today -- I think 4
those, although they're out of scope for today's 5
discussion, I believe they'll be more than adequately 6
discussed as part of the Safety Evaluation Report 7
that the NRC is working on as we speak for the CIS 8
site in New Mexico.
9 But even though they're out of scope I 10 think there's a couple of things I'd like to point 11 out. I think with particular regard to the comments 12 made by Mr. Paul Blanch, he mentioned that, yes, these 13 are one-half to five-inch thick stainless steel 14 canisters that are welded, that they're under 100 15
-- up to 100 pounds pressure of helium internal to 16 the canisters. While that's all true, Paul then 17 conflated potential for degradation of these 18 canisters with what happened at Davis-Besse where 19 boric acid leakage from the reactor vessel basically 20 wasted away the three to six inches of carbon steel 21 on top of the reactor vessel.
22 One thing that Paul didn't point out is 23 that there was only a three-eighth-inch layer of weld 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 stainless steel that was holding up against over 1
2,000 pounds pressure for the better part of a two-2 year operating cycle.
3 So again, you have evidence that's 4
contrary to what Paul was presenting that shows that 5
these canisters are extremely robust and aren't in 6
the environment that they will be in and have been 7
and across the country really not susceptible to any 8
sort of accelerated degradation. And the comment 9
that there's a certainty of degradation is really 10
-- from an engineering perspective is just not 11 correct. These will be addressed during the Safety 12 Evaluation Report and have already been addressed by 13 the licenses that have been issued by the NRC for 14 these canisters across the country already.
15 But anyway I'd like to close by saying 16 that I believe that contrary to a lot that has been 17 said; and I know I'm kind of speaking alone today, is 18 that nuclear is the most environmentally-friendly 19 technology for the production of electricity that 20 there has ever been and may be for a long, long time.
21 I'd like to congratulate NRC's Kevin 22 Coyne's group in putting together a
very 23 comprehensive and thorough Environmental Impact 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Statement Draft Report and I expect that by the time 1
they get to the point of issuing a final report it 2
will exist in pretty much its current state, 3
hopefully enhanced by some of the comments received 4
today and in the webinars that preceded this.
5 So thank you very much for the 6
opportunity for this open discussion. I think this 7
sort of discussion is really unique to this country 8
that we live in and we should congratulate the NRC 9
and the infrastructure that we have for this kind of 10 discussion. So thank you very much.
11 MR. CAMERON: Okay. Thank you, Bruce, 12 for those comments.
13 And, Olin, who do we have next on the 14 phone to talk to us?
15 OPERATOR: We have Karen Hadden.
16 Ms. Hadden, your line is now open.
17 MS. HADDEN: Hi. Can you hear me?
18 MR. CAMERON: Yes, we can, Karen.
19 MS. HADDEN: Hi. Good afternoon.
20 And I would like to start by saying that 21 these comments today are, likewise, under protest.
22 As others have discussed, I feel like this process is 23 inadequate and undemocratic and unfair.
24
97 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I would like to say that I wholeheartedly 1
concur with comments made by Kevin Camps, Becky 2
Halpin, Pat Marida, Lon Burnam, Patty Hughes, and 3
Michael Keegan. I did not hear the speakers before 4
that. But they all did a really excellent job of 5
laying out some of the problems that we're facing 6
with this license application.
7 I'm very, very concerned with the Draft 8
Environmental Impact Statement as inadequate. It 9
fails to adequately acknowledge the risks of the 10 Holtec site and the long transportation routes 11 throughout the country.
12 And I want to read to you a statement 13 that comes straight from an NRC website about the 14 dangers of high-level radioactive waste. And it 15 says, "High-level wastes are hazardous because they 16 produce fatal radiation doses during short periods of 17 direct exposure. For example, 10 years after removal 18 from a reactor, the surface dose rate for a typical 19 spent fuel assembly exceeds 10,000 rems per hour, far 20 greater than the fatal whole body dose for humans of 21 about 500 rems received all at once. If isotopes 22 from these high-level wastes get into groundwater or 23 rivers, they may enter food chains. The dose produced 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 through this indirect exposure would be much smaller 1
than the direct exposure dose, but a much larger 2
population could be exposed." That is directly from 3
the NRC website.
4 So, we have a Draft Environmental Impact 5
Statement that comes out with conclusions of small 6
impacts on numerous categories. It's really hard to 7
take apart this DEIS and enumerate the many things 8
wrong with it. I think it's a good compilation of 9
facts, but with almost no real analysis. And it needs 10 to be done over. It's inadequate as a document. It's 11 inaccurate. It fails to address the very real dangers 12 that are involved that risk the health of the public, 13 that risk our economy, that risk the environment.
14 The whole process is illegal and it should be done 15 over when the time is right.
16 The public hearings should be held after 17 the risks of COVID are over, and this proceeding 18 should not be moving forward until it is legal to 19 develop a consolidated interim storage site. I don't 20 favor the development of any consolidated interim 21 storage site at any point in time, but, certainly, 22 right now it is illegal under the Nuclear Waste Policy 23 Act.
24
99 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Thank you very much.
1 MR. CAMERON: Okay. Thank you, Karen.
2 Thank you very much.
3 Olin, who do we have on next to talk with 4
us?
5 OPERATOR: We have Diane D'Arrigo.
6 Miss Darrigo, your line is open.
7 MS. D'ARRIGO: Hi. Thanks.
8 MR. CAMERON: D'Arrigo, Diane D'Arrigo.
9 MS. D'ARRIGO: Hi. Thanks. Diane 10 D'Arrigo, Nuclear Information and Research Service.
11 I am also testifying under protest. As 12 was stated, previous calls and other callers have, 13 other commenters have stated, the call is for in-14 person meetings after the COVID crisis is over. And 15 there is a chance that this COVID crisis will end.
16 Some people think it won't, but it will. And it's 17 just not fair and it's just not equitable to expect 18 people, the average person who could be impacted by 19 all of this, to put everything aside and go through 20 hundreds of pages of technical documents, which I 21 believe they would do after the crisis is over.
22 So, the decision that's being made here 23 by the NRC, although the claim is that it's for a 40-24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 year license, it's an irreversible decision. Whether 1
the site is actually really only temporary, which is 2
highly question, or whether it is de facto permanent, 3
the site itself is being sacrificed to the Nuclear 4
Age. And if that's what people want, then that's 5
what's going to happen. I do not believe that the 6
people in New Mexico and along the route do want that.
7 It's an irreversible decision for the 8
community, for the region, and for the whole 9
ecosystem. And yet, the NRC is assuming that, presto, 10 in 40 years there will be no more waste there. It's 11 going to take more than 40 years to get the waste 12 there.
13 And
- also, along the
- way, in the 14 Environmental Impact Statement, the assumption is 15 made that there will be no released of radioactivity, 16 and that is, again, as others have mentioned, not a 17 credible assumption.
18 I believe that within each of the 19 categories that were given below, or whatever 20 category of concern that the NRC has in the EIS, yes, 21 there are tricks in the calculations and their 22 assumptions that need to be questioned.
23 And the issue of the kind of waste, the 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 application itself does not envision taking high 1
burnup fuel. It does not envision taking damaged 2
fuel. So, if such fuel would arrive, rather than 3
managing it, because it's not licensed to manage it, 4
supposedly, that kind of material would be sent back.
5 And I don't think that that's a credible option, to 6
take damaged fuel or high burnup fuel, and then, send 7
it back to the reactors from which it came.
8 I think where it is at the reactors is of 9
major concern, and that a lot more effort needs to be 10 put into safer storage wherever it is and move it 11 away from high sea level rise areas. But it needs to 12 be managed as close as possible to where it's 13 generated and not moved back and forth across the 14 country, with the promise of getting rid of it, when, 15 in fact, it's actually being spread.
16 I believe that this application is a foot 17 in the door for actually taking high burnup fuel and 18 damaged fuel, and that there is no -- at neither of 19 the sites is there a facility envisioned to 20 recontainerize the fuel or remove it or fix 21 canisters. There's no dry or wet fuel transfer 22 facility with good shielding, so that workers could 23 actually work on the capability of the canister.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So, a major assumption that's being made 1
is that all of the containers are going to be 2
perfectly fine for the whole time that the waste 3
exists at the site. And at which stage would the NRC 4
eventually require some kind of dry transfer or wet 5
- transfer, some kind of shielded facility to 6
recontainerize and manage the fuel?
7 The containers are only licensed for 8
limited time periods, 20, 30, 40, 50 years, and as I 9
said, the facility's underlying application is only 10 for 40. So, we're able to suspend this belief to do 11 this application, be very focused and narrow and not 12 face the reality; that's the opposition and the 13 concern that we in the general public have, is that 14 there are some very unrealistic assumptions in the 15 Environmental Impact Statement. And we would like 16 additional time, so that we can help the NRC identify 17 these and improve this document and this analysis, 18 and perhaps come to a conclusion that there's a better 19 alternative all the way around.
20 So, that's some levels of opposition that 21 I wanted to express at this point and a concern.
22 Okay.
23 MR. CAMERON: Okay. Thanks. Thank you.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Thank you, Diane.
1 And, Olin, who is the next speaker?
2 OPERATOR: We have State Senator Jeff 3
Steinborn.
4 MR. CAMERON: Oh, good.
5 OPERATOR: Your line is now open, sir.
6 MR. STEINBORN: Thank you. Good morning, 7
everybody.
8 MR. CAMERON: Good morning.
9 MR. STEINBORN: Or good afternoon. Thank 10 you.
11 So, I am State Senator Jeff Steinborn, 12 past Chairman of the New Mexico Legislative Interim 13 Radioactive and Hazardous Materials Committee, which 14 is a joint Senate-House committee that meets round 15 the year. And I am the current Vice Chair of that 16 Committee.
17 And we had many hearings on the Holtec 18 proposal and have taken a deeper dive into many of 19 the issues. And I just have to say -- and I'm going 20 to reiterate some of what I have said before -- but, 21 No. 1, I find the EIS, by definition -- well, not by 22 definition,
- but, unfortunately, in
- practice, 23 deficient and not acceptable, frankly, in terms of 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 covering the range of issues that are considered 1
here.
2 And to New Mexicans and a lot of the 3
people calling in, the transportation issue which is 4
not part of this, is one of the 900-pound gorillas in 5
the room because all this waste will come through all 6
sides of New Mexico and put New Mexicans, give New 7
Mexicans particular exposure. And that is not 8
considered at all, and the arguments we've heard of, 9
"Oh, we will do that later" -- no, transportation 10 should not be an afterthought. And I think, given 11 the significance of this proposal, this is a 12 deficiency that's a fatal flaw in this plan that 13 should preclude it from moving forward until all 14 issues have been considered.
15 Beyond that, other deficiencies within 16 the EIS, obviously, the social justice aspects are 17 huge. I don't know that a proposal of this scale -- I 18 know it's difficult to do the kind of work that would 19 be required to do the due diligence on that, but, as 20 the NRC previously has said, New Mexicans have not 21 been proactively reached out to, educated about this 22 proposal, in a level that could remotely conclude 23 that their interests, that their considerations, have 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 been listened to, have been considered. And yet, as 1
Ed Hughes, a New Mexican, said earlier in this call, 2
New Mexicans continue, time and again, to pay a 3
disproportionate price to meet the high cost, the 4
social cost, of the country's nuclear legacy.
5 Furthermore, you
- know, during this 6
pandemic, it is hard to participate. And one of the 7
disappointing and troubling aspects of the pandemic 8
I've seen in public life is how it really puts 9
everybody in a silo. It's hard to engage. People 10 don't hear about issues unless you have internet 11 access. And, you know, we definitely in this State 12 have a digital divide in the same communities where 13 we're going to be shipping waste through.
14 And yet, I, myself, I hopped onto the 15 call, and I didn't realize I had to press *1, for 16 example. And thankfully, others said, "Hey, you have 17 to do this to be able to speak." So, there are 18 technological challenges there.
19 And I would hope, and I'll ask again for 20 the NRC to push this off until or continue it until 21 the pandemic over, so that we can recognize those 22 inherent limitations of what's going on in the 23 pandemic. It's a matter of basic fairness to the 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 State of New Mexico.
1 I would point out, also, that -- and I 2
think it needs to be repeated -- that communities in 3
the State of New Mexico, including the Governor, but 4
communities, comprising almost 50 percent of the 5
State's population, have passed ordinances opposing 6
this transportation through the State. And in the 7
State of Texas, a great I think 5 million Texans have 8
letters of opposition.
9 Now, you know, in contrast to the level 10 of cooperation we've seen from the federal government 11 on the west side of the State, what have we seen with 12 Holtec? We've seen a company that has repeatedly 13 tried to, as far as I'm concerned, mislead the NRC as 14 to the level of support with the State of New Mexico, 15 once even claiming that a resolution passed by a 16 committee, my committee, that was nothing more than 17 a number of members signing onto a statement, that 18 they tried to claim that we had passed a resolution, 19 which we had not. And I immediately contacted the 20 NRC.
21 This last January, they hired a team of 22 lobbyists to oppose legislation that was making its 23 way through the Legislature to simply have the State 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 do an evaluation, agnostic of the results, to do an 1
evaluation of any private high-level facility in the 2
State of New Mexico, simply to protect its own 3
citizens. And Holtec hired a team of lobbyists to 4
oppose that. This is a company that, aside from its 5
lobbyists, doesn't have any employees living in the 6
State of New Mexico. So, obviously, you know, that 7
does not produce trust. In fact, it produces a lot 8
of mistrust.
9 And finally -- and my time is probably 10 almost out -- I wanted to say that, you know, New 11 Mexico is being made to be the guinea pig in all of 12 this. We're considering a proposal with a lifespan 13 beyond the lifespan of dry cask storage or 14 experience.
There is no federal permanent 15 repository. Obviously, New Mexico communities and 16 the State has all the exposure when it comes to any 17 accident that should occur.
18 And so, this is a proposal, frankly, 19 driven by industry, not driven by real national 20 energy policy, and it's of a level that I recognize 21 the NRC, the staff, may feel like, well, it is not 22 your position to consider is it a wise policy 23 decision; you have a proposal. But I think there, 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 inherently, is the great fundamental flaw of the 1
whole thing, that states don't have consent; that a 2
company and a few individuals can trigger this onto 3
a state and onto a nation.
4 And I think the NRC needs to take 5
seriously, and humbled, about its impact of what it's 6
considering for the residents of our State and the 7
nation in terms of their transportation risk, and, 8
you know, expand the scope of this EIS. Frankly, 9
start over -- I think that would be good -- and 10 consider that and many more citizens' points of view, 11 and also, delay this beyond the pandemic.
12 And further, I call on Congress to adopt 13 a real consent-based approach to this. This is a sad 14 excuse for a national energy policy.
15 So, thank you all for listening today.
16 MR. CAMERON: Okay. Thank you, Senator, 17 for those serious comments. Thank you.
18 And, Olin, we're going to try to see if 19 we can get people who have not addressed us to come 20 on. So, I think (telephonic interference) about the 21
- 1. Let's make sure that the people know that they 22 have to press *1 to come on to speak. But we're just 23 going to wait here and see if we get persons who have 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 not spoken tonight lined up to speak.
1 OPERATOR: Understood.
2 So, again, as a reminder, if you would 3
like to ask a comment or pose a question, that is 4
going to be *1 to get in the queue. Again, *1 to 5
enter the queue for questions or comments.
6 (Pause.)
7 Our next question comes from Jerry Lodge.
8 Mr. Lodge, your line is now open.
9 MR. CAMERON: Hi, Jerry. Jerry, are you 10 on?
11 Is it Jerry or Gary. Terry?
12 (No response.)
13 OPERATOR: We seem to be having a 14 technical issue with that. One moment. I'll get the 15 next question up.
16 MR. CAMERON: Okay.
17 OPERATOR: Next, we have Linda Lewison.
18 Ms. Lewison, your line is open.
19 MS. LEWISON: Thank you.
20 My name is Linda Lewison. I'm with 21 Sierra Club Nuclear Free Campaign National Task Force 22 and Nuclear Energy Information Service in Illinois, 23 watchdog on the nuclear industry for the past almost 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 40 years.
1 I am giving this testimony under protest 2
that these hearings should wait until after COVID in 3
six more months, and I support the details of that 4
that were mentioned before on this call. There's no 5
reason that they cannot be held safely and in person, 6
and the Nuclear Regulatory Commission itself has said 7
that the radioactive waste can be safely stored 8
onsite for 120 years.
9 We oppose this plan, as does Sierra Club 10 policy. I would like to cite three points.
11 President Singh of Holtec had said that 12 he can't guarantee that the casks that they're making 13 will be safe in these circumstances. There is no 14 backup for if something goes wrong with these casks.
15 The Nuclear Waste Technical Review Board, in 2019, 16 has also said that there is no safe way to transport 17 and store the waste, either short-term or long-term, 18 at this time. And in my written testimony, I'll give 19 the citations for these quotes.
20 It is also important to note that Holtec, 21 the company itself, is being investigated for 22 criminal activities in three states. This litigation 23 is ongoing. So, we are already in a compromised and 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 corrupted process.
1 There is a conflict of interest of the 2
NRC, an agency that profits from extending licenses 3
to these companies. That is, your fees are what 4
creates much of the budget of the NRC. One has to 5
ask, since we're discussing environmental impact, 6
what is the "actual environmental impact," in quotes, 7
of doing business with such an applicant who is under 8
investigation in the first place? There is a lack of 9
trust on the integrity of what Holtec is doing, and 10 that continues to put the public and the environment 11 at further risk.
12 In closing, please note that Senator 13 Bingaman from New Mexico has in the past refused to 14 endorse any form of interim storage at all, unless, 15 according to federal law, there is a provision for a 16 permanent repository that is actually selected and in 17 place as a physical actuality in the first place prior 18 to any other plan being put forward.
19 Thank you very much.
20 MR. CAMERON: Okay. Thank you again, 21 Linda.
22 And, Olin, do we have someone else that 23 hasn't spoken yet?
24
112 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 OPERATOR: We do. Janet Greenwald.
1 Ms. Greenwald, your line is now open.
2 MS. GREENWALD: Thank you for this 3
opportunity to speak.
4 I'm Janet Greenwald, and I'm Coordinator 5
of Citizens for Alternatives to Radioactive Dumping, 6
which is an old organization first formed by citizens 7
in southeastern New Mexico in 1978.
8 I would like to address several comments 9
that were made earlier. I was pretty shocked to find 10 out that Nick Maxwell's testimony was cut off. And 11 Nick is the person that probably lives the closest to 12 the proposed high-level waste site. He's a young 13 computer consultant, and he has taken a lot of time 14 and put in a lot of energy into monitoring his local 15 government. And his testimony has to be very, very 16 valuable because he is actually there at the meetings 17 when a lot of these decisions were made to move 18 forward with Holtec International and to go forward 19 with this project. So, I was shocked to hear that.
20 And also, the remarks made about nuclear 21 power, that how safe it is, I mean, that kind of 22 defies common sense at this point, since we've gone 23 through Chernobyl and Fukushima. Also, it sounds 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 like this person hasn't looked into the studies that 1
have been done in Europe in which children that lived 2
close to nuclear power plants had been shown to have 3
higher cancer rates.
4 As far as this whole process with this 5
webinar goes, it's been very frustrating to deal 6
with. For one thing, in NRC announcements, they do 7
not say anywhere -- and I have looked over these 8
announcements over and over again -- that you have to 9
press *1 in order to speak. So, how many people have 10 just stayed on the line waiting for their turn to 11 speak and have not been able to because they didn't 12 do that? I tried to speak in the first webinar, and 13 I did not know about *1. Other people called me and 14 said they had thought that they were in line to speak 15 and that they couldn't speak. So, I know that this 16 is the reality, and it's an incredible misstep.
17 This whole webinar process leaves so many 18 people out in so many different ways. The older 19 people that I have talked to who have definite 20 opinions on the subject really can't face talking to 21 people they can't see or cannot even identify. There 22 is no way that I can reassure them that these are the 23 right people that they will be speaking to. So, 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 there's a big gap there. As we know, trust in 1
government is not real high. So, making the process 2
so difficult for them, for older people and people 3
that are computer-illiterate, people who don't have 4
computers, is a little crazy. I think that it's a 5
great misunderstanding of whoever decided on these 6
formats that New Mexicans who have a low median 7
- income, are largely
- rural, that they could 8
participate fairly in a webinar process.
9 I would ask you to extend the comment 10 period until we can have face-to-face meetings with 11 proper outreach to people. I have talked to a lot of 12 people who have never heard of these webinars. And 13 once they hear of them, they don't really feel 14 confident that they can participate.
15 When we consider environmental justice, 16 and we only consider 50 miles from the site as 17 appropriate to consider environmental justice, I 18 believe a great injustice is being done. This project 19 will affect all of us. And as we know, New Mexico is 20 a minority-majority state and it has a low median 21 income. It's last in its ability to care for its 22 children. And yet, time after time, the nuclear 23 industry targets New Mexico.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 To think that because some business 1
people in Carlsbad, and a few other people who will 2
profit from this project, want this project to come 3
to New Mexico, is a form of consent is a great 4
misunderstanding. The State as a whole has had enough 5
as far as nuclear projects go.
6 I mean, I live downwind from Los Alamos, 7
where, until a short time ago, there was a support 8
group here for contaminated Los Alamos workers, until 9
the leader of that group became too sick to continue 10 his leadership. We have the downwinders in Tularosa.
11 And unless you really dig into that subject, you might 12 think that it's spurious, but those people have 13 suffered so much from the nuclear industry, and they 14 have not been given the same consideration as people 15 in other states.
16 And that's true of New Mexico in regard 17 to many aspects of the nuclear industry. The attitude 18 seems to be, well, we've dumped this kind of waste 19 there; we're doing this kind of dangerous nuclear 20 project there; we've done the nuclear testing there; 21 we're making the nuclear bombs there. And even though 22 people have been contaminated and people are 23 suffering, we, obviously, can do more dumping because 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the State is too poor or too weak to resist.
1 I'm just hoping that this time that is 2
not
- true, because it's a
true violation of 3
environmental justice to take a beleaguered minority, 4
low-resource state and, then, dump everything you can 5
on it, as if these people, our people, don't count.
6 So, speaking a little bit about the 7
siting, the latest USGS maps show, as the older ones 8
did, that the site, the proposed Holtec site, is in 9
the middle of one of the largest karstlands in the 10 United States. And karst is a form of geology where 11 the surface cannot hold rainfall or any other water.
12 And so, the water percolates down to where the rock 13 can hold it. Then, it runs along that rock in 14 discrete channels. In order to find karst, you have 15 to look for it, and that hasn't been done, or it 16 certainly hasn't been documented as being done in the 17 EIS.
18 So, we have to do some kind of, oh, 19 electronic resonancing where we look down into the 20 top layers of soil to see what -- down to 500 feet, 21 let's say -- to see what is going on there. It's 22 really not a very difficult process. It's fairly 23 cheap to do, but that hasn't been done at the Holtec 24
117 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 site.
1 The whole EIS, you know, certainly when 2
it comes to environmental justice and to geological 3
formations, shows very cursory consideration. It 4
makes me feel, once again, like New Mexicans don't 5
count. They're people of color. They're poor. What 6
does it matter what happens there?
7 So, I feel that the comment period needs 8
to be extended and people need to be told about this 9
process. They don't really know at this time.
10 And we do not consent. You know, my 11 husband and I went to the Blue Ribbon Commission 12 studies and meetings in Tempe, Arizona. Those were 13 the closest ones to New Mexico. And there were lots 14 of ideas bandied about, but, certainly, people felt 15 that consent should be at least statewide, not a small 16 group of people in one community, that that would be 17 consent. So, consent was never defined by the Blue 18 Ribbon Commission.
19 A lot of money and energy was put into 20 that project because, as you know, billions of 21 dollars were put into siting a nuclear waste 22 repository in Nevada, and all that money was wasted 23 because the people there didn't consent. Well, the 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 people here don't consent, either.
1 And so, maybe it looked like the easy 2
thing to do to just bring the waste here to New Mexico 3
with all the other waste and nuclear projects that 4
are here, that this is already a nuclear sacrifice 5
area. But the nuclear industry, and Holtec in 6
particular, might be surprised. I think New Mexico 7
is ready to finally fight back for this unfair 8
treatment.
9 I want to thank you for this opportunity 10 to speak once again, and I hope that you truly listen 11 to these comments and don't just put them in the round 12 file, where most public comment goes. Thank you.
13 MR. CAMERON: Okay. Thank you. thank 14 you, Janet. And knowing the NRC staff here that's 15 with me in the room, they are going to consider these 16 comments and not just throw them in the round file.
17 So, thank you for talking to us.
18 And, Olin, if you could just, I guess 19 just remind people, we're going to limit the rest of 20 this to people who haven't spoken already tonight.
21 And if you could just remind people that they need to 22 hit *1.
23 And if you could put the next person for 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 us that hasn't spoken yet?
1 OPERATOR: Absolutely.
2 As you said, if you would like to ask a 3
question or a comment, it is *1 to get in the queue.
4 You will be required to state your name for the 5
recording. Again, if you'd like to get in the queue, 6
that's *1.
7 Our next speaker is Tami Thatcher.
8 Miss Thatcher, your line is now open.
9 MS. THATCHER: Hi. Can you hear me?
10 MR. CAMERON: Yes, we can, Tami.
11 MS. THATCHER: Thank you.
12 I'm Tami Thatcher from Idaho. And, well, 13 I was an advisory engineer at a Department of Energy 14 nuclear reactor. And, you know, we had stainless 15 steel piping for the reactor's primary coolant system 16 and very careful chemistry control of the water, so 17 that it had no chlorides. Because it's long known 18 that stainless steel is susceptible to chloride-19 induced stress corrosion cracking.
20 But we did have our water systems 21 connected to this primary piping, our water being 22 groundwater, which was actually high in chlorides.
23 So, you don't have to be talking about ocean water to 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 have chlorides. You can have groundwater that has a 1
significant chloride amount, enough to be a serious 2
risk to stainless steel.
3 And at the plant I worked for, the well 4
water was isolated by check valves, but they leaked 5
by, enough for our water that our stainless steel 6
piping had to be replaced. It had, through wall 7
stress, corrosion cracking.
8 So, when we're talking about exposure to 9
chloride, sometimes primary coolant piping that's 10 stainless steel is protected from that exposure. You 11 try to protect it from that exposure. Canisters, 12 however, that have already been packaged maybe 20 13 years ago already can be exposed to salt air water.
14 They can be exposed to groundwater sprays. There are 15 plenty of ways they can have chloride exposure, and 16 it is proven, and the NRC knows, that you can have 17 through-wall cracking progress within 20 years.
18 So, I want people to understand that.
19 So, when the gentleman from NEI, when Bruce 20 Montgomery from NEI, says there's no accelerated 21 degradation of the canisters, and he obviously has 22 the years of experience to know what he's talking 23 about, he's not being truthful, I suppose. Based on 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what I've seen at the NEI website, so many assertions 1
on that website are completely bogus. I would 2
recommend to the NRC, when NEI says it's raining 3
outside, you should assume it's sunny and it's not 4
raining. Basically, assume the opposite. If NEI 5
says this is
- safe, there is no accelerated 6
degradation, then the fact is it's not safe and there 7
is accelerated degradation.
8 What the NRC accepted from Holtec's 9
application was a risk assessment that had stipulated 10 that it would not include any age-related mechanisms.
11 So, you had a risk assessment that just said we're 12 simply not going to include age-related mechanisms in 13 calculating the risk of a canister leak, you know, 14 cracking through a wall.
15 So, it's completely bogus. People need 16 to understand the NRC, the NEI, are trying to hide 17 this problem. They allowed the design of these 18 canisters, thin-walled canisters that are stainless 19 steel. Yes, it's good stuff, but you're exposing it 20 to chlorides. It has all the conditions for through-21 wall stress corrosion cracking. Yes, it may take 15 22 to 20 years for the cracking to go through, but you 23 need to understand that, once they go through, you're 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 going to have airborne particulate release from the 1
canisters. You're going to have trouble shipping 2
them to a permanent repository, if you did happen to 3
find one. You have no hot cells for taking the fuel 4
out of a compromised canister. That is not any part 5
of the Holtec design.
6 The NRC's monitoring of that airborne 7
particulate that would be released from these 8
canisters will be modified to whatever extent needed, 9
so that they can say, you know, "We can hardly detect 10 much. The doses are low. Don't worry about it."
11 So, I have to say that's what I think of 12 your treatment of the canisters and your stipulating 13 that leaking canisters are outside the scope of your 14 EIS, when that's going to fundamentally be leaking 15 radionuclides airborne and affecting your criticality 16 risk if you do have water involved in potential 17 leaking into a canister, and criticality concerns.
18 So, I wanted to give those comments, so 19 that people understand what NEI and what the NRC and 20 what Holtec are really trying to pull over on you.
21 So, thank you for this opportunity to 22 comment.
23 MR. CAMERON: Okay. Thank you again for 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 commenting, Tami.
1 And, Olin, do we have someone else who 2
hasn't spoken before on the line?
3 OPERATOR: We do. We have Steven 4
Sondheim.
5 Steven, your line is open, sir.
6 MR. SONDHEIM: Thank you. Thank you.
7 Yes, that name is mispronounced a lot.
8 It's Steven Sondheim. Yes, thank you. I'm a member 9
of the Sierra Club. I'm part of a subcommittee called 10 the Nuclear Free Campaign.
11 And I want to agree with everybody that 12 all this needs to be consent-based, consent-based for 13 the people in the community, for the people in New 14 Mexico, for the people in Texas, and, also, for all 15 the people along the routes. I live in Chicago now, 16 which would be a major route. I used to live in 17 Memphis, which would be a major route.
18 I want to mention this problem that Bruce 19 Montgomery from NEI stated, that -- and I want to 20 refer, actually, to Davis-Besse, where my wife's 21 family lives. They can see it out their window.
22 Davis-Besse and its stainless steel thing wasn't 23 discovered -- in fact, they say it was hidden until 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 it was finally discovered, and it was almost too late.
1 And the parallel to these casks is that there is no 2
way to inspect them, to monitor them, to see if 3
they're leaking, or once they do start to leak, to 4
remove the waste or to repair them. So, it's blind.
5 That's just totally unacceptable.
6 As the previous speaker mentioned, there 7
are corrosive processes, and they wouldn't know if it 8
happened. That's got to be shored up. In fact, they 9
say that there are better cask systems that are 10 thicker and that are also inspectable, monitorable, 11 and where the problem can be found and fixed or 12 removed.
13 Those other comments, most of the germane 14 comments have been made so far. Obviously, we're 15 against moving all this waste across the country.
16 Obviously, these casks need to be better. And 17 obviously, there needs to be public hearings, you 18 know, face to face, and also, where some of these 19 technical things that we're challenging you with are 20 explained, either explained to the satisfaction or 21 back to the drawing board to be explained.
22 Okay. Well, thank you very much.
23 MR. CAMERON: Thank you. Thank you, 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Steven, for those comments from Chicago.
1 And, Olin, I wondered if Terry, if you 2
ever heard back from, I think it was Terry Lodge who 3
could not get on.
4 OPERATOR: We do actually have Terry 5
Lodge up now.
6 MR. CAMERON: Oh, good. Good.
7 Hey, Terry.
8 MR. LODGE: Good afternoon. Can you hear 9
me?
10 MR. CAMERON: Good afternoon. Yes, we 11 can.
12 MR.
LODGE:
I'd like to talk 13 about -- first of all, thank you.
14 I want to join the objections that other 15 people have been making as to the timing and the lack 16 of personal attendance to New Mexico by 17 representatives of the NRC to get comments.
18 This project is years away from becoming 19 operative, and there's plenty of time, and this is a 20 decision for the ages because of this possibility 21 that Holtec could become the substitute for a deep 22 geological repository. So, this is an incredibly 23 important decision. It's a national decision. At 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 least 215 million people presently live, recreate, or 1
work within 50 miles of the (telephonic 2
interference). It's absurd and I'm very tired of the 3
excuse that the NRC is minimally complying with their 4
clearance NEPA and, also, has to observe New Mexico's 5
requirements regarding COVID. There's plenty of 6
time. You could do this in a year, a year and a half, 7
maybe sooner, if there were any genuine leadership on 8
resolving the COVID crisis.
9 My comments are these: one of the 10 glaring absences from the DEIS is recognition and 11 discussion of the official policy of the Department 12 of Energy right now regarding the deep geological 13 repository. They announced, in 2006, that the 14 intention, the official federal government's 15 intention, is to require a standardized disposal 16 canister to be used at whatever repository ultimately 17 would be chosen. That design has never been 18 finalized. It is estimated, however, that if you 19 take the 173,000 metric tons expected there volume 20 for Holtec, you're taught that, instead of 10,000 21 deliveries, 10,000 cargoes traveling literally 22 millions of miles, ultimately, on rail in the United 23 States, there would be as many as 80,000. And that 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 depends on a bunch of unanswered questions.
1 There are 12 or more closed reactor sites 2
right now that do not have any capability to unload 3
or reload or do anything to remediate the canisters 4
that they presently possess. That means that they 5
can't even be loaded into transport canisters of any 6
type to be shipped to Holtec. So, there is a need 7
for some high-tech hot cell type of capability, even 8
to get that waste out of those sites.
9 (Telephonic interference), here they 10 made it clear in 2006 that they do not accept at the 11 repository site, basically, the waste that's put 12 there and they will not repackage it. It will have 13 to be done upstream, as you know, of the project.
14 That means either the reactor sites or at Holtec.
15 And yet, Holtec refuses to permit, and the NRC is not 16 holding them to require, onsite dry transfer storage 17 or other means technologically of handling and 18 reloading the spent nuclear fuel into standardized 19 disposal canisters.
20 It's also a question mentioned, and 21 talked about considerably, that for the first 40 22 years or so
- actually, for the first 23 century -- Holtec doesn't plan on having the 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 capability or having DTS onsite. They don't plan?
1 They don't intend to have any accidents or problems, 2
storage leakage crises of a radiological sort happen, 3
which requires a fantasy thought, which is certainly 4
a characteristic of this entire proposal.
5 So, you have this problem of possibly 6
having to break the overall volume down into 7
thousands more canisters, as I say, as many as 80,000, 8
certainly many hundred thousands, or you have the 9
problem of Holtec becoming a reloading facility. And 10 that implicates Holtec's predictions of how much low-11 level radioactive waste will be generated at the 12 site. If Holtec is the locus where the unloading and 13 reloading into standardized canisters occurs, then 14 there is going to be literally thousands of 15 cans radioactive
- material, in other 16 words -- generated as waste.
17 And presently, the DEIS states a very 18 minimal amount of low-level radioactive waste, 19 basically, a few thousand tons over decades. That's 20 a ridiculous underestimate in any event, but it's 21 certainly a ridiculous underestimate if Holtec 22 actually has to repackage all of this material from 23 the canisters and casks in which the waste arrived, 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and has to, basically, try to meet the disposing of 1
the material that they had not planned on.
2 Another complicating factor is that 3
presently pending before the NRC is a rulemaking by 4
another name, a rule, whereby the agency proposes to 5
re-deregulate what may very likely be low-level 6
radioactive
- waste, deregulate as in
- allowing, 7
essentially, anybody who wants to develop a landfill, 8
even one that doesn't comport with state sanitary 9
landfill requirements, that anybody can open a 10 landfill and accept radioactive material with zero 11 follow up, regulation, or oversight by the Nuclear 12 Regulatory Commission. I think that the effects and 13 implications of that rulemaking reinterpretation, 14 whatever the NRC is calling it this week, is --
15 MR. CAMERON: Olin, I think we lost Terry 16 again for some reason.
17 OPERATOR: I am seeing that on my end 18 here as well. I do apologize. Stand by just a 19 moment.
20 MR. CAMERON: Okay.
21 (Pause.)
22 OPERATOR: Mr. Lodge, if you can hear 23 me -- this is the operator again -- go ahead and press 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
- 1 again, so I can reopen your line.
1 (Pause.)
2 MR. LODGE: Hello?
3 MR. CAMERON: Hello. Is that Terry?
4 MR. LODGE: Yes.
5 OPERATOR: Yes, it is.
6 MR. CAMERON: Okay. Terry, why don't you 7
finish up with your comments for us? We lost you 8
there for a while.
9 MR. LODGE: I don't suppose anyone knows 10 what I was saying when you lost me.
11 MR. CAMERON: Yes, we couldn't hear you 12 there for a while. You were talking about the NRC 13 regulation that would address what's called very low-14 level waste.
15 MR. LODGE: Ah, very good. Fine. Thank 16 you.
17 I believe that the requirements of NEPA 18 obligate the agency to take into account the proposed 19 very low-level waste reinterpretation and analyze it 20 within the context of the Holtec application, because 21 of the fact that it well could mean that there must 22 be more serious attention given to the commitments 23 for where, and in what manner, low-level radioactive 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 waste is disposed of, especially given the fact that 1
it is highly likely in
- fact, it's 2
inevitable -- that there will be thousands of tons 3
more low-level radioactive waste generated by the 4
project than the applicant and the NRC are presently 5
acknowledging.
6 Thank you.
7 MR. CAMERON: Okay. Thank you for 8
bringing that to our attention, Terry.
9 And, Olin, do we have anybody on who 10 hasn't spoken to us yet?
11 OPERATOR: Unfortunately, when the mishap 12 happened with Mr. Lodge, we lost two participants, 13 Ethel
- and, then, I
had another
- name, but, 14 unfortunately, I don't have what it is. But if you 15 give me a moment, I'll get another question queue 16 back up for you.
17 MR. CAMERON: Okay. Great. We look 18 forward to Ethel.
19 OPERATOR: We have a Karen Berdine.
20 Miss Karen, your line is now open.
21 MS. BONINE: Bonine. Yes?
22 MR. CAMERON: Hi, Karen.
23 MS.
BONINE:
Hi.
It's
- Bonine, 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 B-O-N-I-N-E. Chip knows how to say it.
1 MR. CAMERON: Okay. We got it. We got 2
it.
3 MS. BONINE: All right. Yes. The one 4
word or the two words I really want to repeat: we 5
need stronger casks, or canisters rather, stronger 6
canisters. If Germany can build them, why can't 7
Holtec, or perhaps a more reputable company, a more 8
believable company?
9 In
- Japan, during the tsunami at 10 Fukushima, the canisters and casks that they had 11 there withstood the incredible, unimaginable force of 12 the tsunami and the earthquake that accompanied it or 13 preceded it. It is possible to make canisters or 14 casks that can withstand immense forces. And we know 15 that immense forces can and do happen in nature, such 16 as earthquakes, such as tornadoes, such as 17 hurricanes, incredible forces, not to mention the 18 possibility of a terrorist attack on a highly visible 19 storage facility that is projected to have neatly 20 arrayed, partially above-ground storage units that 21 anybody could see from the sky from miles away.
22 And I strongly object to gathering all 23 this waste in one place, where one accident could 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 trigger, even in just one cask, a criticality 1
incident; could create enough energy to trigger 2
breakdowns of many, if not all, of the other canisters 3
or casks in the array. I think this is just 4
foolishness.
5 And it's also illegal because, under 6
federal law, there cannot be a temporary storage 7
facility until a permanent repository has been 8
located and approved.
9 That's all I have to say. Thank you very 10 much.
11 Did you hear me?
12 MR. CAMERON: Okay. Thank you. Yes, 13 yes. Thank you very much, Karen, and we did hear 14 you.
15 And I think we have a new operator. Is 16 it Sarah?
17 OPERATOR: That is correct, sir.
18 MR. CAMERON: Okay. Sarah, we're only 19 taking people who haven't spoken to us before, and I 20 don't know if there's anybody on the list. But there 21 was one person when Olin was with us, a woman, I'm 22 assuming a woman, named Ethel. We didn't get a last 23 name. And he couldn't get her on the line.
24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Can you just tell people to press *1 if 1
they want to talk to us? So, we're not taking people 2
who we've already heard from.
3 OPERATOR: Thank you, sir.
4 Ethel, if you could at this time press 5
- 1, we can open up your line, so you may speak.
6 (Pause.)
7 MR. CAMERON: We've given --
8 OPERATOR: And it is -- I'm sorry, 9
sir -- it is Ethel Rivera.
10 MR. CAMERON: Oh, good. Ethel Rivera.
11 Okay, Ethel.
12 MS. RIVERA: Thank you very much.
13 I would like to just take a moment to 14 express my heartfelt regrets that, once again, the 15 State of New Mexico and the environment are being 16 used as a trash dump for the trash of the United 17 States that no one else wants to have.
18 I want to express my protest of these 19 webinars which the majority of the American people 20 that would be affected by these actions that are being 21 proposed have no idea that this is going on.
22 I live in southeastern Michigan, not too 23 far from the route that the transport of these 24
135 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 materials would be taking over. This whole idea 1
reminds me of the not-too-long-ago event that 2
affected the area that I live in, including all of 3
the Great Lakes, when the Canadian nuclear industry 4
wanted to have a deep underground dump under the 5
shores of Lake Huron, not far from our own Michigan 6
cities. And it took years and many, many protests, 7
many, many hearings, all of which were widely 8
disseminated to the people of both the United States 9
and Canada and all of the surrounding areas that would 10 be affected. We finally were able to, on behalf 11 primarily of the Native Americans who were able to 12 intervene, finally put a stop to that idea.
13 But this is a very similar attempt to 14 have something of immense -- immense -- proportions 15 and immense degradation of our entire environment 16 come before an agency that has immense 17 responsibility, but seems to have abandoned its 18 responsibility to make sure that the citizens of this 19 country are kept in the dark as to what is going on.
20 I applaud the efforts of so many beyond 21 nuclear, Diane D'Arrigo and her organization, and 22 many others, the Sierra Club Nuc Free, and others, 23 but, most importantly, the people of New Mexico, who 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 for years have been taken advantage of, who have 1
suffered immense -- immense -- degradation of their 2
land, of their people, of their society, and once 3
again, are being cited as a good location for 4
continued degradation and poisoning of their land and 5
their people and their degradation of their society.
6 It is just ludicrous that we are 7
continuing these efforts to do these kinds of things 8
in the dark. These webinars are not widely known to 9
even exist. Why does the NRC and its cohorts pursue 10 these efforts to do these things in the dark?
11 And in today's COVID situation, it is 12 ludicrous to think that they are being held. They 13 should be held off until the pandemic has been evaded.
14 They should be restarted. All the issues with regard 15 to the unanswered questions that have been noted in 16 today's and previous webinars/discussions should be 17 addressed. And they should be addressed in open 18 public meetings held across this country, but, 19 primarily, along the routes of the transportation 20 lanes that have been proposed and, of course, widely 21 across the entire State of New Mexico and the adjacent 22 areas of Texas that would be affected.
23 It is, to me, another example of the 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 corruption between private industry and businesses, 1
along with government entities, that are seeking not 2
to improve the lives of the American people, but to 3
continue to enrich their pocketbooks, and without the 4
responsibilities that go along with them.
5 Furthermore, that the NRC and the other 6
agencies involved would even consider doing business 7
with such an organization as Holtec, given the 8
allegations and the situation that the CEO and others 9
in that corporation are under scrutiny for, is just 10 another signal that we are not doing our best to serve 11 the country with the responsibilities that they have 12 sworn to undertake.
13 Thank you very much for your time.
14 MR. CAMERON: And thank you. Thank you, 15 Ethel.
16 And, Sarah, do we have one more that we 17 haven't heard from yet?
18 OPERATOR: We do. Thank you.
19 Diane Turko, your line is open.
20 MS. TURKO: Oh, hi. Hi.
21 MR. CAMERON: Hi.
22 MS. TURKO: I'm Diane Turko. Hi. I'm 23 Director of the Cape Downwinders on Cape Cod in 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Massachusetts, and we are watchdogs for the Pilgrim 1
Nuclear Reactor. We have members all across the Cape 2
and across the State.
3 And I am presenting this testimony under 4
protest. We stand in solidarity with the New Mexicans 5
who are demanding the NRC stop the Holtec license 6
application process until it is safe to hold in-7 person public meetings in New Mexico. We also support 8
the demand for the NRC to hold public meetings in 9
Texas and, also, the 44 impacted states, including my 10 home State of Massachusetts.
11 This proposed Holtec CIS is no better 12 solution for storing nuclear waste than what is 13 already in place across the United States. It's just 14 a complete failure.
15 That the NRC has concluded that impacts 16 from transportation accidents, and its assumption of 17 no release during accidents, is completely 18 irresponsible. You're making it sound like, oh, this 19 is, you know, it's going to pack the stuff up and 20 move it across the country, and don't worry about it.
21 So, the NRC is just kicking the dangerous 22 nuclear waste can down the American highways and 23 rails to dump in the minority communities. This is 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 clearly social and environmental injustice. We find 1
this unacceptable and you do not have our consent.
2 Cape Downwinders will be submitting 3
written comments with many more details.
4 So, thank you for this time, and I really 5
hope that you listen to the people and wait until 6
there can be in-person meetings and hold them across 7
the United States, where all these communities will 8
be impacted.
9 Thank you.
10 MR. CAMERON: Okay. Thank you. Thank 11 you very much, Diane.
12 And I'd like to thank everybody who 13 commented today. And we're over the time. So, we're 14 going to close the meeting out now.
15 And, Sarah, I'm going to go to Kevin 16 Coyne to close the meeting. He's our senior agency 17 official. And after that, we'll be adjourned.
18 So, Kevin?
19 MR. COYNE: Thanks, Chip.
20 I just want to take a moment to thank 21 everyone again for your participation in today's 22 meeting. I think we had over 130 folks participating, 23 and we very much appreciated the comments and 24
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 perspectives that you provided today.
1 All your comments will be captured in the 2
transcript. And we will review and analyze those 3
comments as we prepare the Final Environmental Impact 4
Statement for Holtec International's application.
5 I also want to note that the NRC takes 6
these meetings very seriously. Your comments provide 7
an important piece of information for our 8
environmental review. And to that end, from our side, 9
our environmental safety front-line supervisors and 10 management team actively participate in these 11 meetings.
12 And as Chip pointed out at the beginning 13 of the meeting, many of us are in this room now 14 actively listening to your
- comments, and we 15 appreciate those comments and the time that you've 16 taken out of your day to provide them.
17 Just a reminder that we ask for your 18 comments on the Draft Environmental Impact Statement 19 by September 22nd.
20 And with that, thank you very much.
21 MR. CAMERON: Okay. Thank you.
22 And, Sarah, thank you, and thank Olin for 23 the assistance, too, today.
24
141 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 (Whereupon, the above-entitled matter 1
went off the record at 2:25 p.m.)
2 3
4 5
6 7
8 9