ML20283A713
| ML20283A713 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 10/09/2020 |
| From: | Richard Laufer NRC/SECY |
| To: | Trester Ej Texas Physicians for Social Responsibility |
| SECY RAS | |
| References | |
| ASLBP 19-959-01-ISFSI-BD01, RAS 55832, WCS CISF 72-1050-ISFSI | |
| Download: ML20283A713 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 9, 2020 Elliot J. Trester, M.D.
Texas Physicians for Social Responsibility P.O. Box 163924 Austin, TX 78716
Dear Dr. Trester:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your September 6, 2020, letter to Chairman Svinicki regarding the Interim Storage Project application and Draft Environmental Impact Statement (DEIS) to construct and operate a consolidated interim storage facility near Andrews, Texas. Your letter expresses concern with such a facility being licensed.
Some of the issues raised in your letter bear on matters currently before the Commission in an adjudicatory proceeding. Given that this contested proceeding is ongoing, it would be inappropriate for the Chairman to discuss or comment on these matters at this time. This is because the Commission must remain impartial during the pendency of the proceeding.
Those aspects of your letter specifically concerning the DEIS will be referred to the staff for consideration.
A copy of your letter and this response will be served on the participants in the ISP CISF proceeding.
Sincerely, Richard J. Laufer Acting Secretary Richard J. Laufer Digitally signed by Richard J. Laufer Date: 2020.10.09 14:55:42 -04'00'
BOARD OF DIRECTORS KIMBERLY CARTER, MD LISA DOGGETT, MD, MPH MARY GONZALES. MD KAREN HADDEN SEAN LIU. MEDICAL STUDENT MATTHEW MCCURDY, MD POOJA PUNDHIR, MD HASSAN SEEDE, MEDICAL STUDENT ELLIOT TRESTER, MD.
EXECUTIVE DIRECTOR STEVE MCKEE, MSSW Sunday, September 6, 2020 Chairman Kristine L. Svinicki U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Draft Environmental Impact Statement (DEIS), Docket No. 72-1050; NRC-2016-0231 Interim Storage Project's license application to construct and operate a Consolidated Interim Storage Facility (CISF) for spent nuclear fuel (SNF) and Greater-Than Class C (GTCC) waste.
Dear Ms. Svinicki:
I am a board member of Texas Physicians for Social Responsibility. We are part of a national group that has on the first page of our web site, "We must prevent what we cannot cure." The use of nuclear power has created a massive amount of radioactive waste that is quite problematic, as we can see by the current issue. That is one of the reasons that PSR does not support the use of this power source for energy production.
We are talking about a 40 year "temporary" site in Texas for WCS (and similarly in New Mexico with Holtec) for spent nuclear fuel. This is an example of kicking the radioactive can down the street so you don't have to deal with it. This nuclear waste is going to be around for tens of thousands of years if not millions. (plutonium 239 has a half-life of 24,000 years, and uranium 235, 700 million years - both produced in reactors). Human beings don't live or think in such time frames. Even a few hundred years changes the climate of an area, both physically and how people live in a place. For example, there is an increase in seismic activity in West Texas.
Let's consider the harmful health effects of radioactive producing materials that will be dangerous for hundreds of thousands of years. Certainly, certain radioactive isotopes have made medical care more effective, but most of these are short lived elements. However, long term exposure to radioactivity (or even short term at higher doses) has profound effects.
In an accident where large doses of radioactivity are released, the immediate effects would include nausea, vomiting, diarrhea, hair loss, destruction of the intestinal lining, and often death. In children and pregnant women, P.O. Box 163924 Austin, TX 78716 (512) 643-2060 texaspsr.org
DNA damage can give rise to cancers. In fetuses, miscarriage, birth defects, and premature death all occur. Long term effects of even low doses of radiation increase all cancers, and especially leukemias in children, tumors of the brain and central nervous system, thyroid disease, and cataracts.
The Nuclear Regulatory Commission says that "high-level wastes are hazardous because they produce fatal radiation doses during short periods of direct exposure. For example, 10 years after removal from a reactor, the surface dose rate for a typical spent fuel assembly exceeds 10,000 rem/hour - far greater than the fatal whole-body dose for humans of about 500 rem received all at once. "
Unfortunately, we are stuck with a great quantity of spent nuclear waste.
Part of the problem with nuclear waste is transporting it. While trains are fairly safe, there are of course accidents, and many of the routes are near large cities. In Texas, we will certainly be put at risk by the proposed sites.
Besides accidents, in this ever increasingly fractious world, the risk of high-level nuclear waste as a target for terrorists is clear. This could occur at the source of the waste, along the trajectory to a storage site, or at the site. By having material transported for hundreds of miles, the possibility of theft increases.
Once the material is stored not only would theft be a threat, but as I noted already, the geology of a region would change in the long run and make an area become very unsafe after a number of millennia. It should be noted that this is to be a consolidated interim storage facility to last for only 40 years. We should not be transporting dangerous nuclear waste twice: once to interim storage then to a permanent repository. There must be a long-term solution to this problem.
Finally, we are dealing with sparsely populated areas for storage, but people still live there. All Texans and New Mexicans must have more real input into decisions that will affect them for many years.
There is no easy solution to this problem, but I think that the NRC needs help in developing sound policy for nuclear waste. Under their title the NRC has as its mandate to protect people and the environment. Congress needs to seriously discuss what to do with the nuclear waste that we have, and to prevent more from being produced.
Respectfully, Elliot J. Trester, M.D.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
INTERIM STORAGE PARTNERS LLC
) Docket No. 72-1050-ISFSI
)
(WCS Consolidated Interim Storage Facility) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Letter from NRC Acting Secretary Richard J.
Laufer to Dr. Trester of Texas Physicians for Social Responsibility have been served upon the following persons by the Electronic Information Exchange:
U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Mail Stop: O16-B33 Washington, DC 20555-0001 E-mail: ocaamail.resource@nrc.gov U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 Washington, DC 20555-0001 Paul S. Ryerson, Chair Administrative Judge E-mail: paul.ryerson@nrc.gov Nicholas G. Trikouros Administrative Judge E-mail: nicholas.trikouros@nrc.gov Dr. Gary S. Arnold Administrative Judge E-mail: gary.arnold@nrc.gov Ian Curry, Law Clerk Stephanie Fishman, Law Clerk Molly Mattison, Law Clerk E-mail: ian.curry@nrc.gov stephanie.fishman@nrc.gov molly.mattison@nrc.gov U.S. Nuclear Regulatory Commission Office of the Secretary of the Commission Mail Stop: O16-B33 Washington, DC 20555-0001 Hearing Docket E-mail: Hearing.Docket@nrc.gov U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop - O-14A44 Washington, DC 20555-0001 Joe Gillespie, Esq.
Sara Kirkwood, Esq.
Mauri Lemoncelli, Esq.
Nicholas Moran, Esq.
Patrick Moulding, Esq.
Kevin Roach, Esq.
Carrie Safford, Esq.
Thomas Steinfeldt Rebecca Susko, Esq.
Alana Wase, Esq.
Brian Newell, Senior Paralegal E-mail: joe.gillespie@nrc.gov sara.kirkwood@nrc.gov mauri.lemoncelli@nrc.gov nicholas.moran@nrc.gov patrick.moulding@nrc.gov kevin.roach@nrc.gov carrie.safford@nrc.gov thomas.steinfeldt@nrc.gov rebecca.susko@nrc.gov alana.wase@nrc.gov brian.newell@nrc.gov
WCS CISF - Docket No. 72-1050-ISFSI Letter from NRC Acting Secretary Richard J. Laufer to Dr. Trester of Texas Physicians for Social Responsibility 2
Counsel for Beyond Nuclear Diane Curran, Esq.
Harmon, Curran, Spielberg and Eisenberg 1725 DeSales Street NW, Suite 500 Washington, DC 20036 E-mail: dcurran@harmoncurran.com Mindy Goldstein, Esq.
Emory University School of Law Turner Environmental Law Clinic 1301 Clifton Road Atlanta, GA 30322 E-mail: magolds@emory.edu Nuclear Information and Resource Service (NIRS)
Diane DArrigo 6930 Carroll Avenue Suite 340 Takoma Park, MD 20912 Email: dianed@nirs.org Sustainable Energy and Economic Development (SEED) Coalition Karen D. Hadden Executive Director, 605 Carismatic Lane Austin, TX 78748 E-mail: karendhadden@gmail.com Counsel for Interim Storage Partners LLC Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue NW Washington, DC 20004 Grant Eskelsen, Esq.
Timothy Matthews, Esq.
Ryan Lighty, Esq.
Paul Bessette, Esq.
E-mail: grant.eskelsen@morganlewis.com timothy.matthews@morganlewis.com ryan.lighty@morganlewis.com paul.bessette@morganlewis.com Chris Hebner, Esq.
City of San Antonio, TX P.O. Box 839966 San Antonio, TX 78283 E-mail: chris.hebner@sanantonio.gov Counsel for Sierra Club Wallace Taylor 4403 1st Avenue S.E.
Suite 402 Cedar Rapids, IA 52402 E-mail: wtaylorlaw@aol.com Counsel for Dont Waste Michigan, et al Terry Lodge, Esq.
316 N. Michigan Street Suite 520 Toledo, OH 43604 E-mail: tjlodge50@yahoo.com Dated at Rockville, Maryland, this 9th day of October 2020 Counsel for Fasken Land and Oil and Permian Basin Land and Royalty Owners Monica R. Perales, Esq.
6101 Holiday Hill Road Midland, TX 79707 E-mail: monicap@forl.com Kanner & Whiteley, LLC 701 Camp Street New Orleans, LA 70130 Allan Kanner, Esq.
Elizabeth Petersen, Esq.
Cynthia St. Amant, Esq Conlee Whiteley, Esq.
E-mail: a.kanner@kanner-law.com e.petersen@kanner-law.com c.stamant@kanner-law.com c.whiteley@kanner-law.com Office of the Secretary of the Commission Krupskaya T.
Castellon Digitally signed by Krupskaya T.
Castellon Date: 2020.10.09 15:06:07 -04'00'