ML20305A553

Comment (8472) E-mail Regarding ISP-CISF Draft EIS

ML20305A553
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	10/30/2020
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
85FR27447
Download: ML20305A553 (3)

Text

From: Sally Jane Gellert <SageEdit@aol.com>

Sent: Friday, October 30, 2020 12:56 PM To: WCS_CISFEIS Resource

Subject:

[External_Sender] Draft Environmental Impact Statement (DEIS),

Docket No. 72-1050; NRC-2016-0231

Dear Nuclear Regulatory Commission (TX CIS),

I find it very disturbing that the NRC has not adequately considered the environmental impacts of transporting nuclear waste to & from the proposed Interim Storage Partners (ISP) high-level waste storage site in Texasneither in the cask certification processes nor in this draft environmental impact statement (DEIS). This shortfall is even worse for hotter "high burn up" irradiated fuel, which was not considered in most analyses.

Thousands of intensely radioactive shipments, over decades, would travel through most states &

a vast majority of Congressional districts, mostly by train but also by road & by barge on vital waterways. The impacts are not "small", accidents are more likely than represented. The reports used to make the conclusion of small impact are wrong & must be replaced. They underestimate the probability of serious accidents (especially rail freight & fires).

Fires could cause cask lid bolts to stretch. Radioactive gases & particulates could get out via valves or a fire lasting longer a the mere half-hour & burning hotter than 1475° F, as in the design bases. These & other scenarios could cause cask failure and radioactive releases.

Many transport fires have burned longer than the 1/2-hour or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> NRC considers in its analysis. There are a growing numbers of tankers with flammable chemicals on the rails, increasing the likelihood of high-temperature fires.

The DEIS fails to adequately assess the environmental impacts of the containers that would be used to transport and store the waste. NRC staff have stated that cask concerns must be addressed when the NRC certifies the casks, but the communities through which shipments would move & those in the vicinity of the proposed waste storage site have not been able to participate in the cask certifications due to timing, lack of notification, & lack of opportunity to engage in an adjudicatory way. This alone must be remedied.

There are 6 dry-storage systems, with 16 kinds of canisters, proposed for the ISP site. The environmental impacts of each of these have not been fully analyzed. The safety analysis in the certification & the report used for this DEIS are inadequate; they do not require the container to meet real-world conditions including the length of time & temperature of fires, the length of time

& depth of immersion in water, & collisions at normal highway & rail speeds. Environmental impacts were not considered in the certifications of the cask designs. The cask-certification process is not reasonably accessible for public participation.

NRCs radiation risk numbers ignore the fact that a specific amount of radiation affects females and youths more than adult men. In addition, only cancer & severe birth defects are estimated no evaluation of other known radiation effects, including reduced immunity, autoimmune

diseases, & heart/cardiovascular disease are considered.

I object to these unnecessary risks and urge the NRC to reject the ISP license application.

Sincerely, Sally Jane Gellert 210 Broadway Woodcliff Lake, NJ 07677

Federal Register Notice: 85FR27447 Comment Number: 8472 Mail Envelope Properties (5aa8221e-469b-464b-b073-15745a82e670)

Subject:

[External_Sender] Draft Environmental Impact Statement (DEIS), Docket No.

72-1050; NRC-2016-0231 Sent Date: 10/30/2020 12:56:18 PM Received Date: 10/30/2020 12:56:19 PM From: Sally Jane Gellert Created By: SageEdit@aol.com Recipients:

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