ML20307A227

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Comment (9120) E-mail Regarding ISP-CISF Draft EIS
ML20307A227
Person / Time
Site: Consolidated Interim Storage Facility
Issue date: 11/01/2020
From: Public Commenter
Public Commenter
To:
NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
85FR27447
Download: ML20307A227 (5)


Text

From:

Linda Hanratty <llswenard47@gmail.com>

Sent:

Sunday, November 1, 2020 11:33 AM To:

WCS_CISFEIS Resource

Subject:

[External_Sender] Docket No. 72-1050 (NRC-2016-0231), Interim Storage Partners, LLC/Waste Control Specialists, LLC Consolidated Interim Storage Facility Project Attachments:

NRC Waste Opposition Letters-Gov Abbott Office.pdf Linda Hanratty 4236 Oak Park Court Fort Worth, Texas 76109 To: Nuclear Regulatory Commission (NRC) WCS_CISF_EIS@nrc.gov.

Subject:

Docket No. 72-1050 (NRC-2016-0231), Interim Storage Partners, LLC/Waste Control Specialists, LLC Consolidated Interim Storage Facility Project Comment: Halt Licensing of this Proposal I join Texas Governor Abbott and the City of Fort Worth, Texas, in requesting denial of the license for the proposed Interim Storage Partners(ISP) high-level nuclear waste (HLW) interim storage dump in Andrews, Texas. Texas should not be the nations HLW waste dump, particularly an above-ground dump operated by a private, limited liability company with ties to France, a major producer of HLW. However, my major concern is the proposed transportation of HLW traveling through Tarrant County, Texas, where I reside.

The Nuclear Regulatory Commission (NRC) should hold in-person public hearings along the proposed transportation routes, including one in Tarrant County, Texas, once COVID-19 is under control. This would mean delaying the comment period for ISP from November 3, 2020, to allow for adequate public input on this important matter. Participating in your webinars required a computer, a smart phone, and the ability to navigate a difficult interface, something low-income persons rarely have. In addition, the vast majority of residents and elected officials in Tarrant County have no idea that HLW might be coming soon to their railroad tracks, because the current Environmental Impact Statement (EIS) ignores the impact the transportation of HLW would have on communities along the likely rail routes, such as through Tarrant County.

ISP proposes to store over 40,000 metric tons of spent nuclear fuel (SNF) over a 20-year period, which translates into the transport of approximately 425 casks per year. According to the US Nuclear Waste Technical Review Board 2019 Report to Congress, for decades, small-scale shipments of SNF have occurred. However, transporting large quantities of SNF and HLW has not been done and will require significant planning and coordination by the Department of

Energy (DOE), the agency responsible for waste transportation under the Nuclear Waste Policy Act (NWPA). (https://www.nwtrb.gov/docs/default-source/reports/nwtrb_nuclearwastetransport_508.pdf?sfvrsn=6 ).

The IPS Environmental impact Statement says that the preferred carrier for the HLW is Union Pacific. The NRC defines the exposed population as a band approximately 0.5 miles on either side of the transportation route (the Union Pacific railroad tracks), in part because the containers continuously emit a small amount of radioactivity, and even minor accidents, slow-moving rail cars, or stopped rail cars, would increase radioactive emissions.

(http://www.state.nv.us/nucwaste/news2012/pdf/nureg2125.pdf The Census 2020 population estimate for Tarrant County, Texas, is 2,139,860. The Union Pacific Railroad tracks bisect Tarrant County, from east to west and from north to south. The tracks on the east and south sides of downtown Fort Worth are within one-half mile of such downtown facilities as the Tarrant County Convention Center and Fort Worth City Hall, as well as apartments, a hotel, a law school, and the local transportation center.

Union Pacifics Davidson Yard, southwest of downtown Fort Worth, borders a large natural gas well site, the well-used Trinity Trails, and the Clear Fork of the Trinity River (a major water supply). Commercial, office, and residential uses are within the 0.5-mile radius, as is the Colonial Country Club, home of a PGA golf tournament. It is likely that some of the nuclear waste casks will spend time in the yard to account for rail traffic, etc.

Tower 55, a major transcontinental rail intersection, which handles over 100 trains per day, lies just southeast of downtown Fort Worth. Trains coming from the north would have to turn west at this intersection. Recent improvements have lessened this bottleneck, but delays likely still occur.

The Arlington City Hall, Arlington Main Library, Arlington Police Headquarters, part of the University of Texas at Arlington, Arlington Baptist University, Watauga City Hall, Watauga library, and nineteen schools lie within 0.5 mile of the tracks, along with numerous residential, industrial, and commercial uses. Some of the schools in lower income areas are as close at 0.10-mile from the tracks. As the tracks traverse this urban area, numerous street crossings are at-grade, posing additional risks. One crossing is very near the Arlington Main Library. The crossing on Sylvania Avenue, in Fort Worth, is less than 100 yards from a natural gas tank farm.

The nuclear waste rail cars are readily identifiable, given their huge dumbbell-like shape, size, and weight estimated by the NRC at 150 tons or more. One single railcar would carry more plutonium than was in the bomb dropped on Nagasaki, and more Cesium than was released with the Chernobyl disaster. Unfortunately, with nuclear radiation, a mask will not help, sequestering in your home wont help, and a ventilator wont help.

A fifty-mile radius is sometimes termed the area of influence, presumably because of the possibility of a major accident or terrorist attack. Such an accident could be catastrophic to the Dallas Fort Worth Metroplex and its almost 7.6 million residents.

Licensing the ISP facility would lead to tens of thousands of shipments of deadly radioactive waste coming through Tarrant County, creating risks from accidents, container cracks, and sabotage. Radioactive releases could threaten the health of residents and businesses near the railroad tracks during transport, as well as creating ongoing risks for people living near the proposed interim storage sites. It would be up to first responders in our local governments to be first on the scene, at local taxpayer expense.

Damage from radioactivity to homes, businesses, schools, etc., is usually not covered by insurance policies.

The IPS facility is a threat to the safety and economic viability of my family and my community. Please request funding for hardened storage at existing nuclear power plants until a permanent waste site is approved, preferably one owned and operated by the Federal Government, so state and local governments are not left with potentially astronomically high clean-up costs. And then find transportation routes that do not travel through high-population areas like the Dallas-Fort Worth Metroplex.

Transporting HLW through highly populated areas is an unacceptable risk.

Accidents do happen, and in Tarrant County a serious accident or terrorist attack could be catastrophic.

Letter from Fort Worth Mayor Betsy Price to Texas Governor Abbott is attached.

Federal Register Notice:

85FR27447 Comment Number:

9120 Mail Envelope Properties (CAB9aw1ugkcdSS4THHaVdxtdn0BCxaQY8jQ2_SETZffLjWdYYRw)

Subject:

[External_Sender] Docket No. 72-1050 (NRC-2016-0231), Interim Storage Partners, LLC/Waste Control Specialists, LLC Consolidated Interim Storage Facility Project Sent Date:

11/1/2020 11:32:31 AM Received Date:

11/1/2020 11:32:49 AM From:

Linda Hanratty Created By:

llswenard47@gmail.com Recipients:

Post Office:

mail.gmail.com Files Size Date & Time MESSAGE 6842 11/1/2020 11:32:49 AM NRC Waste Opposition Letters-Gov Abbott Office.pdf 97943 Options Priority:

Standard Return Notification:

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Recipients Received:

BETSY PRICE, MAYOR CITY OF FORT WORTH ¹ 200 TEXAS STREET ¹ FORT WORTH, TEXAS 76102 (817) 392-6118 ¹ FAX (817) 392-2409 October 28, 2020 Governor Greg Abbott Office of the Governor P.O. Box 12428 Austin, Texas 78711-2428

Dear Governor Abbott,

With this letter, the City of Fort Worth joins Governor Abbott and numerous communities across the State of Texas in expressing opposition to the license applications filed with the Nuclear Regulatory Commission (NRC) for consolidated interim storage of high-level regulatory waste, as proposed. Details of these applications are referenced in Gov. Abbotts letter dated September 30, 2020 (attached).

The City of Fort Worth fully recognizes there are significant challenges and risks related to management and long-term storage of high-level nuclear waste. Unfortunately, the proposed storage location in west Texas does not resolve these concerns. In particular, if the NRC approves the filed applications, the Fort Worth community and other surrounding communities anticipate added risk for our collective health, safety, and well-being from the potential transportation of high-level nuclear waste through the region.

Thank you for your consideration of our concerns.

Sincerely, Betsy Price David Cooke Mayor City Manager