ML20308A799
| ML20308A799 | |
| 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: ML20308A799 (8) | |
Text
From:
MoJo <mollypj@yahoo.com>
Sent:
Friday, October 30, 2020 4:49 PM To:
WCS_CISFEIS Resource
Subject:
[External_Sender] Docket ID NRC-2016-0231 (Draft Environmental Statement)
Attachments:
Comments on WCS DEIS due Nov 22 2020pdf.pdf SLO Mothers for Peace
- PO Box 3608
- San Luis Obispo, CA 93403
- https://mothersforpeace.org October 28, 2020 Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001, ATTN: Program Management, Announcements and Editing Staff Re: Interim Storage Partners LLCs License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas -- Docket ID NRC-2016-0231 (Draft Environmental Statement)
NRC:
On November 19, 2018, San Luis Obispo Mothers for Peace (SLOMFP) submitted scoping comments on the Application, Environmental Report, Safety Analysis Report and Emergency Response Plan presently pending before the Nuclear Regulatory Commission (NRC), submitted by Interim Storage Partners/Waste Control Specialists LLC. to transport up to 100,000 metric tons of spent fuel, high-level radioactive waste, from nuclear reactors around the country to western Texas. We continue to stand by the following statements:
SLOMFP does not consent to the irradiated nuclear fuel that has been produced by the Diablo Canyon nuclear reactors being sent to another community.
The movement of over10,000 canisters of highly radioactive waste through thousands of communities is unacceptable. There should be no transport until a viable repository is in place to completely isolate the waste from the environment.
SLOMFP asserts that it is morally repugnant to send this deadly waste on our rails, highways to a poor community of color.
The site would likely become a national radioactive waste dumping ground.
Assuming Yucca Mountain will be the permanent dump, is unacceptable.
Yucca Mountain is Western Shoshone land. The 33-year long attempt to dump radioactive wastes there is a violation of the Treaty of Ruby Valley of 1863, the highest law of the land. It is also an Environmental Justice violation, considering the deadly radioactive fallout already suffered by the Western Shoshone, and others downwind and downstream from the NV (Nuclear Weapons) Test Site.
Diablos waste must continue to be stored on-site as safely and securely as possible until a permanent repository can be found. More robust storage containers and systems are needed at existing reactor sites.
SLOMFP is disappointed that the Draft Environmental Impact Statement does not adequately address the concerns expressed in our scoping comments.
SLOMFP Requests Public Meetings Be Held As Soon As Safe To Do So:
Public meetings should be held in affected communities and along all the potential routes, especially in Texas. SLOMFP demands that the NRC:
Postpone all hearings re: CISF applications until it is safe to gather in large groups, Expand the hearings to include major cities along the likely routes, including San Luis Obispo, CA, and Leave the public comment period open until at least 180 days beyond all public hearing dates. These dangerous proposals for CIS facilities merit full participation by all impacted peoples. It would be unconscionable for the NRC to ramrod this process through during this pandemic! Without full public participation, this National Environmental Policy Act (NEPA) process would lack legitimacy and credibility.
The State of Texas Doesnt Want It: The governor of Texas has expressed concern about the location of placing radioactive waste in this area. He said:
Allowing interim storage of spent nuclear fuel and high-level nuclear waste at sites near the largest producing oilfield in the world will compromise the safety of the region.
This Proposal is a Clear Case of Environmental Injustice: The region around proposed site has a high proportion of low income, Latin American residents, and is already heavily burdened with nuclear activities (radioactive waste
dumping, uranium enrichment, etc.) and dirty fossil fuel industries (widespread, heavily polluting oil extraction and natural gas fracking).
This Proposal Is Contrary to Current Law: This very important issue was not addressed in the DEIS: It is still true that CIS or Consolidated "Interim" Storage Facilities are illegal under federal law. Under the law, no "interim" or "temporary" storage site is allowed unless there is an operating final repository.
The site, although not designed or licensed for permanent isolation of the waste, could too easily become a de-facto permanent site and could hamper efforts to develop less risky storage systems and permanent disposal.
The Impacts of Permanent Storage Must Be Analyzed: The DEIS incorrectly assumes only 40 years of storage even though the waste could be at the site far longer than that, potentially indefinitely. The DEIS incorrectly assumes there will be a permanent repository elsewhere, despite the fact that the only proposed permanent repository at Yucca Mountain has been cancelled. The ISP/WCS application does not provide protections for long term or permanent isolation and the DEIS ignores this. The more-likely reality, that the waste will be at the site for much longer than the 40-year license period, is not addressed in the DEIS. This puts the air, water, soil and ecosystem at long term risk from radioactivity. The EIS must analyze the impacts of this interim storage becoming a dangerous de facto permanent facility.
Hotter High-Level Waste: High burnup fuel was mentioned only once in the DEIS, and in an off-hand manner. We reiterate: NRC should include full evaluation of storage and transport of high burnup fuel. It is a significant portion of the waste that would go to WCS/ISP facility.
Earthquakes: The DEIS played down the possibilities and effects of earthquakes in the region. The Permian Basin, in which this facility would rest, is a region of oil drilling and fracking. It has been scientifically proven that fracking can and does cause earthquakes. Placing a high-level radioactive waste storage in such an area is simply inviting disaster.
Severe Weather and Climatic Conditions: The site of the proposed CIS facility in Andrews County, Texas is subject to severe weather and climatic conditions that could endanger nuclear waste containers. Storing this deadly waste above ground in extreme desert temperatures for decades will only lead to dangerous cracks and leaks, and wont help get the nation closer to a viable permanent site. Extreme temperatures, wind and sand storms, wildfires, lightning strikes and storms, floods, and tornadoes can all impact the site.
Transport Dangers: The issue of transportation of deadly waste from all over the United States is, once again, not addressed in the DEIS. If NRC approves the license, thousands of rail cars of deadly radioactive waste would move across the nation for over 20 years. Millions of people who live near ports and
railroad tracks across the country would also be put at risk from leaks, accidents, or sabotage from irradiated fuels rods. Exposure to radiation leads to cancers, birth defects, and death. In the case of Diablo Canyon, the possibility of the waste being barged on the ocean along our coastline is especially troubling. As representatives of communities that will be impacted by the transportation of waste from Diablo Canyon to any repository we object to the unnecessary movement of this very dangerous material.
Cracked and Leaking Casks Must Be Addressed: The DEIS does not analyze exactly how radioactive waste from a cracked and leaking canister would be handled, since there is no wet pool or hot cell at the site. Inner canisters will have to be transferred multiple times (from on-site storage dry casks, to radiation shielded transfer casks, to transport/shipping casks, to transfer casks, to CISF storage casks}. Yet, NRC is not requiring Dry Transfer Systems (DTS), nor any type of hot cell, so there will be no way to deal with failed fuel or containers, as well as leaks or contamination.
San Luis Obispo Mothers for Peace recommends the No Action Alternative addressed in the DEIS.
Sincerely, San Luis Obispo Mothers for Peace Board members:
Jane Swanson/President Elaine Holder Carole Hisasue Jill ZamEk Linda Seeley Marty Brown Molly Johnson Nancy Norwood Sherry Lewis PDF attached
Federal Register Notice:
85FR27447 Comment Number:
9815 Mail Envelope Properties (1150959527.500372.1604090928264)
Subject:
[External_Sender] Docket ID NRC-2016-0231 (Draft Environmental Statement)
Sent Date:
10/30/2020 4:48:48 PM Received Date:
10/30/2020 4:49:02 PM From:
MoJo Created By:
mollypj@yahoo.com Recipients:
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mail.yahoo.com Files Size Date & Time MESSAGE 8267 10/30/2020 4:49:02 PM Comments on WCS DEIS due Nov 22 2020pdf.pdf 286229 Options Priority:
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Recipients Received:
SLO Mothers for Peace PO Box 3608 San Luis Obispo, CA 93403 https://mothersforpeace.org October 28, 2020 Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001, ATTN: Program Management, Announcements and Editing Staff Re: Interim Storage Partners LLCs License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas -- Docket ID NRC-2016-0231 (Draft Environmental Statement)
NRC:
On November 19, 2018, San Luis Obispo Mothers for Peace (SLOMFP) submitted scoping comments on the Application, Environmental Report, Safety Analysis Report and Emergency Response Plan presently pending before the Nuclear Regulatory Commission (NRC),
submitted by Interim Storage Partners/Waste Control Specialists LLC. to transport up to 100,000 metric tons of spent fuel, high-level radioactive waste, from nuclear reactors around the country to western Texas. We continue to stand by the following statements:
. SLOMFP does not consent to the irradiated nuclear fuel that has been produced by the Diablo Canyon nuclear reactors being sent to another community.
. The movement of over10,000 canisters of highly radioactive waste through thousands of communities is unacceptable. There should be no transport until a viable repository is in place to completely isolate the waste from the environment.
. SLOMFP asserts that it is morally repugnant to send this deadly waste on our rails, highways to a poor community of color.
. The site would likely become a national radioactive waste dumping ground.
. Assuming Yucca Mountain will be the permanent dump, is unacceptable. Yucca Mountain is Western Shoshone land. The 33-year long attempt to dump radioactive wastes there is a violation of the Treaty of Ruby Valley of 1863, the highest law of the land. It is also an Environmental Justice violation, considering the deadly radioactive fallout already suffered by the Western Shoshone, and others downwind and downstream from the NV (Nuclear Weapons) Test Site.
. Diablos waste must continue to be stored on-site as safely and securely as possible until a permanent repository can be found. More robust storage containers and systems are needed at existing reactor sites.
SLOMFP is disappointed that the Draft Environmental Impact Statement does not adequately address the concerns expressed in our scoping comments.
SLOMFP Requests Public Meetings Be Held As Soon As Safe To Do So: Public meetings should be held in affected communities and along all the potential routes, especially in Texas. SLOMFP demands that the NRC:
. Postpone all hearings re: CISF applications until it is safe to gather in large groups,
. Expand the hearings to include major cities along the likely routes, including San Luis Obispo, CA, and
. Leave the public comment period open until at least 180 days beyond all public hearing dates. These dangerous proposals for CIS facilities merit full participation by all impacted peoples. It would be unconscionable for the NRC to ramrod this process through during this pandemic! Without full public participation, this National Environmental Policy Act (NEPA) process would lack legitimacy and credibility.
The State of Texas Doesnt Want It: The governor of Texas has expressed concern about the location of placing radioactive waste in this area. He said: Allowing interim storage of spent nuclear fuel and high-level nuclear waste at sites near the largest producing oilfield in the world will compromise the safety of the region.1 This Proposal is a Clear Case of Environmental Injustice: The region around proposed site has a high proportion of low income, Latin American residents, and is already heavily burdened with nuclear activities (radioactive waste dumping, uranium enrichment, etc.) and dirty fossil fuel industries (widespread, heavily polluting oil extraction and natural gas fracking).
This Proposal Is Contrary to Current Law: This very important issue was not addressed in the DEIS: It is still true that CIS or Consolidated "Interim" Storage Facilities are illegal under federal law. Under the law, no "interim" or "temporary" storage site is allowed unless there is an operating final repository. The site, although not designed or licensed for permanent isolation of the waste, could too easily become a de-facto permanent site and could hamper efforts to develop less risky storage systems and permanent disposal.
The Impacts of Permanent Storage Must Be Analyzed: The DEIS incorrectly assumes only 40 years of storage even though the waste could be at the site far longer than that, potentially indefinitely. The DEIS incorrectly assumes there will be a permanent repository elsewhere, despite the fact that the only proposed permanent repository at Yucca Mountain has been cancelled. The ISP/WCS application does not provide protections for long term or permanent isolation and the DEIS ignores this. The more-likely reality, that the waste will be at the site for much longer than the 40-year license period, is not addressed in the DEIS.
This puts the air, water, soil and ecosystem at long term risk from radioactivity. The EIS must analyze the impacts of this interim storage becoming a dangerous de facto permanent facility.
Hotter High-Level Waste: High burnup fuel was mentioned only once in the DEIS, and in an off-hand manner. We reiterate: NRC should include full evaluation of storage and transport of high burnup fuel. It is a significant portion of the waste that would go to WCS/ISP facility.
Earthquakes: The DEIS played down the possibilities and effects of earthquakes in the region. The Permian Basin, in which this facility would rest, is a region of oil drilling and fracking. It has been scientifically proven that fracking can and does cause earthquakes.2 Placing a high-level radioactive waste storage in such an area is simply inviting disaster.
1 Texas Gov. Greg Abbott joins opposition to nuclear waste project in New Mexico - Carlsbad Current-Argus, October 6, 2020 2 Fault activation by hydraulic fracturing in western Canada -- Science 16 Dec 2016: Vol. 354, Issue 6318, pp. 1406-1409 -
Authors: Xuewei Bao, David W. Eaton
Severe Weather and Climatic Conditions: The site of the proposed CIS facility in Andrews County, Texas is subject to severe weather and climatic conditions that could endanger nuclear waste containers. Storing this deadly waste above ground in extreme desert temperatures for decades will only lead to dangerous cracks and leaks, and wont help get the nation closer to a viable permanent site. Extreme temperatures, wind and sand storms, wildfires, lightning strikes and storms, floods, and tornadoes can all impact the site.
Transport Dangers: The issue of transportation of deadly waste from all over the United States is, once again, not addressed in the DEIS. If NRC approves the license, thousands of rail cars of deadly radioactive waste would move across the nation for over 20 years. Millions of people who live near ports and railroad tracks across the country would also be put at risk from leaks, accidents, or sabotage from irradiated fuels rods. Exposure to radiation leads to cancers, birth defects, and death. In the case of Diablo Canyon, the possibility of the waste being barged on the ocean along our coastline is especially troubling. As representatives of communities that will be impacted by the transportation of waste from Diablo Canyon to any repository we object to the unnecessary movement of this very dangerous material.
Cracked and Leaking Casks Must Be Addressed: The DEIS does not analyze exactly how radioactive waste from a cracked and leaking canister would be handled, since there is no wet pool or hot cell at the site. Inner canisters will have to be transferred multiple times (from on-site storage dry casks, to radiation shielded transfer casks, to transport/shipping casks, to transfer casks, to CISF storage casks}. Yet, NRC is not requiring Dry Transfer Systems (DTS), nor any type of hot cell, so there will be no way to deal with failed fuel or containers, as well as leaks or contamination.
San Luis Obispo Mothers for Peace recommends the No Action Alternative addressed in the DEIS.
Sincerely, San Luis Obispo Mothers for Peace Board members:
Jane Swanson/President Elaine Holder Carole Hisasue Jill ZamEk Linda Seeley Marty Brown Molly Johnson Nancy Norwood Sherry Lewis