ML20308A937

Comment (9930) E-mail Regarding ISP-CISF Draft EIS

ML20308A937
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	11/03/2020
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
85FR27447
Download: ML20308A937 (12)

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From: Deborah Reade <reade@nets.com>

Sent: Tuesday, November 3, 2020 2:53 AM To: WCS_CISFEIS Resource

Subject:

[External_Sender] comments on Docket ID NRC-2016-0231 ISP LLC's proposed CISF, Andrew's County TX Attachments: DWR-WCS_CISComments_11-3-20.pdf To Whom it may concern:

Please confirm that you have received the attached comments and have entered them into the Administrative Record.

Thank you, Deborah Reade Deborah Reade 117 Duran Street Santa Fe NM 87501-1817 Phone 505-986-9284 Reade@nets.com

Federal Register Notice: 85FR27447 Comment Number: 9930 Mail Envelope Properties (DBC65A50.3FF17%reade)

Subject:

[External_Sender] comments on Docket ID NRC-2016-0231 ISP LLC's proposed CISF, Andrew's County TX Sent Date: 11/3/2020 2:52:32 AM Received Date: 11/3/2020 2:53:04 AM From: Deborah Reade Created By: reade@nets.com Recipients:

Post Office: nets.com Files Size Date & Time MESSAGE 297 11/3/2020 2:53:04 AM DWR-WCS_CISComments_11-3-20.pdf 589076 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 Submitted online at:

WCS_CISF_EIS@nrc.gov November 2, 2020 RE: Docket ID NRC-2016-0231 Interim Storage Partners (ISP) LLC's Proposed Consolidated Interim Storage Facility (CISF)

Andrews County, Texas Draft Environmental Impact Statement Comments To Whom it may concern:

I am writing to submit public comments in response to the Draft Environmental Impact Statement (DEIS) (Docket ID NRC-2016-0231) regarding ISPs (AKA "WCS") application for a license to build and operate a CISF for Spent Nuclear Fuel and other High Level Waste (HLW) at their site in Andrews.

Texas and Lea County, New Mexico. This new CISF would be situated with their current low-level and mixed waste dumps, and treatment and storage facilities. Included in one of these storage facilities are many drums of explosive WIPP waste that is too unstable to transport. I am strongly opposed to adding a new facility for HLW to this already-dangerous and poorly sited group of facilities.

The federal government, the NRC, the commercial power reactors and the American public all have the same problem. High-level waste (HLW) in the form of spent nuclear fuel (SNF) is building up in reactors around the country and around the world. The government promised the reactor companies that it would solve this problem by finding a safe place to dispose this waste. The deadline for this has long since passed. Everyone except the public sees consolidated interim storage (CIS) as a nice solution which would allow this problem to be put off on future generations. But moving ahead without a safe solution for this waste is how we got here in the first placerecklessly and irresponsibly. Unfortunately, CIS is not the answer; it would simply create an even more enormous problem, create unreasonable risks, and would waste both time and money that should be spent on making storage at or near reactors safe and secure now, while we actively pursue a true solution for our nuclear waste problem.

Unfortunately, as has been too often the case with the NRC, the entire licensing approach toward adding a new CISF to the current ISP/WCS site is flawed, reckless, and corrupt. There are too many unresolved problems, unsupported assumptions and too many promises that everything will be worked out in the future at every level of this project. It is impossible to believe that NRC is evaluating this project seriously when critical risk assessments of potential accidents at the site or during transportation are eliminated because accidental releases just "won't happen." Perhaps some might remember that DOE freed themselves from their WIPP safety oversight group (The Environmental Evaluation Group or EEG) with the same assumptionthere would never be an accident at WIPP. This was just a few years before a drum exploded underground at WIPP, releasing hazardous and radioactive materials into the environment in a plume that extended more than 100 miles from the site.

All this was caused by multiple human errors and was just as obviousin fact predicted15 years before it happened as the future dangers and risks with ISP's project and site are obvious now. To claim

there will never be any accidents resulting in a releaseespecially when NRC is also allowing thin-walled and damaged containers to be usedis really quite incredible, in the literal sense of the word.

Reckless, in fact. People at NRC can't be that stupid, so I can only conclude that the people in control just don't care or have been corrupted. Don't care about your fellow citizens along the routes or at the final destination in Texas. Allowing this skimpy plan and shoddy project to go forward almost guarantees that an accident with a release will occur in at least one of the 20 cities along the transport routes. We don't need terrorists to attack us; our government happily puts us at high risk of nuclear explosion all on its own.

Both the applicant and NRC seem to thrive on magical thinking since there is no science-based or technically based proof in the DEIS that any of the many major problems with this project can or will be solved anytime soon. The EIS must correct this shortfall.

PUBLIC PROCESS So far NRC has provided no in-person meetings for this latest public process but only online meetings.

This has discriminated against the very people most affected by the project in Andrews County, Texas and Lea County New Mexico. (Note that ISP discharges its effluent into Lea County, New Mexico just a few miles from the town of Eunice.) The population on both sides of the border includes large numbers of minority and LEP persons and low-income people.

It has been known for years that older, poorer, minority and rural people often have inadequate internet connection, less familiarity with online processes, and less access to computers and the internet. This describes much of the population around the ISP/WCS site. Poor people can't spend a lot of money on data even if they have online access through their phones. And in this area of Texas and New Mexico connections can be very poor. The New Mexico Environment Department has come to understand this and has been providing printed materials and in-person meetings for years in this area to make up for the difficulties with online access. The NRC needs to understand and provide for this as well.

But clearly, NRC has ignored this and cut out the very people who should, perhaps, have the most to say about the facility. Both New Mexico's and Texas' Governors and many in higher levels of both state governments have also questioned this practice of eliminating in-person meetings, wondering why the rush? Why can't we wait another year until it's safe to include all the affected communities in in-person meetings? It surely feels like dealing with public participation is just a bother to NRC and that you've already made up your minds about the project. We are just an inconvenient waste of your time.

The lack of translation of materials and the lack of in-person meetings also make it clear that again, NRC, really doesn't care about LEP persons or the minority people living near the site or along the routes. This is discriminatory.

TRANSPORTATION NRC seems content to ignore facility transportationyet this is the phase of the project that affects most people as it will impact a majority of states and will probably go through at least 20 major cities. We have learned from WIPP studies that the transportation phase can create almost all of the negative health effects of an entire project during normal operations. Though WIPP waste is transported by truck and WCS transportation would primarily be by rail, studies to see what and where effects would occur along the routes are critical and must be contained in the EIS. Most WIPP effects occur at rest and truck stops



where workers can, over time, receive many times the dose a nuclear worker is allowed. The same thing could occur at rail yards and stops. Risks from accidents would also follow along the routes, thus putting many millions of Americans at risk.

(Discrimination in the pattern of these risks will be discussed below.)

The EIS application must designate transportation routes and include an array of potential impacts of accidents or terrorism incidents that could occur along these routesa detailed risk assessment covering both city and rural areas. ISP is claiming that accident damage would be minimal, but that is clearly just more magical thinking. Take a look at the picture to the leftalong a potential transportation route to ISP/WCS. Would damage really be minimal to the flimsy canisters in this scenario?

NRC seems to be following several unsupported assumptions in its approach to the safety of facility transportation. First, it is assumed that there will be no through-wall cracks in the thin-walled canisters.

Second, it is assumed that there will be no transportation accidents with canister leaks.

Finally, it is assumed that the damage caused to the canisters each time the waste is transferred will be insignificanteven though the waste will be transferred at least 4 times to ISP/WCS and 4 more times if transported to Yucca Mountain Canisters: It is quite amazing that NRC has the nerve to allow the use of thin-walled, welded canisters that can't be fully inspected or repaired and just pretend that is okay. The rest of the world is using canisters more than 10 times as thick that are repairable. Evidence has already shown that through-wall cracks are possible in a very short time in the thin-walled canisters. With the huge radioactive load inside each one of these canisters, a breach during transportation could wipe out large parts of a major city and completely obliterate a small town. But heyYou're just going through the motions for this entire public process. The outcome is already decided and you probably haven't even read my comments this far.

With thousands of canisters and 40 to 60 years of shipping, to assume there will never be an accident with a breach is just not credible. The project could even extend longer. Train accident statistics alone show that horrendously powerful accidents with fires can occur. With materials this dangerous, a conservative approach is required, yet NRC is rushing forward in a reckless way, ignoring the science and following what they want things to bethe very definition of magical thinking.



And what is the ISP plan if a canister does arrive measurably leaking? The DEIS doesn't include hot cells or Dry Transfer Systems at the facility. This is a recipe for disaster. The EIS must plan for the high consequence/low probability event. Pools should remain if any waste remains on site. Hot cells should be constructed wherever there is dry storage and thicker casks that can be inspected and repaired should be substituted for the weak, thin-walled canisters. All of this must be addressed in an EIS.

Railway transportation: ISP's boosters give many reasons why the huge weight of the canisters is not a problem for railway transportation. However, again, this is wishful thinking. Many of our rail beds nationwide are in such poor condition currently that trains must crawl along so as not to derail. Trestles and other structures are often old and weak. Look at the picture above showing a real train accident on a trestle in southeastern New Mexico last yearpossibly along the actual route. Do you really think the trestle above could withstand the extreme weight of the nuclear railcars trip after trip after trip? This problem of rail infrastructure has been known for years. A comprehensive study of the condition of the railbeds, trestles, bridges etc. must be part of the EIS and must include a cost estimate of the price of repairing and reconstructing this infrastructure to make it able to support the shipment of 10,000 super-heavy casks. Who will pay for this upgrade must also be described. Will it be left to the railroads? To the states? To the reactor sites? Construction of the facility itself should not start until all the transportation infrastructure is in place. Though HLW transportation has occurred in the past, this will take place on a much larger and more frequent level. Will there need to be dedicated rail cars and other items as they become irradiated from multiple shipments? How are railway employees, stations and switching points protected from irradiation? Radiation will be coming through the walls of the shipping containers and it won't be less than a chest X-ray. All this must be included in the EIS.

ISP/WCS IS AN UNSUITABLE SITE AND FACILITY FOR HLW STORAGE

1. Emergencies: The DEIS does not adequately cover emergencies at the site including how to transfer radioactive waste from a damaged canister to a new canister. There does not appear to be a hot cell and equipment planned to be in place to handle such events. The EIS needs to describe all potential problems and emergencies, include risk assessments of such events and include a plan to have equipment, facilities and trained personnel in place to deal with such events, both at the site and during transportation, before waste even begins to be transported to the facility. WIPP has special emergency teams that coordinate with the State of New Mexico in accident drills. HLW is even more radioactive than WIPP waste so the EIS must include the same kind of safety planning. If ISP feel an event does not warrant being included in their emergency plan, they must justify not including it. Just because some events are low probability, if the consequences are high enough, even those events must be included in their emergency plan. All of this should be in the EIS.

2. Economic effects: An accident at ISP/WCS or during facility transportation to the site could also wipe out major current traditional economies for the area and even major portions of revenue for the states of Texas and New Mexico. The current enormous oil and gas production is a primary economic support of both states through taxes and royalties. Agriculture, ranching and tourism also bring in hundreds of millions of dollars in income. A HLW release into the air, water or soil would have catastrophic repercussions on all these industries.

Oil & gas development: Oil and gas development is a special case. The Permian Basin, where the new ISP CISF would be sited, is the largest producing oilfield in the worldsurpassing Saudi Arabia's Ghawar Field, according to the Governor of Texas. (Unsurprisingly, he is not a fan of this project.) As



the Governor so clearly states, "...[T]he Permian Basin is a significant economic and natural resource for the entire country, and the proposed storage facilities would place America's recovering economy and energy security at great risk." An accident and release from the ISP CISF could destroy a large part of this oil and gas industry, an industry that this nation still needs.

3. Fracking & other oil & gas risks to the HLW: Additional risks that need to be covered in the EIS are risks from to the facility and to the HLW from fracking and fluid injection in the nearby oil and gas fields. Fluid injection is likely to cause earthquakes on a level that has been seen in Oklahoma already, or worse. Because of the enormous number of wells in the area (290,000 active wells in Texas and new Mexico), this is an increasing problem. The EIS must contain adequate studies of seismic events of different kinds and how they could affect un-cracked as well as partially and through-wall cracked canisters. Could casks be damaged? could a leak occur at the CISF? It is not enough for ISP/WCS to figure this out on the fly after a cask has fractured and radiation is leaking out with no hot cell or emergency equipment at hand. An increase in frequency and strength of such seismic events must be assumed as they are already following that pattern. Modeling in the EIS must incorporate these geological events into a study of the suitability of the site and must extrapolate into the future for increased fracking, fluid injection, and seismic events to see whether the site is and will be safe for the storage of spent fuel rods and HLW.

4. Increased risk of fire, explosion and radioactive release at ISP/WCS: The ISP site is currently storing at least 73 containers of unstable nitrate-contaminated transuranic waste. These drums are part of the same waste stream and contain the same materials that were incorrectly processed at Los Alamos National Laboratory (LANL) for disposal at WIPP. They are just like the drum that exploded underground and are considered too unstable for transport.

The drums at WCS are not being cooled, though they are being monitored. They have already had to be moved once, under emergency conditions, into a different storage configuration at the site because they started to overheat. The danger that one of these drums could explode is high. To have tens of thousands of tons of HLW also stored in the same waste facility is to invite a repetition of the Kyshtym disaster that occurred in the Soviet Union in 1957a HLW explosion that released two million curies of radioactivity, contaminated a thousand square kilometers and forced the evacuation of more than 10,000 people. This disaster was caused by human error and nitrates very similar to the nitrates that are in the stored, explosive, WIPP waste at WCS. The nitrates and radioactive waste at Kyshtym were being cooled when one of the cooling mechanisms broke and was not repaired for a year. The wastes were heated from by the sun and an explosion was set off by a chance spark in what had become a highly explosive mixture. (EEG 48: An Assessment of the Flammability and Explosion Potential of Transuranic Waste, pages 48-51, by Matthew Silva)

What emergency plan does ISP/WCS have in place to deal with a drum that starts to heat up, indicating it might explode, besides moving it again? What plan do they have in place if a drum actually does explode? or more than one drum? How could this affect HLW stored there and what is the worst case scenario? How the storage of these explosive drums affects the risk to the fuel rods and other HLW stored at the CISF must be analyzed in the EIS.

I believe that it is incompatible to store HLW in the same facility where you are storing highly unstable, potentially explosive drums of mixed radioactive waste. Even if WCS takes all reasonable precautions, as we have learned from the WIPP accidents, human error can cause major consequences.



In fact, human error in packing the drums at LANL is what caused the original problemthe transforming of drums of waste into bombs. Even the most basic risk assessment will tell you that the risk increases significantly for human error to cause an accident, after 10-15 years and that is exactly when the WIPP drum exploded. There are no plans at this time to move these drums of potentially explosive transuranic waste out of ISP/WCS, now or 15 years from now. There is no way to predict when, if ever, the drums will be able to be moved. It would be irresponsible, even to consider licensing ISP/WCS to store spent fuel rods as long as these unstable WIPP drums are present at the same site.

5. Contaminating New Mexico groundwater: Because WCS' effluent is routed into New Mexico instead of into Texas, WCS received a groundwater discharge permit for its facility from the State of New Mexico. This permita monitoring permitis a completely phony permit. It is a monitoring permit that is set up to have no real monitoring of groundwater and no analysis for contaminants during the operational, closure and post-closure phases. The permit ignores any problems caused by a 100 year storm completely, evidently assuming that it will never occur, and does not require vadose zone monitoring which is more appropriate for the unsaturated shallow area where the discharge occurs, than a monitor well that will never have any water in it. Neither the regulator nor the applicant ever told the public that the explosive mixed-waste transuranic WIPP drums are being stored there even after this was pointed out to them.

With this permit NMED and WCS have worked together to create what they themselves describe as a "compromise permit" that will do nothing to protect New Mexico groundwater now or in the future. The regulations do not include any "compromise permits," so NRC needs to look very closely at ISP/WCS as the company that worked to remove monitoring and protections that were in a previous draft permit to end up with such a phony permit that does nothing. A company that is willing to do this would, in my opinion, be willing to skimp on protections for HLW storage as well. Analysis of the effects of this "empty" groundwater discharge permit on the local people and environment and an analysis of the ethical implications of WCS working out such an arrangement to avoid their discharge responsibilities must be included in the EIS.

6. Groundwater at the site: The EIS must also look carefully into the risk of groundwater contamination at the site since the entire TCEQ Radioactive Materials Division in Texas recommended denying a license for even low level radioactive waste disposal there because of the high likelihood of groundwater to intrude into the proposed disposal units. When TCEQ ignored their recommendation and went ahead with site approval anyway, several of the scientists resigned. This is yet another reason why the WCS site is unsuitable for HLW storage. Adding spent fuel rods in possibly cracked canisters even in a shallow configuration could allow water to access the fuel assemblies. Any amount of unborated water in contact with the fuel assemblies could lead to one or more HLW explosions and a large radioactive release.

When WIPP was sited, there were numerous hydrogeological and geological studies of the area to study site suitability. ISP is planning shallow, rather than deep, storage but since some studies put the water table at 14 feet, the HLW could still be affected. Because the original TCEQ studies for WCS were ignored, NRC must require new, up-to-date studies in the EIS and not ignore them if they show that the water table could impinge on the waste.



CANISTERS Again, we come to the problem of the canistersthese thin-walled canisters, that can't be inspected or repaired. But now we are looking at them at the proposed facility, not during transportation. Still, NRC obdurately claims that there will never be an accidental release.

Since these will be sitting in shallow storage for 40 to 60 years and possibly longer, whether there will be leaks and cracks during this time is of paramount importance. With possible through-wall cracks in as little as 16 years, and damage during loading into storage quite high, the likelihood of at least one of the 10,000 canisters having a through-wall crack seems extremely high. But again, NRC is ignoring the prudent and conservative approach and is assuming that not a single one will ever crack nor will a single canister ever leak. Again, this is incredible. Not credible.

It is reckless to allow canisters to be used at all that can't be inspected and can't be repairedespecially when thick-walled, safer canisters that can be both fully inspected and repaired are already available. It is reckless and irresponsible to have no plan for a hot cell at ISP/WCSthe only way to repair canisters that can be fixed. This again assumes there will never be a problem with the canisters and there will never be even a single instance of serious human error.

Instead, what is more likely to be the case is something like what occurred at the WIPP project where for 15 years the HEPA filters sat in their HEPA filter banks where everyone had forgotten to fill in the spaces between each filter. When the explosion did occur, the release went out through the filters as planned, but it also went out straight into the environment through the un-filled spaces between the filters. This is human error.

PERMANENT REPOSITORY The DEIS assumes that Yucca Mountain will open as a HLW disposal repository. However, this is disingenuous. There is no certainty that Yucca Mountain will ever open or that the canisters will be in any shape to be transported to it if it does. After 40 or 60 years the canisters might be too delicate to move again, or because the risk of another 10,000 or more shipments across the country plus perhaps 4 or more transfers, might by then be recognized as extremely dangerous under any circumstances, there is a very real possibility that this cheaply built "storage" facility might become a permanent disposal facility. Then we will have a shallow, permanent HLW disposal facilityforeveron the Texas-New Mexico border. Then these delicate canisters will need to remain "perfect" for hundreds of thousands of years as will their monitoring and maintenance. If we need to isolate transuranic waste deeply underground for eternity, why is it fine to HLW spent fuel assemblies with their tops practically at ground level? That ISP will become a permanent repository is a credible outcome and must be adequately addressed in the EIS.

Another unsupported assumption is that NRC and ISP can get Congress to change the law that now prohibits DOE ownership & transportation of the HLW and prohibits a CIS facility at all until a permanent repository actually exists. This law was written like this exactly so a "temporary" CIS does not become a permanent waste dump and NRC is trying to find a way around this. Again, why the rush?

Why not follow proper procedure and either create a permanent repository first as the law requires, or change the law first and then start the licensing process for a CIS facility? The EIS must justify how ISP and NRC can justify going ahead with this process when it is currently illegal.

Another possibility is that even if Yucca Mountain does open, as mentioned above, the canisters will be too delicate to be transported that far, but maybe they could still be transported just a few miles to WIPP.

New Mexico was promised that WIPP would never take HLW but right now DOE is working to do just that by expanding WIPP and trying to erase any ending date. If the canisters start to crack and leak, this will seem like a great alternative to everyone but nearby affected communities in Texas and New Mexico who will have to make HLW a permanent part of their lives for generations to come. Again, that WIPP becomes a permanent disposal site for the ISP HLW is a credible outcome and must be addressed in the EIS.

ENVIRONMENTAL JUSTICE Siting: We have touched above on some of the discrimination that is occurring in the public process, but it is just one example of the discriminatory nature of the entire project. NRC should have had at least as many scoping hearings, spread out along the routes, as were provided for the Yucca Mountain hearings.

Notice and information should have been provided throughout the country and in a variety of languages so that Low English Proficiency (LEP) persons caould participate equally. Or does NRC feel that only English speakers should participate? Does NRC believe that people whose lives and livelihoods could be destroyed or snuffed out should have no say or even any information about such a project just because they don't speak English well or don't have access to information and meetings online? Evidently.

We've been through this before in southeast New Mexico, and discriminatory actions by NMED resulted in the filing of a Title VI complaint and an investigation of discrimination by EPA. So far NRC looks to be going along in exactly the same way, and this is not acceptable. It is sad that NRC seems to be stuck back 20 or 40 years ago in their understanding of equality and inclusion. But then, perhaps the point is to keep as many people from participating as possible. I believe that to make up for the discriminatory past process, that NRC must extend the EIS process both in time and location with more information meetings when they can be held in person, adequate translation of materials (what is available now is pitiful), and a truly inclusive process. So far, like the project itself, the public process has been both discriminatory and cheap.

Will NRC choose to allow siting of this very dangerous facility not only in a geologically unstable and high resource area, but also in an area that is already overburdened by other polluting and contaminating facilities and home to a large, low-income, minority population?

1.

Background:

On top of high levels of naturally occurring arsenic in the soil, southeastern New Mexico and West Texas have been subjected to pollution and contamination from the WIPP project, URENCO, WCS, the Gnome-Coach Experimental Test Site (all radioactive or mixed projects). An additional hazardous waste dump, Triassic Park, is also permitted near the state border. VOCs from oil refineries are spread far and wide by the high winds. Some of the land has been also contaminated by radioactive particulates from the 1945 Trinity atomic bomb test and then the WIPP explosion and release in 2014. Solid waste dumps, oilfield "landfarms," massive oil and gas development and the occasional superfund site further burden the area near ISP.

2. Disparate impact (siting): Large numbers of people of color and LEP people live both near the site and within 50 miles of the site. Large numbers of people of color live or work near the railroad lines where the waste will travel. It is the poverty, discrimination, lack of access to health care and other social factors combined with the high burden of contamination and pollution from a multiplicity of hazardous, toxic and radioactive facilities already in the site area that have resulted in some of the

highest cancer mortality in the state. This disparate impact has existed for decades. To add another potentially contaminating facility to the area without mitigating the problems that already exist would be highly discriminatory. It is not conservative to assume there will never be a release. At least one release must be assumed and its burden on the surrounding population and any disparate impacts must be modeled in the EIS.

Because ISP/WCS discharges its effluent into New Mexico, effects from this must be included in the EIS. Modeling must include the additional risk caused by the useless "compromise" discharge permit that the New Mexico Environment Department has approved for WCS.

3. Disparate impact (transportation): Both disparate impact studies of the facility and of facility transportation must be done. Transportation must be included for both accidents and impacts from normal operations. In addition to irradiation, diesel exhaust from the additional rail traffic can alone cause a disparate negative health impact on people living or working near the routes. Understanding the extent of this exposure and studying whether environmental justice communities along the route would be disparately impacted is critical. Also, the accident risk itself, both at the site and during transportation is possibly discriminatory as it is likely a high percentage of minority and low-income people live near railroad routes not only in Texas and New Mexico but also across the country. Whether the risk burden of an accident falls more heavily on these environmental justice communities must also be studied and modeled in the EIS.

ALTERNATIVES NRC must choose the no-action alternative for this project. It is a project that has been conceived in haste and is being continued as cheaply as possible in a reckless and irresponsible way. You can't do Nuclear Safety Lite. Real safety is not cheap. This "Safety is a Journey" approach was the attitude at Los Alamos National Laboratory (LANL) and WIPP that resulted in an explosion, a radioactive release and the contamination of 22 individuals. The same reckless attitude with this project could kill and disable hundreds of thousands and render West Texas and southeast New Mexico uninhabitable.

This project is based very little on scientific and technical knowledge and a lot on fantasy, magical thinking, and NRC's choice to ignore the many red flags that this project waves. This is a recipe for disaster. Huge explosions do happen and do destroy thousands or tens of thousands of people and buildings. This is what happened in Beirut when a fertilizer explosion recently destroyed a huge swath of the city. This was caused by ignorance, incompetence and corruption. If we allow the same in our project analysis, our EIS, we should expect an equally bad outcome.

This approach, combined with NRC's refusal to include anyone but the most minimal number of communities in the public process shows that this is a political project that NRC is pursuing to show the reactor sites that the government is at long last meeting their commitments. Somehow the people of this country have been forgotten, as risks to those living along the routes or near the CIS site are being completely ignored. This is discrimination.

NRC must stop wasting time on ISP's proposal and immediately require thick-walled containers that can be fully inspected and repaired. It is true that there are some reactor sites that are not suitable for dry cask storage facilities for various reasons. But most of the sites are suitable. HLW should remain at the site or be moved to a dry cask storage site built as close as possible to the original site to minimize

transportation risks as required by the NWPA. (And built in a suitable locationnot, for instance, at what is now or soon will be the high tide line, as they've chosen to do at San Onofre.)

Hotcells should be maintained safely and securely at sites where they currently exist or be built at the nearby new dry cask storage sites so that inspection, maintenance and repair can proceed normally and without transportation of leaking containers. Reactor Pools should remain viable as long as there is waste on site. Without these capabilities, no HLW storage or disposal facility is truly safe. All of this must be addressed in the EIS.

We must then as a nation work on a real solution to the, admittedly significant, problems of this waste.

Sincerely, Deborah Reade 117 Duran Street Samta Fe. New Mexico 87501 reade@nets.com 11-2-20