ML20309A003
| ML20309A003 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 11/02/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR27447 | |
| Download: ML20309A003 (71) | |
Text
From:
Adrian Shelley <ashelley@citizen.org>
Sent:
Monday, November 2, 2020 4:56 PM To:
WCS_CISFEIS Resource
Subject:
[External_Sender] FW: Let's talk in a bit about comments - thanks Attachments:
Public Citizen and SEED - WCS Comments Docket # NRC-2016-0231.pdf Adrian Shelley l Director, Texas Office Public Citizen l Protecting Health, Safety and Democracy o: 512.477.1155 l c: 713.702.8063 l ashelley@citizen.org 309 East 11th Street, Suite 2, Austin, TX, 78701 http://www.citizen.org/texas From: KarenD Hadden Sent: Monday, November 02, 2020 12:20 PM To: Adrian Shelley
Subject:
Let's talk in a bit about comments - thanks Hi Adrian, Let's talk soon if you have a moment. Our scoping comments are attached.
The full-length Draft Environmental Impact Statement can be found at here (And at NoNuclearWaste.org.) A 20-page overview is also available here Email comments to the NRC to WCS_CISF_EIS@nrc.gov.
Reference Docket ID NRC-2016-0231 in your message.
Thanks, Karen Hadden 512-797-8481 www.NoNuclearWaste.org
Federal Register Notice:
85FR27447 Comment Number:
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Sustainable Energy and Economic Development (SEED) Coalition 605 Carismatic Lane xx Austin, Texas 78748 1
May Ma, Office of Administration, Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Via email to WCS_CISF_EIS@nrc.gov.
RE: Docket # NRC-2016-0231 Waste Control Specialists LLCs Consolidated Interim Spent Fuel Storage Facility Project November 19, 2018
Dear May Ma and NRC Application Review Staff:
Public Citizen, Inc. and the Sustainable Energy and Economic Development (SEED)
Coalition respectfully submit the following scoping comments regarding the license application of ISPs WCS Consolidated Interim Storage Facility (CISF). Please consider the following issues for inclusion in the environmental impact study for the above-referenced spent nuclear fuel storage facility.
We are submitting these comments on behalf of 5,500 Public Citizen members in Texas as well as 2,000 members of SEED Coalition, many of whom would be particularly affected by this proposed project, either as neighbors near the site or because they live near the rail lines that would carry this risky radioactive cargo through their communities.
Public Citizen advocates for a healthier and more equitable world by making government work for the people and by defending democracy from corporate greed. In addition to the comments included here, more than 17,697 of our members across the United States also submitted comments in 2017 and many will be submitting additional comments about Waste Control Specialists proposed high-level interim radioactive waste storage facility in Andrews County, Texas.
The Sustainable Energy and Economic Development (SEED) Coalition is a grassroots organization with over 2000 members, most of whom live in Texas. SEED Coalition advocates for clean air and clean energy, and has promoted solar and wind development in Texas, while opposing coal plants and urging their retirement. SEED Coalition participated in licensing proceedings in opposition to Comanche Peak 3 & 4 and South Texas Project 3 & 4. The organization has also raised concerns about Waste Control Specialists low-level radioactive waste facility, including the proximity of groundwater to the pits in which radioactive waste is being disposed.
2 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 A State of Nevada Report regarding the proposed Yucca Mountain high-level radioactive waste repository project led off by stating that it has the potential to wreak economic, social, and environmental devastation on at least 44 states, including Nevada, hundreds of major cities and thousands of communities across the country through which spent nuclear fuel (SNF) and high-level radioactive waste (HLW) must travel.1 The report noted that tens of thousands of shipments of highly radioactive waste would be an inseparable and dominant component of the federal governments repository program and lamented the fact that the Secretary of Energy recommended that Yucca Mountain be developed as a repository without full disclosure of these transportation impacts and without having assessed the implications of the program for the nation as a whole2 What began in 1983 as a noble experiment that promised to place science ahead of politics, and fairness, equity, and openness above parochialism has degenerated into a technical and ethical quagmire, where facts are routinely twisted to serve predetermined ends and where might makes right has replaced consultation, concurrence, and cooperation as the guiding principle for the program. The shoddy and politically driven science, the heavy-handed federal approach, the constant changing of the rules to negate disqualifying conditions and inconvenient findings, and the deliberate avoidance of responsibility for considering socioeconomic impacts have created an atmosphere of severe distrust, where the already significant impacts associated with the nuclear nature of the program are further exacerbated and amplified. The result is a massive suite of negative impacts, national in scope, inextricably linked to the Yucca Mountain program, and unprecedented in the history of federal government domestic projects.3 Unfortunately, the same politically driven science and heavy-handed federal approach are still in use today as evidenced by the ill-conceived, ill-advised proposals to store spent nuclear fuel in Texas and New Mexico. As with Yucca Mountain, the nation would be put at unprecedented risk by the thousands of shipments of high-level radioactive waste across the country. At least the goal with the failed Yucca Mountain site was a permanent repository. Consolidated interim storage, by contrast, does not move our nation toward permanent disposal. This approach could delay a viable repository, while unnecessarily risking health and safety and creating financial liability. This proposal also creates the very real risk that a permanent repository will become a de facto permanent storage sitea use for which it was never intended and would be wholly unsuited.
Public hearing opportunities have been woefully inadequate for the Waste Control Specialists (WCS) proposal. WCS and their partner, Orano, have formed a joint venture, Interim Storage Partners. Together they seek to import 40,000 tons of spent fuel from nuclear reactors around the country and store it on WCS existing low-level radioactive waste site in Andrews County for 40 years (possibly 60-100) or until a permanent repository is available. This could mean forever.
1 http://www.state.nv.us/nucwaste/yucca/impactreport.pdf.
2 Ibid.
3 Ibid.
3 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 Importing high-level radioactive waste would threaten public health, safety and financial well being. Exposure to radiation can lead to various cancers, genetic damage and birth defects. Human exposure to unshielded high-level radioactive waste is lethal.
Homeowners insurance doesnt cover radioactive contamination, so there are risks to property value as well. The WCS proposal and Holtecs proposed project for nearby New Mexico should be halted immediately. Waste would travel through major cities in Texas and throughout the country in order to reach either or both sites.
Under the Nuclear Waste Policy Amendments Act of 1987, the WCS consolidated interim storage facility cannot legally operate, so the NRC should not even be considering the license application. Yet the applicant is now pushing forward with their proposal, under new corporate ownership of WCS and with a revised application.
We Dont Want Radioactive Waste. We Do Want Public Meetings.
Texans dont want dangerous high-level radioactive waste but the NRC has failed to listen to the voices of many concerned Texans. There has not been a single public meeting on the revised application, submitted by new WCS ownership. The WCS proposal would result in massive transport of radioactive waste across the country, but the public is being given very little opportunity to speak out.
For the original version of the application, NRC held only one Texas meeting, in Andrews, hundreds of miles away from major cities that would be impacted by rail transport of radioactive waste. One meeting was held across the border in Hobbs, New Mexico, and two were accessible by phone and webinar. By contrast, five in-person NRC meetings were held in New Mexico regarding Holtecs proposal. Twenty-four meetings were held for Yucca Mountain at locations across the country.
There is strong opposition to this proposal in Texas. Resolutions opposing the radioactive waste plans and transport were passed by Dallas, Bexar, Nueces, El Paso and Midland counties and the cities of San Antonio, Midland and Denton. The NRC has failed to host a single meeting in any of these locations despite requests to do so. Nor has it extended deadlines for 180 days as requested to allow for full public awareness and participation.
Inadequate Environmental Review and Emergency Plan The inadequate WCS Environmental Report should clearly identify transportation routes that would be used across the country and thoroughly examine:
x Risks to groundwater and the nearby Ogallala Aquifer, which lies beneath eight states, providing drinking water, and water for agriculture, ranching and wildlife.
x The impacts of temperature extremes, wildfires, flooding, earthquakes, tornadoes, lightning, and shifting ground (as reported in recent Southern Methodist University studies) on radioactive waste casks and canisters.
4 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 x The environmental injustice of dumping high-level radioactive waste from around the country on the largely Hispanic Texas / New Mexico region, where many people have limited ability to read or speak English.
x The inadequacy of financial assurances; the stability of new WCS owner J.F.
Lehman, an equity firm that buys and sells companies; and the ties of partner Orano (with a 51% share of the project) to the French government and other entities.
x Improved monitoring, security and worker protections are needed and should be addressed more thoroughly in the Environmental Report. Cumulative impacts of multiple nuclear facilities in the region need to be more fully examined.
x The emergency plan should include actions to be taken in response to an emergency, not just a notification structure. It appears there may not be any viable plans for action should an emergency arise.
Protect Public Health, Safety and Financial Well-Being by Denying the License Sending nuclear reactor waste to Texas to be stored here for decades would accomplish nothing but storing the waste in an alternate location, while risking the health and security of 218 million people within 50 miles either side of potential rail routes.4 It would risk financial disaster, damage to existing businesses, and contamination of land, air and waterways at the WCS site and along transport routes.
An inadequate permanent disposal site could result since the waste would likely never get moved from consolidated interim storage to a permanent repository. This is dangerous waste that must remain isolated for a million years. Storing it for decades above ground in extreme climate conditions would not lead the nation toward the long-term isolation goal, and in fact, could impede progress.
In the interest of our public health and safety, the NRC should halt review and deny the WCS license application for Consolidated Interim Storage in Texas, as well that of the Holtec project proposed for nearby New Mexico.
Consolidated Interim Storage of High-Level Radioactive Waste Risks Creating a De Facto Permanent Site If high-level radioactive waste comes to Texas, its unlikely that it would ever leave. This license application should consider the possibility of an inadequate potential permanent site being created.
If high-level radioactive waste gets stored in Texas and/or New Mexico and utilities no longer have local nuclear waste liabilities, no one would lobby Congress for a permanent repository. Political pressure would evaporate. The waste would be out of sight, out of 4 Sabotage Consequences, Resnikoff and Travers, RMMA - page 4 http://www.state.nv.us/nucwaste/news2008/pdf/rwma0810sabotage.pdf
5 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 mind for most utilities and political leaders in other states. It would thus be unlikely that Congress would ever fund a permanent repository, a facility designed appropriately for long-term storage.
The Federal Government has attempted to find a safe site for a high-level waste repository since 1983, but has failed to do so.
Yucca Mountain was selected for permanent disposal but development has been halted because of inadequacy of the site to isolate waste and societal and political opposition.
Yucca Mountain seeps so badly that plans for the site had to include installation expensive titanium drip shields over the waste. It is questionable whether Congress will ever fund a viable nuclear waste repository, which could cost $100 billion or more to build. With no alternative repository being planned and Yucca Mountain halted, the NRC should evaluate the wisdom of allowing high-level radioactive waste to be transported to a consolidated interim storage site, where it could remain for decades, or until a permanent repository is available. This could essentially mean forever.
The casks and canisters that would be used are not designed for permanent disposal.
The casks, with waste canisters inside them, would be stored outside, above-ground in extreme temperatures, exposed to earthquakes, rain and wildfires, which are becoming increasingly more frequent and intense in the Permian Basin. The high temperature experienced at the site, 113o F, exceeds the design value (101o) of some of the canisters that could be stored there. With above ground storage and exposure to the elements, the risks of degradation of the casks and canisters and water contamination are likely to increase as storage time lengthens. No funding is being set aside for repackaging of the waste.
Canisters may crack and release radiation over time. The Environmental Report should clarify how long casks and canisters are expected to last before there are cracks, metal fatigue, through wall cracks or other defects, including those that may result from accidents, drops, shaking the canisters in transport or shaking due to seismicity. As the cladding around the fuel rods ages, it could become thin and embrittled, making it more dangerous to store and decreasing the likelihood that it will be moved again.
The NRC has said that once there is a crack in a canister it can grow through the canister wall in about 16 years.5 Dr. Kris Singh, President and CEO of Holtec, a company competing for high-level radioactive waste business, has said that even a microscopic through-wall crack will release millions of curies of radionuclides into the environment and that its not feasible to repair the cracks even if you could find them.6 Detailed information regarding this crucial issue is provided in a September 24, 2018 letter from Donna Gilmore of San Onofre Safety to Michael Layton, Director of the NRC Spent Fuel Division. Gilmore raises serious safety concerns, stating:
5 https://www.nrc.gov/docs/ML1425/ML14258A081.pdf Page 4 6 https://sanonofresafety.files.wordpress.com/2015/09/attachment-14-declaration-of-donna-gilmore.pdf
6 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 Were running out of time before these canisters have major leaks, explosions or criticalities. The NRC and nuclear industry have kicked these cans down the road for over 20 years, but were getting to the end of that road. Since aging canisters have not and cannot be inspected for cracks or depth of cracks, let alone repaired, the fuse may be lit on many of these aging canisters, but we cannot see them.7 The NRC should carefully consider the important safety issues raised in this letter, which we incorporate here by reference. Key data and concepts should be included in the Environmental Report and other portions of the WCS license application.
A permanent repository must be designed to isolate nuclear waste for a million years, but the WCS interim storage facility is not designed for long-term disposal. It would be woefully inadequate for permanent storage of radioactive waste that remains dangerous so far into the future. The licensing process for interim storage only accounts for the consequences of storage for a few decades, or possibly up to 100 years.
Thus the Environmental Report parameters are inadequate for a site that could become the de facto permanent site for deadly radioactive waste, and further analysis is essential. Canisters and casks are not designed to last anywhere close to a million years.
There are no provisions in the application for a transfer facility at the site in which damaged or leaking canisters could be repackaged. The Environmental Report should thoroughly examine the effects of long-term storage and explicitly analyze the potential problems that could result involving zirconium or other kinds of cladding, and the potential impacts, including criticality.
Since there is no permanent repository being planned, this application should analyze the possibility that there will never be a final repository, and carefully consider all enhanced standards and guidelines that should be required due to the risk of creating a de facto permanent site.
Liability Risks and Inadequate Financial Assurance The State of Texas could get stuck with billions of dollars of cleanup costs from a transportation accident, a contaminated waste facility, or having to remediate an abandoned high-level radioactive waste site.
Lack of viable financial assurance that would protect Texas.
WCS proposes to use one of two methods to fund decommissioning. The Environmental Report lacks sufficiently detailed information about either of these possibilities.
1. DOE contract. The license application says: Pursuant to a contract with DOE, DOE shall take legal title of the SNF prior to receipt and shall also be responsible for all costs associated with the decommissioning of the WCS CISF pursuant to 10 CFR Part 7 https://sanonofresafety.files.wordpress.com/2018/09/nureg-2224donnagilmorecomments2018 24.pdf
7 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 20 Subpart E at the time of license termination (SAR 13.6.2 Cost of Decommissioning)
The application should discuss the goals and minimal terms that would be involved in such a contract, in order for the public to assess whether financial assurance would be anywhere close to adequate.
2. External sinking fund. If such a fund were to be used, would there be a requirement to use cash as financial assurance? Would bonds be considered? A combination of the two? Sister company stock? WCS was previously allowed to use sister company stock as financial assurance for their low-level radioactive waste facility. This inadequate option should not be permitted, since stock values can plummet. In order to prevent liability problems, the licensee should be required to provide full financial assurance up front, not incrementally over time. An accident with a radiation release could occur sooner than expected and someone would have to pay for remediation. It should not be US taxpayers.
x WCS and Orano have formed Interim Storage Partners (ISP). Orano, previously known as Areva, is largely owned by the French government, and it has a 51%
ownership of ISP. The Environmental Report should include justification for why this could possibly be appropriate or why the NRC should even considered this proposed arrangement in light of Foreign Ownership and Control regulations.
The national security implications of a high-level radioactive waste facility having a foreign-owned company with a controlling interest should be thoroughly examined. U.S. relations with France could become increasingly strained under the current Administration. The NRC should not allow any foreign company to have a controlling interest in any project on U.S. soil involving high-level radioactive waste.
x The business model has changed. Additional financial scrutiny is needed since there have been economic shortcomings for WCS and Areva in the past. J.F.
Lehman & Company now owns both Waste Control Specialists and NorthStar Group Holdings, Inc., a company that plans to decommission nuclear reactors.
x NorthStar Group, in which WCS is a partner, is attempting to purchase Vermont Yankee nuclear reactor. NRC officials have approved the transfer of title, which is yet to be considered by the Vermont Public Utility Commission. There were significant questions as to whether NorthStars financial plans were adequate to provide reasonable assurance that sufficient funds would be available for decommissioning and how long-term storage of spent nuclear fuel stored at Vermont Yankee would be funded. Thats no small expense: NorthStar estimates fuel costs at $287.8 million through 2052. 8 8 https://vtdigger.org/2018/05/24/northstar-makes-new-promises-in-vermont-yankee-sales-deal/
8 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 x WCS has made no commitment to set aside any given amount of financial assurance/decommissioning funds. It should be required to do so and explain how that would be accomplished under permissible terms. Otherwise, there is no guarantee of adequate funds for decommissioning. The company plans to negotiate a contract with DOE, leaving it to the federal government to clean up.
No minimal terms for this contract are provided in the NRC license application. If no deal is struck, if funds turned out to be insufficient or if the federal government failed to pay, Texas and other states with transport routes could get burdened with a disastrous mess and shouldering potentially exorbitant cleanup costs.
x Before any licensing decision is made, a more comprehensive and credible financial assurance and decommissioning plan should be developed based on risks due to contamination, aging, weathering and abandonment. It should also address the new business model, which may not be backed by federal guarantees.
There should be analysis of both WCS and Oranos assets and access to capital and a full examination of decommissioning revenues, and the extent to which these revenues could be used for financial assurance and decommissioning.
x The Environmental Report should acknowledge and discuss the fact that the Price-Anderson Act does not cover storage activity at a private sector Consolidated Interim Storage Facility. It could potentially cover some, but not all, transportation scenarios. The Price-Anderson funds that would available would not be nearly enough to cover a significant radiation release, which should also be discussed in depth.
x WCS license application cites EPRI decommissioning estimates for a high-level radioactive waste site, of $12.65 million for 5,0000 tons, without commenting further as to whether they believe these estimates to be credible. If proportionate, costs would be $101 million for 40,000 tons. The Environmental Report should clarify as to whether WCS agrees with these unrealistically low numbers and if so, why.
x By contrast, a financial assurance package in excess of $250 million was secured for decommissioning the Vermont Yankee plant, a single nuclear reactor. The state of Vermont sought protections against project risks and cost overruns and to ensure the complete cleanup and restoration of the reactor site. 9 x The decommissioning cost estimates suggested in the license application pale in comparison to actual multi-billion dollar cleanup costs of existing radioactive 9 https://publicservice.vermont.gov/announcements/department-files-mou-entergynorthstar-case
9 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 waste sites. Congress seldom adequately or timely funds remediation for such sites. The companies that would profit from radioactive waste storage may be long gone when it comes time for cleanup.
x The Hanford Nuclear Reservation in Washington State is considered Americas most contaminated nuclear site.10 In 2016, the price tag for the remaining environmental cleanup of the Hanford nuclear reservation is estimated at $107.7 billion. The estimate released by the Department of Energy, EPA and the state of Washington included cleanup work planned for completion by 2060, plus some post-cleanup oversight.11 x The Waste Isolation Pilot Plant (WIPP) After less than 15 years of operation the site had a fire and soon afterwards an explosion. The site was closed for 3 years and remediation costs were estimated to reach $2 billion.12 x The Pantex Plant is the primary United States nuclear weapons assembly and disassembly facility. Since 2000, $171 million in compensation and medical bills has been disbursed to more than 1,300 workers and families since the energy employees compensation program began.13 In 2009, soil and groundwater contamination cleanup was projected to cost over $120 million. 14 x Fernald uranium production facility is the site of one of the largest environmental cleanup operations undertaken in U.S. history. It was added to the U.S. EPAs National Priorities List of Superfund Sites most in need of cleanup in 1989. The cleanup was completed after 28 years, at a cost of $4.4 billion.15 x
Savannah River Site (SRS) produced tritium, plutonium and other special nuclear materials for national defense and the space program. Past disposal practices caused site contamination. Cleanup efforts have been underway since the 1980s. Site cleanup completion is currently scheduled for 2065.16 The cleanup cost estimate has increased to $17 billion. 17 x Beatty, Nevada, has the nations first federally licensed low-level radioactive waste dump, which opened in 1962 and closed in 1992. The State of Nevada had to take over ownership and oversight of this site. In 2015, an underground fire led to violent eruptions that spewed hazardous debris 60 feet into the air. The cost to ensure that there is no repeat of the accident is expected to exceed the $9 million that Nevada accepted when it inherited the 10 https://www.bbc.com/news/magazine-26658719 11 https://www.tri-cityherald.com/news/local/hanford/article61912837.html 12 http://www.latimes.com/nation/la-na-new-mexico-nuclear-dump-20160819-snap-story.html 13 http://www.star-telegram.com/news/state/texas/article49500030.html 14 https://www.mysanantonio.com/news/environment/article/Amarillo-weapons-plant-to-clean-up-soil-844339.php 15 http://www.fluor.com/projects/fernald-environmental-remediation 16 https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0403485 17 https://www.postandcourier.com/the-remaining-mission-of-the-savannah-river-site-clean-up/article_186a2452-3039-11e7-83da-47bb41f904b2.html
10 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 site.18 The radioactive waste dump was troubled over the years by leaky shipments and oversight so lax that employees took contaminated tools and building materials home, according to state and federal records.19 x West Valley Demonstration Project is a nuclear waste remediation project focusing on the cleanup and containment of radioactive waste left behind after the abandonment of a commercial nuclear fuel reprocessing plant in 1980. Despite over 30 years of cleanup efforts and billions of dollars having been spent at the site, the property has been described as New Yorks most toxic location in 2013.20 x The decommissioning plans suggested in the WCS license application are also unrealistic because they consider cleanup of a site with wastes that have recently been removed from a reactor, not for wastes stored in canisters or casks that have been degraded by transportation, accidents, weather or aging. Realistic analysis that covers various potential scenarios is needed to ensure accurate decommissioning costs.
x The license application assumes that 20% of the site could become contaminated and requiring remediation. What does this mean? Clarification of this vague statement and further analysis should be provided. Does this mean contamination of 20% of the canisters or casks? Or 20% of the site itself? Does this include the low-level radioactive waste area? The pad on which high-level radioactive waste would be stored?
Is there really such thing as a 20% contaminated site? If a site is no longer safe for workers, isnt it effectively 100% contaminated? If workers were unable to access all or portions of the site, remediation could become difficult or even impossible. Are there robotics available that could be used to remediate a contaminated consolidated interim storage facility? Where and how would such decontamination take place, and at what expense?
The Presence of Water and Risks to Aquifers Must Be Analyzed TCEQs professional staff in the Radioactive Materials Division reviewed the original low-level radioactive waste application and unanimously urged the Commission to deny the license because of water incursion risks. An Interoffice Memorandum on August 14, 2007, relayed their conclusions to TCEQ Commissioners:
x
Groundwater is likely to intrude into the proposed disposal units and contact the waste from either or both of two water tables near the proposed facility. The 18 https://www.reviewjournal.com/local/local-nevada/a-year-after-fiery-accident-at-radioactive-waste-dump-in-nevada-the-meter-is-running-on-a-fix/
19 https://www.theguardian.com/us-news/2015/oct/25/radioactive-waste-dump-fire-reveals-nevada-troubled-past 20 https://en.wikipedia.org/wiki/West_Valley_Demonstration_Project
11 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 Applicant has failed to demonstrate compliance with 30 TAC §336.728(f), which states, "The disposal site shall provide sufficient depth to the water table so that groundwater, perennial or otherwise, shall not intrude into the waste."
x
The Applicant has failed to successfully use numerical modeling to predict the future location of one water table that is expected to intrude into radioactive waste. This constitutes a failure to characterize the proposed site as required by 30 TAC
§336.728(a) which states the proposed disposal site "...be capable of being characterized, modeled, analyzed, and monitored." Moreover, the Applicant's failure to model the future location of the water table violates 30 TAC §336.709(1), which requires analysis of future site conditions.
Monitoring well data in one quarterly report submitted in 2012 by WCS to TCEQ showed the presence of water in 40% of monitoring wells. Pumping removes water at the Compact and Federal facilities of the WCS site.
The Ogallala Aquifer, which provides water for eight states, is very near the WCS site.
Risks of water contamination and the extent to which it could spread over time should be considered in the Environmental Report. Texas Water Development Board maps previously showed water underneath the WCS site location and previous studies of the site, once known as the Flying W Ranch, should be analyzed and the data incorporated into the Environmental Report. This includes a report formerly prepared for the Andrews Industrial Foundation.
Texas Does Not Consent to High-Level Radioactive Waste Storage The WCS license application should acknowledge the significant opposition to the proposal for high-level radioactive waste storage in Texas or New Mexico.
Opposition to the WCS project far exceeds support, and NRC should hear these voices.
x Dallas, Bexar, Midland, El Paso and Nueces counties and the cities of San Antonio, Denton and Midland have passed resolutions expressing opposition.
x More than 23,000 people have now submitted comments opposing the WCS license.
x At least 500 of those comments came from people who live in the Andrews area x Collectively, these resolutions represent 5,474,037 people based on 2017-2018 population data from SuburbanStats.org.21 21 https://suburbanstats.org/population/how-many-people-live-in-texas (The population of the cities of San Antonio and Midland are assumed to be included in the county population)
Dallas County 2,368,139 Midland County 136,872 Nueces County 340,223 Bexar County 1,714,773 El Paso County 800,647
12 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 x While radioactive waste opposition is clearly not a partisan issue, it is also of note that the Texas Democratic Party Platform, 2018 - 2020 includes opposition to consolidated interim storage and transport of high-level radioactive waste.22 In the 2016 election, Democrats cast 43.2% of the votes (3,877,868).
None of the criteria used by WCS to proclaim support for their project meet any reasonable definition of consent. They include:
x A March 2014 study by TCEQ, which was far from a glowing endorsement of the plan, pointing out sabotage risks and the possibility of creating a de facto permanent site. This report was presumed to back up former Governor Rick Perrys support for the WCS project. Governor Greg Abbott has not voiced support for WCS proposal.
x A resolution passed by Andrews County in January 2015, without any public comment, at a hearing attended only by WCS.
x A 2014 resolution by the Texas Radiation Advisory Board, which only has an advisory role in state government.
Department of Energy officials have portrayed the resolution by Andrews County as evidence that Texas was giving consent to high-level radioactive waste storage site, which is false. Andrews County lacks any legal authority to consent to the WCS proposal on behalf of the state. The reality is that there was no citizen input into the decision by five people and the county was looking at potential financial gain as opposed to health and safety concerns of the community. The desire that many community members hold of a safe future for their families and for local businesses was disregarded, although many spoke to NRC about their concerns.
On January 20, 2015, Andrews County Commissioners passed a resolution supporting Waste Control Specialists application for a consolidated interim high-level waste storage site. There had some coverage in the local newspaper of WCS proposal, but there appears to have been little, if any, effort to reach out to citizens about the opportunity to weigh in about high-level radioactive waste storage plans at the Commissioners Court. Not a single member of the public was present at the only Commissioners Court public hearing. Only WCS was present. The resolution was approved with no community debate.
The Environmental Report should note this lack of public input. The process failed to constitute informed local consent, a serious failure considering the magnitude of the decision and the impacts it could have for Andrews County, the State of Texas and the nation as a whole. Many Andrews residents didnt know what was proposed until after the County resolution was passed. Some say that a vote should have been City of Denton 113,383 5,474,037 22 https://www.txdemocrats.org/our-party/texas-democratic-party-platform - in the Environmental Protection, Regulation and Enforcement section
13 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 held and that they would have voted against the project. Testimony at 2017 NRC meetings in Andrews, Texas and Hobbs, New Mexico was dominated by deeply concerned community members who said that they dont want radioactive waste nearby.
The volume of low-level waste arriving at WCS recently has been less than originally projected. As a result, revenues have been down, including the 5% that goes to Andrews County. County dependence on revenue generated at the site may have unduly influenced decisions made regarding storage of high-level radioactive waste.
The Andrews Countys resolution favoring storage of high-level radioactive waste has no legal or regulatory basis. The Blue Ribbon Commission on Americas Nuclear Future report in 2012 recommended a consent-based process, but since the recommendation was never codified or adopted by regulation the definition of consent was never finalized. The Environmental Report should acknowledge that there is no legal basis for the claim that Andrews Countys resolution constitutes consent.
In fact, a fair definition of consent would give weight to the nearest and most affected community. In this case that would be Eunice, New Mexico, located about 4 miles west of the WCS site, and not Andrews, Texas. Eunice is the nearest governmental body, and the Mayor has publicly expressed opposition to the site and raised concerns about transportation. The WCS license application indicates that all rail transport to WCS would come through Eunice. True consent would include a vote for communities at risk because they are close to the proposed consolidated interim storage project or along transport routes.
Eunice, New Mexico, Mayor Johnnie "Matt" White wrote to Public Citizen member Michael Trost, saying:
We have opposed the nuclear waste dump as it is so close to the city. It is only 4 miles and we are uncomfortable with the location. Also the waste material will be transported though the city and my council is very concerned. We have attended the meeting (in Hobbs) and expressed our concerns.
Transportation Risks Higher than NRC Acknowledges Review of the WCS and Holtec license applications should be halted. No licenses should be issued until completion of the transportation route study that the U.S. Department of Transportation plans to release in 2022 and until the public has had adequate response time. Once route information is determined, the NRC should make the information available and host public meetings in cities likely to be on transport routes.
The Environmental Report fails to provide adequate route information. It should be revised to do so. There is no way the public can fully assess the environmental, health,
14 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 safety and environmental justice impacts of transportation without full information regarding how the waste would get to West Texas. People are left to make educated guesses by examining major rail lines and routes that would have been used to transport spent nuclear fuel to Yucca Mountain.
x
An estimated 4,000 rail cars would move across the nation to Texas to the WCS site, in a process lasting over 20 years, threatening the health of communities and the environment.
x
A 2002 study by Radioactive Waste Management Associates for the State of Nevada used RADTRAN and RISKIND computer models to reexamine the truck and rail accident estimates for Yucca Mountain. They found that sabotage impacts would be at least ten times greater than DOE Estimates. They found that remediation of a rail accident involving a radiation release could cost $189 to $270 billion, data that should be included in the Environmental Report.
For the most economically severe rail accident in an urban area under weighted average meteorological conditions, our RADTRAN 5 analysis has estimated the associated costs to be on the order of $270 billion for 10-year-cooled fuel and $145 billion for 25.9-year-cooled fuel, present-day value. For the most economically severe truck accident, our RADTRAN 5 analysis has estimated the associated costs to be on the order of $36.6 billion for 10-year-cooled fuel and $20.1 billion for 25.9-year-cooled fuel. We need to underline the fact that the economic costs could be 3 to 4 times greater if one assumed a realistic urban population density.23 x
RWMA examined accident health consequences analyses with RISKIND and concluded that the number of expected latent cancer fatalities could be up to 40 times higher than DOE estimates. They found that if radioactive waste was involved in a transportation accident similar to the Baltimore rail tunnel fire that there could be 1,580 latest cancer fatalities over one year, and 31,800 latent cancer fatalities over 50 years. The DOE had estimated only 31 latent cancer fatalities for a severe rail accident, and that the waste would have already cooled 26 years.
RWMA concluded that the Baltimore accident conditions were severe enough to have caused the largest release considered in the DEIS for the Yucca Mountain facility. The contamination resulting from the release would cause a policy-makers nightmare. On the one hand, the cost of cleanup could be $13.7 Billion. On the other hand, failure to clean up could result in up to 1,580 latent cancer fatalities over one year, and up to 31,800 latent cancer fatalities over 50 years. The potential health and economic consequences presented give some indication of the tradeoff likely to take place between preventing future health effects and expending a large amount of money to properly remediate an area.24 x
Each rail car would carry as much plutonium as was in the atomic bomb dropped over Nagasaki. The Environmental Report should include information as to the content of spent nuclear fuel canisters, including the percentage of various radionuclides including, 23 http://www.state.nv.us/nucwaste/yucca/impactreport.pdf Page 43 and 36 24 Ibid. Page 42 and 36.
15 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 but not limited to plutonium, uranium, cesium, and americium and their half-lives. Data for high-burnup fuel should be included.
x
The Environmental Reports fail to explain how very heavy loads trainloads would be handled, since loaded rail cars generally weigh close to 213 tons, significantly exceeding the 143 tons/car the rails are designed to handle. The term shipment should be defined. Information is needed regarding number of rail cars that would carry spent nuclear fuel in a given train, whether dedicated trains would be used and what requirements would ensure this, what buffer cars and security would be used and what regulations would apply, and the speed of such trains would travel in order to reduce transport risks, as well as how such speed limits, if they exist, would be enforced.
x
Transportation routes have not been designated. However, DOT rules and guidance would require Class One lines for rail transport of spent nuclear fuel. The Environmental Report should clarify anticipated rail routes, as well as the extent to which barges and trucks would also be used and in what locations. WCS states a preference in the license application for using Union Pacific rail lines, but they have in no way limited the routes they might use. It appears that:
o 90% of the waste would come from reactors east of the Mississippi River.
o It appears that high-level radioactive waste would likely be shipped to WCS on UP lines running along 1-10, 1-20, I -30, and then westward through Dallas/Ft.
Worth and heading north from Monahans to the WCS site.
This map from WCS application appears to indicate that radioactive waste could be transported on numerous rail lines throughout the entire United States, but further discussion of the map and its significance should be included so that the public can know if this is true. A map should be included that overlays locations of reactors and decommissioned sites from which waste might originate and the rail lines. Maps should be provided that indicate routes for waste originating from all specific sites from which WCS could potentially receive spent nuclear fuel.
16 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 The Class One rail lines that could potentially haul this extremely heavy cargo run through the center of many of our largest cities. An analysis of spent nuclear fuel that would have gone to Yucca Mountain found that 218 million people live within the region of PU PUUBLBLBLBLBLLBLBLICICICICICICICCICICICICIC TITITITITIITITITITITITITITITITITITITITIITIITITITITITITITITIITITITIITITITITITIITITITITITIZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZEZ Nx 30 30 3 9 9 E 11thStrereetetetetettetetetetetettetetetetetetetetetetetetetetetetetetetetettetettetetetetettetetetetetettet, Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Su Suititititititititititititittitititititititititittitititititi e e2 x AuA s Su Su Su Suu Su Su Su Su Su Su Su Su Suu Suu Su Su Su Su Su Su Suu Suu Suu Suu Su Su Sustststststtstststststststststststtststststststtststtstststststststaia naablble eEnEnEnEnEnEnEnE ergygygygyygyandnddEcocococococonon mic Development (SSEEEEED)D)D)D Coao litiiono x
17 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 influence, 50 miles on either side of rail lines that would have been used to transport this dangerous waste.25 The WCS plan would also endanger millions of people across the country. In Texas likely routes would go through major cities including Dallas/ Ft. Worth, Houston, San Antonio, Midland and El Paso. People along within a 50-mile region of influence along these rail lines should be considered affected parties since they are at risk for accidents and sabotage.
The concerns of people that live along likely transport routes must be heard in public meetings and the consent of governing bodies along transport routes must be obtained.
The NRC estimated that 10,000 rail shipments would be needed to ship waste to Yucca Mountain if transport was mainly by rail, and based on projected rate, at least one accident was anticipated.26 The accident rates could be similar, or potentially higher for the WCS consolidated interim storage proposal.
There have been numerous train accidents and derailments in West Texas and New Mexico, and the following data should be considered and included in the Environmental Report. A Ten Year Accident/ Incident Overview for Texas Railroads, using data from the Federal Railroad Administration, Office of Safety Analysis shows that from FY2009 to FY2018, there were 8034 rail accidents/ incidents, with a total of 570 fatalities.
Human factors caused 784 train accidents that were not at grade crossings, while 752 were track caused; 168 were collisions and 1550 were derailments. There were 10,225 cars that carried hazardous materials; with 1,24 hazmat cars damaged or derailed and 16 hazmat releases. There were 445 accidents with reportable damage over $100,000, 133 in which damage was over $500,000, and 58 with damage over $1 million. Incidents at public crossings totaled 1854 and highway - rail accidents claimed 206 lives.
Union Pacific Railroad had 5062 accidents in Texas in this timeframe. The Texas and New Mexico Railroad (TNMR), which would be used for transport between Monahans, Texas and Eunice, NM, had 10 accidents. 27 On April 18, 2018 the Ward County Daily reported on a train versus train collision that happened in Monahans, Texas, in a crash that took out more than a dozen cars (photo at 25 http://www.state.nv.us/nucwaste/news2008/pdf/rwma0810sabotage.pdf 26 TCEQ Assessment of Texas High Level Radioactive Waste Storage Options, https://www.documentcloud.org/documents/1100389-tceq-assessment-of-texas-high-level-radioactive.html Originally based on DOEs FEIS for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada, Feb. 2002 27 https://safetydata.fra.dot.gov/OfficeofSafety/publicsite/Query/TenYearAccidentIncidentOverview.aspx 25 25 25 255 255 25 255 25 255 ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht ht htt ht htt ht ht ht ht ht ht ht ht ht ht ht ht ht htt ht htt ht ht ht ht ht ht ht ht http tp tp tp tp tp tp tpp tpp tp tp tp tp tp tpp tp tp tp tpp tp tp tpp tp tp tp tp tp tp tp:/://:/:/:/:/:/:/:/://:/://://://:/://://:/://://://:/://:/:/://:/:/:/:/:/:/:/:/:/:/:/://w
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18 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 left).28 One of the trains was traveling at 70 mph at the time of the accident.
In June 2016, in Panhandle, Texas, a train going 65 mph failed to stop at a signal, and collided head on with another freight train (photo at left).
Three people died. One train had 56 loaded cars and the other had 54 cars. A huge fireball was triggered, cars derailed and debris scattered 400 yards from the site. BNSF estimated damaged at $16 million. The fire burned for twelve hours.29 Risk of Terrorist Attacks on Radioactive Waste Transported through Texas Major Cities Shipping high-level radioactive waste through population centers would create attractive targets for terrorists. If terrorists were to attack, theyd be most likely to do so in a highly populated city like San Antonio, which has numerous military bases, or Houston, which is home to the nations largest petrochemical complex and second largest port, or Dallas/Ft. Worth, which have the some of the nations most congested rail hubs.30 A Texas Commission on Environmental Quality study discussed the risk of a terrorist attack on radioactive waste during transport or at the site as a significant threat.31 The report cited a study entitled Centralized Interim Storage of Nuclear Waste and a National Interim Storage Strategy, which included this reference:
With the presence of any potentially dangerous material, it is important to anticipate the possibility of malicious attack or theft. Due to the deliberate nature of such security threats, one cannot reasonably assign them a probability and calculate an expected cost. Because these attacks often target human lives and aim to create terror, it is important to actively safeguard against the negative consequences of such an attack. Therefore, for interim spent fuel storage, spent 28 https://www.oaoa.com/news/traffic_transportation/vehicle_accidents/article_f7e3395e-435a-11e8-bbe5-5b37334a3c03.html.
30 http://gov.texas.gov/files/ecodev/Logistics_Report.pdf 31 TCEQ 'Assessment of Texas' High Level Radioactive Waste Storage Options' -
https://www.documentcloud.org/documents/1100389-tceq-assessment-of-texas-high-level-radioactive.html
19 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 fuel must be secured against malicious attack and its consequences at all times.
For radioactive materials such as spent fuel, security threats fall into two general categories: sabotage and theft. In the former, the intent is to damage shielding and potentially disperse radioactive material, therefore exposing the environment and population to radiation. The latter involves stealing the material for future use in a radiological dispersal device or dirty bomb, or a potential nuclear device. In addition, each of these types of events may occur during storage, transportation, or fuel transfer. 32 The transportation of spent fuel presents unique security vulnerabilities and challenges.
Differences in risk between storage and transportation are due to a reduced number of security personnel guarding transport, fewer engineered barriers during transport, and potential proximity of transportation routes to population centers. Each of these factors make spent fuel in transit a more appealing and accessible target to attackers, thus increasing risk.33 In 2007 the National Academies (NAS) Committee on Transportation of Radioactive Waste reported that Malevolent acts against spent fuel and high-level waste shipments are a major technical and societal concern.34 They urged an independent examination of security before spent nuclear fuel shipment to a repository.
Sabotage events similar to those evaluated by DOE for Yucca Mountain, in which the casks are penetrated but not perforated, could range from $3.5 billion to $45.8 billion (in 2008 dollars) according to Radioactive Waste Management Associates.
Transportation sabotage events in which the casks are fully perforated could result in cleanup costs of $463 billion to $648 billion.
A terrorist strike on a shipment of radioactive waste could create an immediate health and safety hazard to the surrounding population and resulting radioactive contamination caused could render large areas of land uninhabitable for generations.
This significant risk to human health and safety that must be accounted for and fully addressed in the Environmental Report.
Drones and Armor-Piercing Weaponry 32 Petroski, Robert, Centralized Interim Storage of Nuclear Waste and a National Interim Storage Strategy, Journal of Engineering and Public Policy, vol. 9, (2005) - http://www.wise-intern.org/journal/2005/petroski.pdf Page 24.
33 http://www.wise-intern.org/journal/2005/petroski.pdf, page 26 34 http://www.state.nv.us/nucwaste/news2007/pdf/wm07ymtrans.pdf Page 2
20 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 The Environmental Report should include updated analysis of transportation risks, including the potential impacts of drones being used by terrorists in attacks on radioactive waste shipments. Drones are a dangerous new threat to our troops abroad, as was recently seen in battles with terrorists in Mosul, Iraq.35 A recent report detailed the growing use of drones as terrorist tools.36 A new generation of armor-piercing weaponry has been developed since then and an estimated 48% of all weapons used in Iraq and Afghanistan have disappeared. Due to extensive arms trafficking, no one can say where all these military weapons are today.
Drones now carry warheads. No NRC analysis has been done of the impacts that could occur. Experts say that the thin canisters can be pierced.
Cask safety tests are outdated and inadequate The NRC website says that spent fuel transport packages must met certain conditions:
To show that it can withstand accident conditions, a package must pass impact, puncture, fire and water immersion tests. Transportation packages must survive these tests in sequence, including a 30-foot drop onto a rigid surface followed by a fully-engulfing fire of 1475 degrees Fahrenheit for 30 minutes. These very severe tests equate to the package hitting a concrete highway overpass at high speed, and being involved in a severe and long-lasting fire. The test sequence encompasses more than 99 percent of vehicle accidents. 37 However, real world accidents have exceeded scenarios studied by the NRC. Most of the canister safety analysis was done prior to 9/11. Many of the tests were simulations, not full-scale model testing. Artificial limits were set which have already been exceeded in the real world. One test assumed that the radioactive waste transport package on a train hitting an immovable object at 60 mph would be unharmed, but in 2016 there was a 65 mph head-on train collision in Panhandle, Texas. The force of the oncoming train magnified the impact and the impact was greater than the test scenario, where a train collides at 60 mph into an immovable barrier.38 In the Monahans collision one train was traveling at 70 mph.
The Baltimore rail tunnel fire also significantly exceeded test conditions. RWMA concluded that the Baltimore rail tunnel fire burned for three days with temperatures as high as 1500 degrees Fahrenheit, creating a Category 6 accident fire environment 35 https://www.washingtonpost.com/world/national-security/use-of-weaponized-drones-by-isis-spurs-terrorism-fears/2017/02/21/9d83d51e-f382-11e6-8d72-263470bf0401_story.html?utm_term=.290f6b7d82e4 36 www.memri.org/reports/decade-jihadi-organizations-use-drones---early-experiments-hizbullah-hamas-and-al-qaeda 37 https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/transport-spenfuel-radiomats-bg.html#safety 38 NTSB Collision of BNSF Eastbound Train S-LACLPC1-26K and BNSF Westbound Train Q-CHISBD6-27L, Panhandle, Texas -
https://www.ntsb.gov/investigations/AccidentReports/Reports/DCA16FR008-PreliminaryReport.pdf
21 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 sufficient to cause a breach of the cask and a significant release of radiocesium and other radionuclides. 39 In the real world, firefighting equipment and personnel may not always be close at hand when and where theyre needed. Scott Palmer, chairman of the Oregon State Legislative Board of the Brotherhood of Locomotive Engineers and Trainmen, testified on July 19, 2018 at a New Mexico Radioactive and Hazardous Waste Committee hearing. He said that although fire suppression equipment is available, rail accidents often occur at locations hours away from that equipment.40 Environmental Justice Concerns Executive Order 12898, the Environmental Justice Executive Order, tasks all federal agencies with, identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations[.]41 Federal agencies are further tasked with conducting their programs in a manner that does not exclude participation by certain populations. Specifically:
Sec. 2-2. Federal Agency Responsibilities for Federal Programs. Each Federal agency shall conduct its programs, policies, and activities that substantially affect human health or the environment, in a manner that ensures that such programs, policies, and activities do not have the effect of excluding persons (including populations) from participation in, denying persons (including populations) the benefits of, or subjecting persons (including populations) to discrimination under, such programs, policies, and activities, because of their race, color, or national origin.42 The Environmental Justice Executive Order also tasks federal agencies with collecting and analyzing data comparing health risks borne by different populations, determining whether low-income communities of color are disproportionately impacted. Specifically:
3-302. Human Health and Environmental Data Collection and Analysis.
To the extent permitted by existing law, including the Privacy Act, as amended (5 U.S.C. section 552a): (a) each Federal agency, whenever practicable and appropriate, shall collect, maintain, and analyze information assessing and comparing environmental and human health risks borne by populations identified by race, national origin, or income. To the extent practical and appropriate, Federal agencies shall use this information to determine whether their programs, 39 http://www.state.nv.us/nucwaste/yucca/impactreport.pdf Page 38.
40 Presentation provided to committee at July 19, 2018 hearing -
https://www.nmlegis.gov/handouts/RHMC%20071918%20Item%202%20SNF%20Transportation%20 Safety%20and%20Security%20Concerns.pdf 41 Executive Order 12898, 59 Fed. Reg. 7629 (1994).
42 Executive Order 12898, 59 Fed. Reg. 7629 at §2-2 (1994).
22 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 policies, and activities have disproportionately high and adverse human health or environmental effects on minority populations and low-income populations; 43 In order to promote public participation and access to information, the EJ Executive Order states that Each Federal agency may, whenever practicable and appropriate, translate crucial public documents, notices, and hearings relating to human health or the environment for limited English speaking populations.44 The proposed site in Andrews County and the transport routes through Texas are located in predominantly low-income communities of colorenvironmental justice communities. The Nuclear Regulatory Commission has not ensured that the disproportionate health impacts to environmental justice communities are documented.
Many of the rail transport routes in Texas are through communities with a large percentage of non-English speaking residents. The NRC has not made information available in Spanish, including WCSs application and supporting documents, or provided an opportunity for public participation by Spanish-speaking communities.
Various federal laws and executive orders require the NRC to document the potential effects of this project on environmental justice communities and seek to limit the impact of a proposed site on these communities.
The U.S. Environmental Protection Agency developed the Environmental Justice Screening Tool (EJ SCREEN) for use when documenting impacts to EJ communities.
Public Citizen used EJSCREEN to analyze populations near the rail transport routes in Texas. (See attachments.)
Information about specific rail transport routes is not included in WCSs application.
Public Citizen and SEED Coalition used available public information, including TxDOT rail maps, to determine the most likely rail transport routes in Texas. We used EJ SCREEN to map these routes along various urban and rural corridors across Texas. We counted the population within 0.5 miles of the rail line because that is the population that will be most impacted by waste transport. We looked at demographic data from the 2012-2016 American Community Survey.
Our analysis shows that transportation of spent nuclear fuel is a major environmental justice issue, since it would likely come by rail through many EJ communities. WCSs application is deficient because:
x
There is no analysis of the demographics of populations impacted by the proposal or identification of which are environmental justice communities.
x
There is no analysis of whether environmental justice communities will be disparately impacted. (They will.)
x
There is no documentation of the impacts to EJ communities.
x
There is no discussion of attempts to limit impacts to EJ communities.
43 Executive Order 12898, 59 Fed. Reg. 7629 at §3-302 (1994).
44 Executive Order 12898, 59 Fed. Reg. 7629 at §5-5(b) (1994).
23 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 x
There has been no attempt to provide information, including application materials, to communities with high percentages of non-English speakers.
x
There has been no attempt to conduct public outreach to non-English speaking communities.
x
There has been no attempt to give non-English speaking communities an opportunity to comment on the application or otherwise participate in the process.
We used EJ SCREEN and the American Community Survey to analyze the following rail routes (see attached):
% who speak Spanish at home Rail segment population % minority % Hispanic Speak English Well Do not Speak English Well El Paso to Monahans 100,985 94%
92%
51%
49%
Bexar county 86,262 88%
72%
59%
41%
Bexar County (route 2) 90,644 78%
71%
58%
42%
Houston to San Antonio 114,433 67%
67%
79%
21%
Midland to Eunice 37,415 70%
63%
62%
38%
Harris county 103,509 67%
45%
70%
30%
Beaumont to Houston (southern route) 49,295 72%
42%
89%
11%
Texarkansas to Dallas 92,054 63%
33%
71%
29%
Ft. Worth to Midland 84,583 37%
28%
87%
13%
Tarrant county 74,450 49%
26%
78%
22%
Shreveport to Dallas 97,323 61%
26%
73%
27%
Total Population 930,953 All but one of the routes we analyzed were majority minority. Within these communities, the largest single demographic is the Hispanic population. Many communities have large percentages of peopleabove 40% in many caseswho do not Speak English well. These populations should have been provided information in Spanish and given an opportunity to comment or otherwise participate in the public process despite their lack of facility with English.
Attorney Terry Lodge submitted additional comments to which Public Citizen and SEED Coalition are signatories. Please consider the summary of contentions, the full contentions filed on November 13, 2018, and the comments submitted by Mr. Lodge incorporated into these scoping comments. Also attached are maps and demographic data developed using the EPAs EJSCREEN tool.45 45 https://www.epa.gov/ejscreen.
24 PUBLICCITIZEN x 309 E 11th Street, Suite 2 x Austin, TX 78701 x 512-477-1155 Sustainable Energy and Economic Development (SEED) Coalition x 605 Carismatic Lane x Austin, Texas 78748 This application should be dismissed for all the many reasons discussed. Processing an interim waste storage application is illegal until such time as a final repository has been approved or changes are made in federal law. The plan to ship high-level radioactive waste to Texas and store it for decades imperils the health and safety of the people of Texas, creates financial risks and fails to move the nation toward the goal of a permanent repository. Review of the applications for the WCS project in Texas and the Holtec project in nearby New Mexico should be halted and the licenses denied.
Respectfully Submitted, Adrian Shelley, Director of Public Citizens Texas Office Tom Smitty Smith, Special Projects Director for Public Citizens Texas Office 309 East 11th Street, Suite 2 Austin, Texas 78701 Karen Hadden, Executive Director Sustainable Energy and Economic Development (SEED) Coalition 605 Carismatic Lane Austin, Texas 78748 Adrian Shelley ey eyy eyy, Di Di Di Di Di Di Di Di Di Di Di Di Di Di Di Di D re re re re r ctor of Texas Office Kaaren Hadden, Executive S
i bl E d E T
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The environmental justice screens were done using EPAs EJSCREEN: Environmental Justice Screening and Mapping Tool (https://www.epa.gov/ejscreen)
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31,744 35,698 7,868 14,821 157.65 100%
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2,317 85,181 84%
878 1,837 2%
361 870 1%
172 207 0%
162 54 0%
70 11,336 11%
674 1,500 1%
145 92,414 92%
796 8,571 6,397 6%
273 1,546 2%
361 179 0%
109 150 0%
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156 70 71 0%
53 100%
191 0%
108 50,431 50%
580 50,554 50%
616 6,696 7%
338 25,282 25%
411 75,703 75%
577 15,884 16%
262 October 01, 2018
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October 01, 2018 63,906 100%
526 17,747 28%
270 8,913 14%
230 16,825 26%
374 15,070 24%
263 3,359 5%
164 5,351 8%
149 94,289 100%
753 15,280 16%
326 79,009 84%
618 39,150 42%
459 15,806 17%
271 11,365 12%
382 12,687 13%
340 24,052 26%
511 39,859 42%
578 10,767 100%
145 10,727 100%
144 33 0%
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207 9,033 28%
162 5,304 17%
141 9,823 31%
199 3,664 12%
127 3,920 12%
133 31,744 100%
207 17,646 56%
163 14,098 44%
188 79,139 100%
594 41,884 53%
501 4,215 5%
198 37,255 47%
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October 01, 2018
78,655 100%
597 12,707 16%
349 65,534 83%
546 85 0%
156 N/A N/A N/A N/A N/A N/A N/A N/A N/A 7
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27 25 0%
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612 2,181 3%
369 62,138 72%
918 24,125 12,206 14%
585 9,551 11%
546 198 0%
205 800 1%
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170 100%
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363 41,799 48%
552 44,463 52%
664 6,347 7%
297 24,169 28%
382 62,093 72%
613 9,125 11%
229 September 24, 2018
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September 24, 2018 53,664 100%
661 7,443 14%
279 7,499 14%
197 16,226 30%
393 14,889 28%
323 3,188 6%
169 7,607 14%
278 79,916 100%
899 39,796 50%
640 40,120 50%
517 27,147 34%
437 5,680 7%
236 4,627 6%
357 2,667 3%
172 7,293 9%
362 12,973 16%
413 2,669 100%
146 2,603 98%
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219 4,978 18%
123 4,444 16%
176 8,571 30%
204 4,901 17%
137 5,252 19%
186 28,146 100%
219 14,646 52%
220 13,500 48%
204 64,472 100%
785 39,841 62%
485 3,456 5%
175 24,631 38%
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September 24, 2018
79,591 100%
865 40,276 51%
732 38,108 48%
552 95 0%
62 N/A N/A N/A N/A N/A N/A N/A N/A N/A 177 0%
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N/A 240 0%
106 176 0%
1,133 N/A N/A N/A N/A N/A N/A N/A N/A 10 0%
N/A N/A N/A N/A 86 0%
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612 1,989 2%
351 64,366 71%
918 26,278 21,779 24%
690 2,518 3%
378 123 0%
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552 45,586 50%
728 5,588 6%
304 21,844 24%
405 68,800 76%
626 11,929 13%
229 September 24, 2018
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September 24, 2018 59,790 100%
661 7,913 13%
279 7,127 12%
174 16,088 27%
393 17,028 28%
497 3,668 6%
174 11,634 19%
254 85,056 100%
899 42,632 50%
640 42,424 50%
517 29,359 35%
455 5,585 7%
201 4,589 5%
357 2,890 3%
172 7,479 9%
362 13,064 15%
413 3,074 100%
146 2,992 97%
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219 5,376 18%
149 4,313 14%
176 7,410 24%
189 5,439 18%
183 7,816 26%
207 30,354 100%
219 16,887 56%
212 13,467 44%
190 71,218 100%
774 43,366 61%
603 3,208 5%
294 27,852 39%
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September 24, 2018
86,950 100%
861 43,961 51%
736 41,396 48%
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130 N/A N/A N/A N/A N/A N/A N/A N/A N/A 328 0%
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113 76 0%
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1,133 N/A N/A N/A N/A N/A N/A N/A N/A 57 0%
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September 24, 20 Input Area (sq. miles): 40.25
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687 44,877 39%
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383 54,981 48%
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1,694 9,519 8%
979 32,742 29%
1,543 81,691 71%
2,092 12,537 11%
620 November 12, 2018
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November 12, 2018 71,603 100%
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359 6,359 9%
376 18,687 26%
872 21,042 29%
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747 20,181 28%
1,448 104,914 100%
2,537 67,602 64%
2,183 37,313 36%
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997 2,194 100%
334 1,699 77%
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395 3,831 10%
223 8,851 23%
511 6,532 17%
660 14,313 38%
1,221 37,834 100%
702 25,526 67%
720 12,308 33%
631 85,493 100%
2,026 54,560 64%
1,650 3,098 4%
493 30,934 36%
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November 12, 2018
52,292 100%
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190 30 0%
148 N/A N/A N/A 135 0%
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N/A 213 0%
106 220 0%
1,133 N/A N/A N/A N/A N/A N/A N/A N/A 9
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585 18,273 49%
520 3,422 9%
326 10,944 29%
429 26,471 71%
473 3,901 10%
205 October 01, 2018
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October 01, 2018 22,681 100%
482 2,990 13%
144 3,404 15%
242 6,339 28%
258 6,861 30%
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194 3,087 14%
313 33,992 100%
757 17,639 52%
530 16,353 48%
552 10,705 31%
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280 1,332 4%
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283 5,648 17%
292 1,374 100%
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27 9
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291 1,592 13%
118 1,475 12%
112 3,015 24%
239 1,977 16%
174 4,556 36%
276 12,615 100%
291 8,338 66%
256 4,277 34%
236 27,363 100%
583 17,780 65%
465 1,025 4%
159 9,583 35%
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October 01, 2018
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638 19,001 52%
483 17,178 47%
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21 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 88 87 N/A 34 N/A N/A N/A N/A 18 44 0%
121 23 0%
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105 7
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N/A N/A N/A N/A 72 0%
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4,500 96,569 63%
1,455 30,466 20%
681 768 1%
572 6,856 4%
499 63 0%
83 15,708 10%
1,210 3,150 2%
320 74,896 49%
1,424 78,686 39,941 26%
918 29,751 19%
681 324 0%
570 6,812 4%
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499 83 266 0%
375 100%
1,528 1%
269 77,125 50%
987 76,457 50%
953 12,334 8%
513 39,405 26%
885 114,176 74%
1,257 14,743 10%
357 September 24, 2018
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September 24, 2018 98,158 100%
917 13,262 14%
296 10,461 11%
305 25,715 26%
885 25,503 26%
624 5,916 6%
350 23,217 24%
600 141,247 100%
1,464 76,321 54%
1,111 64,926 46%
1,195 32,371 23%
982 13,101 9%
571 11,626 8%
494 7,828 6%
405 19,454 14%
510 32,555 23%
675 7,267 100%
217 6,624 91%
216 116 2%
76 422 6%
178 104 1%
70 53,446 100%
271 7,520 14%
179 6,681 13%
182 14,119 26%
297 8,779 16%
325 16,348 31%
537 53,446 100%
271 26,891 50%
333 26,556 50%
311 118,061 100%
1,003 78,112 66%
825 5,899 5%
371 39,949 34%
634
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September 24, 2018
144,389 100%
996 79,945 55%
914 56,718 39%
846 513 0%
262 N/A N/A N/A N/A N/A N/A N/A N/A N/A 393 0%
262 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 318 216 N/A 66 N/A N/A N/A N/A 351 1,873 1%
214 866 1%
293 N/A N/A N/A 110 0%
N/A N/A N/A N/A N/A N/A N/A N/A N/A 479 N/A N/A N/A 1,651 1%
N/A 767 1%
147 272 0%
1,252 N/A N/A N/A N/A N/A N/A N/A N/A 547 0%
N/A N/A N/A N/A 511 0%
64,444 45%
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563 1,167 2%
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746 13,903 28%
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65 100%
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582 24,540 50%
705 24,755 50%
861 4,274 9%
392 13,677 28%
789 35,618 72%
1,056 5,603 11%
205 November 12, 2018
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November 12, 2018 30,440 100%
530 4,650 15%
223 3,998 13%
209 9,800 32%
424 8,197 27%
621 1,564 5%
400 3,795 12%
603 45,021 100%
1,180 27,567 61%
824 17,454 39%
1,064 9,030 20%
692 3,145 7%
721 2,850 6%
231 2,430 5%
338 5,280 12%
345 8,425 19%
768 1,790 100%
153 1,694 95%
152 26 1%
28 48 3%
58 22 1%
59 17,085 100%
212 3,285 19%
163 2,520 15%
170 4,737 28%
314 3,044 18%
234 3,499 20%
585 17,085 100%
212 9,525 56%
286 7,560 44%
253 37,020 100%
701 22,295 60%
600 1,711 5%
219 14,725 40%
477
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November 12, 2018
48,635 100%
960 29,314 60%
746 18,387 38%
941 189 0%
106 N/A N/A N/A N/A N/A N/A N/A N/A N/A 57 0%
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176 14 0%
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N/A 104 0%
68 53 0%
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726 25,172 27%
721 498 1%
200 912 1%
235 40 0%
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439 2,072 2%
265 30,006 33%
730 62,048 34,361 37%
661 24,953 27%
717 333 0%
200 883 1%
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235 23 85 0%
101 100%
1,424 2%
239 44,983 49%
606 47,071 51%
503 6,929 8%
302 25,685 28%
413 66,369 72%
577 10,443 11%
204 November 14, 2018
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November 14, 2018 57,305 100%
535 6,750 12%
221 7,911 14%
227 18,306 32%
392 16,335 29%
292 3,296 6%
182 8,004 14%
383 85,125 100%
754 59,266 70%
617 25,859 30%
517 14,700 17%
396 4,041 5%
225 4,277 5%
367 2,841 3%
235 7,118 8%
367 11,159 13%
367 1,991 100%
114 1,952 98%
103 12 1%
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245 5,293 18%
150 4,530 15%
145 8,165 27%
165 5,064 17%
216 6,903 23%
246 29,955 100%
245 16,856 56%
200 13,099 44%
239 68,944 100%
617 40,774 59%
572 3,327 5%
239 28,170 41%
577
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November 14, 2018
79,734 100%
961 55,134 69%
938 22,869 29%
1,030 182 0%
78 N/A N/A N/A N/A N/A N/A N/A N/A N/A 110 0%
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196 112 0%
106 N/A N/A N/A 90 0%
N/A N/A N/A N/A N/A N/A N/A N/A N/A 37 N/A N/A N/A 167 0%
N/A 305 0%
183 98 0%
1,191 N/A N/A N/A N/A N/A N/A N/A N/A 25 0%
N/A N/A N/A N/A 355 0%
24,600 31%
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669 5,478 6%
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163 65 0%
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395 1,733 2%
160 23,387 28%
632 61,176 53,390 63%
639 5,191 6%
343 360 0%
156 930 1%
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82 100%
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157 40,769 48%
398 43,794 52%
476 6,154 7%
326 21,239 25%
375 63,324 75%
540 12,171 14%
227 November 12, 2018
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November 12, 2018 54,499 100%
470 3,875 7%
145 4,835 9%
242 15,879 29%
295 16,973 31%
227 3,834 7%
135 12,937 24%
219 78,409 100%
672 62,988 80%
548 15,421 20%
493 10,498 13%
329 2,244 3%
289 1,990 3%
287 690 1%
138 2,680 3%
306 4,923 6%
328 1,210 100%
91 1,006 83%
90 34 3%
41 45 4%
33 124 10%
79 32,085 100%
219 4,715 15%
135 3,758 12%
135 8,122 25%
239 6,386 20%
174 9,105 28%
239 32,085 100%
219 18,745 58%
216 13,340 42%
184 65,582 100%
542 40,440 62%
412 2,250 3%
187 25,142 38%
481
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November 12, 2018
71,456 100%
875 56,616 79%
890 13,208 18%
579 160 0%
164 N/A N/A N/A N/A N/A N/A N/A N/A N/A 191 0%
117 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 164 91 N/A 163 N/A N/A N/A N/A 56 310 0%
113 62 0%
40 N/A N/A N/A 108 0%
N/A N/A N/A N/A N/A N/A N/A N/A N/A 48 N/A N/A N/A 46 0%
N/A 198 0%
241 74 0%
1,248 N/A N/A N/A N/A N/A N/A N/A N/A 27 0%
N/A N/A N/A N/A 322 0%
14,840 21%
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175 4,536 6%
476 59 0%
37 5,324 7%
395 2,613 4%
674 19,294 26%
803 55,156 41,891 56%
1,126 6,455 9%
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134 4,524 6%
30 0%
476 22 106 0%
73 100%
1,940 3%
674 36,984 50%
890 37,466 50%
965 5,448 7%
332 19,780 27%
722 54,669 73%
678 7,277 10%
281 October 22, 2018
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October 22, 2018 47,834 100%
749 2,835 6%
151 3,633 8%
151 11,402 24%
348 14,136 30%
412 3,104 6%
192 15,828 33%
443 69,002 100%
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944 18,660 27%
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464 4,446 6%
434 2,795 4%
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141 3,684 5%
632 8,130 12%
767 1,593 100%
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114 140 9%
75 330 21%
98 134 8%
215 27,417 100%
360 2,721 10%
172 2,259 8%
161 6,143 22%
268 5,564 20%
219 10,731 39%
353 27,417 100%
360 15,609 57%
354 11,809 43%
305 56,704 100%
822 38,440 68%
612 2,378 4%
175 18,264 32%
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October 22, 2018
76,917 100%
1,527 57,716 75%
1,736 13,812 18%
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326 N/A N/A N/A N/A N/A N/A N/A N/A N/A 142 0%
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342 113 0%
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2,312 N/A N/A N/A N/A N/A N/A N/A N/A 149 0%
N/A N/A N/A N/A 544 1%
19,201 25%
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661 31,358 32%
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239 46,956 48%
493 50,367 52%
571 7,793 8%
302 27,394 28%
413 69,929 72%
513 11,419 12%
204 November 19, 2018
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November 19, 2018 60,056 100%
482 5,952 10%
221 8,268 14%
190 20,469 34%
392 17,203 29%
292 3,628 6%
182 8,164 14%
360 89,530 100%
754 68,561 77%
617 20,969 23%
517 12,073 13%
396 3,196 4%
225 3,526 4%
367 2,174 2%
235 5,700 6%
367 8,896 10%
367 1,673 100%
114 1,619 97%
103 21 1%
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205 5,897 18%
150 4,824 15%
150 8,695 27%
166 5,272 17%
216 7,242 23%
246 31,931 100%
205 18,808 59%
200 13,123 41%
203 72,754 100%
589 42,802 59%
572 3,531 5%
239 29,952 41%
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November 19, 2018
80,152 100%
961 58,853 73%
938 19,831 25%
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78 N/A N/A N/A N/A N/A N/A N/A N/A N/A 84 0%
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196 88 0%
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183 131 0%
1,191 N/A N/A N/A N/A N/A N/A N/A N/A 17 0%
N/A N/A N/A N/A 296 0%
21,299 27%
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