ML20309B078
| ML20309B078 | |
| 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: ML20309B078 (15) | |
Text
From:
Kevin Kamps <kevin@beyondnuclear.org>
Sent:
Tuesday, November 3, 2020 11:36 PM To:
WCS_CISFEIS Resource
Subject:
[External_Sender] Beyond Nuclear's 31st set of public comments, re:
Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Cessation of Irradiated Nuclear Fuel, and Principles for Safeguarding Nuclear Waste at Reactors (Har...
Submitted via: <WCS_CISF_EIS@nrc.gov>
Dear NRC Staff,
We submit these comments on behalf of our members and supporters, not only in New Mexico and Texas, near the targeted ISP/WCS CISF site, but across both of these states, and the rest of the country, along road, rail, and waterway routes that would be used for high risk, highly radioactive waste shipments to ISP/WCS's CISF, as well as to Yucca Mountain, Nevada, on Western Shoshone land -- wrongly and illegally assumed by ISP/WCS, as well as by NRC, to someday (or some decade, or some century) become a permanent disposal repository. This unnecessarily repeated, multiple legged, cross-continental transport of highly radioactive waste, is another significant aspect of the EJ (Environmental Justice) burden associated with this ISP/WCS CISF scheme.
The following subject matter has gotten little to no attention in NRC's ISP/WCS CISF DEIS, a far cry from NEPA's legally binding "hard look" requirement:
Cessation of Irradiated Nuclear Fuel Generation, and Principles for Safeguarding Nuclear Waste at Reactors (Hardened On-Site Storage, HOSS) are the Preferred Alternatives The preferred alternative to ISP/WCS's CISF is to stop making irradiated nuclear fuel, and for what exists, to implement hardened on-site (or near-site) storage, as an urgent safety, security, health, and environmental protection upgrade. See the Principles for Safeguarding Nuclear Waste at Reactors, which lays out the principles of Hardened On-Site Storage (HOSS), below. As you'll see below, the HOSS principles have long been endorsed by 200+
organizations, representing all 50 states.
Please address and rectify your woefully inadequate "hard look" under NEPA, re: this health-, safety-, and environmentally-significant, as well as legally-binding, subject matter above and below.
And please acknowledge your receipt of these comments, and confirm their inclusion as official public comments in the record of this docket.
Thank you.
Sincerely, Kay Drey, President, Board of Directors, Beyond Nuclear and Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear Principles for Safeguarding Nuclear Waste at Reactors (Hardened On-Site Storage, HOSS)
Posted online here <http://www.beyondnuclear.org/on-site-storage/2020/8/19/principles-for-safeguarding-nuclear-waste-at-reactors-harden.html>, and pasted in below, in full.
Principles for Safeguarding Nuclear Waste at Reactors (Hardened On-Site Storage, HOSS)
The following principles are based on the urgent need to protect the public from the threats posed by the current vulnerable storage of commercial irradiated fuel. The United States does not currently have a national policy for the permanent storage of high-level nuclear waste. The Obama administration determined that the Yucca Mountain site, which has been mired in bad science and mismanagement, is not an option for geologic storage of nuclear waste. Unfortunately, reprocessing proponents have used this opportunity to promote reprocessing as the solution for managing our nuclear waste. Contrary to their claims, however, reprocessing is extremely expensive, highly polluting, and a proliferation threat, and will actually complicate the management of irradiated fuel. Nor will reprocessing obviate the need for, or save space in, a geologic repository.
The United States has a unique opportunity to re-evaluate our nuclear waste management plan. We can make wise decisions about safeguarding radioactive waste or go down the risky, costly, and proliferation prone path towards reprocessing.
The undersigned organizations support for improving the protection of radioactive waste stored at reactor sites is a matter of security and is in no way an indication that we support nuclear power and the generation of more nuclear waste.
Require a low-density, open-frame layout for fuel pools: Fuel pools were originally designed for temporary storage of a limited number of irradiated fuel assemblies in a low-density, open-frame configuration. As the amount of waste generated has increased beyond the designed capacity, the pools have been reorganized so that the concentration of fuel in the pools is nearly the same as that in operating reactor cores. If water is lost from a densely packed pool as the result of an attack or an accident, cooling by ambient air would likely be insufficient to prevent a fire, resulting in the release of large quantities of radioactivity to the environment. A low-density, open-frame arrangement within fuel pools could allow enough air circulation to keep the fuel from catching fire. In order to achieve and maintain this arrangement within the pools, irradiated fuel must be transferred from the pools to dry storage within five years of being discharged from the reactor.
Establish hardened on-site storage (HOSS): Irradiated fuel must be stored as safely as possible as close to the site of generation as possible.
Waste moved from fuel pools must be safeguarded in hardened, on-site storage (HOSS) facilities. Transporting waste to a hardened storage facility away-from-reactor, but as close as safely possible to the site of generation, should not be done unless the reactor site is unsuitable for a HOSS facility and the move increases the safety and security of the waste. HOSS facilities must not be regarded as a permanent waste solution, and thus should not be constructed deep underground. The waste must be retrievable, and real-time radiation and heat monitoring at the HOSS facility must be implemented for early detection of radiation releases and overheating. The overall objective of HOSS should be that the amount of releases projected in even severe attacks should be low enough that the storage system would be unattractive as a terrorist target. Design criteria that would correspond to the overall objective must include:
---Resistance to severe attacks, such as a direct hit by high-explosive or deeply penetrating weapons and munitions or a direct hit by a large aircraft loaded with fuel or a small aircraft loaded with fuel and/or explosives, without major releases.
---Placement of individual canisters that makes detection difficult from outside the site boundary.
Protect fuel pools: Irradiated fuel must be kept in pools for several years before it can be stored in a dry facility. The pools must be protected to withstand an attack by air, land, or water from a force at least equal in size and coordination to the 9/11 attacks. The security improvements must be approved by a panel of experts independent of the nuclear industry and the Nuclear Regulatory Commission.
Require periodic review of HOSS facilities and fuel pools: An annual report consisting of the review of each HOSS facility and fuel pool should be prepared with meaningful participation from public stakeholders, regulators, and utility managers at each site.The report must be made publicly available and may include recommendations for actions to be taken.
Dedicate funding to local and state governments to independently monitor the sites: Funding for monitoring the HOSS facilities at each site must be provided to affected local and state governments. The affected public must have the right to fully participate.
Prohibit reprocessing: The reprocessing of irradiated fuel has not solved the nuclear waste problem in any country, and actually exacerbates it by creating numerous additional waste streams that must be managed. In addition to being expensive and polluting, reprocessing also increases nuclear weapons proliferation threats.
Signatories:
National Leonor Tomero, Center for Arms Control and Non-Proliferation John Issacs, Council for a Liveable World Kevin Kamps, Beyond Nuclear Lynn Thorp, Clean Water Action Erich Pica, Friends of the Earth Michele Boyd, Physicians for Social Responsibility Jim Riccio, Greenpeace Diane Kreiger, Nuclear Peace Age Foundation Kevin Martin, Peace Action Tyson Slocum, Public Citizen Susan Gordon, Alliance for Nuclear Accountability Arjun Makhijani, Institute for Energy and Environmental Research
Ken Bossong, SUN Day Campaign Michael Mariotte, Nuclear Information and Resource Service Anna Aurilio, Environment America Winona LaDuke, Honor the Earth Dan Becker, Safe Climate Campaign Dave Hamilton, Sierra Club Geoffrey Fettus, Natural Resources Defense Council Ed Lyman, Union of Concerned Scientists Susan Shaer, Womens Action for New Directions (WAND)
States Alabama Garry Morgan, Bellefonte Efficiency and Sustainability Team, Alabama Chapter of BREDL Tom Moss, North Alabama Peace Network Alaska Stacy Fritz, No Nukes North Arizona Stephen M. Brittle, Dont Waste Arizona Jack and Felice Cohen-Joppa, Nuclear Resister Patricia Birnie, GE Stockholders Alliance Russell Lowes, SafeEnergyAnalyst.org Barbara Warren, Arizona Physicians for Social Responsibility Arkansas Pat Youngdahl, Arkansas WAND California Rochelle Becker, Alliance for Nuclear Responsibility David Hartsough, PEACEWORKERS Jane Williams, California Communities Against Toxics Roland Valentine, Desert Citizens Against Pollution Mary Beth Brangan, Ecological Options Network (EON)
Betty Winholz, SAVE THE PARK Jacqueline Cabasso, Western States Legal Foundation Molly Johnson, Grandmothers for Peace-San Luis Obispo County Chapter Linda Seeley, Terra Foundation Jane Swanson, San Luis Obispo Mothers For Peace Action Committee Marylia Kelley, Tri-Valley CARES Michael Welch, Redwood Alliance Enid Schreibman, Center for Safe Energy Jennifer Olarana Viereck, Healing Ourselves and Mother Earth Dan Hirsch, Committee to Bridge the Gap Pamela Meidell, Atomic Mirror Colorado Bob Kinsey, Colorado Coalition for the Prevention of Nuclear War Sharyn Cunningham, Colorado Citizens Against Toxic Waste, Inc.
Judith Mohling, Rocky Mountain Peace andJustice Center Connecticut Nancy Burton, Connecticut Coalition Against Millstone Judi Friedman, Peoples Action for Clean Energy Sal Mangiagli, Connecticut Citizens Action Network, Haddam Chapter Delaware Alan Muller, Green Delaware District of Columbia (Washington, D.C.)
Louis Clark, Government Accountability Project Florida Bob Krasowski, Florida Alliance for A Clean Environment, The Zero Waste Collier County Group Georgia Tom Ferguson, Foundation for A Global Community Bobbie Paul, Georgia WAND Glenn Carroll, Nuclear Watch South
Bob Darby, Food Not Bombs, Atlanta Hawaii Henry Curtis, Life of the Land Idaho Beatrice Brailsford, Snake River Alliance Chuck Broscious, Environmental Defense Institute Illinois Dave Kraft, Nuclear Energy Information Service Carolyn Treadway, No New Nukes Indiana Grant Smith, Citizens Action Coalition of Indiana John Blair, Valley Watch, Inc.
Iowa Maureen McCue, PSR Iowa Kansas Dave Pack, Kansas City Peaceworks Anne Suellentrop, Kansas City PSR Kentucky Mary Davis, Earth Island Institute Louisiana Nathalie Walker, Advocates for Environmental Human Rights Maine William S. Linnell, Cheaper, Safer Power
Bruce Gagnon, Global Network Against Weapons & Nuclear Power in Space Maryland Dagmar Fabian, Crabshell Alliance Johanna Neumann, Maryland PIRG Max Obuszewski, Baltimore Nonviolence Center Lucy Duff, Peace and Justice Coalition-Prince Georges County Massachusetts Debbie Grinell, C-10 Research and Education Foundation Deb Katz, Citizens Awareness Network Mary Lampert, Pilgrim Watch Michigan Keith Gunter, Citizens Resistance at Fermi Two Michael Keegan, Coalition for a Nuclear Free Great Lakes Georgia Donovan, Izaak Walton League-Dwight Lydell Chapter Terry Miller, Lone Tree Council Patricia Gillis, Voices for Earth Justice Alice Hirt, Dont Waste Michigan Nancy Seubert, IHM Justice, Peace, and Sustainability Office Lynn Howard Ehrle, International Science Oversight Board-Organic Consumers Association Kay Cumbow, Citizens for Alternatives to Chemical Contamination Ronald and Joyce Mason, Swords Into Plowshares Peace Center and Gallery David Gard, Michigan Environmental Council Steve Senesi, Kalamazoo Non-Violent Opponents of War Minnesota Danene Provencher, West Metro Global Warming Action Group, Inc.
Glady Schmitz, Mankato Area Environmentalists George Crocker, North American Water Office Bruce Drew, Prairie Island Coalition Mississippi
Louie Miller, Mississippi Sierra Club Missouri Mark Haim, Missourians for Safe Energy Kat Logan Smith, Missouri Coalition on the Environment Montana Florence Chessin, Missoula Women for Peace, a branch of Womens International League for Peace and Freedom Nebraska Buffalo Bruce, Western Nebraska Resources Council Tim Rinne, Nebraskans for Peace Nevada Judy Treichel, Nevada Nuclear Waste Task Force Jim Haber, Nevada Desert Experience New Hampshire Will Hopkins, New Hampshire Peace Action New Jersey Paula Gotsch, Grandmothers, Mothers and More for Energy Safety Norm Cohen, Coalition for Peace and Justice-UNPLUG Salem Campaign New Mexico Mervyn Tilden, Sovereign Dine Foundation Janet Greenwald, Citizens for Alternatives to Radioactive Dumping Joni Arends, Concerned Citizens for Nuclear Safety Scott Kovac, Nuclear Watch of New Mexico Greg Mello, Los Alamos Study Group Don Hancock, Southwest Research and Information Center New York
Joanne Hameister, Coalition on West Valley Nuclear Wastes Anne Rabe, Center for Health, Environment, and Justice James Rauch, For a Clean Tonawanda Site (FACTS)
Barbara Warren, Citizens Environmental Coalition Phillip Musegaas, Riverkeeper Tim Judson, Central New York Citizens Awareness Network Manna Jo Greene, Hudson River Sloop Clearwater, Inc.
Marilyn Elie, IPSEC (Indian Point Safe Energy Coalition)
Susan Shapiro, Public Health and Sustainable Energy (PHASE)
Michel Lee, Council on Intelligent Energy & Conservation Policy (CIECP)
North Carolina Lewis Patrie, Western North Carolina Physicians for Social Responsibility E.M.T ONan, Protect All Childrens Environment Avram Friedman, The Canary Coalition Jim Warren, North Carolina Waste Awareness and Reduction Network Janet Marsh, Blue Ridge Environmental Defense League North Dakota Kandi L. Mossett, Indigenous Environmental Network Jodie L. White, The Environmental Awareness Committee, Save Our Sacred Earth Campaign Ohio Chris Trepal, Earth Day Coalition Terry Lodge, Toledo Coalition for Safe Energy Sharon Cowdrey, Miamisburg Environmental Safety and Health Network Oklahoma Marilyn McCulloch, The Carrie Dickerson Foundation Oregon Dona Hippert, Oregon Toxics Alliance Charles K. Johnson, Center for Energy Research Nina Bell, Northwest Environmental Advocates
Kelly Campbell, Oregon Physicians for Social Responsibility Gerry Pollet, Heart of America Northwest Pennsylvania David Hughes, Citizen Power Katherine Dodge, Northwest Pennsylvania, Audubon Society Gene Stilp, Taxpayers and Ratepayers United Ernest Fuller, Concerned Citizens for SNEC Safety Patricia Harner, Philadelphia Physicians for Social Responsibility Dr. Lewis Cuthbert, Alliance for a Clean Environment Rhode Island Sheila Dormandy, Clean Water Action Rhode Island South Carolina Susan Corbett, South Carolina Sierra Club Dr. Finian Taylor, Hilton Head for Peace South Dakota Deb McIntyre, South Dakota Peace and Justice Center Charmaine White Face, Defenders of the Black Hills Tennessee Donald B. Clark, Network for Economic and Environmental Responsibility, United Church of Christ Rev. Charles Lord, Caney Fork Headwaters Association Rev. Douglas B. Hunt, Interfaith Power & Light Ralph Hutchinson, Oak Ridge Environmental Peace Alliance Rev. Walter Stark, Cumberland Countians for Peace and Justice Ann Harris, We the People, Inc.
Texas Eliza Brown, SEED Coalition Mavis Belisle, Just Peace Gary Stuard, Interfaith Environmental Alliance
Craig Tounet, Austin Physicians for Social Responsibility Jill Johnston, Southwest Workers Union Utah Margene Bullcreek, Ohngo Guadedah Devia Awareness Vanessa Pierce, HEAL Utah Vermont Arnie Gundersen, Fairewinds Associates, Inc.
Clay Turnbull, New England Coalition on Nuclear Pollution Chris Williams, Vermont Citizens Awareness Network Margaret Harrington Tamulonis, Womens International League for Peace and Freedom Virginia Scott Sklar, The Stella Group, Inc.
Elena Day, Peoples Alliance for Clean Energy Washington Tom Carpenter, Hanford Challenge West Virginia Gary Zuckett, West Virginia Citizens Action Group Wisconsin Charlie Higley, Citizens Utility Board Bonnie Urfer and John LaForge, Nukewatch Wisconsin Al Gedicks, Wisconsin Resources Protection Council Judy Miner, Wisconsin Network for Peace and Justice Wyoming Mary Woolen, Keep Yellowstone Nuclear Free End notes:
The phrase "Hardened On-Site Storage" (HOSS) was coined by Dr. Arjun Makhijani of IEER in early 2002. He unveiled the concept at a summit, hosted by Citizens Awareness Network (CAN) of the Northeast, held at Wesleyan U.
in Middletown, CT in April 2002.
Dr. Gordon Thompson of Institute for Resource and Security Studies then published a report, commissioned by CAN, in Jan. 2003:
Executive Summary of Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security, Institute for Resource and Security Studies (January 2003) focuses on the vulnerability of irradiated fuel stored at the nations nuclear power stations to terrorism and what we can do about it.
Full report of Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security, Institute for Resource and Security Studies (January 2003) focuses on the vulnerability of irradiated fuel stored at the nations nuclear power stations to terrorism and what we can do about it.
The original "Statement of Principles for Safeguarding Nuclear Waste at Reactors" was published in Sept., 2006.
It was then updated in March, 2010. This update incorporated an anti-reprocessing statements.
This update is posted online here: <https://ieer.org/wp/wp-content/uploads/2010/03/HOSS_PRINCIPLES_3-23-10x.pdf>
It was updated again in 2016 (the addition of several New York State groups which wanted to add their endorsement.)
Kevin Kamps Radioactive Waste Specialist Beyond Nuclear 7304 Carroll Avenue, #182 Takoma Park, Maryland 20912 Cell: (240) 462-3216 kevin@beyondnuclear.org www.beyondnuclear.org
Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.
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[External_Sender] Beyond Nuclear's 31st set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Cessation of Irradiated Nuclear Fuel, and Principles for Safeguarding Nuclear Waste at Reactors (Har...
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