ML20309B114
| ML20309B114 | |
| 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: ML20309B114 (120) | |
Text
From:
KarenD Hadden <karendhadden@gmail.com>
Sent:
Tuesday, November 3, 2020 6:44 PM To:
WCS_CISFEIS Resource
Subject:
[External_Sender] Comments on ISP's CISF application Attachments:
Public Citizen and SEED - WCS Comments Docket # NRC-2016-0231.pdf; Dr. Resnikoff Comments - ISP & Holtec, plus resume.docx; Comment letter FINAL - Terry Lodge.pdf; Rail Accidents.xlsx WCS_CISF_EIS@nrc.gov Office of Administration Mail Stop: TWFN-7-A60M Attn: Program Management, Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Draft Environmental Impact Statement (DEIS), Docket No. 72-1050; NRC-2016-0231 Interim Storage Projects license application to construct and operate a Consolidated Interim Storage Facility (CISF) for spent nuclear fuel (SNF) and Greater-Than Class C (GTCC) waste.
Dear NRC Commissioners and Staff,
We, the Sustainable Energy and Economic Development (SEED) Coalition, Public Citizen's Texas Office, Former State Representative Lon Burnam, Tarrant Coalition for Environmental Awareness, Rose Gardner, the Alliance for Environmental Strategies, the Green Sanctuary Ministry of First Unitarian Universalist Church of Austin, and Energia Mia, oppose Consolidated Interim Storage at the Waste Control Specialists site in Texas and at the Holtec site proposed in New Mexico.
The ISP DEIS fails to adequately analyze environmental and cumulative impacts and the socioeconomic risks of the proposed radioactive waste storage application. We call on the NRC to protect public health and safety, the economy and the environment, and to prevent environmental injustice by halting the application process and denying the license for Consolidated Interim Storage.
There has been extensive prolonged opposition to the plan to dump spent nuclear fuel and Greater-Than-Class C waste on Texas. Resolutions in opposition to consolidated interim storage and transport of deadly radioactive waste through the region have been passed by Dallas, Bexar, El Paso, Midland and Nueces Counties, by the cities of San Antonio, Denton and Midland and by the Midland Chamber of Commerce.
This is not a partisan issue. It is about the health and safety of our communities, and the protection of our economy and the environment. Thousands of comments from Texans and people across the country have urged that licensing be halted and that less risky systems of storage be developed. Consolidated interim storage is a band aid approach that does not move
a viable permanent repository forward. Public meetings held in October 2020 demonstrated the ongoing solid resistance to ISP's plans, with 44 of 46 speakers in opposition on the October 15th webinar/ call hosted by the NRC, a meeting that went an hour and a half overtime due to the many individuals wishing to speak. The only two speakers in favor of the plan were paid by industry, as was the pattern throughout the four meetings.
Numerous solid health and safety contentions have been submitted to the Atomic Safety and Licensing Board by attorneys representing numerous organizations and diverse interests, including environmental organizations and oil and ranch interests. Governor Greg Abbott wrote to President Trump in opposition to consolidated interim storage and Texas legislators have sent comments as part of the DEIS process, including Representatives Donna Howard, Celia Israel, Vikki Goodwin and Senator Sarah Eckhardt, and more letters will likely be sent.
We include here the scoping comments of SEED Coalition and Public Citizen from November 19, 2018. The numerous issues raised and data presented were not adequately addressed or incorporated into the DEIS, as they should have been, so these previous scoping comments are submitted as comments on the current DEIS. Our concerns remain valid and the data provided should be incorporated into the Final DEIS. We also adopt by reference the attached comments submitted by Attorney Terry Lodge on November 3, 2020 and Dr. Marvin Resnikoff, Ph.D.
Transportation Concerns We share the concerns raised by comments from Marvin Resnikoff, Ph.D., on behalf of Radioactive Waste Management regarding both ISP's and Holtec's CISF applications. Dr.
Resnikoff notes that "Based on FRA (Federal Railroad Administration) data, the number of freight train accidents per freight train mile is 4.83E-06, or 36 times the NRC/DOT estimate."
This crucial data should be examined and incorporated into the DEIS, along with other important data he has provided regarding potential fire accidents. Dr. Resnikoff points out that "real fires can easily exceed NRC's hypothetical fires." He discusses concerns with the very heavy weight of rail cars loaded with spent nuclear fuel, which exceeds the rating of tracks. He notes that rail car wobbling can become a problem when numerous axles are used, and states that "This additional weight will place a burden on the rail infrastructure. The HI-STAR cask, containing 37 PWR fuel assemblies, will require a 3-car, 12-axle carriage, which will cause a train to slow on curves. This information is missing in the DEIS but should be included in order to fully address transportation concerns.
High-burnup fuel concerns are laid out as well. Resnikoff states that "High burnup fuel contains more fission products, particularly the semi-volatile Cs-137, which would account for high gamma doses to EMTs and the general public. The fraction of volatile Cs-137 in the gap between the cladding and fuel should be based on more recent DOE reports; supporting NRC documents for this gap cesium are not referenced, but, in our experience, are based on outdated 1978 reports. High burnup fuel also has thinner and more brittle cladding that may shatter in high impact accidents.
NRC staff needs to more carefully review the impact of transporting high burnup fuel to the proposed ISP/WCS facility. A spreadsheet containing calculations is also attached." Again, this data should be incorporated into the DEIS.
Cumulative Impacts and Off-Normal Events Analysis
Regarding cumulative impacts the DEIS states Cumulative effects, synonymous with cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. A proposed project could contribute to cumulative effects when its environmental impacts overlap with those of other past, present or reasonably forseeeable future actions. For this environmental impact statement (EIS) other past, present, and future actions considered in the analysis for the proposed consolidated interim storage facility (CISF) project include (but are not limited to) other nuclear facilities, oil and gas production, and wind and solar farms.
Attorney Terry Lodge submitted DEIS comments (attached and adopted as part of our collective comments) on behalf of numerous organizations that included the following in Section VII:
"Design Events II are associated with off-normal operations that can be expected to occur with moderate frequency, approximately once per year. These events could result in members of the general public being exposed to additional levels of radiation beyond those associated with normal operations. During normal operations and off-normal conditions, the requirements of 10 CFR Part 20 must be met. In addition, the annual dose equivalent to any individual located beyond the controlled area must not exceed 0.25 mSv [25 mrem] to the whole body, 0.75 mSv [75 mrem] to the thyroid, and 0.25 mSv [25 mrem] to any other organ. The DEIS notes that ISP/WCS evaluated for the proposed CISF (ISP, 2018) for an operating NUHOMS system included cask handling, transfer vehicle moving, and canister transfer. Off-normal events evaluated for the NAC International (NAC) system components included blockage of half the storage cask air inlets, canister off-normal handling load, failure of instrumentation, small release of radioactive particulate from the canister exterior, and severe environmental conditions (e.g., hypothetical wind). Off-normal events evaluated for the MAGNASTOR system included crane failure during loaded transfer cask movements and crane/hoist failure during the transportable storage canister (TSC) transfer to the vertical concrete cask (VCC). The ISP safety evaluation of these off-normal events for each potential storage system concluded that the proposed storage system would not exceed applicable 10 CFR 72.106(b) dose limits to individuals at or beyond the controlled area boundary and would satisfy applicable acceptance criteria for maintaining safe operations regarding criticality, confinement, retrievability, and instruments and control systems (ISP, 2018).
The DEIS cumulative impact analysis is missing some key information and we question the validity of the dose limit conclusions for this reason. Further analysis is needed, and the information provided here should be included in the Final DEIS. The DEIS is inadequate because it fails to analyze potential impacts of radiation and increased doses that could result to employees at LES/ URENCO-USA, 1.5 miles from ISP's proposed CISF. The "NEF (National Enrichment Facility) is operated by Louisiana Energy Services (LES), which is in turn owned by the Urenco Group. As of 2011, LES operates as URENCO USA...Since the Dedication Ceremony in October 2008, the company has grown to 236 employees with an annual payroll of USD 23 million. At full capacity, NEF can provide 50% of the current enriched uranium demand for civilian nuclear power plants in the U.S.[2] "[1]
DEIS Section 5.1.1.0 Waste Disposal Facilities
On DEIS page 5-9, lines 28-35, CK Disposal is discussed, a potential surface waste disposal facility consisting of a landfill, a liquid processing area and deep well injection. This section states that the facility would be 1.5 miles west of the proposed CISF project and would have an active life of 38 years, and it was reportedly permitted on April 4, 2017. The DEIS further states that "The NRC staff was not able to verify any of the information concerning CK Disposal, including the 2017 permit, but includes the reported information for completeness."
A facility this close to the CISF should have been investigated thoroughly. There is no reason not to be able to verify the information about CK Disposal, since a fair amount of information is publicly available online. This omission must be remedied. The DEIS fails to note whether construction has begun on CK Disposal, or whether the facility is completed and/or operating or whether the company has changed names and opened. It fails to analyze the impacts of this permitted facility despite its very close proximity.
A hearing on CK Disposal's permit was held by the State of New Mexico Oil Conservation Commission in Eunice on January 9, 2017, where public comment was received on Case 15617.
The Commission subsequently held a hearing beginning on February 8, 2017.[2]
During the hearing, experts for LES / URENCO-USA, which operates the National Enrichment Facility, 1.5 miles west of the proposed CISF site, raised and documented serious concerns about impacts from the potential CK Disposal site. Vital information came to light, including a statement that the LES site cannot be evacuated.
The minutes of the Feb. Oil Conservation Commission meeting include on page 4, "The first witness for LES was Stephen Cowne, Head of Compliance for URENCO-USA. He explained that LES' function is to enrich uranium and is subject to the oversight of several federal agencies. He stated that LES rules do not allow evacuation of the plant. He explained the process of shutting down the facility."
The ISP DEIS fails to consider the fact that the LES facility, with some 236 employees, 1.5 miles from where up to 40,000 metric tons spent nuclear fuel cannot be evacuated. This is a serious omission which should be corrected. The DEIS should examine the LES rules carefully and determine how many people could be present at a site that could not be evacuated and for how long they could be exposed if there was an off-normal event at the CISF. Other people in the region might be able to evacuate, but the amount of exposure that employees might receive if they had to remain at the URENCO-USA site for hours or days should be analyzed, along with the number of workers who could potentially be impacted.
The DEIS is also deficient and should be revised to include information regarding other impacts related to the CK Disposal site. This Oil Conservation Commission hearing also raised the issue of potential hydrogen sulfide and chloride releases from CK Disposal. The minutes include the following, "The next witness was Matthew McGovern, Chemistry Services Manager for URENCO-USA. He said he was asked to evaluate CK's application to see if it would affect any of URENCO's operations. He explained his concern about H2S concentrations and released chlorides impacting corrosion rates on some electronic equipment and vehicles, and the possibility of chlorides being deposited in storm water detention ponds."[3]
The ISP DEIS fails to consider the potential impact of hydrogen sulfide and chlorides that could impact corrosion rates at the proposed CISF, for radioactive waste containers, monitoring systems, electronic, vehicles or handling facilities at the site. These should be considered since the CK Disposal Site has been permitted.
The issue of metals or petroleum products that could be transported from CK Disposals ponds was also raised. "LES' next witness was Nadia Glucksberg, Senior Associate, Lead Hydrogeologist and Program Manager with Haley & Aldrich. She testified on the windblown transport of contaminates. She said she was hired by LES to review CK' s permit application with respect to impacts on the environment. She discussed migratory bird protection and the impact on birds if they ingest any amount of metals or petroleum products which might be transported from CK's ponds to the LES facility."[4]
If the CK Disposal site could produce windblown contaminants including metals or petroleum products that could impact the LES site, these contaminants could also reach the equidistant proposed CISF site and should be analyzed fully. The DEIS should consider these impacts of these potential contaminants but failed to do so.
Halt Licensing Now This nation must end environmental injustice and halt disproportionate impacts on people of color. Dumping the most toxic nuclear waste of a whole nation on the largely Latinx Southwest region would be the height of environmental injustice. Its time to protect the land, air and water, wildlife, plant life and aquifers of this region and transport regions along the way. Businesses at risk include pecan growers, the ranching and dairy industries, the oil and gas industry and more. The NRC should protect public health and safety, the economy and the environment, by halting the application process and denying the ISP license application for Consolidated Interim Storage.
Submitted on behalf of SEED Coalition, Public Citizen's Texas Office, Former State Representative Lon Burnam, Tarrant County Coalition for Environmental Awareness, Rose Gardner, Alliance for Environmental Strategies, the Green Sanctuary Ministry of First Unitarian Universalist Church of Austin and Energia Mia, By Karen Hadden Sustainable Energy & Economic Development (SEED) Coalition, Executive Director
[1] https://en.wikipedia.org/wiki/National_Enrichment_Facility
[2] CK Disposal Permit - Feb. 8, 2017 NM Oil Conservation Commission
[3] CK Disposal Permit - Feb. 8, 2017 NM Oil Conservation Commission
[4] CK Disposal Permit - Feb. 8, 2017 NM Oil Conservation Commission
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
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September 24, 2018
86,950 100%
861 43,961 51%
736 41,396 48%
584 84 0%
130 N/A N/A N/A N/A N/A N/A N/A N/A N/A 328 0%
133 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 130 103 N/A 171 N/A N/A N/A N/A 115 225 0%
113 76 0%
80 N/A N/A N/A 165 0%
N/A N/A N/A N/A N/A N/A N/A N/A N/A 58 N/A N/A N/A 153 0%
N/A 203 0%
83 116 0%
1,133 N/A N/A N/A N/A N/A N/A N/A N/A 57 0%
N/A N/A N/A N/A 52 0%
42,989 49%
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0.5 mile Ring around the Corridor, TEXAS, EPA Region 6 Approximate Population: 90,644 UP Bexar County, Route 2 (The study area contains 1 blockgroup(s) with zero population.)
September 24, 20 Input Area (sq. miles): 40.25
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37,834 41,861 4,640 24,901 151.10 99%
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7,516 70,127 61%
2,476 20,475 18%
1,906 499 0%
612 9,040 8%
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149 10,828 9%
896 3,350 3%
687 44,877 39%
1,989 69,556 38,074 33%
2,152 19,936 17%
1,799 303 0%
612 8,971 8%
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1,477 67 143 0%
170 100%
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383 54,981 48%
1,773 59,452 52%
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%
1,602 5,335 7%
359 6,359 9%
376 18,687 26%
872 21,042 29%
1,348 5,539 8%
747 20,181 28%
1,448 104,914 100%
2,537 67,602 64%
2,183 37,313 36%
1,960 25,417 24%
1,634 6,499 6%
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489 1,278 1%
253 5,397 5%
534 11,896 11%
997 2,194 100%
334 1,699 77%
156 175 8%
220 308 14%
195 11 1%
27 37,834 100%
702 4,307 11%
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%
865 34,793 67%
732 16,405 31%
552 52 0%
62 N/A N/A N/A N/A N/A N/A N/A N/A N/A 186 0%
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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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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%
308 1,334 6%
194 3,087 14%
313 33,992 100%
757 17,639 52%
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552 10,705 31%
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201 2,014 6%
280 1,332 4%
171 3,347 10%
283 5,648 17%
292 1,374 100%
126 1,354 99%
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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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375 100%
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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%
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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%
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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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0.5 mile Ring around the Corridor, TEXAS, EPA Region 6 Approximate Population: 153,581 BNSF Harris County September 24, 20 Input Area (sq. miles): 46.38
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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%
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November 12, 2018
48,635 100%
960 29,314 60%
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176 14 0%
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N/A 104 0%
68 53 0%
1,212 N/A N/A N/A N/A N/A N/A N/A N/A 2
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19,321 40%
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265 30,006 33%
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661 24,953 27%
717 333 0%
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101 100%
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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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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%
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617 25,859 30%
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225 4,277 5%
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235 7,118 8%
367 11,159 13%
367 1,991 100%
114 1,952 98%
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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%
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216 13,340 42%
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542 40,440 62%
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1 Comments on ISP/WCS DEIS By Marvin Resnikoff, Ph.D.1 Radioactive Waste Management October 2020 Our review of the DEIS for the proposed ISP/WCS facility is focused on the transportation impact of licensing the proposed Texas facility. The DEIS is based on NUREG-2125, which is based in turn on reports by Hanson and Volpe. We find the probability of serious accidents, particularly, accidents involving fires, are underestimated. Based on FRA data, the number of freight train accidents per freight train mile is 4.83E-06, or 36 times the NRC/DOT estimate.
Since the analysis by the NRC is based on NUREG-2125, which we extensively reviewed for the proposed CIS facility in New Mexico2, weve attached the previous analysis and will not repeat it here.
We are most concerned about fire accidents. Supporting documents to NUREG-2125 model a cask sitting on a pool of fire, a configuration that is not the most serious. NRC regulations require the cask to be at a 1 meter height above a fire pool which implies higher flame temperatures at the ends and sides of a cask. Higher flame temperatures at the cask ends can degrade the cask seals, as shown in studies by Sandia3.
Cask Seals Degrade in Hydrocarbon fire As the figure from NUREG/CR-66724 below shows, the monolithic steel rail cask reaches an internal temperature of 900 degrees centigrade at hour 11 of a theoretical fire. This is due to a hydrocarbon fire temperature of 1000 degrees centigrade for 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. The model that is used by Sandia is a one dimensional model (radius R), so the model does not reflect the temperature at the ends of a cask nor the flame temperature for a cask 1 meter above a pool fire (which is the regulatory requirement). As Greiner shows, for a cask 1 meter above the fire pool, the temperature at the cask ends exceeds the temperature at which the seals degrade in a time that's closer to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, as discussed in the attached report. The fire temperature at the cask ends is higher than below or above the cask body. Greiners results, which appear in a Sandia report, are based on modeling with the program CAFÉ that has been benchmarked for real fires. At the 1 Marvin Resnikoff is a high energy theoretical physicist who has worked on nuclear transportation issues for the Sierra Club and many State governments for 45 years. His resume is attached.
2 (RWMA, 2020) 3 (Greiner, 200), (Greiner, 2005), (Greiner, 2006).
4 (SAND, 2000)
2 point when the seals degrade, the radioactive gases and volatiles may begin to be released from the cask that is under pressure.
Real Fires Can Easily Exceed NRCs Hypothetical Fires In a critique of our comments in the New Mexico proceeding, Holtec states the Sierra Club doesn't address or dispute DOEs finding in the 2008 FSEIS that we used unrealistic parameters.
The reality is DOEs critique appeared in the final environmental impact statement. The State of Nevada didn't have the opportunity to rebut this improper critique within the Department of Energys FSEIS proceeding. Further, the NRC has not considered recent fire accident probabilities. We have also raised the issue of the increased probability of a rail fire accident based on recent FRA data. This issue has not been addressed by the NRC. The matter of fire probabilities is discussed in detail in our attached comments on the CIS DEIS. Further, real fire accidents have exceeded the 11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> analysis carried out in NUREG/CR-6672 such as the 2013
3 fire accident in Lac-Megantic, Quebec5 that burned for almost two days and destroyed half the town. There was therefore a genuine material dispute with the NRC that was not properly addressed by the NRC hearing panel. In any future proceeding regarding Yucca mountain or the CIS facility we would use the Greiner results which have also been produced by Sandia laboratory to counter the NRC.
The DEIS also assumes an unrealistic 10-hour exposure time for emergency workers, implying the cask can be moved in this time period. NRC staff need to more closely examine real train derailments, particularly accidents involving fires, and the time to restore service. NUREG-2125 examines fires that burn up to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, while some real fires have burned for 2 days, as discussed in the attached report.
As the capacity of spent fuel casks has increased, the weight of the casks has increased as well.
This additional weight will place a burden on the rail infrastructure. The HI-STAR cask, containing 37 PWR fuel assemblies, will require a 3-car, 12-axle carriage, which will cause a train to slow on curves.
NUREG-2125 considers only mid burnup fuel, 45 GWd/MTU, cooled for 9 years, and not high burnup fuel, with burnup between 60 to 70 GWd/MTU. High burnup fuel contains more fission products, particularly the semi-volatile Cs-137, which would account for high gamma doses to EMTs and the general public. The fraction of volatile Cs-137 in the gap between the cladding and fuel should be based on more recent DOE reports; supporting NRC documents for this gap cesium are not referenced, but, in our experience, are based on outdated 1978 reports. High burnup fuel also has thinner and more brittle cladding that may shatter in high impact accidents.
NRC staff needs to more carefully review the impact of transporting high burnup fuel to the proposed ISP/WCS facility. A spreadsheet containing our calculations is also attached.
References (Greiner, 2000) Greiner, et al, NUMERICAL PREDICTION OF HEAT-FLUX TO MASSIVE CALORIMETERS ENGULFED IN REGULATORY FIRES WITH THE CASK ANALYSIS FIRE ENVIRONMENT (CAFE) MODE, SAND2000-1194C, July 2000.
(Greiner, 2005) Greiner, et al,, THERMAL PROTECTION PROVIDED BY IMPACT LIMITERS TO CONTAINMENT SEAL WITHIN A TRUCK PACKAGE, Proceedings of PVP2005, 2005 ASME Pressure Vessels and Piping Division Conference, July 17-21, 2005, Denver, Colorado, USA.
(Greiner, 2006) Greiner, et al, FIRE DURATIONS OF CONCERN FOR A MODERN LEGAL WEIGHT TRUCK CASK, Proceedings of PVP2006-ICPVT-11, 2006 ASME Pressure Vessels and Piping Division Conference, July 23-27, 2006, Vancouver, BC, Canada 5 (TrainsMag, 2018)
4 (Hanson, 2008), Hanson, B.D., et al, Fuel-In-Air FY07 Summary Report, PNNL-17275, Rev. 1, September 2008.
(RWMA, 2020) Resnikoff, M, Comments on CIS DEIS, Radioactive Waste Management Associates, September 2020.
(SAND, 2000) Sprung, J.L., et al., Reexamination of Spent Fuel Shipment Risk Estimates, NUREG/CR-6672, (SAND2000-0234), Sandia National Laboratories, Albuquerque, NM, March 2000. Vol. 1 (the main report) is available as ADAMS Accession No. ML003698324.
(TrainsMag, 2018) Trains Wreck, Vol. 2, Crashes that Changed Railroading, September 2018.
Comments on CIS DEIS By Marvin Resnikoff, Ph.D.6 Radioactive Waste Management Associates September 2020 Summary Our review of the CIS DEIS7, including the supporting document NUREG-21258, and its supporting documents9, show that the accident rate for rail freight and the fire accident rate for rail freight are underestimated. In a severe impact accident, according to NUREG-667210, the lid bolts may stretch, allowing gases and volatiles to escape. In a severe fire accident, which may involve more than one tank car, fires have burned for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, longer and hotter than considered in the DEIS and NUREG-2125. NUREG-2125 considers a 3-hour hydrocarbon fire by one tank car; NRC regulations11 consider a 1/2 hour all-encompassing fire. Since the DEIS is based on NUREG-2125, which is incorrect, the NRC must correct the supporting documents and the CIS-DEIS itself.
Rail Freight Accident Rate/Probability 6 Marvin Resnikoff is a high energy theoretical physicist who has worked on nuclear transportation issues for the Sierra Club and many State governments for 45 years. His resume is attached.
7 (NRC, 2020) 8 (NRC, 2014) 9 (Volpe, 2006) and (Hanson, 2008) 10 (SAND, 2000) 11 10 CFR 71.73
5 According to NUREG-2125, the average freight rail accident frequency is 1.32
- 10-7 per railcar mile based on DOT historic accident frequencies from 1991 to 2007. We have determined this accident frequency is an underestimate. From the DOT Federal Railroad Administration database, for the more recent period 2010 to 2018, the accident frequency is 3.4915E-06, or 26 times greater than the NRCs number. If we assume almost all rail accidents are freight train accidents, the accident frequency, the number of freight train accidents per freight train mile is 4.83E-06, or 36 times the NRC/DOT estimate. While the NRC estimates 8 accidents over a 20-year period to the proposed CIS, we estimate 168 rail accidents, assuming 3-car trains. This also assumes the rail infrastructure, including bridges, remains at the same safety level. A summary of these calculations appears in the attached spreadsheet12, based on FRA spreadsheets of yearly accident data.
Accidents can include impact or fire, which are discussed in the next section. NUREG-2125 and NUREG/CR-6672 showed that a severe impact accident, between 90 and 120 mph, can lead to a lid opening in the transportation cask13. The estimated probability for the 7 impact accidents considered is, according to the NRC, 1 in a billion. The release is from a cask without an internal canister, such as the CASTOR cask; for the Holtec cask, with an internal canister, the DEIS assumes no release on impact. As shown above, the NRC accident probabilities are underestimates. Further, NUREG-2125 considers only mid burnup fuel, 45 GWd/MTU, cooled for 9 years, and not high burnup fuel, between 60 to 70 GWd/MTU, which contains more fission products, particularly the semi-volatile Cs-137, which would account for high gamma doses to the population and EMTs in a severe impact accident. Higher burnup can also cause a thinning of the cladding. The DEIS also assumes a 10-hour exposure time, which is entirely unrealistic for a severe accident in a populated area, such as Las Vegas. Radiation doses to EMT and the public are minimized by the NRC, by unrealistically assuming a cask can be moved within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. To see how unrealistic a 10-hour time period is, consider the following. An empty Holtec transfer cask, Holtecs HI-TRAN cask, fell off the highway in Andover, Vermont, on the way to the Vermont Yankee former reactor on June 25, 202014. The local road was closed for 2 days while emergency equipment, including a crane (9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> to assemble) and a heavy-duty tow truck were brought in. An accident involving radioactive materials could easily take much longer.
NRC staff need to focus more realistically on the recovery time for a serious accident involving radioactivity, since this will reflect an NRC bias and whether the public can accept any other part of the DEIS.
Weight In order to reduce the cost of dry storage, the nuclear industry has moved to larger casks with greater capacity. The first Holtec cask, the HI-STAR 60 (loaded weight 82 tons) held 12 PWR fuel assemblies. The HI-STAR 100 (loaded weight 140 tons) held 24 PWR fuel assemblies. The latest Holtec edition, the HI-STAR 190 XL (loaded weight 208 tons) contains 37 PWR fuel assemblies. As the capacity of Holtec casks increased, the weight of the casks increased as well.
12 (Resnikoff, 2020) 13 (NRC, 2014), p. 123 and Table 5-10.
BBrattleboro Reformer, June 27, 2020.
6 This additional weight will place a burden on the rail infrastructure. The general nationwide rail system has an axle limit of approximately 36 tons, or 143 tons for a 4-axle rail car, which is a problem since the HI-STAR 190 XL itself, without the carriage and cask restraints, weighs 208 tons. Other heavy casks, such as the Areva MP-197, face a similar predicament. While the loaded weight of the CASTOR V/21 cask (138 tons) plus carriage may exceed 143 tons, it is much lighter than the HI-STAR 190 XL. Larger CASTOR casks are also in use in Europe.
Rail cars that exceed 143 tons are in service on US rails, but must have more than 4 axles. GE diesel engines, such as the AC6000CW, weigh between 212 and 216 tons. The Navy M-290 transport cask weighs 260 tons, on a 3-car, 12-axle carriage. At 36 tons per axle, 12 axles can support 432 tons. DOE originally proposed an 8 axle car for the HI-STAR 190 XL, but design calculations showed wheel hunting, which produces side to side wobbling and potential derailment under high speed. The new car, being designed by Atlas, is similar to the 12-axle M-290 rail car. A 3-car, 12-axle carriage will cause the train to slow down on curves.
Rail Fires and Cask Damage While the rail accident rate, according to FRA, has declined in the years between 2010 and 2018, the same is not true for the fire accident rate, which has risen over the same years. Our review of the FRA data show 392 accidents involving fire of varying severity between the years 2010 through 2018, ranging between 16 and 79 fire accidents per year. Comparing the periods 2000 to 2009 considered in NUREG-2125, and the period 2010 to 2018, the fire accident rate has almost doubled. NRC staff should consider the most recent data. Graphs showing rail fires per freight train mile for the years 2000 - 2009, and years 2010 - 2018 appear as Fig. 1 and 2, respectively.
The reason for this increase of fire accidents is not difficult to understand; more tanker cars are on the rail, mainly from North Dakota to refineries on both coasts.
Figure 1. Rail Fires, Yrs 2000 - 2009.
0.00E+00 1.00E-08 2.00E-08 3.00E-08 4.00E-08 5.00E-08 6.00E-08 7.00E-08 8.00E-08 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Fire/FRTRN Mi Year Fire/FRTRN Mi
7
8 Figure 2. Rail Fires, Yrs 2010 - 2018.
The bottom line is more fires have been occurring per accident than is acknowledged by NUREG-2125.
Based on FRA data, as seen in the attached spreadsheet, fire accidents occur in about 2% of rail accidents. The fire accident probability calculated by Volpe15, and used in NUREG-2125, is orders of magnitude smaller, and does not reflect reality. NRC staff need to more seriously examine recent rail fires and potential damage to cask seals, particularly the work at Sandia by Greiner16.
The NRC does not correctly analyze the more serious consequences of a rail fire. NUREG-2125 states one CAFÉ nonregulatory fire was runsimulating the cask being on the ground and at the center of the pool17. NUREG-2125 states this is the most severe case; it is not, and it is not even the regulatory configuration. According to 10 CFR 71.73, a cask must be 1 meter above a hydrocarbon pool fire. As shown by Greiner18, in a hydrocarbon fire with a horizontal cask at 1 meter above the pool fire, the flame temperatures at the extremities (the ends and the sides of the cask) are the hottest; the bottom and the top of the horizontal cask are at lower temperatures.
Greiner ran the CAFÉ model for a 3-hour fire. The cask seal degraded at 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, if the impact limiters were missing, which might occur in an impact accident, followed by a fire. If the impact limiters were present, serving as insulation, the seals would degrade a short time after the 3-hour fire was extinguished. However, rail fires can easily exceed 1/2 hour or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Generally, trains hauling tanker cars can have 50 or more tanker cars in a train consist. One of 15 (Volpe, 2006) 16 (Greiner, 2000) 17 (NUREG-2014), Fig. D-27.
18 (Greiner, 2000) 0.00E+00 2.00E-08 4.00E-08 6.00E-08 8.00E-08 1.00E-07 1.20E-07 1.40E-07 1.60E-07 1.80E-07 2010 2011 2012 2013 2014 2015 2016 2017 2018 Fire/100 million FRTRN Mi Year Fire/FRTRN Mi
9 the most serious train fire accidents occurred in Lac Megantic, Quebec, in July 2013, where a 74-car, tanker car train from North Dakota, derailed and burned for almost 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and destroyed half the town, killing 47 residents19. It took hundreds of firefighters from Maine, Quebec and Ontario to extinguish the fire.
Without a more serious review of the probability and consequences of real rail fire accidents, NUREG-2125 reads like a fairy tale.
Severe Rail Accident Radioactive Releases NUREG-2125 bases the release of gases and volatiles in spent fuel on a report by Hanson20.
However, Hanson consider a release due to impact, not a fire. Nevertheless, Hanson does indicate how much cesium is in the gap between the cladding and the fuel itself in section 4.3, page 4.12. But Hanson does not have reference for the fraction 3 x 10-5 for cesium within the gap. In fact the value 3
- 10-5 is an old number, based on studies by Lorenz in 1978 and has little relevance to high burnup fuel, 60 - 70 GWd/MTU. The average burnup for the fuel considered by Hanson is on the order of 30 - 40 GWd/MTU.
Cesium Release in Fire Accidents In NUREG-2125, fraction of cesium released to the internal cask environment (the rod to cask release fraction), is 3
- 10-5 (Table E-16). This release fraction pertains to an impact accident and does not pertain to a fire accident. NUREG-2125, based on Hanson, does not have a release due to a fire. The source of the parameter values in table E-16 is listed as Hanson, section 4.3, page 4.12. But Hanson does not have that value for volatiles 3
- 10-5 in that section or in any section of the Hanson report. So where NUREG-2125 obtains the number 3
- 10-5 for volatiles is not documented. In fact, it is an old number, based on experiments by Lorenz in 1978.
Hanson does examine fission gas releases (FGR), mainly inert gases Xe and Kr, as a function of burnup. For medium burn up fuel, the FGR ranges from 0.25% to 18%, a very large spread. But when one looks at burnups on the order of 65 to 70 MWd/MTU, the FGR gas release is on the order 3% to 4.4% and the inventory of Cs is also greater. Obviously the higher the burn up, the more fission gas is generated in nuclear fuel and also the amount of cesium produced. Hanson does investigate the measured release fraction of fission gases for higher burnup fuel, on the order of 3 to 4%. But this release is not a function of fire. It is based on impact making a release from the fuel and from the cask itself.
In table 1.3 of PNNL-17275, the FGR from fuels is listed. The average burn up for the fuel is what we would call medium burn up fuel, on the order of 30 to 45 MWd/MTU. And the FGR varies from.25% to 11%. But Hanson does consider high burnup fuel in table 1.3. Hanson does analyze the amount of cesium percentage in the gap between fuel and cladding (Table 1.4),
from 0.2% to 10%. But it does not list the gap cesium in high burnup fuel, a curious omission.
19 (TrainsMag, 2018) 20 (Hanson, 2006)
10 This gap cesium would be released in a serious accident. On page 1.12 of Hanson, the section titled Fission-Gas Release, volatile radionuclide release is listed. It states that the main contributor to FGR are the fission products xenon and Krypton since they are gases highly mobile and do not react with other elements. But for Cs, the report goes on to state that the fraction of cesium elements may be volatile at the temperatures of interest for fuel handling transport. Table 1.4 list the gap and grain boundary inventories measured by leaching for some of the fuels in table 1.3. But the fuels listed are medium burner and only minimal quantities it states with the exception of iodine are located outside of the fuel matrix. In the type of accident that NUREG-2125 considers, namely, impact, Hanson states the volatile element release is going to be similar to fine particles of fuel with the exception of iodine and sometimes cesium which are similar to the FGR. The respirable fraction is similar to that for gas. However, NUREG-2125 and Hanson in particular are measuring particulates and not gases in their experimental setups.
Fire analysis for truck and rail casks are contained in chapter 4. In addition impact limiters are modelled as undamaged. NUREG-2125 says it makes little difference whether the impact limiters are included or not, but we strongly disagree. According to Greiner, the presence of impact limiters makes a major difference on the heat that cask ends will experience. We discuss next Greiner results which show seal damage due to a fire, but none of the results in NUREG-2125 for fires up to three hour duration result in the release of radioactive material. None of the fire accidents consider seal damage; this directly contradicts the experimental results by Greiner both in terms of the Nevada supported papers and also the Sandia papers by Greiner.
Impact Limiter and Seal Damage21 NUREG-2125 states that cask seals would not be damaged in a regulatory fire, or even a fire of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> duration. Experimental data by Greiner22 shows this is incorrect. Greiner employed the CAFÉ (Container Analysis Fire Environment) computer code to simulate the response of a truck package designed to transport one PWR fuel assembly in a 7.2-m-diameter pool fires.
Simulations were performed with the package centered over the fire, and offset axially from that location by 1 and 2.5 m. In all simulations the package body was 1 m above the fuel pool as required by NRC regulations, 10 CFR Part 71.73. Simulations were also carried out with the absence of an impact-limiter version. When the center of the no impact limiter cask is within 2.5 m of the pool center, fires shorter than 0.7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> can cause the seal to reach the degradation temperature. By contrast, the intact package protects the seal in fires that last roughly 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Taking into account the internal cask pressure and fuel cladding damage, Greiner did not estimate the amount of volatiles released and the potential health effects.
In more detail23, Table 10 shows results of a 3-hour fire. The seal reaches its temperature of concern at t = 2.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />. It reaches its maximum temperature of TS,Max = 496 oC at t = 3.15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />, 0.15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after the fire is extinguished.
21 (Greiner, 2005) 22 Ibid.
23 Ibid.
11 Conclusion Our review of the DEIS for the proposed CIS facility focused on the transportation impact of licensing the proposed New Mexico facility. The DEIS is based on NUREG-2125, which is based in turn on reports by Hanson and Volpe. We find the probability of serious accidents, particularly, accidents involving fires, are underestimated. Over a 20-year period, we estimate 168 rail accidents to the proposed CIS, assuming 3-car trains. Based on FRA data, the number of freight train accidents per freight train mile is 4.83E-06, or 36 times the NRC/DOT estimate.
We are most concerned about fire accidents. Supporting documents model a cask sitting on a pool of fire, a configuration that is not the most serious. NRC regulations require the cask to be at a 1 meter height above a fire pool which implies higher flame temperatures at the ends and sides of a cask. Higher flame temperatures at the cask ends can degrade the cask seals, as shown in studies by Sandia.
The DEIS also assumes an unrealistic 10-hour exposure time, implying the cask can be moved in this time period. NRC staff need to more closely examine train derailments, and the time to restore service.
As the capacity of Holtec casks have increased, the weight of the casks has increased as well.
This additional weight will place a burden on the rail infrastructure. The HI-STAR cask, containing 37 PWR fuel assemblies, will require a 3-car, 12-axle carriage, which will cause a train to slow on curves.
NUREG-2125 considers only mid burnup fuel, 45 GWd/MTU, cooled for 9 years, and not high burnup fuel, between 60 to 70 GWd/MTU, which contains more fission products, particularly the semi-volatile Cs-137, which would account for high gamma doses to EMTs and the general public. The fraction of volatile Cs-137 in the gap between the cladding and fuel should be based on more recent DOE reports; supporting NRC documents for this gap cesium are not referenced, but, in our experience, are based on outdated 1978 reports. High burnup fuel also has thinner and more brittle cladding that may shatter in high impact accidents.
NRC staff needs to more carefully review the impact of transporting high burnup fuel to the proposed CIS facility. A spreadsheet containing our calculations is attached.
References (Greiner, 2000) Greiner, et al, NUMERICAL PREDICTION OF HEAT-FLUX TO MASSIVE CALORIMETERS ENGULFED IN REGULATORY FIRES WITH THE CASK ANALYSIS FIRE ENVIRONMENT (CAFE) MODE, SAND2000-1194C, July 2000.
(Greiner, 2005) Greiner, et al,, THERMAL PROTECTION PROVIDED BY IMPACT LIMITERS TO CONTAINMENT SEAL WITHIN A TRUCK PACKAGE, Proceedings of
12 PVP2005, 2005 ASME Pressure Vessels and Piping Division Conference, July 17-21, 2005, Denver, Colorado, USA.
(Greiner, 2006) Greiner, et al, FIRE DURATIONS OF CONCERN FOR A MODERN LEGAL WEIGHT TRUCK CASK, Proceedings of PVP2006-ICPVT-11, 2006 ASME Pressure Vessels and Piping Division Conference, July 23-27, 2006, Vancouver, BC, Canada (Hanson, 2008), Hanson, B.D., et al, Fuel-In-Air FY07 Summary Report, PNNL-17275, Rev. 1, September 2008.
(Resnikoff, 2020) Resnikoff, M, RWMA, Rail Accidents, xls, June 2020.
(NRC, 2014) Spent Fuel Transportation Risk Assessment, NUREG-2125, January 2014.
(TrainsMag, 2018) Trains Wreck, Vol. 2, Crashes that Changed Railroading, September 2018.
(SAND, 2000) Sprung, J.L., et al., Reexamination of Spent Fuel Shipment Risk Estimates, NUREG/CR-6672, (SAND2000-0234), Sandia National Laboratories, Albuquerque, NM, March 2000. Vol. 1 (the main report) is available as ADAMS Accession No. ML003698324.
(Volpe, 2006) Volpe Center, Spent Nuclear Fuel Transportation Risk, Draft Report, Volpe National Transportation Systems Center, Cambridge, MA, 2006.
13 M.RESNIKOFF, PH.D. RESUME EDUCATION Ph.D., Physics - 1965, University of Michigan M.S., Physics - 1962, University of Michigan B.A., Physics/Math - 1959, University of Michigan
SUMMARY
OF PROFESSIONAL EXPERIENCE Marvin Resnikoff is Senior Associate at Radioactive Waste Management Associates and is an international consultant on radioactive waste management issues. He is Principal Manager at Associates for dose reconstruction and risk assessment studies of radioactive waste facilities and transportation of radioactive materials. A nuclear physicist and a graduate of the University of Michigan, Dr. Resnikoff has worked on radioactive issues since his first project at West Valley, New York in 1974.
Throughout his career, he has assisted public interest groups and state and local governments across the US, Canada, Germany and England on radioactive waste storage and transportation issues. He has authored or co-authored four books on radioactive waste issues including Living Without Landfills, regarding low-level waste landfills, and The Next Nuclear Gamble, regarding transportation of radioactive waste.
PROJECTS Radiological Implications of Fracking. Dr. Resnikoff examined the radiological implications of fracking in papers on indoor radon concentrations and drill rock disposal in landfills from the Marcellus shale formation. For Delaware Riverkeepers (PA), FreshWater Accountability Project (OH) and Residents for the Protection of Lowman and Chemung (NY) he wrote reports that examined the implication of disposal of drill cuttings and drill fluids on landfills and the environment. In 2011 he was an invited speaker at the national conference of the Water and Environment Federation. He examined several fracking sites in Pennsylvania.
Dose Reconstruction. He has conducted dose reconstruction studies of oil pipe cleaners in Mississippi and Louisiana, residents of Canon City, Colorado near a former uranium mill, residents of West Chicago, Illinois near a former thorium processing plant, and residents and
14 former workers at a thorium processing facility in Maywood, New Jersey. He has also served as an expert witness for plaintiffs in Karnes County, Texas, Milan, New Mexico and Uravan, Colorado, who were exposed to radioactivity from uranium mining and milling activities. He has worked on personal injury cases involving former workers and residents at the ITCO and other oil pipe cleaning yards in Louisiana and Texas. He also evaluated radiation exposures and risks in worker compensation cases involving former workers at Maywood Chemical Works thorium processing plant.
He also served as an expert witness in a case involving the Port St. Lucie reactors and brain cancer developed by two children and in a case involving clean-up of an abandoned radioactive materials processing facility in Webster, Texas. He investigated phosphogypsum plants in Florida, Texas and Alberta, Canada and served as an expert witness in a personal injury case involving a Texas phosphogypsum worker. He served as an expert witness in a case involving plutonium workers at INEEL, and federal border guards in Brownsville, TX. He is also a member of the Health Physics Society. In June 2000, he was appointed to a Blue Ribbon Panel on Alternatives to Incineration by DOE Secretary Bill Richardson.
Decommissioning. In February 1976, assisted by four engineering students at State University of New York at Buffalo, Dr. Resnikoff authored a paper that, according to Science, changed the direction of power reactor decommissioning in the United States. His paper showed that power reactors could not be entombed for long enough periods to allow the radioactivity to decay to safe enough levels for unrestricted release. The presence of long-lived radionuclides meant that large volumes of decommissioning waste would still have to go to low-level or high-level waste disposal facilities. He assisted public interest groups and served as an expert witness before the NRC on decommissioning the Yankee-Rowe, Diablo Canyon, Big Rock Point and CT Yankee reactors.
He conducted studies on the remediation and closure of the leaking Maxey Flats, Kentucky radioactive landfill for Maxey Flats Concerned Citizens, Inc. and of the leaking uranium basin on the NMI/Starmet site in Concord, Massachusetts under grants from the Environmental Protection Agency. He co-authored a study on the cost of remediating the former West Valley, New York reprocessing plant site. He also conducted studies of the Wayne and Maywood, New Jersey thorium Superfund sites and proposed low-level radioactive waste facilities at Martinsville (Illinois), Boyd County (Nebraska), Wake County (North Carolina), Ward Valley (California) and Hudspeth County (Texas). He also served as an expert witness for CRPE, a public interest
15 groups, regarding the proposed expansion of the Buttonwillow, California NORM landfill and for Earthjustice re. the licensing of an irradiation facility near the Honolulu airport in Hawaii. In August 2010, he was an invited panelist at President Obamas Blue Ribbon Commission on Nuclear Safety. In October 2011, he was an invited panelist at the annual conference of the Water Environment Federation on the subject of radioactivity in Marcellus shale wastes.
Transportation of Irradiated Nuclear Fuel. In addition to dose reconstruction and decommissioning cases, Dr. Resnikoff also works on the risk of transporting radioactive material. Under a contract with the State of Utah, Dr. Resnikoff was a technical consultant to DEQ on the proposed dry cask storage facility for high-level waste at Skull Valley, Utah. He assisted the State on licensing proceedings before the Nuclear Regulatory Commission. He has also prepared studies on transportation risks and consequences for the State of Nevada and the Nevada counties: Clark, White Pine, Lander and Churchill. In addition, at hearings before state commissions and in federal court, he investigated proposed dry storage facilities at the Point Beach (WI), Prairie Island (MN), Palisades (MI), Maine Yankee, Connecticut Yankee and Vermont Yankee reactors.
He is presently working for the State of Nevada on Yucca Mountain repository issues before the Nuclear Regulatory Commission (NRC). He is also serving as an expert witness for Earthjustice on a proposed NRC license for a food irradiator at the Honolulu, Hawaii airport. In 2013, he was an invited panelist before the Nuclear Waste Technical Review Board, Implication of High Burnup nuclear Fuel on decommissioning and transportation.
Nuclear Waste Management. Dr. Resnikoff is an international expert in nuclear waste management, and has testified often before State Legislatures and the U.S. Congress. In Canada, he conducted studies on behalf of the Coalition of Environmental Groups and Northwatch for hearings before the Ontario Environmental Assessment Board on issues involving radioactive waste in the nuclear fuel cycle and Elliot Lake tailings and the Interchurch Uranium Coalition in Environmental Impact Statement hearings before a Federal panel regarding the environmental impact of uranium mining in Northern Saskatchewan. He also worked on behalf of the Morningside Heights Consortium regarding radium-contaminated soil in Malvern and on behalf of Northwatch regarding decommissioning the Elliot Lake tailings area before a FEARO panel. He conducted a study for Concerned Citizens of Manitoba regarding transportation of irradiated fuel to a Canadian high-level waste repository. He authored a report for Greenpeace on the environmental assessment of a proposed intermediate level waste repository under Lake
16 Huron, and for the Provincial Womens Council of Ontario on radioactive waste management costs in a proceeding before the Ontario Energy Board. As part of an international team of experts for the State of Lower Saxony, the Gorleben International Review, he reviewed the plans of the nuclear industry to locate a reprocessing and waste disposal operation at Gorleben, West Germany. He presented evidence at the Sizewell B Inquiry on behalf of the Town and Country Planning Association (England) on transporting nuclear fuel through London.
He has extensively investigated the safety of the West Valley, New York and Barnwell, South Carolina nuclear fuel reprocessing facilities. His paper on reprocessing economics (Environment, July/August, 1975) was the first to show the marginal economics of recycling plutonium. He completed a more detailed study on the same subject for the Environmental Protection Agency, "Cost/Benefits of U/Pu Recycle," in 1983. His paper on decommissioning nuclear reactors (Environment, December, 1976) was the first to show that reactors would remain radioactive for several hundred thousand years. In March 2004, Dr. Resnikoff was project director and co-author of a study of groundwater contamination at DOE facilities, Danger Lurks Below.
Dr. Resnikoff has prepared reports on incineration of radioactive materials, transportation of irradiated fuel and plutonium, reprocessing, and management of low-level radioactive waste. He has served as an expert witness in state and federal court cases and agency proceedings. He has served as a consultant to the State of Kansas on low-level waste management, to the Town of Wayne, New Jersey, in reviewing the cleanup of a local thorium waste dump, to WARD on disposal of radium wastes in Vernon, New Jersey, to the Southwest Research and Information Center and New Mexico Attorney General on shipments of plutonium-contaminated waste to the WIPP facility in New Mexico and the State of Utah on nuclear fuel transport. He has served as a consultant to the New York Attorney General on air shipments of plutonium through New York's Kennedy Airport, and transport of irradiated fuel through New York City, and to the Illinois Attorney General on the expansion of the spent fuel pools at the Morris Operation and the Zion reactor, to the Idaho Attorney General on the transportation of irradiated submarine fuel to the INEL facility in Idaho and to the Alaska Attorney General on shipments of plutonium through Alaska. He was an invited speaker at the 1976 Canadian meeting of the American Nuclear Society to discuss the risk of transporting plutonium by air. In July and August 1989, he was an invited guest of Japanese public interest groups, Fishermen's Cooperatives and the Japanese Congress Against A-and H-Bombs (Gensuikin).
17 Research Director of the Radioactive Waste Campaign. Dr. Resnikoff was formerly Research Director of the Radioactive Waste Campaign, a public interest organization conducting research and public education on the radioactive waste issue. His duties with the Campaign included directing the research program on low-level commercial and military waste and irradiated nuclear fuel transportation, writing articles, fact sheets and reports, formulating policy and networking with numerous environmental and public interest organizations and the media. He is author of the Campaign's book on "low-level" waste, Living Without Landfills, and co-author of the Campaign's book, Deadly Defense, A Citizen Guide to Military Landfills.
Project Director at the Council on Economic Priorities. Between 1981 and 1983, Dr.
Resnikoff was a Project Director at the Council on Economic Priorities, a New York-based non-profit research organization, where he authored the 390-page study, The Next Nuclear Gamble, Transportation and Storage of Nuclear Waste. The CEP study details the hazard of transporting irradiated nuclear fuel and outlines safer options.
1974 - 1981. Between 1974 and 1981, he was a lecturer at Rachel Carson College, an undergraduate environmental studies division of the State University of New York at Buffalo, where he taught energy and environmental courses. The years 1975-1977 he also worked for the New York Public Interest Group (NYPIRG).
1965 - 1973. In 1973, Dr. Resnikoff was a Fulbright lecturer in particle physics at the Universidad de Chile in Santiago, Chile. From 1967 to 1973, he was an Assistant Professor of Physics at the State University of New York at Buffalo. He has written numerous papers in particle physics, under grants from the National Science Foundation. He is a 1965 graduate of the University of Michigan with a Doctor of Philosophy in Theoretical Physics, specializing in group theory and particle physics.
Dr. Resnikoff is a member of the Health Physics Society. Dr. Resnikoff also has published many articles and books as well as being invited to speak at many prestigious conferences.
Law Office TERRY JONATHAN LODGE 316 N. Michigan Street, Suite 520 Phone (419) 205-7084 Toledo, Ohio 43604-5627 Fax (419) 932-6625 lodgelaw@yahoo.com November 3, 2020 U.S. Nuclear Regulatory Commission Commissioners and NRC Staff c/o Regulations.gov @ Docket ID NRC-2016-0231 WCS_CISF_EIS@nrc.gov Jennifer.Borges@nrc.gov James.Park@nrc.gov RE: Interim Storage Partners CISF, Docket ID NRC-2016-0231, Draft Environmental Impact Statement (Public Comment Submission)
Dear NRC Commissioners and Staff:
Dont Waste Michigan, Citizens for Alternatives to Chemical Contamination, Public Citizen, Inc., San Luis Obispo Mothers for Peace, Nuclear Energy Information Service, Citizens Environmental Coalition, Sustainable Energy and Economic Development Coalition and Leona Morgan hereby submit their comments on the Draft Environmental Impact 1
Statement for the Interim Storage Partners LLCs Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste (Draft Report for Comment) (hereinafter DEIS), Docket ID NRC-2018-0052 (NUREG-2237) that has been compiled on Interim Storage Partners/Waste Control Specialists (ISP/WCS) application for a license to build and operate a Consolidated Interim Storage Facility (CISF) for spent nuclear fuel (SNF) and high-level radioactive waste in Andrews County, Texas.
On behalf of these organizations, I write to express their opposition to the ISP/WCS proposal, and we insist that the NRC terminate its licensing in order to protect public health and safety, the environment and our economy.
I. The Environmental Impact Statement Is Arbitrarily Limited To Analysis Of The CISFs First 40 Years Of Existence The NRC's limitation on the scope of the DEIS to the initial license period of 40 years is 2
These organizations and Ms. Morgan sought to intervene and participate in the underlying 1
licensing proceedings involving ISP/WCSs application for an NRC license to build and operate the CISF.
See ISP/WCS Draft Environmental Impact Statement (DEIS) at pp. 2-2.
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unlawful and arbitrary. This is so because of ISP/WCS and NRC admissions of the likelihood that the facility will be operating beyond 40 years, and that considerable contemplated activity undertaken at the CISF within the 40-year licensing period will extend beyond the 40-year period, discussed below.
! ISP anticipates continued storage for approximately 60 years or until a final geologic repository is licensed and operating in accordance with the Nuclear Waste Policy Act (NWPA) of 1982, as amended. ISP/WCS Environmental Report, Rev. 2, p. 1-2.
! The range of alternatives considered was based on the constraints of technical design requirements, the presence/absence of public and governmental support for a CISF, and on meeting the need to provide a safe option for storing SNF for 60-100 years or until a permanent geologic repository is licensed, constructed, and operating pursuant to the requirements of the NWPA. ISP/WCS ER, Rev. 2, p. 2-1.
! The NRC Staff acknowledges in the DEIS the likelihood of a far longer storage period:
ISP stated that it may seek to renew the license and anticipates that the SNF would be stored at the CISF for 60 to 100 years (ISP, 2020). ISP/WCS DEIS, p. 9-16.
! Expectation admitted by a competitor of ISP/WCS of a much longer operation life for CISFs. Joy Russell, Holtec Vice-President, has recommended to the U.S. Department of Energy (DOE), in her emailed Response to RFI on Private Initiatives to Develop Consolidated SNF Storage Facilities, 1/27/2017, that The CIS should have a minimum service life of 300 years.
3
! The NRC's 2014 Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (Continued Storage GEIS), which contemplates the potential that storage 4
of spent nuclear fuel (SNF) at a Consolidated Interim Storage Facility (CISF) might continue indefinitely. Id. at, inter alia, xxxii, l, liii, lvi, lxii, 2-35, 4-2, 4-28, 5-8, 5-10, 5-18.
! Testimony of then-Secretary of the DOE Rick Perry before a subcommittee of the U.S.
House Appropriations Committee on March 26, 2019 that, as governor of Texas, he was very supportive of the notion that the ISP/WCS low-level radioactive waste dump site should become a permanent site for spent nuclear fuel.
5 https://www.energy.gov/sites/prod/files/2017/02/f34/Jan%2027%2C%202017%20-3
%20Joy%20Russell%20-%20Response%20to%20the%20RFI%20on%20Private%20Initiatives.pdf https://www.nrc.gov/docs/ML1419/ML14196A105.pdf 4
https://www.youtube.com/watch?v=CgtHCsQzffc&feature=youtu.be (at 27:50 - 28:55):
5 Q (Congressman Simpson): Let me ask you a question, even the site in Texas, do you think that they would be willing to accept permanent storage?
A (DOE Secretary Rick Perry): You know, Im gonna leave that up to the current governor to answer for you directly, but I can tell you what the previous governor said, and he was very supportive of Page 2 of 25
Considerable activity is planned to take place beyond the arbitrary 40-year term of the project. If the NRC has guessed wrong and there is no deep geological repository by the fortieth year, questions of continued institutional control will have to be resolved, which is a tacit admission that there will be relicensing. NEPA analysis thus cannot be curtailed at 40 years.
Without adequate institutional controls, failed spent nuclear fuel (SNF) containers could release catastrophic amounts of hazardous radioactivity directly into the surface environment, to blow downwind, flow downstream, bioconcentrate up the food chain, and harm people for generations.
There will be an expensive and logistically complicated repackaging of SNF from the varied types of transport canisters in which it arrives at ISP/WCS, into DOE-ordered standardized transport, aging and disposal (TAD) canisters in a geological repository. The NRC does not intend to require a Dry Transfer System (DTS) during the initial 40-year license.
But a DTS may be needed within the first 40 years to safely remediate or repackage SNF from failing or failed containers in order to protect worker and public health and the environment.
Moreover, a DTS capability is necessary for externally contaminated casks and canisters, damaged ones, and leaking ones. Emergent circumstances might pose a critical need for the capability during the initial operations period, and beyond, notwithstanding the NRCs position that there will be no need to require a DTS until the end of the first century of CISF operations.
ISP/WCS proposes to use a Start Clean/Stay Clean policy to avoid problematic containers. According to the DEIS:
The proposed CISF would be designed and operated using a start clean/stay clean philosophy, meaning that it would be designed and operated as a radiological contamination-free facility (ISP, 2020). All components of the proposed CISF, including the transportation casks and storage canisters, are designed to minimize the potential for any contamination. Storage canisters are welded shut and sealed to prevent leaks and would not be opened during transportation to the proposed CISF or during storage.
Transportation casks would be surveyed prior to shipment to the proposed CISF to ensure that all transportation standards are satisfied in accordance with NRC (10 CFR Part 71) and DOT (49 CFR Part 173) requirements. Transportation casks would not be shipped to the proposed CISF unless all appropriate NRC and DOT regulations are satisfied.
Continual radiological monitoring of storage cask systems would be conducted throughout the license term of the facility to identify any potential contamination.
it being a permanent site, worked that way, we had a low level nuclear commission that worked towards that while I was the governor. Again, Im not gonna speak for the current governor or the current legislature but for 14 years prior to those individuals coming on the scene there was a clear effort to make
- and the people of Andrews, the citizens of that county are very very supportive of that. My point is we've got to find a solution to this, 39 states as final repositories is not an appropriate solution to this.
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DEIS at 2-11.
But there is no explanation of what provisions would be made for the SNF that is rejected by ISP/WCS and left behind at the reactor sites. There is also no discussion of what happens to arriving canisters or casks with external contamination. While the NRC Staff insists that external contamination would have been limited by required surveys at the reactor site prior to shipment, and canister inspections would occur upon arrival at the proposed CISF project, there 6
is no recognition that 100% perfection of containment is likely not attainable, and hence, no admission and discussion of decontamination measures for damaged, leaking or otherwise problematic arriving canisters or casks. The DEIS mentions, without any details, that there will be plans to inspect casks upon arrival at the CISF and take corrective actions when canisters do not meet acceptance criteria, including unacceptable external contamination (ISP, 2018).7 Mention of unspecified corrective actions fails to discharge the NRC Staffs mandatory responsibility of public disclosures required by NEPA.
In fact, ISP/WCSs unspecified corrective actions reference contrasts with the slightly more candid approach taken in the Holtec DEIS. The complete lack of disclosure of ISP/WCS intentions about what will be done with contaminated canisters at the ISP/WCS site inspires more questions than it answers:
Holtec:
Factors that contribute to the containment of SNF during normal operations include the use of sealed (welded closure) canisters that would remain closed for the duration of storage, the engineered features of the cask system, and plans to reject and return canisters that have unacceptable external contamination (Holtec, 2019b).
Holtec DEIS at 4-91 (Emphasis added).
Compare ISP/WCS:
Factors that contribute to the containment of SNF during normal operations include the use of sealed (welded closure) canisters that would remain closed for the duration of storage, the engineered features of the cask system, and plans to inspect casks upon arrival at the CISF and take corrective actions when canisters do not meet acceptance criteria, including unacceptable external contamination (ISP, 2018).
ISP/WCS DEIS at 4-85 (Emphasis added).
DEIS at 2-21.
6 DEIS at 4-85.
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ISP/WCSs mere plan to inspect casks is an evasive and unlawful plan to have a plan.
ISP/WCSs implicit fantasy expectations of perfect management of spent nuclear fuel by having a philosophy of start clean/stay clean is an illogical dodge to avoid having a dry transfer system (DTS) at the CISF, making it clear that there will be no genuine corrective action available for serious canister or cask failures.
During the 40-year licensing term, problems can, and likely will, develop with SNF containers. Even if they first arrive at the CISF in acceptable condition, age-related degradation over time is inevitable. If a DTS is never built at the ISP/WCS CISF, then catastrophic releases of hazardous radioactivity into the environment are increasingly likely, especially if operations continue beyond the first 40-year license term. Absent a DTS, which is a fundamental prerequisite for invocation of the NRC's Continued Storage Rule, loss of institutional control may come significantly sooner and more catastrophically than expected to ISP/WCS.
In addition, the NRC Staff makes only passing references to the decommissioning stage of the ISP/WCS CISF, and confines it to discussions of the local environmental effects that would follow from dismantling the facility based on implicit magical thinking that there will be 8
100% containment of the radiation onsite. But decommissioning, whether at the end of 40, 80 or 120 years, will be an extremely complicated and involved project. Perhaps 40,000 MTU of SNF will have to be transported offsite to a permanent repository. The SNF will have to be repackaged in perhaps 32,000 or more uniform containers. Assuming for purposes of example that the waste will be reloaded into tens of thousands of containers and Yucca Mountain will be the destination repository, a transport campaign of up to 32,000 trips traveling the approximately 950 miles to Nevada equals more than 30,000,000 transport miles. This campaign will require many years, possibly decades. Unless it is to occur entirely within the initial 40-year licensing period, some portion of this massive transport effort will take place outside of it.
When it forces the most dramatic radioactive repackaging effort imaginable, decommissioning will generate thousands of tons of low-level radioactive waste (LLRW) in the form of discarded canisters and even casks, a far greater volume of LLRW than is currently predicted in the DEIS. Repackaging will take years, with attendant risks of error, equipment failure, and material failure; nonetheless, mention of this enormous repackaging obligation is omitted from the DEIS.
II. The First 40 Years Of Operations Comprise An Irretrievable Commitment Of Resources, Which Compels The Scope Of The EIS To Encompass Relicensings And The Potential For De Facto Permanent SNF Disposition At ISP/WCS Successful delivery of 3,400 SNF shipments projected by ISP/WCS will cause irreversible change with dramatic environmental effects in west Texas. The second-largest concentration of highly-irradiated nuclear waste on the planet will have been achieved (assuming See, for example, DEIS at xxi, xxv, xxvii, xxix, xxx, xxxi, xxxii, xxxiii, xxxv.
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the Holtec LLC CISF in New Mexico goes into operation). There will have been created a supposedly temporary storage site for SNF, which is to serve as the originating site for 32,000 or more dispatches of SNF to a repository. And there will be entropy in the form of weathering, temperature spikes, corrosion, chemistry and constant irradiation within the storage casks, and deterioration will be under way. Many billions of dollars will have been expended by ratepayers and taxpayers to create SNF consolidation in one place. In other words, forty years from now, there will be an abundant, irretrievable commitment of resources in the construction and operation of ISP/WCS. That irretrievable commitment obligates the undertaking of a much more comprehensive NEPA investigation than is represented in the DEIS.
Section 102 of the National Environmental Policy Act (NEPA) (42 U.S.C. § 4332) requires that all agencies of the Federal Government:
( C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on --
(I-iv)... ;
(v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented.
Likewise, Council of Environmental Quality regulation, 40 C.F.R. § 1502.16, requires intensive analysis in an EIS of irreversible or irretrievable resource commitments:
This section [Environmental Consequences] forms the scientific and analytic basis for the comparisons [of alternatives].... The discussion will include the environmental impacts of the alternatives including the proposed action, any adverse environmental effects which cannot be avoided should the proposal be implemented, the relationship between short-term uses of mans environment and the maintenance and enhancement of long-term productivity, and any irreversible or irretrievable commitments of resources which would be involved in the proposal should it be implemented. (Emphasis added).
See also 10 C.F.R. § 51.71(a) of the NRCs NEPA regulations, which requires that the EIS disclose any irreversible and irretrievable commitments of resources which would be involved in the proposed action.
Once there has been an irretrievable commitment of resources in the technology development stage, the balance of environmental costs and economic and other benefits shifts in favor of ultimate application of the technology. Scientists' Institute for Public Information, Inc.
- v. Atomic Energy Commission, 481 F.2d 1079, 1090 (D.C. Cir. 1973). That is, the overall impact from implementing a large-scale program is that implementation controls or restricts options from the time of implementation forward. The EIS must therefore take a pragmatic and realistic view of the scope of the action being contemplated. The view must be one neither confined by the literal limits of the specific proposal nor one unbounded except by the limits of the designer's imagination. Swain v. Brinegar, 542 F.2d 364, 369 (7 Cir. 1976).
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The arbitrary cutoff of NEPA analysis at 40 years, in light of irreversible or irretrievable commitments to remaining segments of the proposed action (such as preparing to convey the SNF to a repository or installing long-term institutional controls for the waste to remain in west Texas forever), is unacceptable. The agency must address the activities of that segment as a whole with the other segments. United States Dept of Energy et al. (Clinch River Breeder Reactor Plant), CLI-82-23, 16 NRC 412, 424 (1982).
III. The EIS Must Encompass and Address Environmental Impacts Associated With Relicensing And Decommissioning, Because Relicensing And Decommissioning Are Reasonably Foreseeable The evidence cited above from the DEIS and other sources shows that relicensing of operations at the end of 40 years is a reasonably foreseeable future action. Even if the facility is not relicensed, decommissioning in the form of transporting 20,000 canisters or more of SNF to a repository is beyond a reasonably foreseeable action, it is a certainty - and if it is not a certainty, the possibility of ISP/WCS becoming a forever SNF repository must be analyzed in the EIS.
Site-specific activities that are foreseeable because they will be inevitable will take place outside the initial 40-year license period. Those activities must be encompassed within the EIS and not be presumed to be addressed by the Continued Storage GEIS.
An EIS is required for major Federal actions, which are actions with effects that may be major and which are potentially subject to Federal control and responsibility. Department of Transportation v. Public Citizen, 541 U.S. 752, 763, 124 S.C. 2204, 159 L.Ed.2d 60 (2004)
(quoting 40 C.F.R. § 1508.18). Consolidation of SNF at the ISP/WCS CISF, as well as managing it for 40 years and more is incontestably major and subject to Federal control and responsibility. Effects, according to NEPA regulations, are (1) direct, which are caused by the action and occur at the same time and place, and (2) indirect, caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable.
An EIS must analyze not only the direct impacts of a proposed action, but also the indirect and cumulative impacts of past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions.
Colorado Envtl. Coalition v. Dombeck, 185 F.3d 1162, 1176 (10th Cir.1999) (quoting 40 C.F.R.
§ 1508.7). Federal regulations do not explicitly require an EIS to include a discussion of cumulative impacts, Edwardsen v. United States Dep't of Interior, 268 F.3d 781, 786 (9th Cir.
2001), but they do direct[ ] agencies to consider cumulative impacts in determining the scope of an EIS. Id., citing 40 C.F.R. § 1508.25(c)(3) (scope of an EIS includes consideration of cumulative impacts).
The types of impacts that must be considered include ecological (such as the effects on natural resources and on the components, structures, and functioning of affected ecosystems),
aesthetic, historic, cultural, economic, social, or health [effects]. 40 C.F.R. § 1508.8. Agencies
... have a duty to discuss in the FEIS impacts that are reasonably foreseeable. Utahns for Better Transp. v. U.S. Dept. of Transportation, 305 F.3d 1152 (10th Cir. 2002) (citing Sierra Club v.
Page 7 of 25
Marsh, 976 F.2d 763, 767 (1st Cir.1992)).
The scope of an agency's NEPA inquiry must include both connected actions and similar actions. 40 C.F.R. § 1508.25(a)(1), (3). Actions are connected if they trigger other actions, cannot proceed without previous or simultaneous actions, or are interdependent parts of a larger action and depend on the larger action for their justification. 40 C.F.R. § 1508.25(a)(1).
It is legally inappropriate to defer consideration of cumulative impacts to a future date, because NEPA requires consideration of the potential impact of an action before the action takes place. City of Tenakee Springs v. Clough, 915 F.2d 1308, 1313 (9 Cir. 1990) (citing 42 th U.S.C. § 4332(2))( C)(v) irretrievable commitments). [C]umulative impact analysis must be timely. It is not appropriate to defer consideration of cumulative impacts to a future date when meaningful consideration can be given now. Kern v. U.S. Bureau of Land Mgmt., 284 F.3d 1062, 1075 (9th Cir. 2002).
The treatment of multiple relicensings of ISP/WCS operations across a possible 100-year span is unlawful piecemealing or segmentation. Such artificial partitioning of the overall project ignores the obvious interdependence of the license periods. Consolidation of SNF and the operation of the CISF will compel a massive transport campaign at the back end of CISF operations to move the SNF to a repository. Decommissioning encompasses more than remediation of the damage done by the project to the local environment in Texas; it implicates the notion of further disposition of the SNF stored at ISP/WCS. The common timing and geography of the two or more ISP/WCS CISF licenses are similarities that provide a basis for evaluating their environmental consequences together.... 40 C.F.R. § 1508.25(a)(3). Looming decisions over license extensions and after that, abandonment or decommissioning, are all causally connected to the huge project of SNF centralization at the CISF in the first place. Since transport, storage operations and decommissioning or abandonment all tie directly back to the original decision to license the CISF, each phase and possibility must be identified and analyzed now, within this 2020 EIS, not in a supplemental EIS with foregone license extension approval, decades from now.
IV. The Major And Forseeable Activity Of SNF Repackaging During ISP/WCS Operations Goes Wholly Unmentioned In The DEIS The NRC Staffs utter failure to acknowledge and consider ISP/WCSs massive canister repackaging obligation within the DEIS is a fatal deficiency.
In the Final Supplemental Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada, Vol. I (2008) (Yucca SEIS), the DOE stated:
In 2006, DOE proposed a modified approach to repository design, development, and operation. Central to this proposed approach is the use of a canister concept for commercial spent nuclear fuel that minimizes handling of individual spent fuel Page 8 of 25
assemblies; limits the need for complex surface facilities; and simplifies repository design, licensing, construction, and operation. DOE would use a TAD canister to transport, age, and dispose of commercial spent nuclear fuel without ever reopening the canister, thereby simplifying and reducing the number of handling operations involved in the packaging of spent nuclear fuel for disposal. In addition, the canistered approach offers the advantage of the use of practices that are familiar to the nuclear industry and the NRC, which would make the repository easier to design, license, construct, and operate. Although DOE has a small amount of spent nuclear fuel of commercial origin that it could ship to the repository uncanistered in a cask, consistent with the analysis in the Yucca Mountain FEIS, this Repository SEIS assumes that it would transport and receive all DOE spent nuclear fuel and high-level radioactive waste in disposable canisters. On October 13, 2006, in the Notice of Intent to prepare Supplement to the Final Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, NV (71 FR 60490), DOE announced that it would prepare a supplement to the Yucca Mountain FEIS to evaluate potential environmental impacts of the modified repository design and operational plans. In its Notice of Intent, DOE described the primarily canistered approach whereby most commercial sites would package their spent nuclear fuel in TAD canisters, and all DOE materials would be packaged in disposable canisters at DOE sites.
Id. at p. 1-5 (Emphasis added).
As a result, the DOEs present approach involves:
... a primarily canistered approach to operate the repository; under this approach, most commercial spent nuclear fuel would be packaged at the reactor sites in TAD canisters.
DOE would repackage commercial spent nuclear fuel that arrived in packages other than TAD canisters into these canisters in newly designed surface facilities at the repository.
The Department would package essentially all DOE material in disposable canisters at the DOE sites. Most spent nuclear fuel and high-level radioactive waste would arrive at the repository by rail. Some shipments would arrive by truck. At the repository, DOE would place the TAD and other disposable canisters in waste packages that were manufactured from corrosion resistant materials. DOE would array the waste packages in the subsurface facility in tunnels (emplacement drifts).
Id. at § 1.4.2, p. 1-14.
Robert Alvarez, a senior scholar at the Institute for Policy Studies who is a former senior policy adviser to the Secretary of Energy and deputy assistant secretary for national security and the environment from 1993 to 1999, provided expert testimony in support of the undersigned commenters during their pursuit of intervenor status in this licensing proceeding.
According to Alvarez, a 2012 Energy Department study concluded that waste package Page 9 of 25
sizes for the geologic media under consideration are significantly smaller than the canisters being used for on-site dry storage by the nuclear utilities. And a nuclear industry study found 9
in 2014 that casks and canisters being used by the power utilities will be at least partially, and maybe largely, incompatible with future transport and repository requirements, meaning that some, if not all, of the [used nuclear fuel] that is moved to dry storage by the utilities will ultimately need to be repackaged.10 After analyzing the volume of SNF and the Holtec plan to store up to 173,600 tons, Mr.
Alvarez determined that Repackaging for disposal may require approximately 80,000 small canisters. Since ISP/WCS intends to take on about 25% of that tonnage at 40,000 MTU, it is 11 reasonable to assume that ISP/WCS will be responsible for putting at least 20,000 of the presently-contemplated uniform design canisters on the rails to a future repository. Yet there is zero mention, not to mention analysis, of this looming obligation in the DEIS. It has implications for site contamination, worker safety, public safety, potential damage to the environment, decommissioning, low-level radioactive waste volumes generated at the ISP/WCS site, and the need to have a Dry Transfer System (DTS) capability there commencing when the CISF begins to accept SNF.
This is an enormous omission from the DEIS. The DEIS must fulfill and satisfy to the fullest extent possible the requirements established for final environmental impact statements in section 102(2)( C) of NEPA. 40 C.F.R. § 1502.9(a). If a draft statement is so inadequate as to preclude meaningful analysis, the agency shall prepare and circulate a revised draft of the appropriate portion. Id. A revised DEIS coupled with additional public participation is required here.
Nowhere does the DEIS disclose any other details about this policy. Only if the harm in question is so remote and speculative as to reduce the effective probability of its occurrence to zero may the agency dispense with the consequences portion of the analysis. State of New York
- v. Nuclear Regulatory Com'n, 681 F.3d 471, 482 (D.C.Cir. 2012).
General statements about possible effects and some risk do not constitute NEPAs hard look absent a justification regarding why more definitive information could not be provided. Neighbors of Cuddy Mountain v. United States Forest Service, 137 F.3d 1372, 1380 http://www.beyondnuclear.org/storage/kk-links/Alvarez%20SNF%20at%20close 9
d%20reactors%20rev%202.pdf Chris Phillips, Ivan Thomas and Steven McNiven, Nuclear Industry Study on the Feasibility of 10 Standardized Transportation, Aging and Disposal Canisters for Used Nuclear Fuel, Energy Solutions Federal EPC. WM2014 Conference, March 2-6, 2014, Phoenix, Arizona, USA.
http://www.wmsym.org/archives/2014/papers/14011.pdf http://www.beyondnuclear.org/storage/kk-links/Alvarez%20SNF%20at%20closed%20reactors 11
%20rev%202.pdf Page 10 of 25
(9 Cir. 1998). [S]ome quantified or detailed information is required. Without such information, th neither the courts nor the public... can be assured that the [agency] provided the hard look that it is required to provide. Id. at 1379. In order to rely on mitigation to obviate further analysis, the measure must be identified and its effectiveness analyzed. Nat'l Parks & Conservation Ass'n v.
Babbitt, 241 F.3d 722, 733-736 (9th Cir. 2001) (holding EIS must be prepared where monitoring and mitigation measures were uncertain). The agency must provide analytic data on the efficacy of a proposed measure, and the court must decide whether it will render such impacts so minor as to not warrant an EIS. Id. at 734.
There being no disclosure in the DEIS of details of this controversial planned policy, and no identification of its environmental dangers and human health implications, the DEIS is seriously flawed. It is axiomatic that the EIS shall be supported by evidence that the agency has made the necessary environmental analyses. 40 C.F.R. § 1502.1. The DEIS must fulfill and satisfy to the fullest extent possible the requirements established for final environmental impact statements in section 102(2)© of NEPA. 40 C.F.R. § 1502.9(a). If a draft statement is so inadequate as to preclude meaningful analysis, the agency shall prepare and circulate a revised draft of the appropriate portion. Id.
A revised DEIS and subsequent public participation is required here.
V. The Omission Of Serious Transportation Analysis From The DEIS Comprises Segmentation And Fails To Fulfill NEPA Disclosure Obligations The paucity of discussion of truck, barge and rail transport of SNF to the Texas CISF is especially egregious. According to the NRC Staff, ISP/WCS predicts the receipt of 3,400 shipments and up to 40,000 MTU of SNF, on the one hand, but cannot possibly have any idea whatsoever of the identities of the sources of the SNF. Put another way, ISP/WCS ambitiously expects to consolidate one-third or more of the predicted output of SNF in the United States commercial nuclear power industry inventory at its site, yet cannot imagine which utilities will be using their services and over what railroad corridors.
The NRCs low-key approach to disclosure of the likely rail and other mode transit routes does not convey the comparatively candid approach that ISP/WCS took in its Environmental Report. Figure 2.2-4 on p. 2-71 of the ISP Environmental Report is a national map of rail transportation routes that was reproduced in the ISP/WCS ER. Figure 2.2-4 at p. 2-71, ISP/WCS Environmental Report.
The NRC acknowledged that ISP/WCS proposes using the national rail network for transportation of SNF from reactor sites to the proposed CISF and eventually from the CISF to a permanent geologic repository for disposal bud did not reproduce the national rail route map that ISP/WCS had included in its ER. ISP/WCS DEIS pp. 2-19, 2-20 (ISP anticipates that the national rail network would be used for transportation of SNF from reactor sites to the proposed CISF and eventually from the CISF to a permanent geologic repository for disposal.). However, to the NRC, the routes remain a Great Unknown the mystery of which defies investigation or Page 11 of 25
discussion under NEPA:
Because no arrangements regarding which nuclear power plants would store SNF at the proposed CISF have been made yet, the exact locations of SNF shipment origins have not been determined; therefore, the details regarding the specific routes that would be used also are not known at this time. SNF may be shipped from the locations of currently decommissioned reactor sites that are identified on the map in Figure 2.2-4. The origin, destination, and distance of potential SNF rail shipments from these decommissioned reactor sites are provided in EIS Table 3.3-1. If the proposed CISF is approved for and loaded to full capacity (i.e., 40,000 MTU in Phases 1-8), then it is reasonable to assume that shipments of SNF would also come from many of the existing reactor sites nationwide. Additionally, the SNF stored at the proposed CISF project would eventually need to be transported to a permanent geologic repository, in accordance with the U.S.
national policy for SNF management established in the Nuclear Waste Policy Act of 1982, as amended (NWPA). The NWPA requires that DOE submit an application for a repository at Yucca Mountain, Nevada.
Unless and until Congress amends the statutory requirement, the NRC assumes that the transportation of SNF from the CISF to a permanent repository will be to a repository at Yucca Mountain, Nevada.
ISP/WCS DEIS at 3-8 to 3-9.
All the NRC can imagine appears to be the map appearing in the DEIS at 2-78, which depicts only four 4 reactors out of 131 in the country, Maine Yankee, and the three San Onofre units. Clearly, the NRC Staff does not wish for residents of major urbanized regions through which hundreds or thousands of SNF shipments will travel to have an unequivocal understanding that the shipments are coming through their cities and suburbs. The NRC is unlawfully attempting to predetermine the outcome of this national policy decision by keeping the public from obtaining an accurate, graphic understanding of the implications and transit corridors of millions of miles of mostly rail-delivered SNF. The NRC Staff in its authorship of the DEIS adopts by mention the probable rail and truck routes contained in maps published by the DOE in the Final Supplemental Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada, Vol. I (2008) (Yucca SEIS) but the NRC Staff has declined even to 12 The maps appear at Yucca SEIS pp. 2-46 and 2-47. But see maps Fred Dilger, Ph.D. generated 12 from the 2008 FSEIS data for 45 states and 20 urban areas:
Nevada Agency for Nuclear Projects - Representative Transportation Routes to Yucca Mountain and Transportation Impacts (Cask Shipments by State),
http://www.state.nv.us/nucwaste/news2017/ymroutes17.png Nevada Agency for Nuclear Projects - Cities Potentially Affected by Shipments to Yucca Mountain (pdf-2.45M), http://www.state.nv.us/nucwaste/news2017/pdf/Cities_Affected.pdf Page 12 of 25
reproduce those maps within the DEIS itself:
The exact routes for SNF transportation to and from the proposed CISF would be determined in the future prior to making the shipments. However, to evaluate the potential impacts of these shipments and to aid the evaluation of the ISP transportation analyses, the NRC staff considers that representative or bounding routes applicable to a national SNF shipping campaign such as those described and evaluated in Section 2.1.7.2 of DOEs Final Supplemental Environmental Impact Statement for a geologic repository at Yucca Mountain (DOE, 2008) and NRCs most recent SNF transportation risk assessment in NUREG-2125 (NRC, 2014), provide sufficient information about potential transportation routes to support the analysis of impacts in EIS Section 4.3. The NRC staff considers the routes evaluated in these prior transportation analyses to be representative or bounding for SNF shipments to and from the proposed CISF project because they were derived based on typical transportation industry route selection practices, they considered existing power plant locations, and can be applied to EIS analyses using conservative or bounding assumptions (e.g., as described further in Section 4.3 of this EIS, selecting a route that is longer than most of the routes that would actually be used).
ISP/WCS DEIS, p. 3-9.
Notably, when the NRC Staff borrowed selectively from the Yucca SEIS, it did not also adopt or require important collateral transportation policies to which DOE has committed for a geological repository. The ISP/WCS DEIS does not contemplate dedicated trains or the use of special DOE-prescribed transport canisters. The Yucca SEIS strongly assumes that uniform TAD canisters will be loaded at commercial reactor sites. Instead of the use of more expensive dedicated trains, the NRC Staff assumes that While SNF shipments would be traveling at a slower speed than other trains, the NRC staff reasonably assumes that rail carriers would make adjustments to account for SNF shipments. DEIS at 5-18.
This unsupported and naive statement ignores the potential for, and thus does not assess the prospects that perishables, cattle and fossil fuel cargoes may be assigned more urgent delivery priority than SNF and that as a consequence, SNF may set for varying and unpredictable periods of time at rail sidings. The mechanistic assumptions are illustrated in the DEIS by the calculation that the maximally exposed individual is located 30 m [98 ft] from the rail track and is exposed to the direct radiation emitted from all 3,400 passing rail shipments of SNF at full build-out (Phases 1-8) under normal operations. The resulting accumulated dose is 0.019 mSv [1.9 mrem].
Nevada Agency for Nuclear Projects - States Potentially Affected by Shipments to Yucca Mountain with Congressional Districts (pdf-7.05M),
http://www.state.nv.us/nucwaste/news2017/pdf/States_Affected.pdf Nevada Agency for Nuclear Projects - Congressional Districts Potentially Affected by Shipments to Yucca Mountain - 115th Congress (pdf-882K),
http://www.state.nv.us/nucwaste/news2017/pdf/Congressional_Districts_Affected.pdf Page 13 of 25
For any individual phase (including the proposed action, Phase 1) assuming the number of shipments is 425, the maximally exposed individual dose result was 0.0024 mSv [0.24 mrem].
The assumptions are excessively optimistic. People can (and will) get closer than 100 feet away, and the dose increases exponentially, the closer one gets. Shipments could pause, like you've said, increasing exposure time, and thus dose delivered. Externally contaminated shipments could give off much more than the 10 mR/hr at 6.6 feet dose rate (in the 1990s, many hundreds of Orano/Areva's shipping containers bound for the La Hague reprocessing facility, hundreds of them, a full one-quarter to one-third of all cargoes, emitted an average of 500 times the permitted dose; in one case, it was 3,300 times permissible; it was due to external contamination - and this involved the very same company involved with the ISP/WCS CISF, Moreover, as Dr. Marvin Resnikoff, Ph.D. pointed out in his comments in this proceeding:
13
! The DEIS also assumes an unrealistic 10-hour exposure time for emergency workers, implying the cask can be moved in this time period. NRC staff need to more closely examine real train derailments, particularly accidents involving fires, and the time to restore service.
NUREG-2125 examines fires that burn up to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, while some real fires have burned for 2 days.
! As the capacity of spent fuel casks has increased, the weight of the casks has increased as well. This additional weight will place a burden on the rail infrastructure. The HI-STAR cask, containing 37 PWR fuel assemblies, will require a 3-car, 12-axle carriage, which will cause a train to slow on curves.
! NUREG-2125 considers only mid burnup fuel, 45 GWd/MTU, cooled for 9 years, and not high burnup fuel, with burnup between 60 to 70 GWd/MTU. High burnup fuel contains more fission products, particularly the semi-volatile Cs-137, which would account for high gamma doses to EMTs and the general public. The fraction of volatile Cs-137 in the gap between the cladding and fuel should be based on more recent DOE reports; supporting NRC documents for this gap cesium are not referenced, but, in our experience, are based on outdated 1978 reports. High burnup fuel also has thinner and more brittle cladding that may shatter in high impact accidents.
More than 90% of the SNF will travel exclusively or predominantly by rail. In many instances, rail spur segments will have to be reconstructed from closed and cleared former nuclear plant sites to allow transport of the SNF stored there. While the DEIS acknowledges that there is likely to be need for serious and expensive reconstruction of infrastructure simply to move the waste from its current locations, the NRC Staff did not attempt to quantify the need or the expense, and repeated an identical paragraph from the Holtec DEIS which communicates the Comments on ISP/WCS DEIS by Marvin Resnikoff, Ph.D., Radioactive Waste Management, 13 (October 2020).
Page 14 of 25
Staffs balk in that proceeding:
14 Some reactor sites, in particular, those that have been shut down or decommissioned but continue to store SNF in dry storage casks, may require local transportation infrastructure upgrades to remove the SNF from the site (DOE, 2014). These upgrades, for example, could include installing or upgrading rail track, roads, or barge slips necessary to transfer SNF offsite. Because these infrastructure upgrades would be needed - regardless of whether the proposed CISF project is approved - to allow shipment of SNF from reactor sites to a repository in accordance with the Nuclear Waste Policy Act of 1982 (NWPA),
these enhancements are beyond the scope of the proposed action and are therefore not evaluated further. Additionally, because these infrastructure improvements are expected to be small construction projects limited to preexisting, previously disturbed, and previously evaluated reactor sites that are dispersed throughout the U.S., the environmental impacts are expected to be minor and are not evaluated further for cumulative impacts in Chapter 5 of this EIS.
ISP/WCS DEIS p. 4-10. The Staff cited lame excuses for refusing to include the reactor site infrastructure rebuild need in the DEIS: This cost was not quantified in this EIS, because it (i) would be difficult to establish, (ii) would vary based on the individual generation sites, and (iii) would be a common need for both the proposed CISF and the No-Action alternative. ISP/WCS DEIS p. 8-1. Thus the NRC Staff has concealed potentially needed major infrastructure replacement or improvement of offsite rail, highway and perhaps other physical resources as well as its economic cost, in order to justify the construction and operation of the ISP/WCS CISF.
In 2017, Fred Dilger, using the Yucca SEIS transportation data on behalf of the State of Nevada Agency for Nuclear Projects, published a set of route maps, showing road and rail routes admitted by DOE as the most likely to be used to haul highly radioactive wastes to Yucca Mountain, NV. As might be expected, the further away from the American Southwest such 15 shipments originate, the more similar or even identical the routes for hauling highly radioactive wastes become, whether bound for Nevada, New Mexico or Texas. DOE also published barge route maps in its February 2002 Final EIS on Yucca.16 Yucca SEIS maps, however, have their limitations. The ISP/WCS CISF, after all, is located about 1000 miles from Yucca Mountain, so at some point, the routes to Yucca and west See the identical passage in the Holtec DEIS at 4-13.
14 Dilger's route maps are posted online under the year 2017 at 15 http://www.state.nv.us/nucwaste/trans.htmt http://www.beyondnuclear.org/waste-transportation/2017/6/29/potential-barge-rou 16 tes-on-us-surface-waters-to-ship-high-lev.html Page 15 of 25
Texas diverge significantly. But using the Yucca SEIS maps as a starting point to understand the range of the SNF transportation campaign from reactor sites to west Texas, clearly thousands of miles of rail, highway and waterway routes to ISP/WCS - information that is available but disregarded by the NRC Staff -- are completely undisclosed within the DEIS.
There are additional omissions of considerable technical and practical importance as they relate to transporting SNF, questions concerning the unique thermal traits of the waste to be shipped, the stability of fuel cladding, differential energy levels between generations of nuclear fuel, and more. To that end, the undersigned commenters adopt and incorporate by reference as though fully stated herein as their comments, pp.11-15 of the comments made by the Sierra Club and filed in this DEIS proceeding on or about November 2, 2020.
Transportation of SNF to ISP/WCS (and ultimately away from ISP/WCS) is the sine qua non of the project. But apart from the sparse explanation in the DEIS, multiple transportation issues have been segmented from, or excluded from, coverage that is required by NEPA.
Agencies must consider connected actions within the same EIS. 40 C.F.R. § 1508.25(a)(1). This prevents segmentation, the attempt to circumvent [the] NEPA by breaking up one project into smaller projects and not studying the overall impacts of the single overall project. Coalition on W. Valley Nuclear Wastes v. Chu, 592 F.3d 306, 311 (2d Cir. 2009)
(quoting Stewart Park & Reserve Coal., Inc. v. Slater, 352 F.3d 545, 559 (2d Cir.2003)) (internal quotation marks omitted). Connected actions include those that (1) [a]utomatically trigger other actions which may require environmental impact statements; that (2) [c]annot or will not proceed unless other actions are taken previously or simultaneously; or that (3) [a]re interdependent parts of a larger action and depend on the larger action for their justification. 40
§ 1508.25(a)(1).
Generally, in determining whether actions are connected so as to require consideration in the same EIS, courts employ an independent utility test, which asks whether each project would have taken place in the other's absence. See, e.g., N. Plains Res. Council, Inc. v. Surface Transp. Bd., 668 F.3d 1067, 1087 (9th Cir. 2011); Wilderness Workshop v. U.S. Bureau of Land Mgmt., 531 F.3d 1220, 1228-29 (10th Cir. 2008). If so, they have independent utility, and are not considered connected actions. N. Plains Res. Council, 668 F.3d at 1087-88. Here, transportation is the sine qua non of the ISP CISF; without shipment and delivery of SNF and GTCC waste, there is nothing to store.
The NRC must ensure, and find, that the rail, truck and barge routes used for delivery from reactor sites to ISP/WCS will not pose the potential for, or cause, disparate environmental impacts on the minority and low-income populations found in those transportation corridors.
Severance of transportation aspects from the ISP/WCS application means that there will be no equitable steps taken to share the burdens and risks of accident, sabotage, terrorism, and/or routine radioactive exposure from the shipments. Segmentation is a serious legal mistake from an overall NEPA perspective as well as from the standpoint of Environmental Justice. Absent an embrace of EJ obligations under NEPA, the selection of transportation delivery routes is likely to Page 16 of 25
disproportionately burden local minority and low-income populations found in the respective transportation corridors, from the reactor sites all the way through to the ISP/WCS CISF.
The NRC Staff has not identified, nor analyzed, several critical issues related to SNF transportation. By effectively segmenting or excluding identification and analysis of transportation matters from the EIS, the NRC Staff is predetermining the outcome of the NEPA stage of ISP/WCSs application. Predetermination occurs when an agency irreversibly and irretrievably commits itself to a plan of action that is dependent upon the NEPA environmental analysis producing a certain outcome, before the agency has completed that environmental analysis which of course is supposed to involve an objective, good faith inquiry into the environmental consequences of the agency's proposed action. Forest Guardians v. U.S. Fish &
Wildlife Serv., 611 F.3d 692, 714 (10th Cir.2010). [I]f an agency predetermines the NEPA analysis by committing itself to an outcome, the agency likely has failed to take a hard look at the environmental consequences of its actions due to its bias in favor of that outcome and, therefore, has acted arbitrarily and capriciously. Id. at 713.
The DEIS transportation analysis is a shallow glance, not a hard look. The DEIS must fulfill and satisfy to the fullest extent possible the requirements established for final environmental impact statements in section 102(2)( C) of NEPA. 40 C.F.R. § 1502.9(a). If a draft statement is so inadequate as to preclude meaningful analysis, the agency shall prepare and circulate a revised draft of the appropriate portion. Id. A revised DEIS is certainly required as to transportation aspects of the project.
VI. Failure to Consider Reasonable Alternatives Renders DEIS Inadequate And Incomplete There are several reasonable alternatives which have not been identified nor analyzed in the DEIS.
Construction and operation of the licensed Private Fuel Storage CISF in Utah instead of ISP/WCS is an unconsidered reasonable alternative (and is one that these commenters would 17 oppose).
Licensing, construction and operation of the Holtec LLC CISF in New Mexico, is an unconsidered reasonable alternative (and is also one which these commenters oppose).
Construction of the ISP/WCS proposal, but including a Dry Transfer System, is a reasonable alternative to the pending application (which these commenters would oppose in any event).
The PFS license is still in effect. See ML14255A395, 17 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML14255A395 Page 17 of 25
The evaluation of alternatives mandated by NEPA is meant to be an evaluation of alternative means to accomplish the general goal of an action; it is not an evaluation of the alternative means by which a particular applicant can reach his goals. Van Abbema v. Fornell, 807 F.2d 633, 638 (7th Cir. 1986)); also, Sierra Club v. Marsh, 714 F.Supp. 539, 577 (D.Me.
1989). The existence of a reasonable, but unexamined, alternative renders the EIS inadequate.
See DuBois v. U.S. Dept. of Agric., 102 F.3d 1273, 1287 (1st Cir. 1996), cert. denied, 117 S.C.
1567 (1997).
The DEIS must fulfill and satisfy to the fullest extent possible the requirements established for final environmental impact statements in section 102(2)( C) of NEPA. 40 C.F.R.
§ 1502.9(a). If a draft statement is so inadequate as to preclude meaningful analysis, the agency shall prepare and circulate a revised draft of the appropriate portion. Id. A revised DEIS is obligatory here.
VII. Incomplete Off-Normal Events Analysis Renders DEIS Inadequate Design Events II are associated with off-normal operations that can be expected to occur with moderate frequency, approximately once per year. These events could result in members of the general public being exposed to additional levels of radiation beyond those associated with normal operations. During normal operations and off-normal conditions, the requirements of 10 CFR Part 20 must be met. In addition, the annual dose equivalent to any individual located beyond the controlled area must not exceed 0.25 mSv [25 mrem] to the whole body, 0.75 mSv
[75 mrem] to the thyroid, and 0.25 mSv [25 mrem] to any other organ.
The DEIS notes that ISP/WCS evaluated for the proposed CISF (ISP, 2018) for an operating NUHOMS system included cask handling, transfer vehicle moving, and canister transfer. Off-normal events evaluated for the NAC International (NAC) system components included blockage of half the storage cask air inlets, canister off-normal handling load, failure of instrumentation, small release of radioactive particulate from the canister exterior, and severe environmental conditions (e.g., hypothetical wind). Off-normal events evaluated for the MAGNASTOR system included crane failure during loaded transfer cask movements and crane/hoist failure during the transportable storage canister (TSC) transfer to the vertical concrete cask (VCC). The ISP safety evaluation of these off-normal events for each potential storage system concluded that the proposed storage system would not exceed applicable 10 CFR 72.106(b) dose limits to individuals at or beyond the controlled area boundary and would satisfy applicable acceptance criteria for maintaining safe operations regarding criticality, confinement, retrievability, and instruments and control systems (ISP, 2018).
The NRC Staffs review and acceptance of the ISP off-normal design basis events analysis, however, is contingent upon the completion of the NRC safety evaluation report (SER) for the proposed CISF. DEIS at 4-95-4-96. Consequently, the NRC Staff cannot make a finding of the environmental impacts associated with off-normal events. And SER review and approval will happen well beyond the close of this public comment period. Thus the public is being deprived, due to mere scheduling concerns, of the opportunity to consider ISP off-normal design Page 18 of 25
basis events analysis for possible environmental concerns the events or analysis of them may raise.
The DEIS must fulfill and satisfy to the fullest extent possible the requirements established for final environmental impact statements in section 102(2)( C) of NEPA. 40 C.F.R.
§ 1502.9(a). If a draft statement is so inadequate as to preclude meaningful analysis, the agency shall prepare and circulate a revised draft of the appropriate portion. Id. A revised DEIS is required here.
VIII. The Staff Has Not Completed The FSER, Consequently The DEIS Contains No Radiological Accident Analysis And Is Incomplete The NRC staffs review and acceptance of the ISP/WCS accident analysis is contingent upon the completion of the NRC FSER for the proposed CISF project. The NRC safety review staff has not yet evaluated ISP/WCSs accident analysis to determine if the required safety criteria have been met with an acceptable safety margin. Nor, of course, has that review been documented in the FSER. DEIS at 4-96. The NRC cannot grant a license for construction and operation of the proposed CISF project until it determines that all regulatory requirements of the AEA and NRC are satisfied.
The DEIS must fulfill and satisfy to the fullest extent possible the requirements established for final environmental impact statements in Section 102(2)( C) of NEPA. 40 C.F.R.
§ 1502.9(a). This means that maximum efforts are required to make the EIS information available to the public during the comment period. If a draft statement is so inadequate as to preclude meaningful analysis, the agency shall prepare and circulate a revised draft of the appropriate portion. Id. A revised DEIS with new public comment opportunity is required here.
IX. The Continued Storage Rule Statement Is Inapplicable To ISP/WCSs First 120 Years ISP/WCS has defined a site-specific spent nuclear fuel storage facility that does not qualify for the exclusions and automatic assumptions conferred by the Continued Storage GEIS.
In the DEIS, the NRC Staff concluded that For the period of time beyond the license term of the proposed CISF, the NRCs Continued Storage GEIS (NUREG-2157) and rule at 10 CFR 51.23 apply. The Staff insists that it need not consider environmental impacts beyond the initial 40-year license term (and thus avoid the controversy the commenters have raised in the license application litigation) by hiding behind a serious dissimulation. The Staff asserts in the DEIS:
Although some characteristics of the proposed ISP CISF differ from the PFSF design, the Continued Storage GEIS acknowledges that not all storage facilities will necessarily match the assumed generic facility, and therefore when it comes to size, operational characteristics, and location of the facility, the NRC will evaluate the site-specific impacts of the construction and operation of any proposed facility as part of that facilitys licensing process. Thus, based on the site-specific analysis contained in this EIS and in the NRCs accompanying SER, no further analysis of impacts beyond the license term of Page 19 of 25
the CISF is needed, and the impact determinations in the GEIS are incorporated by reference.
DEIS at 5-14. But NUREG-2157 does say that not all storage facilities will necessarily match the assumed generic facility. The GEIS states the NRC assumes that any proposed away-from-reactor ISFSI would likely be similar to the assumed generic facility described above from the standpoint of the size, operational characteristics, and location of the facility....
NUREG-2157 at 5-2. Contrary to the Staffs attempt to have a dry transfer (DTS) system viewed as an operational characteristic, the DTS is a functional, physical facility component of the ISFSI. Id. The Staff has contrived the conversion of a clear expectation expressed in NUREG-2157 that at some point there must be a DTS, into a mere option that can be rejected upon a whim.
The ISP/WCS proposal departs significantly from the Continued Storage GEIS parameters and assumptions, and does not qualify for protection from closer scrutiny in the CISF Environmental Impact Statement. According to the Continued Storage GEIS, there is no DTS capability anywhere in the United States, including at any of the nuclear plant sites from which spent nuclear fuel shipments to west Texas might originate. Thus it appears that there may be 18 leaking, damaged and/or externally contaminated casks that cannot be remediated anywhere, that may be sent to ISP/WCS and endangering workers, the public and the environment.
And the NRC Staff concedes that:
Under some accident conditions, the radiation shielding on the transportation cask can be damaged, causing the radiation dose in the proximity of the package to increase. Under rare severe accident conditions, the potential for breaching a transportation cask and releasing a fraction of the radioactive contents is possible and has been considered in past SNF transportation risk assessments (NRC, 2014a, 2001; DOE, 2008). These prior assessments conservatively modeled accidental releases of radioactive material.
DEIS at 4-17. And:
Potential accident scenarios associated with SNF transportation using rail could result in members of the general public being exposed to additional levels of radiation beyond those associated with normal operations....
DEIS at 4-79. Implicitly, radiological effects could be major if the transportation of SNF is not error-free: [T]he radiological impact to workers from incident-free transportation of SNF to and from the proposed CISF project would be SMALL. Id. Since the NRC admits there could be radiological damage to SNF en route to west Texas, and there is no DTS capability anywhere in Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, 18 NUREG-2157 (Continued Storage GEIS) p. 2-20.
Page 20 of 25
the country, it is the height of irresponsibility to maintain that NUREG-2157 should be so creatively misrepresented as to provide a shield to protect ISP/WCS from economic burdensomeness of having the capability from the first day SNF begins shipment.
The determination of when ISP/WCSs license would expire, and when the GEIS waivers and protections would attach, is unclear because the applicant may seek one or more additional 40-year license renewals. The GEIS bulwark is inapropos for the entirety of whatever time periods the ISP/WCS CISF is intended by its owner and the NRC to continue to be licensed and operating.
X. The DEIS Misrepresents The Availability Of Federal Price-Anderson Insurance As Mitigation For Transportation Accidents The NRC Staff asserts that accidents involving SNF shipments would be tiny and not worth the trouble of calculating with any precision:
As discussed in EIS Section 4.3.1.2.2.3, at full build-out (Phases 1-8), the NRC staff estimates that there will be less than three rail accidents of any severity. Therefore, the NRC staff expects there to be zero accidents that would result in a release of radioactive material or a loss of shielding. As a result, the NRC staff has not attempted to directly quantify the economic cost of any particular hypothetical accident in this EIS. Any attempt to calculate the economic costs of unlikely accidents with any precision is difficult, because the costs can differ significantly depending on variables such as the location and conditions of the accident; the nature of the contamination dispersion and deposition; level of development; and land use.
DEIS at 8-6.
But the Staff admits that the DOE has estimated costs for a severe, maximum radiological transportation accident:
The NRC staff notes that for the Final Supplemental Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada, final Yucca Mountain EIS (DOE, 2008), the U.S. Department of Energy (DOE) estimated that the costs for a severe, maximum reasonably foreseeable SNF transportation accident could range from $1 million to $10 billion.
Id.
And to placate any doubters, the Staff states that there is federal nuclear accident insurance available just in case shipping SNF to ISP/WCS induces a catastrophe:
The Price-Anderson Act provides accident liability for incidents (including those Page 21 of 25
caused by sabotage) involving the release of nuclear material for SNF transportation (NRC, 2019). Currently the amount of coverage per incident this Act provided is over
$13 billion. In addition, Congress enacted legislation that developed a method to promptly consider compensation claims of the public for liabilities resulting from nuclear incidents that exceed this designated limit.
DEIS at 8-6 to 8-7.
But there is no Price-Anderson coverage available here. The federal Price-Anderson Act covers contractors who operate Department of Energy (DOE) nuclear facilities. P.L. 109-58 set the liability limit on DOE contractors at $10 billion per incident within the United States, to be adjusted for inflation every five years. The most recent inflation adjustment, in 2013, increased the limit to $12.7 billion. Price-Anderson authorizes DOE to indemnify its contractors for the entire amount of their liability, so that damage payments for nuclear incidents at DOE facilities would be paid by the Federal Government. ISP/WCS will not be a federal government contractor, and under the Nuclear Waste Policy Act, DOE has no authority to take title to, and manage, SNF waste that is destined for CISF storage (viz., DOE has no power to make ISP/WCS a DOE contractor) unless and until a permanent repository is licensed and operating. Since there is no scenario presently under which ISP/WCS can be a federal contractor for DOE, Price-Anderson coverage will not be available, and the representations in the DEIS are false and misleading.
An agency's action is held to be arbitrary and capricious when it relies on factors Congress did not want considered, or utterly fails to analyze an important aspect of the problem, or offers an explanation contrary to the evidence before it, or its explanation - as is apt here--is so implausible that it cannot be ascribed to differing views or agency expertise. See Motor Vehicles Mfrs. Assn. v. State Farm Mut., 463 U.S. 29, 43, 103 S.C. 2856, 2867 (1983).
XI. The Low-Level Radioactive Waste Analysis Fails To Account For Canister Repackaging The DEIS proclaims the various stages of activity at ISP/WCS will generate small quantities of low-level radioactive waste (LLRW). According to the NRC Staff, [t]he operations stage for the proposed action (Phase 1) and full build-out (Phases 1-8) would generate limited amounts of LLRW {approximately 11.7 cu. m [15.2 cu. yd] annually}, which would be disposed at the WCS LLRW facility. LLRW would consist of contamination survey rags, anticontamination garments, and other health physics materials. DEIS at xxxvi.
The NRC staff predicts minimal LLRW volumes from the massive decommissioning stage, which, as explained above, will necessarily involve onsite repackaging for shipment offsite of perhaps 20,000 transport, aging and disposal (TAD) canisters. The Staff says of the decommissioning stage:
For LLRW, decommissioning would generate 11.2 tons [12.3 short tons] for the proposed action (Phase 1) and 78.05 metric tons [86.03 short tons] of waste for full build-out Page 22 of 25
(Phases 1-8), which would be disposed at the WCS LLRW facility.
DEIS at xxxvii.
The vacuousness of this conclusion is breathtaking. Respecting low-level radioactive waste that can be anticipated from the overall construction, operation and decommissioning of ISP/WCS under optimal management, the DEIS fails the hard look required by NEPA.
[S]ome quantified or detailed information is required. Without such information, neither the courts nor the public... can be assured that the [agency] provided the hard look that it is required to provide. Neighbors of Cuddy Mountain v. United States Forest Service, 137 F.3d 1372, 1379 (9 Cir. 1998).
th XII. The NRCs Proposed Very Low-Level Waste Interpretive Rulemaking Should Be Accounted For And Analyzed The NRC is conducting a proposed interpretive rulemaking at Docket ID NRC-2020-0065 entitled Transfer of VLLW Nuclear Waste to Exempt Persons for Disposal, wherein the NRC proposes to reverse longstanding requirements for licensed control over radioactive wastes and materials generated by a licensed nuclear facility. The NRC seeks to abandon its regulatory authority over the destination and disposition of untold quantities of variably radioactive waste, dubbed Very Low-Level Waste. The NRCs reinterpretation would authorize any of the 2,600 municipal and private sanitary and industrial landfills and hazardous waste sites in the United States to seek an exemption to receive and dispose of VLLW. These new facilities, which are quite controversial because they intrinsically will provide unregulated disposition sites for licensed radioactive material and waste by another name, will compete directly and cost-advantageously for LLRW business. It is foreseeable that instead of disposing of ISP/WCS low-level radioactive waste at the WCS LLRW dump, the newly-renamed VLLW will be dumped in any number of these cheaper, fly-by-night landfills.
The undersigned commenters have already noted how the DEIS fails to acknowledge the likelihood of thousands more tons of LLRW as a result of canister repackaging for disposal in a repository. If they are correct, the DEIS must account for the VLLW interpretive rulemaking and investigate and analyze its likely effects on the LLRW volumes and disposition as a result of construction, operation and decommission of the ISP/WCS facility.
XIII. DEIS Assumptions Involving Yucca Mountain As The Final SNF Repository Are Illegitimate For Any Purpose There has been no final decision made by NRC either approving or disapproving the issuance of a construction authorization for a geologic repository at Yucca Mountain. See NWPA Sec. 114(d); 42 U.S.C. § 10,134(d). The NRC adjudicatory proceeding for the Yucca Mountain license application is currently suspended, and there is no date or criteria for its resumption. Nowhere within the NWPA is there any statutory requirement, or even an implication or presumption, that NRC must issue a decision approving or denying the Yucca Page 23 of 25
Mountain license application. The NRC Staff statements in the DEIS are erroneous.
The statement, Unless and until Congress amends the statutory requirement, the NRC assumes that the transportation of SNF from the CISF to a permanent repository will be to a repository at Yucca Mountain, Nevada - inaccurately assumes (a) that an authorization to construct a geologic repository at Yucca Mountain will be issued by NRC, (b) that Yucca Mountain will be constructed by DOE in accordance with that authorization, and © that NRC will issue an additional license authorizing DOE to receive and possess SNF at the Yucca Mountain site. These assumptions are even more objectionable because they were made by NRC Staff (supposedly an impartial regulator) notwithstanding that NRC is still considering the Yucca Mountain license application and NRC has not yet made a decision to grant (or deny) that application. While NRC Staff is arguably free to assume in the DEIS that SNF at the ISP/WCS CISF will be transported to a geologic repository, at some point in the future, it cannot assume that Yucca Mountain will be that geologic repository.
The NRC Staffs erroneous assumption is not consistent with the NRCs existing regulations. Under 10 C.F.R. § 51.80(b)(1), the DEIS must incorporate NUREG-2157, which is the NRCs generic environmental impact statement (GEIS) on extended SNF storage. In the GEIS NRC found it most likely that a repository will be available, but not that a repository at Yucca Mountain will be available. See 79 Fed. Reg. 56,238, 56,254 (Sept. 19, 2014).
The Yucca Mountain proposal also is illegal, as it would violate the Treaty of Ruby Valley of 1863, signed by the U.S. government with the Western Shoshone Indian Nation, and the Shoshones have made it clear in their intervention in prior Yucca licensing proceedings that they intend to contest on the treaty problem as well as other bases.
In sum, the NRC Staff cannot assume in the ISP/WCS DEIS that either a construction authorization for Yucca Mountain or a license to possess SNF at Yucca Mountain will be issued without prejudging the outcome of the still-pending and highly contested construction authorization proceeding required by Section 114(d) of the NWPA, 42 U.S.C. § 10134(d), and Section 189a the Atomic Energy Act, as amended, 42 U.S.C. § 2239(a). The DEISs dependence on such an assumption is contrary to law and unfounded, and all conclusions derived from that assumption are false and contradict NEPA.
XIV. Objection To Recent Alterations To NEPA Regulations And Interpretations The undersigned commenters object to any reliance on or application of President Trumps June 4, 2020 Executive Order on Accelerating the Nations Economic Recovery from the COVID-19 Emergency by Expediting Infrastructure Investments and Other Activities on the ground that it is unconstitutional, violates NEPA, violates the federal Administrative Procedures Act, violates the Atomic Energy Act and the Nuclear Waste Policy Act, and comprises an unlawful rulemaking.
The undersigned commenters further object to any reliance on, or application of the Page 24 of 25
Council on Environmental Qualitys (CEQ) new NEPA regulations issued July 16, 2020 because they are unconstitutional, violate NEPA and violate the Administrative Procedure Act.
The below commenters state that the objectionable proposals of the CEQ are in excess of statutory jurisdiction, authority, or limitations, or short of statutory right. 5 U.S.C. § 706(2)( C).
XV. Conclusion Taken as a whole, this DEIS does not fulfill and satisfy to the fullest extent possible the requirements established for final statements in section 102(2)( C) of the Act. 40 C.F.R. § 1502.9(a). The agency must insure that environmental information is available to public officials and citizens and this information must be of high quality as [a]ccurate scientific analysis, expert agency comments, and public scrutiny are essential to implementing NEPA. 40 C.F.R. § 1500.1(b). NEPA emphasizes the importance of coherent and comprehensive up-front environmental analysis to ensure informed decision making to the end that the agency will not act on incomplete information, only to regret its decision after it is too late to correct. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208, 1216 (9th Cir. 1998) (quoting Marsh v. Or. Natural Res. Council, 490 U.S. 360, 371, 109 S.C. 1851, 104 L.Ed.2d 377 (1989)).
Here, the NRC asks the public to assume the adequacy and accuracy of partial data without providing any basis for doing so. NEPA requires more. WildEarth Guardians v. Montana Snowmobile Ass'n, 790 F.3d 920, 927, (9 Cir. 2015).
th The NRCs Draft Environmental Impact Statement for the ISP/WCS CISF must be corrected, revised and republished for public review and comment.
Thank you.
Sincerely,
/s/ Terry J. Lodge Terry J. Lodge, Esq.
Counsel for Dont Waste Michigan, Citizens for Alternatives to Chemical Contamination, Public Citizen, Inc., San Luis Obispo Mothers for Peace, Nuclear Energy Information Service, Citizens Environmental Coalition, Sustainable Energy and Economic Development Coalition and Leona Morgan Page 25 of 25
Year Total Mi Total Acc Acc/Mi Total Fire Fire/Mi Total Expl Total FRTRN Mi Fire/FRTRN Mi Year Fire/100 million FRTRN MI Year rail car ac/rail car km 2010 704814252 2655 3.77E-06 29 4.11456E-08 2
5.08E+08 5.71E-08 2010 5.71 1991 2.08E-07 2011 717632844 2780 3.87385E-06 27 3.76237E-08 2
5.23E+08 5.16E-08 2011 5.16 1992 1.91E-07 2012 731578122 2437 3.33115E-06 16 2.18705E-08 0
5.34E+08 3.00E-08 2012 3.00 1993 1.68E-07 2013 748455721 2543 3.39766E-06 29 3.87464E-08 0
5.42E+08 5.35E-08 2013 5.35 1994 1.64E-07 2014 765815363 2523 3.29453E-06 53 6.92073E-08 0
5.56E+08 9.53E-08 2014 9.53 1995 1.53E-07 2015 738454623 2617 3.54389E-06 55 7.44799E-08 0
5.34E+08 1.03E-07 2015 10.30 1996 1.39E-07 2016 689667850 2308 3.34654E-06 79 1.14548E-07 0
4.92E+08 1.61E-07 2016 16.07 1997 1.32E-07 2017 705745198 2387 3.38224E-06 43 6.09285E-08 0
5.05E+08 8.52E-08 2017 8.52 1998 1.19E-07 2018 710422879 2477 3.48666E-06 61 8.58644E-08 0
5.10E+08 1.20E-07 2018 11.97 1999 1.12E-07 average 7.24E+08 2.53E+03 3.4915E-06 acc/frtrn mi =
4.83E-06 5.23E+08 8.40E-08 8.40 Year 392 1.38E+00 Fire/FRTRN Mi Year Fire/100 million FRTRN MI 2000 1.12E-07 2000 23 5.49E+08 4.19E-08 2000 4.19 2001 1.18E-07 2001 35 5.38E+08 6.51E-08 2001 6.51 2002 1.12E-07 2002 28 5.47E+08 5.12E-08 2002 5.12 2003 1.12E-07 2003 42 5.61E+08 7.49E-08 2003 7.49 2004 1.02E-07 2004 28 5.84E+08 4.80E-08 2004 4.80 2005 1.00E-07 2005 34 5.97E+08 5.70E-08 2005 5.70 2006 1.04E-07 2006 29 6.24E+08 4.65E-08 2006 4.65 2007 9.60E-08 2007 16 5.86E+08 2.73E-08 2007 2.73 2008 10 5.65E+08 1.77E-08 2008 1.77 avg =
1.32E-07 2009 22 4.76E+08 4.63E-08 2009 4.63 4.76E-08 26.7 Volpe 267 ACC/MI =
3.4915E-06 acc/km =
2.16863E-06 Fire/MI =
6.04905E-08 Fire/FTM =
8.40E-08 (Fire/Mi)/(Fire/
FRTRN Mi) 1.39E+00 Fire/Acc =
0.017325084 F/A 2010 = 0.010922787 F/A 2018= 0.024626564 0.00E+00 1.00E-08 2.00E-08 3.00E-08 4.00E-08 5.00E-08 6.00E-08 7.00E-08 8.00E-08 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Fire/FRTRN Mi Year Fire/FRTRN Mi 0.00E+00 2.00E-08 4.00E-08 6.00E-08 8.00E-08 1.00E-07 1.20E-07 1.40E-07 1.60E-07 1.80E-07 2010 2011 2012 2013 2014 2015 2016 2017 2018 Fire/100 million FRTRN Mi Year Fire/FRTRN Mi 0.00 2.00 4.00 6.00 8.00 10.00 12.00 14.00 16.00 18.00 2010 2011 2012 2013 2014 2015 2016 2017 2018 Fire\\100 million FRTRN Mi Year Fire/100 million FRTRN MI 0.00 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Fire/100 million FRTRN Mi Year Fire/100 million FRTRN MI
Rail Shipments Northeast Site Reactor State
- Shipments 2010-2048 Rail Mi Min Rail Mi Max Total Rail Mi Min Total Rail Mi Max Haddam Neck Haddam Neck CT 40 4105 4442 164200 177680 Millstone Millstone 1 CT 91 4139 4476 376649 407316 Millstone 2 CT 199 4139 4476 823661 890724 Millstone 3 CT 138 4139 4476 571182 617688 Pilgrim Pilgrim MA 18 4263 4600 76734 82800 Yankee-Rowe Yankee-Rowe MA 15 3998 4335 59970 65025 Maine Yankee Maine Yankee ME 55 4435 4771 243925 262405 Seabrook Seabrook1 NH 80 4282 4619 342560 369520 Vermont Yankee Vermont Yankee VT 137 4078 4415 558686 604855 Total =
3217567 3478013
- Fire =
0.39 0.42 Range 0.09652701 0.1043404 0.51481072 0.5564821 Rail Shipments East Coast Site Reactor State
- Shipments 2010-2048 Rail Mi Min Rail Mi Max Total Rail Mi Min Total Rail Mi Max Haddam Neck Haddam Neck CT 40 4105 4442 164200 177680 Millstone Millstone 1 CT 91 4139 4476 376649 407316 Millstone 2 CT 199 4139 4476 823661 890724 Millstone 3 CT 138 4139 4476 571182 617688 Crystal River Crystal River 3 FL 17 4175 4653 70975 79101 St Lucie St Lucie 1 FL 147 4315 4840 634305 711480 St Lucie 2 FL 85 4315 4840 366775 411400 Turkey Point Turkey Point 3 FL 85 4662 5140 396270 436900 Turkey Point 4 FL 86 4662 5140 400932 442040 Edwin Hatch Edwin Hatch 1 GA 288 3929 4266 1131552 1228608 Vogtle Vogtle 1 GA 283 3985 4322 1127755 1223126 Pilgrim Pilgrim MA 18 4263 4600 76734 82800 Yankee-Rowe Yankee-Rowe MA 15 3998 4335 59970 65025 Calvert Cliffs Calvert Cliffs 1 MD 320 3829 4166 1225280 1333120 Maine Yankee Maine Yankee ME 55 4435 4771 243925 262405 Brunswick Brunswick 1 NC 156 4145 4482 646620 699192 Brunswick 2 NC 152 4145 4482 630040 681264 Shearon Harris Shearon Harris 1 NC 43 4046 4383 173978 188469 Shearon Harris NC 146 4046 4383 590716 639918 McGuire McGuire 1 NC 164 3916 4253 642224 697492 McGuire 2 NC 173 3916 4253 677468 735769 Seabrook Seabrook1 NH 80 4282 4619 342560 369520 Oyster Creek Oyster Creek 1 NJ 110 4061 4398 446710 483780
Salem Salem 1 NJ 101 3950 4287 398950 432987 Salem 2 NJ 108 3950 4287 426600 462996 Hope Creek NJ 105 3978 4315 417690 453075 Indian Point Indian Point 2 NY 34 3981 4318 135354 146812 Indian Point 3 NY 19 3981 4318 75639 82042 North Anna North Anna 1 VA 289 3944 4281 1139816 1237209 Surry Surry 1 VA 330 4065 4402 1341450 1452660 Vermont Yankee Vermont Yankee VT 137 4078 4415 558686 604855 Total =
16314666 17737453
- fire =
1.96 2.13 Range 0.48943998 0.5321236 2.61034656 2.8379925