ML20317A281
| ML20317A281 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 11/12/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR27447 | |
| Download: ML20317A281 (10) | |
Text
From: Kevin Kamps <kevin@beyondnuclear.org>
Sent: Tuesday, November 3, 2020 8:33 PM To: WCS_CISFEIS Resource
Subject:
[External_Sender] Beyond Nuclear's 27th set of public comments, re:
Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Responses to statements made by ISP proponents during the first NRC call-in public comment session o...
Attachments: DC Capitol Dome train.jpg; 2 78 Interim Storage Partners, LLC - Revision 2 to WCS Consolidated Interim Spent Fuel Storage Facility Environmental Report, Part 1 of 9, Chapter 1 and 2. -
ML18206A518.pdf
Dear NRC Staff,
We submit these comments on behalf of our members and supporters, not only in New Mexico and Texas, near the targeted ISP/WCS CISF site, but across both of these states, and the rest of the country, along road, rail, and waterway routes that would be used for high risk, highly radioactive waste shipments to ISP/WCS's CISF, as well as to Yucca Mountain, Nevada, on Western Shoshone land -- wrongly and illegally assumed by ISP/WCS, as well as by NRC, to someday (or some decade, or some century) become a permanent disposal repository. This unnecessarily repeated, multiple legged, cross-continental transport of highly radioactive waste, is another significant aspect of the EJ (Environmental Justice) burden associated with this ISP/WCS CISF scheme.
The following subject matter has gotten little to no attention in NRC's ISP/WCS CISF DEIS, a far cry from NEPA's legally binding "hard look" requirement:
Responses to statements made by ISP proponents during the first NRC call-in public comment session on Oct. 1, 2020 On Oct. 1, Jay Thomas of Orano Group International -- a lead company in the ISP scheme --
tried to soothe concerns about the high risks of irradiated nuclear fuel transportation, by saying that up to a year's time is invested in preparing a shipment for transport.
If that's the case, then ISP's proposed 3,400 shipments could take a grand total of 3,400 years to prepare before shipments commence, all told?! That's a bit longer than NRC's arbitrarily and capriciously short 40-year scope in the DEIS!
Jay Thomas also boasted about the testing done on shipping containers. But computational model analysis and scale-model testing is not the same as full-scale physical safety testing to destruction.
And Jay Thomas's mere mention of "Tribal Nations" reveals the EJ burden of irradiated nuclear fuel shipping to the proposed ISP CISF.
But neither ISP in its Environmental Report, nor NRC in its DEIS, has even identified Native American reservations that would be impacted by ISP-bound shipments.
Fortunately, the State of Nevada Agency for Nuclear Projects has done such EJ analysis work:
State of Nevada - Measures of Community Impact for The Transportation of Hazardous Materials: The Case of Indian Tribes and High-Level Nuclear Waste -- Conference Paper -
Waste Management 2005 - Fred Dilger, Robert Halstead, James David Ballard (pdf-1.24M)
Although the case study is in the context of Yucca Mountain, NV-bound shipments, it must be pointed out that the further from the American Southwest the origin site, the more similar to identical shipment routing would be, whether bound for Yucca Mountain, NV, or ISP, TX.
Also on October 1st, Edward Davis of the Nuclear Industry Council, another ISP proponent, boasted about WIPP shipments as some kind of sign as to how swimmingly ISP shipments would also go. He left out the Valentine's Day, 2014 "impossible leak" at WIPP however. A barrel burst in the WIPP underground, leading to an environmental release of TRU; a couple-dozen workers at the surface exposed to ultra-hazardous TRU alpha particle inhalation doses; a three-year shutdown of the site; and a cost of $2 billion in recovery expenses. Significantly, that burst barrel happened in the WIPP underground, rather than during the shipment from Los Alamos to WIPP. If that barrel had burst during transit across NM, the consequences could have been even worse.
Incredibly, in the aftermath of the WIPP barrel burst, Los Alamos and its contractor nonetheless rushed a large number of additional potentially bursting barrels to WCS in TX. WIPP would not accept them, nor could WIPP accept them, then being shut down by the barrel burst. So, in order to keep to its arbitrary schedule, so that it wouldn't lose out on milestone bonuses, a large number of potentially bursting barrels were rushed down to WCS, for no good reason. To show how dangerous that Los Alamos to WIPP shipment was, some of those potentially bursting barrels are still there to this day, nearly nine years later, still stuck at WCS. Why? Because they are still too dangerous to ship on to WIPP, now re-opened. That distance is "only" about 40 miles or less.
And yet, Los Alamos and its contractor, as well as WCS, conspired to take the very high risk of shipping that large number of potentially bursting barrels 350+ miles, from Los Alamos to WCS, so that all the companies involved could make a buck. Thank goodness none of those potentially bursting barrels bust while in transit. If a burst 2,000+ feet below ground cost $2 billion, and took three years, to recover from, how much time and money would a burst at the surface during transport take to recover from? How many workers, emergency responders, and downwind/downstream residents would have been harmed?!
Mr. Davis's boasting about WIPP's safety record on transport was thus incomplete and inapt.
Also on Oct. 1, Jack Edlow, another IPS proponent (who would make a fortune on being the transport middleman, as CEO and President of Edlow International) said that rail shipments through Takoma Park, MD would never happen. He said this in response to my own prior testimony, naming me by name, stating that I was mistaken about the likely shipments impacting my very own office located there, as well as those who live in adjoining condos and houses, as
well as those waiting for Metro trains on the adjacent tracks at Takoma Metro Station. But I must set the record straight.
Dr. Fred Dilger, commissioned by the Nevada State Agency for Nuclear Projects, has documented this Takoma Park, MD rail route. See Page 19 of 45 on the PDF counter for a map
<http://www.state.nv.us/nucwaste/news2017/pdf/States_Affected.pdf>, showing the Calvert Cliffs nuclear power plant irradiated nuclear fuel rail route through Takoma Park, MD.
Page 7 of 45 on the PDF Counter in the same document linked above, shows rail shipping routes through the District of Columbia. It shows not only the Calvert Cliffs export route through Takoma Park, but also shows a North Anna nuclear power plant (in Virginia) export route traversing Washington, D.C., before then also passing through Takoma Park.
Page 41 of 45 shows the North Anna rail route, passing through the heart of the nation's capital (very close to the U.S. Capitol Building, actually; see the attached photo, showing a train traveling this very route, and how very close by it passes the U.S. Capitol), before then also passing through Takoma Park, MD.
Page 20 of 20 on the PDF counter in this document
<http://www.state.nv.us/nucwaste/news2017/pdf/Cities_Affected.pdf> also shows these Mobile Chernobyl rail routes that pass through the D.C. metro area, including Takoma Park, MD.
Here is the full package of Dr. Dilger's routing analyses, including a statement of methodology:
2017 - - - - - - - - - - - - - - - -
- Nevada Agency for Nuclear Projects - Representative Transportation Routes to Yucca Mountain and Transportation Impacts (Cask Shipments by State) - Fred Dilger PhD
- Nevada Agency for Nuclear Projects - Cities Potentially Affected by Shipments to Yucca Mountain (pdf-2.45M)
- Nevada Agency for Nuclear Projects - States Potentially Affected by Shipments to Yucca Mountain with Congressional Districts (pdf-7.05M)
- Nevada Agency for Nuclear Projects - Congressional Districts Potentially Affected by Shipments to Yucca Mountain - 115th Congress (pdf-882K)
I'm not sure which is worse. Jack Edlow, who touts himself as an international expert on highly radioactive waste transportation, not knowing any of this, but erroneously asserting strongly that I was mistaken in my comments. Or that he does know this information, but is intentionally deceiving the public by denying it. It's all the harder to understand how Jack Edlow does not know about these D.C., and MD and VA suburbs, transport routes, when he himself has been long based in the D.C. area, conducting his radioactive waste and nuclear materials transportation business, including advocating for the opening of high-level radioactive waste dumps out West, so he and his company can make hundreds of millions of dollars, or billions of dollars, or more, by being involved in those shipments.
Edlow also mentioned his experience with irradiated nuclear fuel shipments from Iraq, Ghana, Nigeria, and Colombia, back to the U.S. This begs the question, are those foreign origin irradiated nuclear fuel assemblies ultimately bound for the CISFs in NM (Holtec) and TX (ISP)?
This is the very question Don't Waste Michigan et al.'s expert witness, Dr. David Ballard, asked during the environmental scoping and ASLB licensing proceeding stages, after all. He asked it because the grand total of inventory at the CISFs of 213,600 metric tons (173,600 at Holtec, 40,000 at ISP) is far and away larger than the entire commercial irradiated nuclear fuel and high-level radioactive waste inventory in the U.S. will ever be. So the question is begged, will foreign wastes be imported to the TX and/or NM CISFs? Will military wastes?
As posted Nov. 29, 2018 at Beyond Nuclear's website, here again is Ballard's expert witness work, linked, which NRC has largely to entirely ignored thus far:
Expert witness declarations by James David Ballard, Ph.D., re:
high-level radioactive waste transport risks Expert witness declaration by James David Ballard, Ph.D., Professor, Criminology and Justice Studies, California State University, Northride, "Holtec HI-STORM UMAX Interim Storage Facility (a.k.a. CISF): Human-Initiated Events (HIE), Transportation of the Inventory, and Storage of Highly Radioactive Waste Materials."
The declaration was filed on September 14, 2018, as part of a legal intervention against the Holtec International/Eddy-Lea Energy Alliance CISF in New Mexico by legal counsel Terry Lodge on behalf of a seven-group grassroots environmental coalition.
Expert witness declaration by Dr. James David Ballard, entitled "Interim Storage Partners:
Transportation of the Inventory and the Storage of Highly Radioactive Waste Materials."
This declaration was filed on November 13, 2018, as part of a legal intervention against the Waste Control Specialists/Interim Storage Partners CISF in Texas, by legal counsel Terry Lodge on behalf of a seven-group grassroots environmental coalition.
Edlow also mentioned air transport. Was he referring to irradiated nuclear fuel being air transported? Is this even legal? Aren't there prohibitions against the air transport of plutonium in the U.S.? Isn't irradiated nuclear fuel at least 1% plutonium in composition? Did Edlow International violate the law, with the air shipments of irradiated nuclear fuel Edlow mentioned and boasted of having conducted? Were the irradiated nuclear fuel assemblies transported by air contained in containers capable of withstanding the forces of an air crash, such as impact on hitting the ground, and even the possibility of a high temperature, long duration fire, as due to the airplane's fuel igniting on impact?
Edlow stated during his comment that "routing is yet to be determined," and that it would "avoid heavily populated areas." ISP opponents like Don't Waste Michigan et al. in their licensing proceeding intervention, and Beyond Nuclear in its environmental scoping and DEIS comments,
have strongly contested this notion that "routing is yet to be determined," and that "heavily populated areas" would be avoided. Just look at these 20 case studies by Dr. Dilger:
http://www.state.nv.us/nucwaste/news2017/pdf/Cities_Affected.pdf That's 20 major urban areas of heavy population density right there, that would be crisscrossed by irradiated nuclear fuel shipments. Granted, Dilger's report is in the context of the Yucca Mountain dump. But as mentioned previously, the further from the American Southwest the origin site, the more similar, to identical, the shipping routes would be, regardless of whether shipments are bound for Yucca Mountain, NV, or ISP, TX.
Dilger cites the same 2008 DOE Yucca FSEIS that NRC does in this ISP DEIS, making Dilger's routing maps entirely appropriate and relevant for me to raise here.
And check out these barge routes that DOE admitted to in its Feb. 2002 Yucca FEIS:
http://www.beyondnuclear.org/waste-transportation/2017/6/29/potential-barge-routes-on-us-surface-waters-to-ship-high-lev.html That documents additional heavily populated centers along potential barge shipping routes that could be used in the ISP scheme, including several around metro New York City, for example.
Incredibly, one such route, from Indian Point, would pass immediately adjacent to New York City, on the Hudson River. New York City, of course, is the most densely populated urban area in the U.S. The safety and security risks to human health and the environment of ever doing any such thing cannot be overstated.
Again, it is frightening if Edlow is ignorant of all this. I doubt that he is. Rather, I think he is attempting to keep the impacted public in the dark for as long as possible about the shipment routes, even though they are very know-able right now, and long have been.
But NRC itself is complicit in such deception and secrecy. Which is itself very frightening. After all, the Japanese Parliament concluded in 2012 that the root cause for the Fukushima Daiichi nuclear catastrophe was collusion between industry, government regulatory agency, and elected officials. NRC's complicity with ISP and Edlow International, to keep knowable shipment routing obscured for as long as possible, shows that such potentially catastrophic nuclear collusion exists here too. And such intentional obscurantism, secrecy, and deception is certainly a violation of NEPA's hard look, public disclosure, and public participation requirements.
But even ISP itself reveals heavily populated urban centers that would be impacted by its shipments. See Figure 2.6-1, Transportation Routes, on Page 2-78, in Chapter 2, of ISP's ER.
(See this route map, also attached.) Although this route map accounts for only 4 atomic reactors out of 131 in the U.S. (one at Maine Yankee, and three at San Onofre CA), it nonetheless shows many heavily populated urban areas in the country impacted by ISP shipping. To name but a few examples, of many: Cleveland OH; Toledo OH; South Bend IN; Kansas City, MO and KS; Oklahoma City, OK; Tulsa, OK; Dallas, TX; Fort Worth, TX; El Paso, TX; Denver, CO; Salt Lake City, UT; Las Vegas, NV; and metro LA, CA. Of course, if shipments from the other 127
reactors in the country were also accounted for, then many other heavily populated urban areas would be revealed to be impacted as well.
Note that for NM, TX, and OK, the inbound shipment route is overlapped by the outbound shipment route, when ISP exports its inventory to Yucca Mountain, NV. Thus, those heavily populated urban areas in TX and OK would be hit, coming and going. Hit twice, for no good reason. This reveals the nonsensical risk taking nature of CISFs, which would require a multiplication of shipments, and thus risks.
Obviously, Edlow's comments were false. And yet NRC facilitator Chip Cameron saw fit to say "Thank you, Ed," for commenting about "routes not having been determined yet." This was inappropriate for Cameron to say. Don't Waste Michigan et al. in its licensing proceeding intervention, as well as its environmental scoping and DEIS comments, have strongly challenged any such notion that routes have not been determined yet. It was yet another instance of Cameron revealing his bias in favor of the CISFs. For example, during a Holtec CISF DEIS call-in session, Cameron told a member of the public, and CISF opponent, Nick Maxwell, what subject matter he could not speak about, before allowing him to speak. Myself, as well as Ed Hughs, objected in real time to Cameron's entirely inappropriate attempted censorship of Maxwell. Another example was Cameron's cutting off CISF opponent Noel Marquez during the Holtec CISF environmental scoping in-person public comment meeting in Carlsbad, NM, in May 2018, long before Marquez's allotted time had expired. Cameron even approached the podium in a menacing manner, physically, as if he were about to seize the microphone away. Again, myself, and others in attendance, protested Cameron's behavior in real time. These examples of Cameron's misbehavior and clear revelation of bias are outrageous and objectionable. They are akin to Tony Hsia's pep rally speech to conclude an NRC Spent Fuel Project Office regulatory conference across Rockville Pike from NRC HQ several years ago, when he shouted "Together we can get this done!" while fist pumping the air. By we, Hsia meant NRC and industry. By this, he meant CISFs. I have objected to Hsia's most inappropriate words in previous comments.
At this Oct. 1st call-in session, dump opponents outnumbered dump proponents by a count of 30 to 4, in terms of those who made verbal public comments. All 4 dump proponents were industry representatives, looking to make money from the ISP scheme.
Please address and rectify your woefully inadequate "hard look" under NEPA, re: this health-, safety-, and environmentally-significant, as well as legally-binding, subject matter above.
And please acknowledge your receipt of these comments, and confirm their inclusion as official public comments in the record of this docket.
Thank you.
Sincerely, Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear
Kevin Kamps Radioactive Waste Specialist Beyond Nuclear 7304 Carroll Avenue, #182 Takoma Park, Maryland 20912 Cell: (240) 462-3216 kevin@beyondnuclear.org www.beyondnuclear.org Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.
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[External_Sender] Beyond Nuclear's 27th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Responses to statements made by ISP proponents during the first NRC call-in public comment session o...
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