NRC-2019-0052, Comment (123) from Christopher D. Carson on Holtec International HI-STORE Consolidated Interim Storage Facility Project
| ML20302A439 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/15/2020 |
| From: | Cecilia Carson - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 85FR16150 00123, NRC-2019-0052 | |
| Download: ML20302A439 (2) | |
Text
SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 Post Office Box 1035 ADD: Jill Caverly Fort Worth COMMENT (123) Texas 76101 USA PUBLICATION DATE: 3/20/2020 publius+reg@man-and-atom.info CITATION 85 FR 16150
+1 (646) 628-5076 September 15, 2020 Office of Adminislration Mail Stop TWFN-7-A60M attention : Program Management, Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington DC 20555-0001 reference: Docket ID NRC-2018-0052 ESTEEMED COMMISSIONERS :
The proceedings regarding the proposed Holtec Consolidated Interim Storage Facility have been criticized on the basis that people who might be affected by the transportation of spent fuel to the facility ought to be consulted. It is in that capacity that I come forward. Fort Worth is a major rail center, and I would expect at least a third of shipments headed to the vicinity of El Paso to go by way of my home town.
Hundreds of carloads of explosive, corrosive, toxic, and otherwise hazardous materials pass through Fort Worth in a typical day. Many of them, such as liquefied petroleum gas, anhydrous ammonia, or chlorine, are volatile fluids under pressure, separated from the outside world only by a skin of steel perhaps a centimeter or two thick. It is a testimony to the American railroading profession that, for all the thumping and banging in the classification and switching yards here as trains are broken up and rebuilt, years may elapse between incidents which result in injury to members of the public.
It is safe to say that those who have spoken in opposition to the CISF project do not generally accept the judgment of Commission staff that the anticipated environmental impacts of transporting spent fuel to the facility are minimal. Rather they speak in highly-colored terms of people and places along the transport routes being irradiated and contaminated, employing language clearly calculated rather to alarm than to illuminate -
"Mobile Chernobyls" being perhaps the most luridly obnoxious example.
And what, pray tell, do they wish me to be alarmed about? In the three generations during which spent fuel packages of various designs have been transported on land and water in (and between) a number of coun-tries, never once has a transport flask cracked open. Flasks have been subjected to all manner of ludicrous tests, including being dropped from a helicopter onto a spike, and slammed into by a rocket-propelled railway loco-motive, without losing their integrity. Even if one did, the material within is a tough, refractory ceramic, inert to air and water, and sealed up in metal ; nor is there any force within the package that would work to disperse the contents. In short, a path to the kind of destruction seen at Lac-Megantic, which we continually invite by our reliance on fossil fuels, is not to be found.
At the time of the Windscale inquiry, some 40 years ago, one of the most respected jurists in Britain found
that, on the basis of the evidence before him, the transport of spent fuel was far from burdening the public with undue risks. Nothing in the experience of the intervening time tends to contradict that. Suppose that operation of the CISF resulted in a carload of spent fuel passing through Fort Worth every day, which is more than I anticipate. This would cause me far less concern than I already feel about the unit coal trains which in fact do move on a daily basis. I decline to be afraid, merely because someone who clearly does not know what he is talking about tells me I should. In fact the suggestion is offensive to the citizen who is conscious of his duties.
Since very few of those who speak in opposition seem to confine themselves to a single point, I feel justified in leaving the question which most nearly concerns me, in order to observe that none of the other objections they continually advance appears to be any better-founded.
The site represents an environmental injustice against marginalized and Indigenous communities? Only if some widespread harm arises from the facility, an assumption which they justify, if at all, by appealing to a comic-book under§tanding of science.
The project itself cannot be considered, because the Nuclear Waste Policy Act does not permit away-from-reactor Storage? The use of the inoperable GE-Midwe§l: reprocessing plant for the purpose would seem to indicate otherwise.
The scope of the environmental impact Study is too narrow, because it does not comprehend the entire enterprise of nuclear energy in all its aspects? In framing the Atomic Energy Act, Congress has explicitly declared that the employment of this force of nature for civil purposes is in the national interesl:. Since the powers of the Commission derive from this Act, the quesl:ion is utterly beyond its competence.
Realisl:ically, when the nature and scope of the project at hand are considered, so long as the separate nuclear safety review finds the Holtec proposal sound, it is difficult to see how the findings of the draft Envi-ronmental Impact Statement can be challenged. The character of these objections, and the manner in which they are brought forward, leaves me with no confidence that they are offered in good faith. In our American political sysl:em, the drasl:ically misinformed and even the disingenuous have the right to air their opinions in public debate, and so we mu§l: be on our guard le§l: such views come to shape our national policy. As such, although I find myself indifferent to the CISF proposal on its merits, I feel obligated to rise in support of it.
RESPECTFULLY,
~ili/
CHRISTOPHER D. CARSON 2