Beyond Nuclear's 32nd set of public comments, re: Docket ID NRC-2018-0052, re: NRC's Holtec/ELEA CISF DEIS

As submitted via <holtec-cisfeis@nrc.gov>, by Nuclear Issues Study Group. Beyond Nuclear's radioactive waste specialist Kevin Kamps took part in NISG's Sept. 16th "People's Hearing" Zoom. Kevin's verbal comments were then transcribed by NISG and submitted to NRC. See them below...

Dear NRC Staff,

 The following comments were transcribed from the video recording of the People’s Hearing held by the Nuclear Issues Study Group on Wednesday, September 16, 2020 (Available online: https://www.youtube.com/watch?v=CfCBsXCQyOU). These written comments are being submitted with the consent of the commenters. The transcription was made possible by the work of the Nuclear Issues Study Group volunteers.

Comment sent on behalf of:

KEVIN KAMPS

Okay, thanks so much. Thank you to everyone at NISG for organizing this People’s Hearing. I really appreciate it. I just wanted to compare your professionalism and quality to the NRC's lack of that and just compare NRC’s got several thousand people on staff and a budget that approximates a billion per year, so, good job you guys. So, I serve as Radioactive Waste Specialist at Beyond Nuclear and I'm also on the board of Don't Waste Michigan and on the Advisory Board of Citizens for Alternatives to Chemical Contamination. Those latter two are Michigan-based groups, and I just wanted to mention all three because we're official legal interveners in the rigged NRC process. But now that the NRC has entirely kicked us out of the Holtec proceeding and is soon to do so on the Interim Storage Partners proceeding, we are now, all of our groups and others, you know, allied with NISG, in the second highest court in the land, the U.S. Court of Appeals for the District of Columbia Circuit. And one of the ideas that Libbe shared earlier, and others, that it's illegal, what they're proposing here in this proceeding should never have started. That is one argument, but there are dozens more that were brought by Terry Lodge on behalf of a coalition and by Wally Taylor on behalf of Sierra Club which is the biggest and oldest environmental group in the country. So, we'll see what happens in court. I've got my Don't Waste Michigan hat on for these comments tonight. So I'm from Kalamazoo, Michigan, which is Potawatomi land, and we have three nuclear power plants on the Lake Michigan shoreline in Michigan. We've got Palisades, and Cook units 1 and 2 in Southwest Michigan on Potawatomi land, and Big Rock Point up north on Odawa land. Fortunately, Big Rock is shut down, but they still have the high level waste there, but Palisades and Cook are still operating, making more high level radioactive waste every year. And so in NEPA speak, National Environmental Policy Act, I’d like to say that the preferred alternative to the Holtec CISF is to stop making it. And I’ve heard others say that tonight. So imagine the two years left that Palisades supposedly has—I don’t believe them—they lied about shutting down in 2018, and now they are saying they are going to shut down in 2022, but imagine the years of waste they would not generate. Cook, two giant units is not planning to operate for years more, they are planning to operate for decades more. So imagine the waste that would not exist if they just shut down. We don’t need them. We have enough electricity already. If more is needed, it can be provided by renewables and efficiency. Those are the preferred alternatives. Also speaking on behalf of Don’t Waste Michigan, I want to say that: we do not consent to Holtec or ISP. We do not consent. And we did have to fight this fight in Michigan. There were folks who said, “Get it out of here, we don’t care where it goes, we don’t care how it gets there.” We did have to fight this fight over years, but in the end there was a consensus reached and it included folks like Ian Zabarte from the Western Shoshone coming to Michigan, coming to Don’t Waste Michigan meetings, meeting people, explaining about being targeted with the national dump site down there, and we reached consensus. We can’t dump our problems on other people. But having said that, it’s a dilemma, because right now all that waste is very near the water of Lake Michigan. The problems that San Onofre faces we have been facing in West Michigan for a quarter century, or more than that actually, and right now we have historic high Lake Michigan water levels with severe erosion including very close to the Palisades independent spent fuel storage installation. I was just out there in April and again in August, and it’s the highest I’ve ever seen and I visited that site for 30 years. It was 30 paces from the water’s edge to the bluff which is about a hundred feet, and just over that small sand dune is the high level radioactive waste. So all it’s going to take is a severe storm or an earthquake, because the dry cask storage at Palisades is on a sand dune. It’s 55 feet of loose sand underneath, anchored to nothing, and an earthquake could simply open the sand and let the lake flow in, and the waste could fall in the lake. So we have real problems, but our preferred alternative to CISFs is Hardened On-Site Storage, which is endorsed by 200 groups across the country from all 50 states, and if that's not safe on site, then as near to the site as possible, and safe or as safely possible, so further inland, to higher ground and fortified against natural disasters, against accidents, against attacks, and the same applies at other places like San Onofre or Prairie Island, Minnesota, which is the Prairie Island Indian community, one of the worst of these unsuitable sites. And just the final thing I'll talk about is transportation that others have raised. We do not consent to the risks of heavy haul trucks or legal weight trucks or rail shipments through Michigan to rush the waste out of the, out of the state to a place like Holtec or ISP, just multiplying transportation risks because it would have to move again. And it's not going to Yucca, so we don't know where it would go. It's probably stuck in New Mexico and Texas. But I would like to emphasize the barge shipments on Lake Michigan that are potential, if a single barge were to sink and release even a fraction of its contents into Lake Michigan, Lake Michigan is the headwaters of the Great Lakes, one of them. Forty million people, four-zero million people in this generation alone depend on the Great Lakes for drinking water, for fisheries, for recreation, for industry. It's one of the biggest regional industries in the world, between the two countries, so eight states, two provinces, and a very large number of Native American First Nations. The Great Lakes are 21% of the planet’s, I'm sorry, 21% of the planet’s surface freshwater, 84% of North America’s surface freshwater. We cannot rush into these shipments like Holtec and ISP would like to do, so as an interim measure we need to do Hardened On-Site or near site storage. Thank you very much.

Nuclear Issues Study Group
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