Beyond Nuclear's 20th set of public comments, re: Docket ID NRC-2018-0052, NRC's Holtec/ELEA CISF DEIS -- Mobile Chernobyl shipping risks
Dear NRC Staff,
This is my 20th set of public comments in this proceeding.
I submit these comments on behalf of our members and supporters, not only in New Mexico, near the targeted Holtec/ELEA Laguna Gatuna site, but across New Mexico, and the rest of the country, along road, rail, and waterway routes that would be used for high risk, highly radioactive waste shipments to Holtec's CISF, as well as to Yucca Mountain, Nevada, on Western Shoshone land -- illegally assumed by Holtec, as well as NRC, to someday become a permanent disposal repository.
The following subject matter has gotten little to no attention in NRC's Holtec CISF DEIS, a far cry from NEPA's legally binding "hard look" requirement.
Mobile Chernobyl shipping risks
Southeastern New Mexico has the dubious distinction that every single train car load of high-level radioactive waste will pass through on its way into (and, if it ever leaves, out of) Holtec's CISF. But transport impacts, to import far more irradiated nuclear fuel than currently exists in the U.S. (Holtec has applied for up to 173,600 metric tons of irradiated nuclear fuel to be "temporarily stored" in NM; less than 100,000 MT currently exists in the U.S.), would extend across Texas, and will also be felt nation-wide. In that sense, when it comes to radioactive waste transportation, we all live in southeastern NM.
In fact, Holtec -- and NRC -- erroneously assume the irradiated nuclear fuel will leave NM, bound for a permanent dump-site on Western Shoshone land at Yucca Mountain, NV. If that were to happen (which it will not, for reasons given below), southeastern NM, and much of the northern tier of TX (including Dallas/Fort Worth), and much of Oklahoma (including Oklahoma City) would be hit coming and going. This is shown by Figure 4.9.1, TRANSPORTATION ROUTES FOR SPENT NUCLEAR FUEL, in Holtec's ER, Rev. 0, Page 4-40. (Incredibly, NRC's DEIS does not even include this woefully inadequate single transport routing map. In that sense, NRC's DEIS is even more woefully inadequate than Holtec's ER!) It would be a Mobile Chernobyl double whammy. Eastern irradiated nuclear fuel would pass through these communities during the in-bound phase, to NM. Then, during the out-bound phase, going to NV, it would pass through these very same communities in NM, TX, and OK for a second time. This shows the nonsense of CISFs, in the sense of doubling transport risks for communities in NM, TX, and OK for no good reason whatsoever.
A de facto permanent surface storage parking lot dump at Holtec's Laguna Gatuna site in NM would only increase safety risks. It would not decrease them. It would multiply transport risks, as it would only be temporary (supposedly). All that highly radioactive waste would have to move again, to a permanent burial site (yet to be identified – that’s a big IF!). And that could be back in the same direction from which it came in the first place! If the permanent burial site is in the Eastern U.S., then many additional states would have seen irradiated nuclear fuel shipments coming (out to NM), and going (back East).
Holtec and NRC’s assumption that the dump at Yucca Mountain, Nevada will open someday, to take the high-level radioactive waste away, is inappropriate. The vast majority of Nevadans has expressed its very adamant non-consent for 33 years now, and still vehemently oppose it. This is reflected by bipartisan resistance by elected officials, at both the state government level, as well as the U.S. congressional delegation level.
In addition, the Western Shoshone have clearly communicated their non-consent to being dumped on, for several decades now. A dump at Yucca Mountain would violate the Treaty of Ruby Valley of 1863, the highest law of the land, equal in stature to the U.S. Constitution itself.
In addition, more than a thousand environmental, environmental justice, social justice, and public interest organizations, representing every state, oppose the Yucca dump, and have done so for 33 years. Here is a partial listing:
<http://archives.nirs.us/radwaste/yucca/yuccaopponentslist.htm>
For these reasons, the Yucca dump will never happen. But, if Holtec and NRC are assuming the Yucca dump will happen, they should then analyze the environmental, safety, and health impacts of CISF to Yucca dump transports. Any such analysis, as in NRC's DEIS, is woefully inadequate. Not a hard look, but hardly a look. This violates NEPA.
Holtec and NRC’s assumption that another permanent burial dump will be opened, by someone, somewhere, someday, somehow, is also inappropriate. After all, the search for a national geologic repository has gone on since the 1950s, but has utterly failed. And DOE’s most recent estimate for the opening of the U.S.’s first repository is 2048, 28 years from now. Except they have no idea where that will be. It won't be Yucca Mountain. There is every likelihood that 2048 date will slip into the future as well, as all previous target dates have, since 1957.
The failed Private Fuel Storage, LLC parking lot dump targeted at the Skull Valley Goshutes Indian Reservation in Utah, likewise assumed the Yucca dump would open. They were, of course, incorrect.
So PFS’s “Plan B” was to “return to sender.” If 40,000 metric tons of irradiated nuclear fuel – less than 1/4th the capacity Holtec has applied for – what would that “return to sender” policy have looked like?
Maine Yankee was a PFS consortium member. 60 rail sized containers of irradiated nuclear fuel would have traveled 5,000 miles round trip, accomplishing absolutely nothing, other than exposing millions of people in numerous states to high-risk shipments.
Holtec also has a "start clean/stay clean" policy for its CISF. This is outrageous. If problem casks arrive at Holtec's CISF, Holtec has said it would simply ship the problem cask back to the nuclear power plant site from whence it came. Shipping leaking, contaminated, damaged, defective, or otherwise problematic casks back across the country, right back through the same communities from which it passed in the first place, is absurd and dangerous. All this, so that Holtec can avoid the expense and trouble of building a dry transfer system (DTS) at its CISF. Outrageously and absurdly, NRC has blessed Holtec's "return to sender" policy. This, despite the agency relying on DTS's, in its Continued Spent Nuclear Fuel Storage Rule (Nuclear Waste Confidence Rule, or Nuke Waste Con Game), as the basis for claiming that indefinitely long away from reactor ISFSI (such as Holtec's CISF) would be safe and sound, as a DTS would allow for the irradiated nuclear fuel in problem casks to be offloaded in brand new replacement casks. Well, not if the DTS is never built in the first place. Holtec plans to build no DTS. NRC is letting them get away with this. Holtec's and NRC's remarkably weak argument seems to be that if a DTS were ever required, it could simply be built later. But of course, this doesn't address the time and expense it takes. There could simply be no time to build a DTS during a fast-breaking cask emergency at the CISF, not before large-scale releases of hazardous radioactivity had already occurred, harming not only CISF workers, but also area residents downwind, downstream, up the food chain, and down the generations.
Another version of this back-and-forth-across-the-country shipping nonsense is the fact that permanent burial sites could be located right back in the same direction from which the waste came in the first place. In fact, at one time, DOE was targeting two sites in Maine, seven sites in Vermont, and two sites in New Hampshire, for permanent burial dumps. (See Beyond Nuclear’s backgrounder, re: the NH targets, at: <http://static1.1.sqspcdn.com/static/f/356082/24115710/1487366549330/New_Hampshire_dump_final+draft.pdf?token=ZDgyvKfq8uxG4HPqWmvVvXBuwmY%3D>).
This game of high-risk, high-level radioactive waste musical chairs, or hot potato, on the roads, rails, and waterways, is unacceptable. It amounts to Radioactive Russian roulette. Multiplying transport risks for no good reason is wrong, and makes no sense.
Holtec's Quality Assurance (QA) failures mentioned in previous comments are very significant to shipping risks. Shipping casks would be less capable of withstanding severe accidents (such as high-speed crashes, including into immovable objects, like bridge abutments; high-temperature, long-duration fires; deep, long-lasting underwater submersion; drops from tall heights, onto unyielding surfaces, such as bridge foundations, or spiked objects; or some combination of all those), as well as intentional attacks (such as with shaped charges, or anti-tank weapon systems – see below), or other powerful explosions or intense fires (such as explosive/flammable cargoes on passing trains, including, nowadays, crude oil “Bomb Trains,” as from the Bakken oil fields in North Dakota).
Adding to these shipping risks, is the potential for barge shipments on surface waters. Holtec's CISF is supposed to use "mostly rail" shipping containers -- which can also mean many barges (some two dozen or more U.S. reactors lack direct rail access, meaning barges on surface waters -- the Great Lakes, rivers, seacoasts -- could be used to haul the 180-ton, rail-sized casks to the nearest rail head). Backgrounders (including more details on the high risks) on these various barge routes (including maps) were originally written for the Yucca dump scheme; however, Holtec's CISF would very likely involve such barging, as well.
DOE’s Feb. 2002 Yucca Mountain Final Environmental Impact Statement gives a preview of barge shipments that could well be required to ship high-level radioactive waste to the Southwest. The following barge shipment routes were proposed under the Yucca Mountain plan:
The NRC DEIS is largely to entirely devoid of any analysis of such barging transport risks.
(However, with something as simple as a rushed NRC rubber-stamp amendment, Holtec could apply for, and quickly get, permission to truck in smaller-sized, "Legal Weight Truck" (LWT) casks to its NM CISF. This mix of trains/barges and trucks, would mean even more American communities would be exposed to Mobile Chernobyl risks. Of course, if barges are not used for Holtec's rail sized casks, at nuclear power plant sites lacking direct rail access, then the only other option would be heavy-haul trucks. Heavy-haul trucking risks are also largely to entirely absent from NRC's DEIS, a violation of NEPA's hard look requirement.)
Dirty Bomb on Wheels security risks would also abound. See: <https://web.archive.org/web/20150908070611/http://www.nirs.org/factsheets/nirsfctshtdrycaskvulnerable.pdf>This was made clear by the test of an anti-tank missile against an (empty) irradiated nuclear fuel shipping cask at the U.S. Army’s Aberdeen Proving Ground in Maryland. The June 1998 test targeted a German CASTOR cask. While certified for storage-only in the U.S. (the cask model is deployed at Surry, VA), it is widely used for transport in Europe. CASTORs have thicker die cast iron walls, as compared to thinner walled steel casks used in the U.S., including Holtec's. That is, CASTORs are significantly more robust, more capable to withstand such an attack. However, even the CASTOR, the Cadillac of shipping casks as some have called it, was severely breached by the anti-tank missile. A hole as big around as a grapefruit or softball was blown clean through the side wall. Had irradiated nuclear fuel been inside, the hole would have created the pathway for release of disastrous amounts of hazardous radioactivity – all the more so, if an incendiary attack were combined with the explosive attack. In short, shipping containers were not designed, nor are they capable, to withstand such attacks. See:
Given the problems with this <holtec-cisfeis@nrc.gov> email address not working at time, please acknowledge receipt of these, and all of my comments. Thank you.
September 5, 2020