Beyond Nuclear - Centralized Storage

Dear Friends and Colleagues,

Thanks to all those who have submitted verbal comments during the previous Oct. 1st, 6th, and 8th U.S. Nuclear Regulatory Commission (NRC) call-in sessions thus far.

Please still take more action -- call in and submit verbal comments -- this Thursday, Oct. 15th. NRC Draft Environmental Impact Statement (DEIS) public comment call-in session begins at 11am Eastern/10am Central/9am Mountain/8am Pacific. The call-in numbers are:

CALL IN NUMBER (888) 989-9268 Pass Code 5300047#

Follow the voice prompts, asking for your name and organizational affiliation if any. To get in line to submit verbal comments, PRESS *1 [star-one] and give your name.

See below for more background.

Please spread the word. Thank you.

---Kevin Kamps, Beyond Nuclear & Don't Waste Michigan

---------- Forwarded message ---------
From: Diane D'Arrigo <dianed@nirs.org>
Date: Mon, Oct 5, 2020 at 11:59 AM
Subject: Oct 15th--last chance to Call in/ Say NO to Hi Level Nuclear Waste Dump in TX and thousands of shipments
To: Diane D'Arrigo <dianed@nirs.org>, Karen Hadden <karendhadden@gmail.com>

CALL IN TO COMMENT ON THE Nuclear Regulatory Commission draft Environmental Impact Statement for

Supposedly "Interim" Nuclear Waste Dump and Massive Transport Across the US for Decades

OCTOBER 15th

We have one last chance left to let the Nuclear Regulatory Commission know we don't want nuclear waste moved across the country for 40 years (or centuries, or de facto permanently) to a supposedly temporary site! They refuse to wait until after the COVID-19 crisis and hold in-person meetings in TX or along the routes to get the waste there.

Please call in on Oct. 15th. TEXANS are asking for AS MANY AS POSSIBLE TO CALL IN

Please Call in to the Nuclear Regulatory Commission's "Public Meeting" on the

draft Environmental Impact Statement for the proposed HIGH LEVEL NUCLEAR WASTE SITE in Andrews TX

Talking points below

Link to 10/15 meeting details/notice: https://www.nrc.gov/pmns/mtg?do=details&Code=20201101

Link to Draft Environmental Impact Statement on which we are commenting https://www.nrc.gov/docs/ML2012/ML20122A220.pdf

Link to the Power Point NRC will use in ENGLISH--https://www.nrc.gov/docs/ML2027/ML20274A035.pdf

Lin to the Power Point en Espanol https://www.nrc.gov/docs/ML2027/ML20274A036.pdf

If you access the Power Point you will not need to connect by computer to the WEBEX webinar site, which can be confusing--it requires you to sign in twice and once you are in you can see the Power Point and follow along changing the slides yourself. So if you download the power point in advance and look at it during the oral presentation by NRC on the phone you don't have to connect via WEB EX or computer.

CALL IN NUMBER (888) 989-9268 Pass Code 5300047# TO get in line to speak PRESS *1 [star-one] and give your name.

The first 30-40 minutes will be a power point presentation by NRC describing that all environmental impacts are small or moderate

[even though it is from bringing in and storing the majority of the radioactivity in the nuclear power and weapons complex...

they won't be mentioning that it's such an enormous part of the nuclear waste generated in the country since the dawn of the nuclear age

but they will tell us it can't possibly have a Large Impact]

Then public comments are usually 3-4 minutes each, but can go up to 5 minutes or longer.

All previous NRC calls have had people who want to speak Push *1 [star-one] to get in the queue. You can do this at any time-the sooner you do it the sooner you get to speak, at least in theory.

The final call-in meeting is:

THURS OCT 15 from 10am-1pm Central Time/11am-2pm Eastern Time (9am-12pm Noon Mountain/8am-11am Pacific)

(888) 989-9268 Pass Code 5300047# TO get in line to speak PRESS *1 [star-one]

Details on each session including WEB EX connection info are at www.nonuclearwaste.org

[It is actually much easier to simply advance the slides of the slideshow oneself, while listening to the audio portion of slideshow presentation via telephone connection. Here are links to the slideshow presentation:

Regarding the presentation slides the NRC staff will use in this Thursday’s meeting, the slides are available in ADAMS and through the NRC’s public website for its review of the Interim Storage Partners license application. You can find them using these links: in ADAMS and the NRC public website.]

TALKING POINTS

Waste Control Specialists/ Interim Storage Partners propose bring in 40,000 Metric Tonnes of irradiated ('spent") nuclear fuel- the hottest waste in the nuclear power and weapons fuel chain....this is the waste from the cores of nuclear power reactors which can give a lethal dose unshielded in minutes and which will stay dangerous for more than 1 million years. The Draft Environmental Impact State for this proposal is here

Illegal-- CIS or Consolidated "Interim" Storage Facilities are illegal under federal law. Under the law, no "interim" or "temporary" storage site is allowed unless there is a final repository is operating...because the site would become de-facto permanent although not designed or licensed for permanent isolation of the waste

EJ- Sending the most deadly waste in the country to communities of color clearly violates Environmental Justice Principles. This region is largely Hispanic. Public Citizen and Lone Star Legal Aid did analyses showing that the people in the region would be disproportionately impacted.

Transport across the country is through poorer communities, often communities of color so the movement of the waste for decades puts them at greater risk--and all of us who travel on roads, rails and waterways and live and work near transport corridors are being put at risk with no input. Requests for public meetings along the routes have been rejected so the project can move quickly despite the COVID 19 crisis hitting the whole country and poorer and people of color more so.

Synergistic effects of other facilities and industries The proposed site is next 2 other operating nuclear facilities--Waste Control Specialists is a burial ground for nuclear waste and LES Urenco enriches uranium using dangerous chemicals. It is also in the Permian Basin home to the largest deposits of oil and gas in North America thus home to oil and gas drilling, fracking and processing.

Effect on Water The TCEQ (TX Commission on Environmental Quality) technical team evaluating the neighboring waste site Waste Control Specialists Texas (WCS) unanimously recommended against the license and TO NOT TO PUT NUCLEAR WASTE THERE BECAUSE THE WATER RESOURCES WOULD NOT BE PROTECTED. The technical experts were ignored and the license granted for political reasons under Governor Bush. This is the SAME SITE targeted for HIGH LEVEL WASTE from nuclear power across the country. The threat to the water cannot be "SMALL" or "MODERATE."

NO DTF Dry Transfer Facility- There is no shielded facility to repackage damaged fuel or containers-- without a fuel pool, the only other option is a Dry Transfer Facility. There is no plan to build a Dry Transfer Facility, or a fuel pool. How can NRC believe there will never be a need to recontainerize aging nuclear fuel that is in aging containers, especially when they are out in the open exposed to severe heat, cold, hail, flooding, tornados, earthquakes, possible wildfires and other extremes.

The ISP Draft Environmental Impact Statement (DEIS) is Misleading, Incomplete and Denies or Ignores Reality. It:

--Fails to assess the additional risk to the country that one or more CIS sites will cause. Not all waste will be moved from all nuclear power reactors sites to ISP/WCS (or to the Holtec site proposed nearby) thus the CIS sites are ADDITIONAL sites requiring massive transport risks, with no guarantee that the sites sending the waste will really be cleaned up.

--Incorrectly assumes only 40 years of storage even though the waste could be at the site far longer than that, potentially indefinitely. The DEIS incorrectly assumes there will be a permanent repository elsewhere, despite the only proposed permanent repository at Yucca Mountain having been rightly cancelled in 2010. The ISP/WCS application does not provide protections for long term or permanent isolation and the DEIS ignores this. The more-likely reality—i.e., that the waste will be at the site for much longer than the 40-year license period—is not addressed in the DEIS. This puts the air, water, soil and ecosystem at long term risk from radioactivity.

--Incorrectly assumes all waste and containers that arrive will be intact and waste will not need to be re-containerized for the decades it will remain at the WCS ISP site. The DEIS fails to address what happens when waste must be repackaged. The application and the DEIS should require a wet or dry transfer facility to shield the intensely radioactivity so it can be repaired or transferred to new containers. Workers, passers-by and the environs could receive massive, potentially lethal, gamma doses in that scenario--yet no assessment is provided in the DEIS.

--Fails to address the environmental impacts of returning damaged containers of high-level radioactive waste if they arrive in unacceptable condition. ISP’s plan is to "return to sender" with no analysis of the logically higher risk of transporting failed fuel and/or containers twice.

--Ignores potential higher risks from damaged fuel and high burnup fuel.

--Fails to acknowledge or respect the institutional racism in selecting the ISP WCS site in West Texas.

--Fails to acknowledge impacts on all transport routes to the site. I call on NRC to hold in-person DEIS meetings all along the potential routes and to extend the comment period until six months after the COVID-19 crisis ends.

Talking Points / Risks / Key issues from SEED COALITION

HALT LICENSING NOW!
This deadly waste shouldn’t be shipped across the country to be dumped in the Southwest for decades... perhaps forever.
Fails to get the waste into a permanent repository
Could hamper efforts to develop less risky storage systems and permanent disposal
This waste must be isolated from living things for a million years. Consolidated Interim Storage is a band-aid approach that makes matters worse, not better.
It would be massive environmental injustice
Health and safety risks from potential contamination
Transportation risks - accidents, leaks, sabotage, and even routine transport emissions, which the NRC calls "less than a chest X-ray"
Impacts to water, air, soil - WCS site is near the Ogallala Aquifer - the nation's largest aquifer
Financial risks - could cost billions of dollars to remediate contamination
Lack of a dry cask transfer facility - so there would be no way to repackage cracked or leaking canisters
The region has temperature extremes, wildfires, intense winds, flooding - not safe for radioactive waste.
Earthquakes and radioactive waste don't mix
Impacts to businesses - the Permian Basin region is the largest oil-producing region in the world.
Heavy trains, train traffic, lack of safety training and equipment, Lack of full-time paid fire departments in many areas.
Consolidated Interim Storage is ILLEGAL under the Nuclear Waste Policy Act.... NRC has no business processing this license application by Waste Control Specialists (WCS) / Interim Storage Partners (ISP) for Texas - or the Holtec application for nearby New Mexico.
Resolutions opposing nuclear waste dumping and transport have been passed by Dallas, Bexar, Nueces, Midland and El Paso Counties, and the cities of San Antonio, Midland and Denton, plus the Midland Chamber of Commerce. This represents the voices of 5.4 million Texans.
These inadequate webinars make a mockery of "public meetings". The NRC must schedule real, in-person public meetings after Covid risks are over - in Dallas/Ft. Worth, Houston, San Antonio, El Paso, Midland and Andrews in Texas and along transport routes across the country. The comment period should remain open until this is accomplished.