Beyond Nuclear - Centralized Storage

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:

Stringent Criteria for a Highly Radioactive Waste Geologic Repository; 1,000+ organizations opposed to the Yucca dump targeted at Western Shoshone land in NV.

Please take into consideration the list of "Stringent Criteria for a Highly Radioactive Waste Geologic Repository," which I prepared several months ago, below. In order to legitimately open a safe, sound, publicly accepted permanent geologic repository, one that is protective of health, safety, and the environment, DOE will need to identify a location that meets all of these stringent criteria, and, as mentioned at the end, perhaps others yet to be identified.

Actually, not DOE -- but a replacement agency or institution. For, just as consent-based siting was listed as a top final recommendation by the Blue Ribbon Commission on America's Nuclear Future Final Report in Jan., 2012, so too was replacement of DOE in this role, as DOE has garnered so much public distrust over these and related matters, that the damage to trust is permanent and irreparable, and DOE must be replaced. (Of course, much the same could be said of NRC, as well.)

I provide this listing, as promised in earlier comments I've submitted in this proceeding, in order to show that the proposed Yucca Mountain, Nevada dump-site violates many, to most, to all of these criteria. But not only should Yucca Mountain be removed from any further consideration for a permanent dump-site, it will be removed. Why? Because the Western Bands of the Shoshone Nation of Indians, the State of Nevada, and more than a thousand environmental, environmental justice, social justice, and public interest organizations, representing many millions of American members, demand it, just as they have for 33 years and counting, ever since passage of the infamous "Screw Nevada" Act of 1987, the Nuclear Waste Policy Amendments Act of 1987, which singled out Yucca Mountain as the only site in the country for further consideration as a permanent repository. Beneath the following "Stringent Criteria" listing, I have also included a partial listing of the 1,000-group+ environmental, justice, and public interest coalition, representing every state, that is adamantly opposed to the Yucca dump.

Thus, for all of these reasons, ISP/WCS's and NRC's assumption that Yucca Mountain will someday become a permanent repository, is bogus, illegal, erroneous, and improper. Neither ISP/WCS nor NRC can justify calling this proposed CISF "temporary" or "interim." If it is licensed, constructed, and operated, it will certainly become very long-term surface storage, likely indefinite, and perhaps even de facto permanent -- a surface storage/disposal parking lot dump.

Citations:

Stringent Criteria for a Highly Radioactive Waste Geologic Repository

(posted online at: <http://archive.beyondnuclear.org/repositories/2020/5/26/stringent-criteria-for-a-highly-radioactive-waste-geologic-r.html>;

1,000+ organizations opposed to the Yucca Mountain dump targeted at Western Shoshone Land in Nevada

(posted online at: <http://archives.nirs.us/radwaste/yucca/yuccaopponentslist.htm>).

(both documents are reproduced in their entirety, below)

Of course, transporting high-risk, high-level radioactive waste once, instead of multiple times, makes good sense. Thus, CISFs make no sense. Irradiated nuclear fuel should be transported only once, from the nuclear power plant sites where it is currently located, to a permanent repository. But that permanent repository must meet all of the stringent criteria listed above. Yucca Mountain cannot do so. Therefore, Holtec and NRC should stop illegally and improperly assuming it will do so. If Holtec and NRC refuse to stop, then Yucca dump opponents -- the Western Shoshone, the State of Nevada, and more than a thousand environmental and public interest groups, representing many millions of people -- will see to it that ISP/WCS and NRC are stopped, just as the adamant resistance to the Yucca dump has stood strong for 33 years, and counting.

So, for the irradiated nuclear fuel that already exists, geologic isolation, at a site meeting all the stringent criteria above, is the preferred alternative to ISP/WCS's CISF in TX, a mere 0.37 miles from NM.

For the irradiated nuclear fuel that does not already exist, the preferred alternative to ISP/WCS's CISF, is to not generate it in the first place. Dangerously age-degraded reactors should be shut ASAP for safety's sake alone. Proposed new reactors should be cancelled, and no new reactors built in the future. The electricity supply for replacing these shutdown old, and cancelled proposed new, reactors should be provided by energy efficiency and conservation savings in the first place, and any newly or otherwise needed electricity should be provided, instead of by nuclear power, by ever more clean, safe, secure, reliable, and affordable renewable energy, such as by solar and wind power.

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,

Kay Drey, President, Board of Directors, Beyond Nuclear

and

Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear