Wednesday
May272020
Additional Background Information, on demanding public comment mtgs. across US on transport routes to CISFs
ADDITIONAL BACKGROUND INFORMATION
Earlier this month, the U.S. Nuclear Regulatory Commission (NRC) opened its public comment period on the Waste Control Specialists, LLC/Interim Storage Partners (WCS/ISP) Draft Environmental Impact Statement (DEIS). The WCS/ISP consolidated interim storage facility (CISF) for commercial irradiated nuclear fuel and other highly radioactive waste (such as Greater-Than-Class-C "low-level" radioactive waste), if constructed and operated, would "temporarily store" (for decades, centuries, or perhaps even de facto permanently) up to 40,000 metric tons of high-level radioactive waste (HLRW). But this of course would entail shipping such wastes, from the nuclear power plant sites where they are currently located, across most states in the Lower 48, to Andrews County, west Texas, right on the New Mexico border. (90% of reactors and HLRW are in the eastern half of the U.S. 75% are east of the Mississippi River.)
On March 20, 2020, NM's U.S. congressional delegation made similar demands of NRC, within the unwilling "host" state itself, in the Holtec International/Eddy-Lea Energy Allliance (Holtec/ELEA) CISF DEIS public comment proceeding. That proceeding is very closely related in so many ways to this WCS/ISP CISF DEIS public comment proceeding. In fact, the two proposed dumps are but 39 miles apart, across the NM/TX state line. Holtec CEO Krishna Singh even said, at his CISF license application launch press conference on Capitol Hill a couple-three years ago, that he sees WCS/ISP's CISF as complementary to his own, not as a competitor. We are fortunate that NM's delegation is so strong and active on such a critical fight. Their traction shows that congressional demands are taken seriously by NRC (which granted a extension to the public comment period in response), even when the agency attempts to ignore citizens' concerns. But we've not (yet anyway) seen such an effort by TX's congressional delegation. Hopefully, that will still happen, with enough constituent pressure. And it would be great for Members of Congress in other states to also make such demands, in congressional districts and states along the inevitable HLRW transport routes across the country.
Despite the national pandemic emergency, NRC's countdown clock for public comments continues to tick away, toward the current Sept. 4th deadline. We must take action now.
And despite the nationwide high-level radioactive waste transport risks (Mobile Chernobyls on the rails and roads, Dirty Bombs on Wheels in terms of security risks, Floating Fukushimas in terms of barge shipments on waterways, and even Mobile X-ray Machines That Can't Be Turned Off risks of "routine," hazardous gamma- and neutron-radiation emissions, even during "incident-free" shipments), NRC has planned only a small handful of public comment meetings, exclusively in the immediate vicinity of the WCS/ISP CISF (these planned meetings are currently postponed due to the pandemic, or will be held by webinar/call-in). But what about the 44 other states (or more) that would see TX-bound HLRW shipments roll through by truck, train, or barge? Why doesn't NRC plan to hold meetings along transport routes, once safe to do so again, post-pandemic?
It appears that NRC has bowed to pressure from CISF proponents, who have called for the unwilling "host" state in-person public comment meetings to be replaced by mere webinars/call-ins. But the NM US congressional delegation, in the context of Holtec/ELEA, will not back down from its demand for in-person public comment meetings, once safe to do so, across the Land of Enchantment. NRC dare not deny that demand. Will the TX US congressional delegation stand up for its constituents, and also demand of NRC, in-person public comment meetings, once safe to do so, in the context of the WCS/IPS CISF DEIS?
But NRC, in an April 21st letter, in the context of Holtec/ELEA, has added but a single webinar public comment opportunity, for the rest of the country outside NM along the high-risk transport routes! NRC currently plans zero in-person public comment meetings, in 44 or more states, thus impacted! Will NRC attempt to get away with the same short changing of the American public in the WCS/ISP CISF DEIS public comment proceeding?!
What states, cities, and U.S. congressional districts, will these Mobile Chernobyls pass through, you ask? NRC, in its Holtec DEIS, has cited a 2008 DOE Final Supplemental EIS re: Yucca transport routes. (WCS/ISP, being only 39 miles away from Holtec, will thus use almost identical transport routes nationwide.) The State of NV Agency for Nuclear Projects' has carefully -- and helpfully! -- analyzed that very document. See its road and rail route maps, and shipment numbers, here:
- Nevada Agency for Nuclear Projects - Representative Transportation Routes to Yucca Mountain and Transportation Impacts (Cask Shipments by State) - Fred Dilger PhD
- Nevada Agency for Nuclear Projects - Cities Potentially Affected by Shipments to Yucca Mountain (pdf-2.45M)
- Nevada Agency for Nuclear Projects - States Potentially Affected by Shipments to Yucca Mountain with Congressional Districts (pdf-7.05M)
- Nevada Agency for Nuclear Projects - Congressional Districts Potentially Affected by Shipments to Yucca Mountain - 115th Congress (pdf-882K)
For its part, NRC has not provided a single route map in its DEIS! And for its part, Holtec provided a sole route map in its license application Environmental Report (LA ER). ISP/WCS has provided an almost identical single route map in its LA ER. But Holtec's and ISP/WCS's almost identical route maps account for only four (one in Maine; three in southern California) of the 131 atomic reactors in the U.S.! What about the other 127 reactors in this country?! NRC is being even more secretive than Holtec and WCS/ISP, in the attempt to keep the impacted public in the dark across the country!
As if road and rail routes weren't enough to worry about already, check out potential barge routes on surface waters from coast to coast!
Two decades ago, during the U.S. Department of Energy's (DOE) Yucca Mountain, Nevada HLRW dump DEIS (targeted at Western Shoshone land), over the course of a hard-won 199-day public comment period, DOE ultimately held two-dozen public comment meetings, including in a dozen states outside of NV. Again, Yucca's capacity limit is 70,000 metric tons of irradiated nuclear fuel and high-level radioactive waste. WCS/ISP has applied for permission to "temporarily store" 40,000 MT in TX.
On March 25, 2020, 50 anti-nuclear, environmental, EJ, social justice, and public interest groups also wrote NRC, urging a 199-day public comment period in the Holtec/ELEA CISF DEIS proceeding.
A coalition of environmental groups is similarly urging that this WCS/ISP DEIS have the equivalent 199-day public comment period, and have at least half the number of public comment meetings, including along transport routes outside of TX, as Yucca did 20 years ago, including outside of NV.
Currently, even NRC's now 120-day public comment period, ending Sept. 4th, in this WCS/ISP DEIS proceeding, falls far short of the requested duration.
In the Holtec/ELEA proceeding, the 50-group coalition also called for the public comment proceeding to be kept open throughout the pandemic, for all the called-for, in-person public comment meetings to still take place once safe to do so, and for the 199-day public comment deadline clock to not commence until post-pandemic, once safe to do so after the end of the current national emergency, such as when an effective vaccine is available for all U.S. residents.
Instead, NRC plans to let the clock run during, and despite, the deadly pandemic.
The environmental coalition's requests are very reasonable. After all, Holtec's CISF represents 2.5 times more HLRW than the Yucca scheme (173,600 metric tons, versus 70,000 MT). WCS/ISP's represents half again as much HLRW as the Yucca scheme (40,000 MT, v. 70,000).
But we are also being backed up by 24 Democratic U.S. Senators (including five who were campaigning for the presidency up until recently); see their April 8th letter to the White House Office of Management and Budge (OMB), here.
And we are being backed up by 14 Democratic U.S. House of Representatives committee chairmen; see their April 1st letter to OMB, here.
Given all that, please help us secure more in-person public comment meetings, by urging both your U.S. Senators, and your U.S. Representative, to demand one from NRC in your state/congressional district, once safe to do so. At the same time, urge your Congress Members to demand NRC keep the public comment period open indefinitely, and to only start the 199-day public comment period countdown clock once the national pandemic emergency is over, and in-person public comment meetings are once again safe to hold.
You can call your U.S. Congress Members' D.C. offices via the U.S. Capitol Switchboard at (202) 224-3121. You can also email, webform, fax, and/or snail mail your request to your Congress Members' D.C. and/or in-state/district offices. Here is a sample script you can use as is, or feel free to edit it:
"Dear Senator/Representative X, please contact NRC [U.S. Nuclear Regulatory Commission] and demand that a WCS/ISP, TX CISF DEIS [Consolidated Interim Storage Facility Draft Environmental Impact Statement] public comment meeting be held in our state/district, once safe to do so. Also demand that the public comment period be kept open indefinitely, and that a 199-day public comment period countdown clock commence only after it is safe to once again hold in-person public comment meetings. Given the high risks of high-level radioactive waste trains, trucks, and barges, and the fact that WCS/ISP's CISF would ship and store more than half the High-Level Radioactive Waste (HLRW) volume as the Yucca Mountain dump scheme in Nevada, targeted at Western Shoshone land (40,000 metric tons, versus 70,000 MT), it is only proper that NRC hold at least half as many meetings along transport routes, and an equally long comment period, as did DOE [U.S. Department of Energy] on Yucca 20 years ago. As it stands, NRC's still too short 120-day comment period ends on Sept. 4th, and only a handful of meetings would be held, all in just the immediate vicinty of the unwilling 'host community' of west Texas. Given the accident and attack risks of Mobile Chernobyls, Dirty Bombs on Wheels, and Floating Fukushimas, and even the 'incident-free' Mobile X-ray Machines That Can't Be Turned Off risks of 'routine' shipments, adequate time, and numbers of meetings across the U.S., for public comment, are vitally needed. And given the environmental justice burden that high-level radioactive waste shipments would represent -- as attested to by none other than Mustafa Ali, former head of EJ at US EPA, on Democracy Now! last September -- public comment meetings must be held in transport corridor communities nationwide, including in our state. Please demand this of NRC, on behalf of your constituents."
Please spread the word! Working together, we can win the dozen, in-person public comment meetings, in a dozen states outside TX, that we are due, based on the hard-won DOE/Yucca precedent set 20 years ago! Thank you for taking action to defend Mother Earth!
Update on July 15, 2020 by
admin
admin
U.S. Representative Lloyd Doggett (TX-35th) wrote NRC, urging public comment meetings across the Lone Star State be delayed until after the pandemic emergency -- currently raging in Texas -- ends, and the public comment period be held open until after the in-person meetings are completed, including in his congressional district.
Similarly, U.S. Rep. Jamie Raskin (MD-8th) has written NRC, urging the comment period be extended "throughout the duration of the pandemic," and to end it "no sooner than six months after this FEMA-declared emergency has passed."
Since March 20th, the united New Mexico U.S. congressional delegation has stood strong in its demand that NRC hold five in-person public comment meetings across the Land of Enchantment -- which inevitably will mean an extension to the current Sept. 22nd deadline in the Holtec CISF proceeding, in order to accommodate them.
Such calls are also being backed up by 24 Democratic U.S. Senators (including five who were recently campaigning for the presidency); see their April 8th letter to the White House Office of Management and Budget (OMB), here.
And we are also being backed up by 14 Democratic U.S. House of Representatives committee chairpersons; see their April 1st letter to OMB, here.
Both congressional letters in early April demanded that the White House Office of Management and Budget suspend public comment and participation periods, in light of the pandemic emergency.
Instead, thus far, NRC has attempted to ram through the CISF public comment periods, exploiting or taking advantage of the pandemic emergency in order to do so.