Centralized Storage
With the scientifically unsound proposed Yucca Mountain radioactive waste dump now canceled, the danger of "interim" storage threatens. This means that radioactive waste could be "temporarily" parked in open air lots, vulnerable to accident and attack, while a new repository site is sought.
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Entries by admin (702)
November 3, 2020Beyond Nuclear's 27th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Responses to statements made by ISP proponents during the first NRC call-in public comment session on Oct. 1, 2020
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:
Responses to statements made by ISP proponents during the first NRC call-in public comment session on Oct. 1, 2020
On Oct. 1, Jay Thomas of Orano Group International -- a lead company in the ISP scheme -- tried to soothe concerns about the high risks of irradiated nuclear fuel transportation, by saying that up to a year's time is invested in preparing a shipment for transport.
If that's the case, then ISP's proposed 3,400 shipments could take a grand total of 3,400 years to prepare before shipments commence, all told?! That's a bit longer than NRC's arbitrarily and capriciously short 40-year scope in the DEIS!
Jay Thomas also boasted about the testing done on shipping containers. But computational model analysis and scale-model testing is not the same as full-scale physical safety testing to destruction.
And Jay Thomas's mere mention of "Tribal Nations" reveals the EJ burden of irradiated nuclear fuel shipping to the proposed ISP CISF.
But neither ISP in its Environmental Report, nor NRC in its DEIS, has even identified Native American reservations that would be impacted by ISP-bound shipments.
Fortunately, the State of Nevada Agency for Nuclear Projects has done such EJ analysis work:
State of Nevada - Measures of Community Impact for The Transportation of Hazardous Materials: The Case of Indian Tribes and High-Level Nuclear Waste -- Conference Paper - Waste Management 2005 - Fred Dilger, Robert Halstead, James David Ballard (pdf-1.24M)
Although the case study is in the context of Yucca Mountain, NV-bound shipments, it must be pointed out that the further from the American Southwest the origin site, the more similar to identical shipment routing would be, whether bound for Yucca Mountain, NV, or ISP, TX.
Also on October 1st, Edward Davis of the Nuclear Industry Council, another ISP proponent, boasted about WIPP shipments as some kind of sign as to how swimmingly ISP shipments would also go. He left out the Valentine's Day, 2014 "impossible leak" at WIPP however. A barrel burst in the WIPP underground, leading to an environmental release of TRU; a couple-dozen workers at the surface exposed to ultra-hazardous TRU alpha particle inhalation doses; a three-year shutdown of the site; and a cost of $2 billion in recovery expenses. Significantly, that burst barrel happened in the WIPP underground, rather than during the shipment from Los Alamos to WIPP. If that barrel had burst during transit across NM, the consequences could have been even worse.
Incredibly, in the aftermath of the WIPP barrel burst, Los Alamos and its contractor nonetheless rushed a large number of additional potentially bursting barrels to WCS in TX. WIPP would not accept them, nor could WIPP accept them, then being shut down by the barrel burst. So, in order to keep to its arbitrary schedule, so that it wouldn't lose out on milestone bonuses, a large number of potentially bursting barrels were rushed down to WCS, for no good reason. To show how dangerous that Los Alamos to WIPP shipment was, some of those potentially bursting barrels are still to this day, nearly nine years later, still stuck at WCS. Why? Because they are still too dangerous to ship on to WIPP, now re-opened. That distance is "only" about 40 miles or less. And yet, Los Alamos and its contractor, as well as WCS, conspired to take the very high risk of shipping that large number of potentially bursting barrels 350+ iles, from Los Alamos to WCS, so that all the companies involved could make a buck. Thank goodness none of those potentially bursting barrels bust while in transit. If a burst 2,000 feet below ground cost $2 billion to recover from, how much would a burst at the surface during transport cost to recover from? How many workers, emergency responders, and downwind/downstream residents would have been harmed?!
Mr. Davis's boasting about WIPP's safety record on transport was thus incomplete and inapt.
Also on Oct. 1, Jack Edlow, another IPS proponent (who would make a fortune on being the transport middleman, as CEO and President of Edlow International) said that rail shipments through Takoma Park, MD would never happen. He said this in response to my own prior testimony, naming me by name, stating that I was mistaken about the likely shipments impacting my very own office located there, as well as those who live in adjoining condos and houses, as well as those waiting for Metro trains on the adjacent tracks at Takoma Metro Station. But I must set the record straight.
Dr. Fred Dilger, commissioned by the Nevada State Agency for Nuclear Projects, has documented this Takoma Park, MD rail route. See Page 19 of 45 on the PDF counter for a map <http://www.state.nv.us/nucwaste/news2017/pdf/States_Affected.pdf>, showing the Calvert Cliffs nuclear power plant irradiated nuclear fuel rail route through Takoma Park, MD.
Page 7 of 45 on the PDF Counter in the same document linked above, for rail shipping routes through the District of Columbia. It shows not only the Calvert Cliffs export route through Takoma Park, but also shows a North Anna export route traversing Washington, D.C., before then also passing through Takoma Park.
Page 41 of 45 shows the North Anna rail route, passing through the heart of the nation's capital (very close to the U.S. Capitol Building, actually), before then also passing through Takoma Park, MD.
Page 20 of 20 on the PDF counter in this document <http://www.state.nv.us/nucwaste/news2017/pdf/Cities_Affected.pdf> also shows these Mobile Chernobyl rail routes that pass through the D.C. metro area, including Takoma Park, MD.
Here is the full package of Dr. Dilger's routing analyses, including a statement of methodology:
2017 - - - - - - - - - - - - - - - -
- 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)
I'm not sure which is worse. Jack Edlow, who touts himself as an international expert on highly radioactive waste transportation, not knowing any of this, but erroneously asserting strongly that I was mistaken in my comments. Or that he does know this information, but is intentionally deceiving the public by denying it. It's all the harder to understand how Jack Edlow does not know about these D.C. and MD and VA suburbs transport routes, when he himself has been long based in the D.C. area, conducting his radioactive waste and nuclear materials transportation business, including advocating for the opening of dumps out West, so he and his company can make hundreds of millions of dollars, or billions of dollars, or more, by being involved in those shipments.
Edlow also mentioned his experience with irradiated nuclear fuel shipments from Iraq, Ghana, Nigeria, and Colombia, back to the U.S. This begs the question, are those foreign origin irradiated nuclear fuel assemblies ultimately bound for the CISFs in NM (Holtec) and TX (ISP)? This is the very question Don't Waste Michigan et al.'s expert witness, Dr. David Ballard, asked during the environmental scoping and ASLB licensing proceeding stages, after all. He asked it because the grand total of inventory at the CISFs of 213,600 metric tons (173,600 at Holtec, 40,000 at ISP) is far and away larger than the entire commercial irradiated nuclear fuel and high-level radioactive waste inventory in the U.S. will ever be. So the question is begged, will foreign wastes be imported to the TX and/or NM CISFs? Will military wastes?
As posted Nov. 29, 2018 at Beyond Nuclear's website, here again is Ballard's expert witness work, linked, which NRC has largely to entirely ignored thus far:
Expert witness declarations by James David Ballard, Ph.D., re: high-level radioactive waste transport risks
Expert witness declaration by James David Ballard, Ph.D., Professor, Criminology and Justice Studies, California State University, Northride, "Holtec HI-STORM UMAX Interim Storage Facility (a.k.a. CISF): Human-Initiated Events (HIE), Transportation of the Inventory, and Storage of Highly Radioactive Waste Materials."
The declaration was filed on September 14, 2018, as part of a legal intervention against the Holtec International/Eddy-Lea Energy Alliance CISF in New Mexico by legal counsel Terry Lodge on behalf of a seven-group grassroots environmental coalition.
This declaration was filed on November 13, 2018, as part of a legal intervention against the Waste Control Specialists/Interim Storage Partners CISF in Texas, by legal counsel Terry Lodge on behalf of a seven-group grassroots environmental coalition.
Edlow also mentioned air transport. Was he referring to irradiated nuclear fuel being air transported? Is this even legal? Aren't there prohibitions against the air transport of plutonium in the U.S. Isn't irradiated nuclear fuel at least 1% plutonium in composition? Did Edlow International violate the law, with the air shipments of irradiated nuclear fuel Edlow mentioned and boasted of having conducted? Were the irradiated nuclear fuel assemblies transported by air contained in containers capable of withstanding the forces of an air crash, such as impact on hitting the ground, and even the possibility of a long temperature, high duration fire, as due to the airplane's fuel igniting on impact?
Edlow stated during his comment that "routing is yet to be determined," and that it would "avoid heavily populated areas." ISP opponents like Don't Waste Michigan et al. in their licensing proceeding intervention, and Beyond Nuclear in its environmental scoping and DEIS comments, have strongly contested this notion that "routing is yet to be determined," and that "heavily populated areas" would be avoided. Just look at these 20 case studies by Dr. Dilger:
http://www.state.nv.us/nucwaste/news2017/pdf/Cities_Affected.pdf
That's 20 major urban areas of heavy population density right there, that would be crisscrossed by irradiated nuclear fuel shipments. Granted, Dilger's report is in the context of the Yucca Mountain dump. But as mentioned previously, the further from the American Southwest the origin site, the more similar to identical the shipping routes, whether shipments are bound for Yucca Mountain, NV, or ISP, TX.
Dilger cites the same 2008 DOE Yucca FSEIS that NRC does in this DEIS, making Dilger's routing maps entirely appropriate and relevant for me to raise here.
And check out these barge routes that DOE admitted to in its Feb. 2002 Yucca FEIS:
That documents additional heavily populated centers along potential barge shipping routes that could be used in the ISP scheme.
Again, it is frightening if Edlow is ignorant of all this. I doubt that he is. Rather, I think he is attempting to keep the impacted public in the dark for as long as possible about the shipment routes, even though they are very knowable right now, and long have been.
But NRC itself is complicit in such deception and secrecy. Which is itself very frightening. After all, the Japanese Parliament concluded in 2012 that the root cause for the Fukushima Daiichi nuclear catastophe was collusion between industry, government regulatory ageny, ad elected officials. NRC's complicity with ISP and Edlow International, to keep knowable shipment routing obscured for as long as possible, shows that such potentially catastrophic nuclear collusion exists here too. Such obscurantism is a violation of NEPA's hard look, public disclosure, and public participation requirements.
But even ISP itself reveals heavily populated urban centers that would be impacted by its shipments. See Figure 2.6-1, Transportation Routes, on Page 2-78, in Chapter 2, of ISP's ER. Although this route map accounts for only 4 atomic reactors out of 131 in the U.S. (one at Maine Yankee, and three at San Onofre CA), it nonetheless shows many heavily populated urban areas in the country impacted by ISP shipping. To name but a few examples, of many: Cleveland; Toledo; South Bend; Kansas City; Oklahoma City; Tulsa; Dallas; Fort Worth; El Paso; Denver; Salt Lake City; Las Vegas. Of course, if shipments from the other 127 reactors in the country were also accounted for, then many other heavily populated urban areas would be revealed to be impacted as well.
Note that for NM, TX, and OK, the inbound shipment route is overlapped by the outbound shipment route, when ISP exports its inventory to Yucca Mountain, NV. Thus, those heavily populated urban areas in TX and OK would be hit, coming and going.
Obviously, Edlow's comments were false. And yet NRC facilitator Chip Cameron saw fit to say "Thank you, Ed," for commenting about "routes not having been determined yet." This was inappropriate for Cameron to say. Don't Waste Michigan et al. in its licensing proceeding intervention, as well as its environmental scoping and DEIS comments, have strongly challenged any such notion that "routes have not been determined yet." It was yet another instance of Cameron revealing his bias in favor of the CISFs. For example, during a Holtec CISF DEIS call-in session, Cameron told a member of the public, and CISF opponent, Nick Maxwell, what subject matter he could not speak about, before allowing him to speak. Myself, as well as Ed Hughs, objected in real time to Cameron's inappropriate censorship of Maxwell. Another example was Cameron's cutting off CISF opponent Noel Marquez during Holtec CISF environmental scoping in-person public comment meeting in Carlsbad, NM, in May 2018, before Marquez's allotted time had expired. Cameron even approached the podium in a menacing manner, physically, as if he were about to seize the microphone away. Again, myself, and others in attendance, protested Cameron's behavior in real time. These examples of Cameron's misbehavior and clear revelation of bias are outrageous and objectionable. They are akin to Tony Hsia's pep rally speech to conclude a Spent Fuel Project Office regulatory conference several years ago, when he shouted "Together we can get this done!" while fist bumping the air. By we, Hsia meant NRC and industry. By this, he meant CISFs. I have objected to Hsia's words in previous comments.
At this Oct. 1st call-in session, dump opponents outnumbered dump proponents by a count of 30 to 4, in terms of those who made verbal public comments. All 4 dump proponents were industry representatives, looking to make money from the ISP scheme.
Please address the subject matter above, re: our many objections to NRC's outrageous conduct of this ISP/WCS CISF public comment proceeding.
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,
Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear
Beyond Nuclear's 26th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Responses to NRC's call-in public comment sessions
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:
Responses to NRC's call-in public comment sessions
As we have commented previously, the summary (variously referred to by NRC as the "Overview" or the "Reader's Guide"), mentioned in NRC's slideshow presentation during the public comment call-in sessions, contains a glaring error, which in fact contradicts the DEIS itself. The Reader's Guide/Overview states that the Private Fuel Storage, LLC CISF license, targeting the Skull Valley Goshutes Indian Reservation in Utah, has been terminated. But this is a false statement. The license has not been terminated. PFS's request to terminate the license was withdrawn.
Also, the 40-year scope of the DEIS, we have also protested in previous comments.
The reasonably foreseeable need for a Dry Transfer System (DTS), from day one at ISP, makes NRC's decision not to require one, and ISP's decision not to voluntarily build one, all the more outrageous. It is reasonably foreseeable that a problem cask, whether one just arrives from off-site, or one that has degraded after decades of "temporary" storage on-site, would need to have a DTS available, to handle the emergency situation. The emergency situation could be very fast-breaking. There would be no time or ability to instantly construct a very expensive and complicated DTS, ad hoc, willy nilly, thus making a fast-breaking emergency situation all the worse.
Also during the call-in session introductory slideshows, James Park of NRC claimed there is no liquid in the canisters. But what about the water remaining inside the canisters? Vacuum drying the inner canisters when they are loaded with irradiated nuclear fuel in wet storage pools does not get out all the water. There is at least a trace amount left, sealed within the then welded shut or otherwise sealed inner canister.
And what about tritium? There is certainly a significant amount of tritium present in irradiated nuclear fuel. In fact, tritium is able to escape straight through the wall of certain grades of steel. The metallurgy of the steel is incapable of containing the very small tritium molecules, which pass straight through the steel wall. And could not tritium combine with oxygen to form tritiated water molecules inside the canister? While escape of tritium in gaseous or vapor form is bad enough, so too would be escape of tritiated water.
As the irradiated nuclear fuel cools over time, the condensation of water (tritiated or not) within the canister could initiate a corrosion risk, eating from the inside-out.
Also, there is a significant risk that surface (as due to extreme rainfall flooding) and/or groundwater could interact with the irradiated nuclear fuel containers, introducing infiltrating water into the container. In that way, liquid in the canisters -- which James Park denied was or even could be a problem -- could well become a problem. Not just in terms of corrosion potential, but even in terms of criticality risk. If a critical mass were to form in the irradiated nuclear fuel -- as by fuel failure, creating a pile of irradiated nuclear fuel debris on the bottom of the container, right where water would/could itself build up -- infiltrating or accumulating liquid water could spark an inadvertent criticality. This would be an extreme risk for health, safety, and environment, and could have extreme consequences.
NRC's slide show presentations claimed that less than 30,000 scoping comments were received. But by our coalition's own count, actually more than 45,000 comments opposed to the CISF were generated during the environmental scoping phase alone.
Now for a word on technical issues with the NRC's process itself. I gave up on regulations.gov two years ago, during the CISF environmental scoping phase, when regulations.gov was dysfunctional more often than it was functional. I've submitted written comments entirely by email in both CISF DEIS proceedings. In the Holtec proceeding, I had many problems with the email as well. I registered this with NRC staff at the time. The problems were eventually resolved. But I had to wonder how many others were similarly hitting a brick wall with NRC's Holtec submission email address. And sure enough, I learned from colleagues that the Holtec regulations.gov page was also not working on multiple occasions. Such dysfunctions with the regulations.gov and email address are a form of suppression of public participation rights under NEPA. The burden should not be on the public to have to constantly inform NRC its systems are not working properly. And yet, that has been our experience, time after time.
And sure enough, I just learned from a colleague today, who had his emails rejected by the ISP DEIS NRC email. He eventually succeeded in submitting it via regulations.gov. But again, the public should not hit brick walls when submitting comments to the very email address NRC has provided for this purpose.
Similarly, I stopped trying to make NRC's WebEx work on my laptop computer. I would simply phone into the call-in, and follow along during the NRC slideshow presentation, by listening to the audio via the phone line, while scrolling through a copy of the slideshow I'd downloaded onto my computer. Again, such Rube Goldberg Machine workarounds, because of the complexity or dysfunctionality of the NRC's own systems, makes for more burdens on the public.
During the slideshow presentations, James Park verbally said out loud that a person, at 100 feet distance, passed by every single one of the 3,400 irradiated nuclear fuel casks bound for ISP, would receive only a 1.09 milli-Rem dose of radioactivity, altogether. First of all, the written text in the slideshow said 1.9 mR. So which is it? 1.09 or 1.9? Because the latter figure is nearly twice that of the former. Which is mistaken, James Park's verbal statement, or the written figure in the slideshow itself?
But besides that, what about if that person were closer than 100 feet away? The radiation dose would increase significantly, the closer the person got to the shipping containers, correct? NRC's regulations allow for a dose of 10 mR/hr, at a distance of 6.6 feet. At the shipping container surface, a dose of 200 mR/hr is allowed.
Also, it seems NRC's assumption is that those 3,400 shipments would continue to roll on past that hypothetical person, without ever stopping, pausing, idling, etc. in front of them.
The longer the shipment takes to pass by the person, the higher the dose to the person, right? These are like Mobile X-ray Machines That Can't Be Turned Off. The longer they linger nearby, the higher the exposure dose.
And what if one or more of those shipments is externally contaminated? Orano (formerly Areva) had a terrible problem with severely contaminated shipments in the 1990s in France. One-quarter to one-third of all shipments inbound to La Hague for reprocessing (amounting to several hundreds of shipments) were externally contaminated above permissible dose rate levels. On average, these contaminated shipments exceeded permissible dose rates 500-fold. In one case, the exceedance was 3,300-fold.
So NRC has made a number of optimistic assumptions, in order to arrive at its figure of 1.9 mR dose to a person passed by every single one of the 3,400 shipments en route to ISP, at a distance of 100 feet. How about if that person is closer to the shipping container than 100 feet? What if the shipment pauses for an extended period of time, further exposing the person? What if the shipment is externally contaminated? NRC should do the "hard look" at all these real world risk possibilities.
As I've commented elsewhere, there is evidence that people, members of the public, can get much closer to train cars than 100 feet away. Just look at all the graffiti on the sides of train cars, for example.
And what about the scenario of a car stopped at a railroad crossing by a train hauling irradiated nuclear fuel. What if the lead car, closest to the tracks, includes a pregnant woman in the front seat? She and her fetus are much closer than 100 feet to the passing train car hauling irradiated nuclear fuel, correct? What if that train car comes to a pause right in front of her, for an extended period? What if that side of the container holding the irradiated nuclear fuel is externally contaminated? What if the radiation shielding on that side of the container is flawed or damaged? NRC must address such real world risks. For, it has been known since the pioneering work of Alice Stewart et al. in the 1950s that a single X-ray to the fetus increases the baby's risk of cancer by 50%. These are very significant risks that NRC has done little to no analysis about.
NRC said in its slideshow presentations that "No accidental release of canistered fuel [would occur] under the most severe impacts studied." So NRC has simply assumed safety? Isn't that convenient, to ISP's (and NRC's for that matter) purposes? There are any number of real world severe accident possibilities that could breach a shipping container and release significant amounts of hazardous ionizing radioactivity. These could include long lasting, high temperature fires; long lasting, deep underwater submersion; powerful explosions, whether accidental or intentional. The list goes on.
To make matters worse, industry and NRC whistleblowers have documented widespread quality assurance violations associated with the design and fabrication of shipping and storage casks and canisters. Thus, the structural integrity of the containers sitting still is questionable, let alone in transport on trains, trucks, or barges, where severe forces could come to bear in accident (or attack) scenarios, testing the containers to the breaking point.
While transport is a weak link, even on-site storage at ISP would be quite vulnerable to intentional attack. ISP would be one of the single greatest accumulations of highly radioactive irradiated nuclear fuel in the world. In that sense, it would be a giant radioactive bull's eye on the landscape, at risk of being attacked from the air, or by sophisticated weapons, such as anti-tank missiles, shaped charges, etc. NRC cannot and should not simply assume that "no accidental release of canistered fuel [would occur] under the most severe impacts studied." The U.S. Court of Appeals for the 9th Circuit, in SLOMFP v. NRC, has ruled that NRC must address such risks of attack in EISs. As irradiated nuclear fuel from the 9th Circuit, including from Diablo Canyon as but one example, could well be shipped to ISP, it is all the more legally-compelling that NRC must include such security analyses in its ISP EIS. Yet NRC has refused to do so thus far.
Please address the subject matter above, re: our many objections to NRC's outrageous conduct of this ISP/WCS CISF public comment proceeding.
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
NCAC comments to NRC, re: the agency's ISP/WCS CISF DEIS
Native Community Action Council's comments were submitted by Ian Zabarte, NCAC Secretary.
NEIS comments opposed to ISP/WCS CISF, submitted to NRC, re: DEIS
Nuclear Energy Info. Srv. of Chicago's director, Dave Kraft, submitted the comments.