Beyond Nuclear's 22nd set of public comments, re: Docket ID NRC-2018-0052, re: NRC's Holtec/ELEA CISF DEIS -- Risk of De Facto Permanent, Surface Storage, Parking Lot Dump

Submitted via <holtec-cisfeis@nrc.gov>

Dear Holtec-CISFEIS Resource and NRC Staff,

This is my 22nd 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 and improperly assumed by Holtec, as well as NRC, to someday become a permanent disposal repository.

Due especially to the numerous problems I have experienced submitting public comments via this <holtec-cisfeis@nrc.gov> email address, please acknowledge receipt of these comments, and their proper placement in the official public record for this proceeding.

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.

Risk of De Facto Permanent, Surface Storage, Parking Lot Dump

What if Holtec/ELEA's so-called consolidated interim storage facility (CISF for short, supposed to operate for “only” 40 years, which is already a long time, in most people’s books!) becomes much longer term, or even de facto permanent?

What if future replacements for today’s U.S. Representatives from southeastern New Mexico's, and adjacent, U.S. congressional districts in NM and TX, decide enough is enough, and the high-level radioactive wastes need to leave, after having been there for decades, or even centuries? Those one or two future U.S. Representatives from southeastern NM, and nearby, would then face the daunting challenge of overcoming the inertia, or even active opposition, of the other 433-434 Members of the U.S. House of Representatives, who might be just fine with the high-level radioactive wastes staying at Holtec/ELEA's CISF forevermore (it’s not in their congressional district, after all!) – which is how long they remain will hazardous by the way.

In 2008, under court order, the U.S. Environmental Protection Agency acknowledged that commercial irradiated nuclear fuel remains hazardous for a million years into the future. This is actually an underestimate. Take Iodine-129, as but one example. Its half-life is 15.7 million years. It will remain hazardous for at least ten half-lives, or 157 million years. I-129 is in high-level radioactive waste, too.

A 2013 U.S. Senate bill – forerunner to current versions of the legislation in Congress – added to the risks of consolidated "interim" storage facilities becoming de facto permanent, surface storage, parking lot dumps, by stating a preference for co-location of pilot consolidated interim storage facilities for "priority" irradiated nuclear fuel, alongside full-scale, lesser priority consolidated interim storage facilities, and even the permanent repository (that is, burial dump).

Also, the waiver of, or doing away with, any connection or "linkage" between development of centralized or consolidated interim storage facilities, and progress toward opening a repository, only increases the risk that supposedly "temporarily" (interim) stored highly radioactive wastes will simply be allowed to remain in centralized, or consolidated, so-called “interim,” surface storage facilities, indefinitely into the future. In other words, they could become de facto permanent, surface storage, parking lot dumps.

U.S. Senator Jeff Bingaman (D-NM), Chairman of the Energy and Natural Resources Committee, warned against this de-linkage in 2012. In fact, the requirement for a permanent disposal repository being opened and operating was, and still is, essential and foundational in the Nuclear Waste Policy Act of 1982, as Amended, the benchmark law on commercial irradiated nuclear fuel management for the past four decades. This was, and still is, a safeguard against consolidated interim storage facilities from becoming de facto permanent surface “disposal” sites, or parking lot dumps.

Note that the linkage requires an operating repository, not just a nearly licensed one, nor just a proposed one by someone, for someday, somewhere, some way. Remarkably, current DOE projections for the opening of the country's first permanent burial dump are not until the year 2048, 28 years from now, although they still don’t know who will make it happen, where, nor how! There is every possibility that even this 2048 repository opening date is overly optimistic.

And it must be remembered that by spring 2010, this country already needed a second repository, even though it is very far from having it's first one yet. The George W. Bush administration DOE, in late 2008, published its Report on the Need for a Second Repository, that officially acknowledged that the Yucca Mountain dump's legal capacity limit of 63,000 metric tons of commercial irradiated nuclear fuel would already be surpassed by the quantity of commercial irradiated nuclear fuel generated in this country, as early as spring 2010. The commercial irradiated nuclear fuel generated since 2010 is excess to Yucca's capacity limit, and will require a second repository elsewhere. By the terms of the Nuclear Waste Policy Act of 1982, as Amended, this second repository must be in the eastern U.S., to fulfill the principle of regional equity. After all, 90% of reactors and the irradiated nuclear fuel they have generated, are located in the eastern half of the country. 75% are located east of the Mississippi River.

But since the mid-1980s, the only targeted sites for the first repository have been in the West -- Deaf Smith County, Texas; Hanford, Washington; and Yucca Mountain, Nevada. Since 1987's Nuclear Waste Policy Amendments Act (popularly known as the "Screw Nevada" Act), the sole target has been Western Shoshone land.

But of course, the Yucca Mountain dump will never open, for a long list of reasons. Please see my "Stringent Criteria" list, for the reasons why the Yucca dump never will, and never should, open.

So in that sense, our country currently needs two permanent repositories, even though we don't even have the first one yet. It is dubious even the first repository will be open by 2048, let alone two. Thus, the idea that Holtec/ELEA's CISF is "temporary" or "interim" is very dubious. It will be very long-term storage, and perhaps even de facto permanent, risking becoming a surface storage parking lot dump.

2048 will be 106 years after Enrico Fermi generated the first cupful of high-level radioactive waste of the Atomic Age, in his Chicago Pile-1 at the University of Chicago squash court under the Stagg Field football stadium, on Dec. 2, 1942 as part of the Manhattan Project race for the atomic bomb. 2048 is 91 years after the first civilian, or commercial, irradiated nuclear fuel was generated, at the Shippingport atomic reactor, northwest of Pittsburgh, in the Beaver Valley of PA, very near the OH state line. Such already long-term storage, and such remarkable delays in high-level radioactive waste management and disposal, are another red flag, cautionary tale, and warning about Holtec/ELEA’s consolidated interim storage facility, so-called, instead becoming a very long-term, indefinite, or even de facto permanent, surface storage, parking lot dump.

Beyond Nuclear's 21st set of public comments, re: Docket ID NRC-2018-0052, NRC's Holtec/ELEA CISF DEIS -- Risks of Loss of Institutional Control if De Facto Permanent, Surface Storage, Parking Lot Dumps are Abandoned, Containers Fail, and Release Catastrophic Amounts of Hazardous Radioactivity into the Environment

Submitted via: <holtec-cisfeis@nrc.gov>

Dear Holtec-CISFEIS Resource and NRC Staff,

This is my 21st 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 and improperly assumed by Holtec, as well as NRC, to someday become a permanent disposal repository.

Due especially to the numerous problems I have experienced submitting public comments via this <holtec-cisfeis@nrc.gov> email address, please acknowledge receipt of these comments, and their proper placement in the official public record for this proceeding.

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.

Risks of Loss of Institutional Control if De Facto Permanent, Surface Storage, Parking Lot Dumps are Abandoned, Containers Fail, and Release Catastrophic Amounts of Hazardous Radioactivity into the Environment

DOE (the U.S. Department of Energy) has warned in its EIS (Environmental Impact Statement) on the proposed Yucca Mountain, Nevada national burial dump, that loss of institutional control would eventually prove catastrophic. Entropy means that things fall apart, over long enough periods of time. The Second Law of Thermodynamics holds that disorder increases with time. DOE was focused on this happening at nuclear power plant sites, if irradiated nuclear fuel was abandoned there forever. But the same is true here. If institutional control is eventually lost at the Holtec International/Eddy-Lea Energy Alliance's CISF (de facto permanent, surface storage, high-level radioactive waste parking lot dump), the containers will eventually fail, and catastrophically release their hazardous, high-level radioactive waste contents into the living environment. Persistently hazardous, and even deadly, radioactive fallout would then flow with the winds and the waters, downwind and downstream, up the food chain, and down the generations, over greater and greater distances over longer and longer time periods. Remember, high-level radioactive waste remains hazardous, even deadly, for at least a million years into the future. This was acknowledged by the U.S. Environmental Protection Agency (EPA) in 2008, under court order in the Yucca Mountain proceeding. On July 9, 2004, the second highest court in the land, the U.S. Court of Appeals for the District of Columbia Circuit, ruled that EPA's cutting off of regulations at Yucca Mountain, just 10,000 years post-burial, was illegal, a violation of the Nuclear Waste Policy Act of 1982, as Amended. The court ordered EPA back to the drawing board, to correct its illegal Yucca Mountain regulations. This led to EPA's 2008 regulatory revision, recognizing a million years of hazard. The 2002 lawsuit, which was consolidated with a dozen additional lawsuits in NEI v. EPA, was brought by NIRS (Nuclear Information and Resource Service), Public Citizen, Citizens Action Coalition of Indiana, Nevada Nuclear Waste Task Force, and Citizen Alert of Nevada. The environmental coalition's legal counsel was Geoff Fettus of Natural Resources Defense Council.

Actually, even acknowledging a million years of hazard is a lowball estimate. Take the artificial (that is, manmade) radioactive isotope Iodine-129. It has a half-life of 15.7 million years, thus at least 157 million years of associated hazard, and perhaps even 314 million years.

Such impacts could extend to the immediately adjacent surface waters, and perhaps even nearby, underlying aquifers, such as the Ogallala Aquifer. Despite the 40-odd mile distance from the Holtec site to the western edge of the Ogallala, as mentioned just above, releases from the Holtec CISF could well eventually extend 40 miles downwind and downstream -- especially considering the direction of prevailing weather patterns and winds. Thus, the Ogallala can also be considered downwind and downstream, over a long enough time period. Aquifers directly under or adjacent to Holtec/ELEA's CISF are simply in harm's way nearer term, more directly. Also, downwind or downstream surface level fallout from Holtec/ELEA's CISF could eventually find its way into the Ogallala, through natural flow paths (blowing with the winds, flowing with the rains, deposition onto and into soil, downward flow to aquifers). The Ogallala, North America’s largest, provides essential drinking and irrigation water for millions in Texas, New Mexico, Oklahoma, Kansas, Colorado, Nebraska, Wyoming, and South Dakota. As the water protectors at the Standing Rock Sioux Tribe reservation say on the Missouri River in North Dakota, Mni Wiconi, Water Is Life. This was made very clear by drinking water contamination disasters, in just the past decade, is such widespread locations as: Flint, Michigan (Flint River lead poisoning); Charleston, West Virginia (toxic chemical spill into the Elk and Kanawha Rivers); the Animas, San Juan, and Colorado Rivers in Colorado, New Mexico and Utah, and further downstream (EPA toxic wastewater release from an abandoned gold mine); Toledo, Ohio (Lake Erie toxic blue green algae contamination); Marshall, Michigan (Enbridge of Canada toxic tar sands crude oil spill into Talmadge Creek and the Kalamazoo River, the largest inland oil spill in U.S. history) -- to name but a few examples. A radioactive release into or contamination of the Ogallala would be similarly catastrophic. As mentioned, radioactive releases into surface waters and groundwaters nearer by the Holtec/ELEA CISF would simply take place sooner, rather than later, as compared to the Ogallala itself, given distances and radioactivity flow with the elements.

Making these risks all the worse, NRC has allowed a quality assurance (QA) failure crisis to persist in the U.S. nuclear power industry for years and decades. These QA failures extend not only to on-site storage casks at reactors, but also to the shipping cask and away-from-reactor storage cask realm, directly relevant to Holtec's CISF. The inner canisters are identical, whether used for on-site storage at reactors, transport, or away-from-reactor storage at the CISF.

Industry and even NRC whistle-blowers called attention to these QA failure risks 20 long years ago, yet little to nothing has been done to correct them since. Industry whistle-blower Oscar Shirani questioned the structural integrity of NRC-approved and industry-utilized storage casks sitting still, let alone traveling 60 miles per hour or faster on the railways. Shirani was backed up in his allegations by NRC Midwest Region (Region III) dry cask storage inspector, Dr. Ross Landsman, who warned “The NRC should stop the production of the casks, but they do not have the chutzpah to do it. This is the kind of thinking that causes space shuttles to hit the ground.” Shirani and Landsman were commenting directly upon Holtec container QA violations.

Such QA failures, shoddy design, and shoddy fabrication, re: the storage casks, means that their eventual failure, and release of their deadly hazardous high-level radioactive waste contents, will only happen all the sooner.

Although Shirani and Landsman’s revelations were about Holtec casks, NRC’s incompetence at best, or even collusion with industry, when it comes to cask QA violations, extends to other cask models and designs, including NAC (Nuclear Assurance Corporation) and Areva (Orano) casks to be used at ISP's CISF at WCS, TX, just 40 miles from Holtec's in NM. The QA violation crisis also extends to many, most, or all other dry cask models, such as VSC-24s (Ventilated Storage Casks), as but one additional example, as deployed at Palisades in MI, Point Beach in WI, and Arkansas Nuclear One. Holtec has bragged in its license application for this CISF that it could accommodate any and all cask model designs approved by NRC, with no exceptions. NAC challenged such claims by Holtec with an intervention in the NRC ASLB Holtec CISF licensing proceeding. But I mention the widespread QA violations, because whether Holtec containers, or other designs, the loss of institutional control and container breach risk still applies, at Holtec's CISF.

Nuclear Assurance Corporation (NAC) container – certainly to be used at ISP's CISF at WCS, TX, but also potentially to be used at Holtec's CISF in NM -- QA failures are of specific concern. In autumn 2016, shoddy welding by NAC led to the bottom literally falling out of an irradiated nuclear fuel assembly transfer caddy, allowing the assembly to strike the bottom of the storage pool at Chalk River Nuclear Labs in Ontario, Canada. Such bad welding calls into question the welds on NAC storage and transport containers as well.

At Davis-Besse atomic reactor on the Great Lakes shoreline near Toledo, Ohio, an Areva (now called Orano; previously called Cogema) design Transnuclear NUHOMS storage cask was loaded with irradiated nuclear fuel, despite local environmental interventions (including by Don't Waste Michigan) to stop it, after it was revealed the walls of inner canisters holding the high-level radioactive waste were ground too thin, violating technical specifications. But violations of technical specifications for the design and manufacture of casks in the U.S. are as rampant as QA violations. NRC looks the other way in both cases.

In fact, faulty welding was a major example of the Holtec container QA violations cited by Shirani and Landsman. See a 2004 summary of Shirani and Landsman's allegations, including re: faulty welding, posted online at this link here.

The Dangers of Transporting Nuclear Waste/Stop Environmentally Unjust Nuclear Dumps

Video presentation recorded on July 8, 2020, published on Sept. 7, 2020, on "The Dangers of Transporting High-Level Radioactive Waste." Beyond Nuclear's radioactive waste specialist, Kevin Kamps, presents from the beginning to the 22 minute mark in the recording, followed by Tim Judson, Ex. Dir. of NIRS.

A big focus was the transport risk associated with consolidated interim storage facilities (de facto permanent, surface storage, parking lots dumps) for irradiated nuclear fuel, targeted at New Mexico and Texas, but also the permanent dump-site targeted at Western Shoshone land at Yucca Mountain, Nevada.

Catherine Skopic was a lead organizer of the event, and the Manhattan Sierra Club Chapter a primary sponsor.

View the recording here.

Environment TV (ETV) provided this write up:

This video is an excerpt from a ZOOM event entitled: STOP ENVIRONMENTALLY UNJUST NUCLEAR DUMPS.

To view the full version go to: @ https://www.youtube.com/watch?v=0RwuG... which is on the You Tube Channel: PeaceActionNewYorkSt and they have given ETV permission to edit their event for our various communications platforms.

This excerpt was edited for the Westchester public access TV station of Altice, for our sister show, Environmental News and Views with Host/producer Marilyn Elie.

The original event had this program:

Speakers;

KAREN CAMPBLIN - NAACP Environment & Climate Justice Committee Chair

LEONA MORGAN - Dine, Navajo Organizer; Co-Founder, Nuclear Issues Study Group

KEVIN KAMPS - Beyond Nuclear; Nuclear Waste Watchdog

ROSE GARDNER - Alliance for Environmental Strategies, New Mexico

Support Speakers:

MICHEL LEE, Esq. - Sr. Analyst, Promoting Health and Sustainable Energy (PHASE)

MARI INOUE, Esq. - Co-Founder, Manhattan Project for A Nuclear-Free World

TIM JUDSON - Executive Director, Nuclear Information Resource Service (NIRS)

Our Goals:

1. Inform organizations/individuals about the proposed nuclear landfills & nuclear dumps

2. Inspire people to submit comments to NRC before [Sept. 22, Oct., and Nov. 3 deadlines]; write letters to editors

3. We Can Stop This - encourage actions to prevent the EJ violation of nuclear landfills & dumps

View the recording here.

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:

Over 50 National and 700 Regional/State/Local Grassroots Environmental Groups Publicly Opposed to the Yucca Mountain High-Level Radioactive Waste Dump.

<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:

(See NIRS fact-sheets on barge shipments of deadly high-level radioactive waste on waterways, by state, posted online September 28, 2004, at this link here.)

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:

<https://web.archive.org/web/20150908070611/http://www.nirs.org/factsheets/nirsfctshtdrycaskvulnerable.pdf>.

Please address your woefully inadequate "hard look" under NEPA, re: this health- and environmentally-significant subject matter above.

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.

US regulators take public comments on nuclear fuel plan

As reported by AP.

Please note that Jack Edlow's claim in the article, that states must first "consent" to high-level radioactive waste shipments, before they pass through, is false. When pressed, the other side -- including the U.S. DOE -- typically invokes the Interstate Commerce Clause of the U.S. Constitution, to say no consent is required, to haul high-level radioactive waste through a community, county, state, or Native American reservation.

In fact, when Beyond Nuclear's Kevin Kamps asked about transport corridor consent, DOE's John Kotek did just that -- explicitly invoked the Interstate Commerce Clause -- at the "kick off" meeting for "consent-based siting" public comment in DC in Dec. 2015.

Edlow looks to ultimately make hundreds of millions of dollars, or more, as an irradiated nuclear fuel transport middleman, on the CISFs, hence his false propaganda. He's been at it for many decades, and his father before him.