Beyond 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
November 3, 2020