Beyond Nuclear's public comment #3, re: NRC's Holtec/ELEA CISF DEIS, Docket ID NRC-2018-0052 -- re: complexity and risk of multiple required cask-to-cask canister transfers

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Dear NRC Staff,

The inner canisters will have to be transferred (from on-site storage dry casks, to radiation shielding/transfer casks, to transport/shipping casks, again to transfer casks, then to CISF storage pits; and then, if and when high-level radioactive wastes are exported to a permanent repository, the reverse process) multiple times. Nowhere in the NRC DEIS is this complexity, and high risk for something to go wrong, reflected, admitted, nor analyzed adequately.

Just the stage of lowering the inner canisters into the CISF storage pits (VVMs, Vertical Ventilated Modules, in Holtec parlance) could prove damaging and dangerous. As revealed by a whistle-blower at San Onofre nuclear power plant in California in August 2018, lowering a 50-ton, fully-loaded canister into a storage pit there nearly led to an 18-foot free-fall drop, due to human error. If not for the whistle-blower's courageous revelation, this incident may never have been made publicly known. He was made to pay for his courage with his job. But Southern California Edison would very likely not have ever revealed it. Same for Holtec. Same for any contractors or sub-contractors involved. And NRC either didn't even know it had happened, or else was also complicit in the cover up.

Another example of potential for damage and danger also comes from San Onofre. A large number of inner canisters have been significantly gouged while being lowered into their storage pits. This significantly risks early failure of these containers, as degradation and corrosion now has a weak link to attack. Through-wall cracks are all the more likely, all the sooner, because of this gouging, resulting from Holtec's dangerously poor design of the UMAX system.

Making matters worse, NRC is not even requiring Dry Transfer Systems (DTS), neither at the nuclear power plant origin sites, nor at Holtec/ELEA's CISF, nor anywhere in between. So there will be no way to deal with failed fuel or containers, as well as leaks or contamination, if and when they occur.

Expert witness Bob Alvarez, serving Holtec/ELEA opponents, a former senior advisor to the U.S. Energy Secretary, has testified in these CISF proceedings that under DOE's latest Yucca dump plans, targeting Western Shoshone land in NV, high-level radioactive wastes can only be buried in TADs -- standardized Transport, Aging, and Disposal containers specially designed for use at the Yucca dump. This would require dividing up the contents of 10,000 containers at Holtec/ELEA's CISF into 80,000 smaller TADs. Nowhere is this addressed in the Holtec ER, nor the NRC DEIS. And yet both Holtec and NRC assume Yucca will be the ultimate dump, itself an outrage, as Ian Zabarte, Principal Man of the Western Bands of the Shoshone Indians, and secretary of the Native Community Action Council, testified on the June 23, 2020 webinar/call-in public comment meeting. He made clear the Western Shoshone hold title to Yucca Mountain, as acknowledged by the U.S. government when it signed the "peace and friendship" Treaty of Ruby Valley in 1863.

That Holtec container to TAD container repackaging process described above will have significant risks and potential impacts for health, environment, and safety, and yet could not be done without a DTS. The entire complex, high risk subject matter area is missing from NRC's Holtec CISF DEIS, another violation of NEPA's "hard look" requirement, and even a violation of the Atomic Energy Act, given the inherent, large safety risks.

I submit these comments on behalf of our members and supporters in New Mexico, as well as along the transport routes in most states who would be impacted by this dangerous, unnecessary proposal.

Please acknowledge receipt of these comments. Thank you.