This public comment is in response to the Draft Environmental Impact Statement (Docket ID NRC-2016-0231) regarding Interim Storage Partner’s (ISP) application for a license to build and operate a “Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas” (NUREG-2239).
The undersigned organizations oppose ISP’s proposal and ask that the NRC halt its licensing in order to protect public health and safety, the environment and our economy. It appears from the Draft Environmental Impact Statement (DEIS) and other license application documents that there would be no dry cask transfer facility (Dry Transfer System, DTS) at the proposed site, which means there would be no way to repackage waste. The site is not designed for long-term disposal, but a dangerous de facto permanent surface dump could result if waste casks or canisters are damaged or corroded and cannot be moved.
ISP’s application to store radioactive waste in Texas would bring in 40,000 tons of irradiated nuclear fuel from nuclear reactors around the country. 90% of those reactors and their irradiated nuclear fuel are in the eastern half of the country; 75% are east of the Mississippi River.
The plan would target a Latinx community with forever deadly highly radioactive waste. The waste would be stored above ground in a region prone to earthquakes, sinkholes, temperature extremes, wildfires, and intense storms and flooding, all of which can increase contamination risks. ISP’s scheme would exacerbate existing environmental injustice and threats to the Ogallala and other aquifers. WCS is already a national dump for so-called “low-level” radioactive wastes and other hazardous materials. In addition, the URENCO USA uranium enrichment facility is right next to the WCS/ISP site. In fact the two nuclear complexes are on one former ranch that straddled the New Mexico/Texas border. The majority Hispanic town of Eunice, New Mexico — through which every single one of the 3,400 irradiated nuclear fuel rail casks bound for ISP would pass — is within just a few miles of the WCS/ISP site.
Consolidated interim storage facilities (CISFs) are an illegal approach that does not solve the highly radioactive waste problem. The Nuclear Waste Policy Act of 1982, as Amended, prohibits the U.S. Department of Energy (DOE) from taking ownership of commercial irradiated nuclear fuel, unless and until a permanent repository is licensed and operational. In illegally considering this application, the NRC has ignored expert testimony, widespread local, regional, and even national opposition, and many tens of thousands of written and oral comments.
• Account for disproportionate impacts to low-income communities of color (environmental justice communities) in the American Southwest and along transport routes there and nationwide.
• Detail transportation routes and consider nationwide risk to millions of Americans along transport routes.
• Consider the risk of leaks, contamination, sabotage/intentional attacks, or severe transportation accidents.
• Include a plan to repackage leaking waste casks and a plan to move waste when required.
• Complete the required alternatives analysis by considering Hardened On-Site Storage (HOSS), at or near reactors, as an alternative to Consolidated Interim Storage.
• Consider lessons learned from past accidents, nor the potential for future radioactive waste accidents to cost hundreds of millions to billions of dollars to clean up.
• Detail cumulative impacts of the proposed facility and nearby sites — including the Holtec CISF, URENCO and the Waste Isolation Pilot Plant, in New Mexico — on workers, local residents, and the environment.
On behalf of our members and supporters, our organizations oppose Consolidated Interim Storage Facilities at this and other sites, including Holtec International/Eddy-Lea Energy Alliance’s CISF, targeted at Laguna Gatuna in southeastern New Mexico, just 40 miles from WCS. The DEIS fails to adequately analyze environmental and cumulative impacts and the socioeconomic risks of the two proposed CISF applications in the same local area. The NRC should protect public health and safety, the economy and the environment, by halting the application processes and denying the licenses for both ISP’s and Holtec’s proposed facilities.
We also oppose as unacceptably dangerous the plan to multiply transport risks, and the environmental justice burden, that is inherent in Consolidated Interim Storage. As ISP/WCS itself admitted in its Environmental Report (Revision 2, Chapter 2, Figure 2.6-1, Transportation Routes, Page 2-78), the outbound shipments from the CISF, heading to Yucca Mountain, Nevada for permanent burial, would travel through the very same communities in New Mexico, Texas, and Oklahoma that had already seen the inbound shipments, carrying irradiated nuclear fuel from eastern reactors, to the CISF in the first place. These outbound shipments could number in the several tens of thousands if the irradiated nuclear fuel is repackaged at WCS (itself a hazard to workers and local residents), into smaller-sized TAD (Transport, Aging, and Disposal) containers, required for compliance with DOE’s Yucca repository design plans. CIS makes no sense, and would significantly increase transport risks and EJ burdens.