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Hardened On-Site Storage (HOSS) of nuclear wastes is the safest method

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(Transport dangers) Any mainline rail can be used. The condition of the rails in the U.S. is not good. Think of recent train derailments – as NIRS has often asked, “What if nuclear waste had been aboard?” The irradiated nuclear fuel casks aboard trains bound for Holtec/ELEA, NM, combined with the rail cars, would weigh around 180 tons. These would be among the heaviest loads on the rails, and would risk further damaging them.

(Waste container contamination) sometimes the exterior of shipping casks are contaminated, sometimes severely so. Above, 49 such incidents of external contamination were documented in the U.S. from 1949-1996. As revealed by Mycle Schneider of WISE-Paris in the mid- to late 1990s, Areva (now called Orano in the U.S., as at the WCS, TX CISF) experienced a very large number of externally contaminated HLRW shipments.

Decommissioning Nuclear Power Plants: What Congress, Federal Agencies and Communites Need to Know Highly Radioactive Irradiated Nuclear Fuel: Need for Hardened On-Site Storage; Risks of Off-Site Transport Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear , July 16, 2018  https://static1.1.sqspcdn.com/static/f/356082/27949948/1532014874603/7+16+18+Capitol+Hill+Decommissioning+and+HLRW+congressional+briefing+EESI+with+further+note+slides+added.pdf?token=p2q8spOdyd5eCfAnSiIAvb%2FMi2g%3D

 Because pools are outside radiological containment structures that surround reactors (which can themselves fail, as shown at Fukushima Daiichi), the first step in the direction of Hardened On-Site Storage (HOSS) is to “expedite transfer” of irradiated nuclear fuel from indoor “wet” pools to outdoor dry storage. However, there must be significant upgrades to safety, security, health- and environmental protection associated with dry cask storage – that is, Hardened On-Site Storage (HOSS).

The three reactor meltdowns, and associated containment breaches, at Fukushima Daiichi, resulted in 160,000 nuclear evacuees in Japan, beginning on 3/11/11. • However, then serving Prime Minister Kan publicly revealed on the one year commemora/on of the beginning of the nuclear catastrophe, than had the Unit 4 high-level radioac/ve waste storage pool caught fire, he had a secret con/ngency plan in the works to evacuate 35 to 50 million Japanese ci/zens from the metro Tokyo area and northeastern Japan. He said it would have been the end of the Japanese state. • The pool came precariously close to catching fire. The only reason it didn’t was sheer luck.
Risks of Pool Storage, Transfers
 IP’s long term (~early 1990s-present) pool leakage of radioac/vity into soil, groundwater, Hudson River (tri/um, Sr-90, radioac/ve cesium, cobalt, nickel)
• Heavy load drop risk of pool drain down, zirconium fire (Prairie Island, MN & Palisades, MI transfer cask crane dangles; Vermont Yankee crane slip)
Some examples of dry cask/canister failures
• Defective welds (Ventilated Storage Cask-24s, Palisades, MI)
• Inner canister wall thickness ground too thin, below technical specifica/ons (TransNuclear/NUHOMS, Davis-Besse, OH)
• Hydrogen gas genera/on, explosion, and fires (VSC-24s, Palisades & Point Beach, WI) • Ver/cal casks moved several inches out of posi/on; horizontal casks’ concrete structure and radia/on shielding damaged by earthquake (accompanied by a week long coverup exposed by CNN), mul/ple cask models at North Anna, VA (con/nued)
Some more examples of dry cask/canister failures
• Cracking visible on exterior surface of cask concrete face (radia/on shielding), VSC-24s at Palisades • Problema/c shims – Palisades, 1994; San Onofre, CA, 2018
• Inner seal leaks, risking loss of iner/ng Helium gas, which could lead to corrosion of irradiated nuclear fuel, as well as overheating (Surry, VA).
Dr. Makhijani originated the concept, and coined the phrase, Hardened On-Site Storage (HOSS). He was the keynote speaker in April 2002 at a Ci/zens Awareness Network (CAN) summit in CT, opposing the Yucca dump by advoca/ng HOSS as an alterna/ve • Commissioned by CAN, Dr. Thompson wrote a report, “Robust Storage,” in Jan. 2003, punng more flesh on the bones of the HOSS concept.
Need for Robust, or Hardened On-Site Storage (HOSS)  
Statement of Principles for Safeguarding Nuclear Waste at Reactors (HOSS)—2006; 2010; 2016; 2018 • Require a low-density, open-frame layout for fuel pools (to provide convec/on air current cooling) – that is, empty the pools as much, and as soon, as possible (a.k.a. “expedited transfer”);
• Establish hardened on-site storage (retrievability; real-/me monitoring for radia/on, temperature, pressure; as close as possible, as safely as possible, to point of genera/on);
• Protect fuel pools;
• Require periodic review of HOSS facili/es and fuel pools; • Dedicate funding to local and state governments to independently monitor the sites;
• Prohibit reprocessing (something Holtec/ELEA wants to do at its CISF in southeastern NM)
Statement of Principles for Safeguarding Nuclear Waste at Reactors (HOSS)—2006; 2010; 2016; 2018
• Many hundreds of public interest and environmental organiza/ons, represen/ng all 50 states, including from NY State: Coali/on on West Valley Nuclear Wastes; Center for Health, Environment, and Jus/ce; For a Clean Tonawanda Site (FACTS); Ci/zen’s Environmental Coali/on; Riverkeeper; Central New York Ci/zens Awareness Network; IPSEC (Indian Point Safe Energy Coali/on); Public Health and Sustainable Energy (PHASE); Council on Intelligent Energy & Conserva/on Policy (CIECP); Hudson River Sloop Clearwater.
HOSS where appropriate/acceptable There are a number of sites where Hardened ON-SITE Storage is not appropriate. Prairie Island, MN is in the flood plain of the Mississippi River, immediately adjacent to the Prairie Island Indian Community, an environmental injus/ce. Palisades, MI’s dry cask storage is just 150 yards from the water of Lake Michigan, and violates NRC earthquake safety regula/ons. San Onofre, CA is on the edge of the Pacific, in an earthquake and tsunami zone.
Dr. Mary Sinclair, a co-founder of Don’t Waste Michigan, warned about such radioac/ve waste risks to the Great Lakes, as well as rivers – the drinking water supplies of our na/on – and the coasts, at risk of rising sea levels, more than 20 years ago. In those cases, hardened storage should s/ll be implemented, as close as possible to the point of waste genera/on as is safely possible, as by moving irradiated nuclear fuel a short distance inland, to higher ground. For example, San Onofre’s wastes could move a number of miles east, deeper into the heart of Camp Pendleton, rather than a thousand miles east to New Mexico. At Camp Pendleton, they’d have the added bonus of thousands of U.S. Marines to provide security.
Dispersed/Concealed HOSS v. Plain View/Clustered Configura/on “Bowling Pins” Graphic from “Robust Storage” by Dr. Gordon Thompson, Jan. 2003 ……….
Summary of Whistle-blower Allega/ons of Holtec QA Viola/ons
• Faulty welds • Unqualified fabrica/on materials
• Defec/ve neutron shielding material
• Failure to perform coupon tes/ng, Post-Weld Heat Treatment
• Bypassing of hundreds of non-conforming condi/ons, without reanalysis of structural integrity • Improper, uncer/fied design decisions and changes on the fly
• No root cause inves/ga/on of epidemic of QA viola/ons
• Interference with QA audit, falsification of QA documenta/on • NRC incompetence, or worse—collusion, complicity
Holtec Whistle-Blowers  
Oscar Shirani, Commonwealth Edison/Exelon QA inspector
• Shirani said Holtec casks are “nothing but garbage cans” if they are not made in accordance with government specifica/ons;
• He ques/oned Holtec casks’ structural integrity sinng s/ll, at 0 mph, let alone going 60 mph+ (accident forces) on the rails
Dr. Ross Landsman, NRC Region 3 dry cask storage inspector (re;red) • Has compared NRC/Holtec decision making to NASA’s, that led to “Space Shuqles hinng the ground”
• Will serve as environmental coali/on expert witness in impending NRC licensing proceeding for Holtec/ELEA’s proposed CISF targeted at southeastern NM (which began today, with NRC’s Federal Register No/ce)
Need for Emergency Cask-to-Cask Transfer Capability
• Urgent need to empty irradiated nuclear fuel from vulnerable and leaking storage pools into HOSS, ASAP, but…
• Essen/al to maintain operability of empty pool, in order to have cask-to-cask transfer capability, if and when needed
• Science fiction/fantasy of NRC’s on-site or away-from-reactor “Dry Transfer Systems”
Dry Transfer Systems (DTSs) exist only on paper, but have never actually been built in the real world. No source of funding for building them has been iden/fied. The ratepayer funded Nuclear Waste Fund, with a current balance of around $37 billion, is already inadequate. It is intended for permanent geological disposal, not for on-site or away from reactor interim storage. Breach of contract awards paid by the Dept. of Energy to nuclear u/li/es are funded by the U.S. Judgment Fund, that is, taxpayers.
Risks of Off-Site Transport
Severe accidents • Attacks • Mobile X-Ray Machines That Can’t Be Turned Off
High Burn-Up makes everything worse (thermal heat, radioac/vity)
But “lower burn-up” is plenty bad enough already in those regards!
Shipping Cask/Canister issues
Consolidated Interim Storage Facili/es Waste Control Specialists, LLC, Andrews County, Texas (WCS)
Eddy-Lea [Coun;es] Energy Alliance, New Mexico (ELEA)
Why are these sites on the TX/NM borderlands being targeted for CISFs?
• WCS, TX is near or above the Ogallala Aquifer. WCS is already a na/onal “low-level” radioac/ve waste dump.
• Holtec/ELEA, NM is just 16 miles from the Waste Isola/on Pilot Plant (WIPP) for military plutonium contaminated waste disposal. In Feb. 2014, WIPP experienced an industrial fire in the underground, followed a few days later by a waste barrel burst, and radioac/vity release to the environment that had been previously deemed “impossible” by DOE officials
Sacrifice Zone?! The TX/NM borderlands are being treated by CISF proponents as an energy or nuclear sacrifice zone. The environmental jus/ce (EJ) viola/ons of these CISF proposals are significant. The local area’s large Hispanic communi/es are already heavily polluted by fossil fuel (oil extrac/on, fracked natural gas) and nuclear industries (trans-uranic waste disposal at WIPP, na/onal LLRW disposal at WCS, uranium enrichment at URENCO, proposed Interna/onal Isotopes DuF6 de-conversion plant).
Near term HLRW shipping campaign
• 2021 as a start date for a “pilot” CISF has been proposed
• 2024 as a start date for a full-scale CISF has been proposed
• Such near term dates may have slipped at Holtec/ELEA, NM and WCS, TX, but the former licensing proceeding schedule is nonetheless on a very fast pace: July 30th deadline for environmental scoping public comment, despite request by scores of environmental groups for a three month extension; and as of today, the announcement of a September 14, 2018 licensing intervention legal contentions submission deadline.
The two proposed CISFs are less than 40 miles apart (Nuclear Sacrifice Zone)
These two proposed CISFs violate environmental jus/ce (EJ), amount to environmental racism or radioac/ve racism, the context of Na/ve Americans as well. The Mescalero Apache Indian Reserva/on is not far from the Trinity atomic blast site. It was also targeted by DOE, and Private Fuel Storage, LLC, for a CISF two decades ago. However, Mescalero tradi/onals Rufina Marie Laws and Joe Geronimo led the successful campaign to bloc that CISF. ….
CIS: De Facto Permanent Surface Storage Parking Lot Dump, or else Multiplying Transport Risks
If “parked” at a CISF, would the HLRW ever move again? Would the vote in the U.S. House against moving it again be 434 to 1?! Likewise, would the U.S. Senate vote be 98 to 2 against?!
• “Interim” or “temporary” could be a bait and switch, and become de facto permanent.
• As former U.S. Senate Energy and Natural Resources Commiqee chairman, Jeff Bingaman of NM, advocated – the linkage between CIS and geological disposal must be maintained. Democra/c members of Congress from NM have that same posi/on today, and oppose – or else are skep/cal of — Holtec/ELEA’s CISF accordingly.
Yucca Mountain, Nevada; Geologic Repository (Permanent Burial)
The Western Shoshone Indian homeland, Newe Sogobia, is not a nuclear wasteland.
• Each Shimkus tour of the Yucca Mountain Project costs $10,000 or more of U.S. taxpayer money, just to open the gate. This waste must end!
• The 6th toe on the Yucca dump mutant zombie is twitching, again!
Routes: Yucca Mountain, NV-bound (map on original)
Highly radioac/ve irradiated nuclear fuel shipments have long been called “Mobile Chernobyls” by cri/cs, due to their high risks.
Yucca-bound routes (map)
12,145 truck & train shipments, over the course of 50 years, would impact 44 states, under the current 70,000 metric ton Yucca Mountain scheme • Scores of major cities would be impacted • 330 of 435, or 75%, of U.S. congressional districts would be impacted
Compare this with the few thousand, at most, irradiated nuclear fuel shipments that have taken place in the U.S. since the beginning of the Atomic Age • State of Nevada Agency for Nuclear Project’s director Robert Halstead published “Reported Incidents Involving Spent Nuclear Fuel Shipments, 1949-1996.”
72 Reported Incidents • 4 accidental radioac/ve material contamina/on release incidents beyond the vehicle • 4 accidental radioac/ve material contamina/on releases confined to the vehicle • 13 traffic accidents resul/ng in no release or contamina/on • 49 accidental surface contamina/on incidents • 2 other incidents men/oned but no available descrip/ons
WCS, TX-bound routes (map) 
Any mainline rail can be used. The condition of the rails in the U.S. is not good. Think of recent train derailments – as NIRS has often asked, “What if nuclear waste had been aboard?” The irradiated nuclear fuel casks aboard trains bound for Holtec/ELEA, NM, combined with the rail cars, would weigh around 180 tons. These would be among the heaviest loads on the rails, and would risk further damaging them.
WCS, TX-bound routes (map) 
Holtec/ELEA, NM-bound routes (including exports to Yucca) (map)
Holtec’s license applica/on transport route map only shows 2 nuclear power plant origin points, amoun/ng to 4 reactors. What about the 121 reactors, at scores of other nuclear plants? Holtec’s “return to sender”/”start clean, stay clean” policy is nonsense. Is Holtec just trying to save money by not building a pool or DTS at its CISF?
Would a leaking or contaminated cask really be allowed to go back to where it came from in the first place? Is this legal? Is this wise? Maine Yankee, with around 60 casks, is 2,300 miles away. Such a return trip would mean 4,600 miles round trip, through a dozen states in between ME and NM. Note that a place like Fort Worth, TX would be clobbered, coming and going – coming to NM, and going to NV – under the Holtec/ELEA plan.
Highly Radioac/ve LIQUID Waste Truck Shipments?! (DOE is out of control)
Dr. Gordon Edwards of Canadian Coali/on for Nuclear Responsibility in Montreal has calculated that a mere 2 fluid ounces of this highly radioac/ve liquid waste would be enough to contaminate Washington D.C.’s Georgetown Reservoir, in viola/on of EPA’s Safe Drinking Water Act Maximum Contaminant Level for Stron/um-90.
Highly Radioac/ve Liquid Waste Truck Shipments (map)
Congress needs to exercise oversight! Thank you to U.S. Rep. Brian Higgins (Buffalo, NY), and U.S. Sen. Kirsten Gillibrand of NY, for taking ac/on and speaking out in opposi/on to these high-risk, unnecessary highly radioac/ve liquid waste truck shipments!
Barge Shipments  (map) 
Floating Fukushimas Barges from Indian Point, down the Hudson River, past Manhaqan? Barges from CT Yankee on Long Island Sound? Barges from Oyster Creek, past Staten Island? Really? The security risks alone, let alone safety risks, argue against this!
But barge shipments are proposed on numerous surface waters: • The Great Lakes (Lake Michigan, bordering MI, WI, IN, and IL) • Rivers (in numerous states, impac/ng VA, LA, MS, TN, AL, NE, KS, MO either directly or downstream) • Bays & Harbors (in DE, MA, and MD) • Seacoasts (CA, FL)
Road and Rail Routes (map)
Road and Rail Routes  (another map )
Too close for comfort  (picture of convoy Washington)
See the work of Rick Hind of Greenpeace, re: hazardous chlorine train car shipments through D.C. and Capitol Hill.
Road and Rail Routes (Yucca-bound) • hqp://www.state.nv.us/nucwaste/news2017/ pdf/States_Affected.pdf [44 states = 88 U.S. Senators!] • hqp://www.state.nv.us/nucwaste/news2017/ pdf/Ci/es_Affected.pdf [scores of major ci/es] • hqp://www.state.nv.us/nucwaste/ news2017/115th%20Congressional%20Districts %207252017.pdf[330 of 435 = 75% of U.S. House Districts!]
Or Heavy-Haul Truck?  (picture)
As shown by this Big Rock Point, MI reactor pressure vessel shipment (290 tons), there is an alterna/ve to barges. However, this shipment itself, in Oct. 2003, experienced numerous incidents during the course of its journey to South Carolina – including damaging the tracks and causing derailments of trains in its wake
Transport Risk: Underwater Submersion (Interstate 40, Oklahoma, 2002)  (picture)
Inadequate regulatory requirements means safety is threatened Thanks to Public Ci/zen for its 2002 analysis: The regulatory requirement (the design criteria) is that a cask that has undergone the puncture test (a cask must withstand a free-fall from 40 inches, onto an 8-inch long spike) must then withstand submersion under 3 feet of water. But many surface water barge transporta/on routes are much deeper than 3 feet.
An undamaged cask must withstand submersion under 200 meters (656 feet) of water for 1 hour. But if there is an accident, how can the op/mist assump/on be made that a cask would not be damaged? How would a mobile crane capable of liuing 100+ tons be brought in, set up, and operated, all in less than an hour? What about depths greater than 656 feet, such as exist near proposed barge routes in Lake Michigan?
Safety is threatened A damaged cask submerged deeper than 3 feet could contaminate drinking water supplies. Casks can weigh 125 tons or more, and would be extremely difficult to retrieve in 1 hour, especially in remote areas. Water pressure over a long enough /me period could breach a cask. There is enough fissile material (U-235, Pu-239) s/ll present in the irradiated nuclear fuel that if a cri/cal mass were to form in an accident, and modera/ng water leaks into the shipping container, an inadvertent nuclear chain reac/on could occur. Emergency response would then be a suicide mission in terms of the gamma and neutron radia/on being emiqed. Releases of radioac/ve gases, liquids, and par/cles out the breach into the surface water would be made all the worse.
Transport Risk: High-Temperature, Long-Dura/on Fire (Howard Street Tunnel fire beneath downtown Bal/more, MD, July 2001) (picture)
Inadequate Regulatory Requirements of the Burn Test …again leaves safety threatened. Casks must withstand an engulfing fire at 1,475 degrees Fahrenheit (800 degrees Celsius), for 30 minutes. But other materials that share the roads, rails, and waterways burn at much hoqer temperatures than that (diesel burns at 1,800 degrees F, for example), and for much longer than 30 minutes.
The 2001 train fire in Bal/more burned for more than 3 days, and probably reached temperatures hoqer than 1,500 degrees F.
Dr. Marvin Resnikoff of Radioac/ve Waste Management Associates studied this accident, and asked, what if a Holtec container had been involved? He published his results in “Radiological Consequences of Severe Rail Accidents Involving Spent Nuclear Fuel Shipments to Yucca Mountain: Hypothe/cal Bal/more Rail Tunnel Fire Involving Spent Nuclear Fuel.”
Resnikoff found that the Holtec container would have failed and released a por/on of its hazardous radioac/vity with the smoke, to blow downwind. Acute dose excess latent cancer fatali/es would have numbered from around 10 to 50. If an adjacent sports stadium was filled to capacity at the /me of the release, 20 to 120 people would later have died from radio-genic cancer.
Dr. Resnikoff calculated that 10 square kilometers of downtown Bal/more would have been moderately contaminted. Another 10 sq. km would have been heavily contaminated. The cleanup bill would have cost $13. 7 billion (in Year 2001 dollars).
If the cleanup was not done, a 1-year dose from living in contaminated areas would have caused from around 250 to around 1,600 latent cancer fatali/es. A 50-year dose from living in contaminated areas would have caused around 5,000 to 32,000 latent cancer fatali/es.
Transport Risk: Attack
See the Transporta/on Research Board and Na/onal Research Council’s “Going the Distance? The Safe Transport of Spent Nuclear Fuel and High-Level Radioac/ve Waste in the U.S.,” published by the Na/onal Academies Press in 2006. It cited security as a significant unresolved issue.
In fact, as Robert Halstead of the State of Nevada Agency for Nuclear Projects wrote on 6/5/18: “The Blue Ribbon Commission [on America’s Nuclear Future, in its Jan. 2012 Final Report] based on the NAS 2006 report, recommended that 13 specific measures be adopted before the commencement of shipments to federal facili/es, for the purposes of enhancing safety, security, and public acceptance.”
Truth be told, liqle to nothing has been done in this regard in the past dozen years. TOW and other an/-tank missiles, shaped charges, sophis/cated military grade explosives, and incendiaries, remain a risk to high-level radioac/ve waste shipments.
Transport Risk: Attack
Dirty Bombs on Wheels A June 1998 test of a TOW an/-tank missile, against a German CASTOR shipping cask, at the U.S. Army’s Aberdeen Proving Ground, blew a hole several inches across clean through the wall of a 15-inch die cast iron cask. This would, when combined with an incendiary, provide the pathway for disastrous amounts of hazardous radioac/vity, such as vola/le Cs-137, to escape into the environment.
When I raised such risk scenarios at a 10/1/2015 subcommiqee hearing, Rep. Shimkus responded that he’d personally fired a TOW, and that they are challenging to operate, making it difficult for an aqacker to hit a moving highlevel radioac/ve waste shipment.
But TOWs were designed to be used against Soviet T-72 tanks, capable of speeds of up to 37 mph. We have to assume HLRW shipments could well slow below speeds of 37 mph, as in the congested Chicago area, and that aqackers in possession of TOWs would be trained to use them. Rep. Shimkus did agree with me, however, that an/-tank weaponry has advanced since TOWs were developed, 40 years ago. This means modern weaponry is an even bigger risk to HLRW shipments, if in the wrong hands.
Where the Radioactive Poisons Go (diagram of human body)
The preceding chart shows where in the human body various radioac/ve isotopes concentrate, to do their harm. In case of a shipping cask breach and release of gases, vola/les, par/cles, liquids, and other radioac/ve materials from HLRW, this is how they can harm humans downwind, downstream, up the food chain, and down the genera/ons (many are very long las/ng in the environment).
“Routine” or “Incident-Free” Shipments: Mobile X-Ray Machines That Can’t Be Turned Off
The phrase “mobile X-ray machines that can’t be turned off” was coined by Lauren Olson in 1997. NRC regula/ons allow for 10 milli-Rem/hour dose rates at a distance of 2 meters (6.6 feet) from a cask. That’s 1 to 2 chest X-rays per hour. At the cask surface, NRC allows 200 mR/hr, or 20 to 40 chest X-rays per hour
But sometimes the exterior of shipping casks are contaminated, sometimes severely so. Above, 49 such incidents of external contamination were documented in the U.S. from 1949-1996. As revealed by Mycle Schneider of WISE-Paris in the mid- to late 1990s, Areva (now called Orano in the U.S., as at the WCS, TX CISF) experienced a very large number of externally contaminated HLRW shipments.
25 to 33% of all shipments bound for the La Hague reprocessing facility – many hundreds, over the course of many years – were externally contaminated beyond regulatory limits. On average, they emiqed 500 /mes the permissible dose rate. One emiqed 3,300 /mes the allowable dose rate.
H.R. 3053
U.S. Rep. Fred Upton (R-MI) , from the mid-1990s to the present, has advocated for the Yucca dump. He is the immediate past chairman of the U.S. House Energy & Commerce Commiqee, and is s/ll a subcommiqee chairman on that commiqee. U.S. Rep. John Shimkus (R-IL), a subcommittee chair, is now the chief advocate for the Yucca dump, and hence sponsor of H.R. 3053.
The Nuclear Waste Policy Amendments Act of 2018 On 6/5/18, Robert Halstead published “Revised Comments on HR3053 to Nevada Commission on Nuclear Projects.” Halstead reported that HR3053 would increase the amount of HLRW that could be buried at Yucca, from 70,000 metric tons to 110,000 MT, a major policy change.
Such an increase would accelerate waste container degrada/on, and hazardous radioac/vity releases to the environment.
Halstead reported that HR3053 would eliminate the prohibi/on on opening an MRS (Monitored Retrievable Storage facility, another name for CISFs) in Nevada, risking de facto permanent surface storage. HR3053 would also accelerate the NRC licensing process, by providing certain land and water rights to DOE, and expedi/ng the NRC licensing proceeding, and changing licensing procedures.
This could effec/vely gut fair hearings on the State of Nevada’s more than 200 legal and technical conten/ons, already having won hearings based on their merits.
Halstead also reported that major, significant Yucca Mountain funding uncertain/es remain, despite passage of HR3053 on the House floor on May 10, 2018. HR3053 also violates the Blue Ribbon Commission Final Report, as via non-consent based si/ng, as well as retaining (even strengthening) Office of Civilian Radioac/ve Waste authority within DOE, rather than crea/ng an independent nuclear waste management organiza/on.
HR3053 also authorizes CIS, and allows DOE to take /tle and liability for commercial irradiated nuclear fuel at MRS facili/es. Consent-based si/ng is required for MRS facili/es. However, ironically enough, consentbased si/ng is NOT required for permanent disposal at Yucca Mountain! HR3053 limits MRS facili/es to 10,000 metric tons.
Lake Michigan barge shipments (map)
An irony of Rep. Upton’s Yucca dump advocacy is the risk it would present to Lake Michigan. Lake Michigan is drinking water for 16 million people, and is headwaters for the Great Lakes downstream. They supply a total of 40 million people drinking water in the U.S. and Canada, and a large number of Na/ve American First Na/ons.
Dr. Gordon Edwards of CCNR has calculated that a mere 2 irradiated nuclear fuel assemblies, releasing their Sr-90 content into Lake Superior, would violate US EPA SDWA MCLs. Lake Superior is significantly more voluminous than Lake Michigan. Thus, even less Sr-90 that is contained in a couple irradiated nuclear fuel assemblies could violate US EPA SDWA MCLs if release into Lake Michigan. Each rail-sized cask on barges would hold 24 to 37 pressurized water reactor irradiated nuclear fuel assemblies.
IL road and rail routes (map) 
The irony of Shimkus’s sponsorship of HR3053 for IL is the large number of shipments origina/ng at reactors in other states that would pass through. IL has more atomic reactors than any other state – 14 altogether, 11 s/ll opera/ng (3 are undergoing decommissioning). But compare the number of IL HLRW exports, to the numbers of HLRW trans-shipments, origina/ng at reactors in other states, headed to Western dump-sites.
Under the mostly rail shipment scheme analyzed in DOE’s Feb. 2002 FEIS for the Yucca repository, 861 rail casks origina/ng at IL’s 14 reactors would be dwarfed in number, compared to the 6,166 shipments, origina/ng at reactors in other states, that would pass through IL, bound for the Southwest. Mostly rail s/ll would mean 1,071 Legal Weight Truck (LWT) cask shipments via interstate highway. For IL, not a single one would have originated at an IL reactor!
The greater Chicago area would be hard hit, especially on the south and west sides, including within just several miles of the heart of downtown, due to such rail rou/ng constraints.
Senate E&W Appropria/ons
Lamar Alexander (R-TN) is the chairman of the U.S. Senate Appropria/ons Commiqee subcommiqee on Energy & Water Appropria/ons. Diane Feinstein (D-CA) is the Ranking Member. Both are more interested in CIS than in the Yucca dump. Feinstein could be responding to clamor from some near San Onofre to “get it out of here, we don’t care where it goes, nor how it gets there.”
LA road and rail routes (map) 
But ironically enough, Sen. Feinstein and the NIMBYs in southern CA should care how it goes – study the large impacts shipments would have on the greater LA metro region. Barge shipments from Diablo Canyon nuclear power plant, into Oxnard, could significantly increase the HLRW shipping impacts on LA. In other words, be careful what you wish for…
We Do NOT Consent!  (photo) 
The Western Shoshone do not consent to the Yucca Mountain dump
• The State of NV does not consent to the Yucca Mountain dump
• A growing groundswell in NM and TX do not consent to CISFs
• Transport corridor communi/es in 44 states or more do not consent to Mobile Chernobyls, Floa/ng Fukushimas, and Dirty Bombs on Wheels
It has been 76 years since Enrico Fermi generated the first HLRW of the Atomic Age, in his Chicago Pile-1 reactor during the Manhaqan Project. And we s/ll don’t know what to do with that first cupful! It has been 61 years since the first “civilian” reactor was built – by the U.S. Nuclear Navy! – at Shippingport, PA. And we s/ll don’t know what to do with the irradiated nuclear fuel from it!
Summary/Conclusion • We oppose waste generation • We oppose current risky pool and inadequate dry cask storage • We oppose the Yucca Mountain dump and Centralized Interim Storage Facili/es • We oppose unnecessary, high-risk HLRW shipments • We advocate for Hardened On-Site Storage, as close as possible to the point of generation. This is an urgently needed and long overdue safety, security, health, and environmental protection upgrade.

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