CALL IN TO COMMENT ON THE Nuclear Regulatory Commission draft Environmental Impact Statement for 
 
Supposedly "Interim" Nuclear Waste Dump and Massive Transport Across the US for Decades
 
Oct 1, 6, 8, 15th
 
We have 4 Chances left to let the Nuclear Regulatory Commission know we don't want nuclear waste moved across the country for 40 years to a supposedly temporary site! They refuse to wait until after COVID 19 crisis and hold in-person meetings in TX or along the routes to get the waste there.
 
Please call in on Oct 1, 6, 8 and/or 15th. TEXANS are asking for AS MANY AS POSSIBLE TO CALL IN THIS THURS OCT 1st 
 
Please Call in to the Nuclear Regulatory Commission's "Public Meeting" on the 
draft Environmental Impact Statement for the proposed HIGH LEVEL NUCLEAR WASTE SITE in Andrews TX this  
THURSDAY OCT 1st 
from 6-9 PM eastern/ 5-8 PM central/ 4-7 PM mountain/ 3-6 PM pacific/ 2-5 PM alaska
 
Talking points below
 
 
CALL IN NUMBER  (888) 989-9268 Pass Code 5300047#   TO get in line to speak PRESS *1 and give your name.
Here is the Link to see the power point slide Webinar: URL  https://usnrc.webex.com/ Meeting Number 199 125 5213    Password  ISPDEIS
(They might post a link to download the powerpoint in advance so we can download it in advance and not have to join by computer webex but they might not.)
 
The first 30-40 minutes will be a power point presentation by NRC describing that all environmental impacts are small or moderate 
[even though it is from bringing in and storing the majority of the radioactivity in the nuclear power and weapons complex...
they won't be mentioning that it's such an enormous part of the nuclear waste generated in the country since the dawn of the nuclear age 
but they will tell us it can't possibly have a Large Impact]
 
Then public comments usually 2-3 minutes each 
 
All previous NRC calls have had people who want to speak Push *1 to get in the queue. You can do this at any time-the sooner you do it the sooner you get to speak at least in theory.
 
The 4 meetings are
 
THURS OCT 1 from 5-8 Central Time
TUES OCT 6 from 1- 4 Central Time
THURS OCT 8 from 5-8 Central Time
THURS OCT 15 from 10-1 Central Time
 
Details on each session are at www.nonuclearwaste.org 
 
 
TALKING POINTS
 
Waste Control Specialists/ Interim Storage Partners propose bring in 40,000 Metric Tonnes of irradiated ('spent") nuclear fuel- the hottest waste in the nuclear power and weapons fuel chain....this is the waste from the cores of nuclear power reactors which can give a lethal dose unshielded in minutes and which will stay dangerous for more than 1 million years. The Draft Environmental Impact State for this proposal is here

Illegal-- CIS or Consolidated "Interim" Storage Facilities are illegal under federal law. Under the law, no "interim" or "temporary" storage site is allowed unless there is a final repository is operating...because the site would become de-facto permanent although not designed or licensed for permanent isolation of the waste
 
EJ- Sending the most deadly waste in the country to communities of color clearly violates Environmental Justice Principles. This region is largely Hispanic. Public Citizen and Lone Star Legal Aid did analyses showing that the people in the region would be disproportionately impacted. 
Transport across the country is through poorer communities, often communities of color so the movement of the waste for decades puts them at greater risk--and all of us who travel on roads, rails and waterways and live and work near transport corridors are being put at risk with no input. Requests for public meetings along the routes have been rejected so the project can move quickly despite the COVID 19 crisis hitting the whole country and poorer and people of color more so.
 
Synergistic effects of other facilities and industries  The proposed site is next 2 other operating nuclear facilities--Waste Control Specialists is a burial ground for nuclear waste and LES Urenco enriches uranium using dangerous chemicals. It is also in the Permian Basin home to the largest deposits of oil and gas in North America thus home to oil and gas drilling, fracking and processing. 
 
Effect on Water The TCEQ (TX Commission on Environmental Quality) technical team evaluating the neighboring waste site Waste Control Specialists Texas (WCS) unanimously recommended against the license and TO NOT TO PUT NUCLEAR WASTE THERE BECAUSE THE WATER RESOURCES WOULD NOT BE PROTECTED. The technical experts were ignored and the license granted for political reasons under Governor Bush. This is the SAME SITE targeted for HIGH LEVEL WASTE from nuclear power across the country.  The threat to the water cannot be "SMALL" or "MODERATE."
 
 
NO DTF Dry Transfer Facility- There is no shielded facility to repackage damaged fuel or containers-- without a fuel pool, the only other option is a Dry Transfer Facility. There is no plan to build a Dry Transfer Facility, or a fuel pool. How can NRC believe there will never be a need to recontainerize aging nuclear fuel that is in aging containers, especially when they are out in the open exposed to severe heat, cold, hail, flooding, tornados, earthquakes, possible wildfires and other extremes.
 
 
The ISP Draft Environmental Impact Statement (DEIS) is Misleading, Incomplete and Denies or Ignores Reality. It:
 
--Fails to assess the additional risk to the country that one or more CIS sites will cause. Not all waste will be moved from all nuclear power reactors sites to ISP/WCS (or to the Holtec site proposed nearby) thus the CIS sites are ADDITIONAL sites requiring massive transport risks, with no guarantee that the sites sending the waste will really be cleaned up.
 
--Incorrectly assumes only 40 years of storage even though the waste could be at the site far longer than that, potentially indefinitely. The DEIS incorrectly assumes there will be a permanent repository elsewhere, despite the only proposed permanent repository at Yucca Mountain having been rightly cancelled in 2010. The ISP/WCS application does not provide protections for long term or permanent isolation and the DEIS ignores this. The more-likely reality—i.e., that the waste will be at the site for much longer than the 40-year license period—is not addressed in the DEIS. This puts the air, water, soil and ecosystem at long term risk from radioactivity.
 
--Incorrectly assumes all waste and containers that arrive will be intact and waste will not need to be re-containerized for the decades it will remain at the WCS ISP site. The DEIS fails to address what happens when waste must be repackaged. The application and the DEIS should require a wet or dry transfer facility to shield the intensely radioactivity so it can be repaired or transferred to new containers. Workers, passers-by and the environs could receive massive, potentially lethal, gamma doses in that scenario--yet no assessment is provided in the DEIS.
 
--Fails to address the environmental impacts of returning damaged containers of high-level radioactive waste if they arrive in unacceptable condition. ISP’s plan is to "return to sender" with no analysis of the logically higher risk of transporting failed fuel and/or containers twice.
 
--Ignores potential higher risks from damaged fuel and high burnup fuel. 
 
--Fails to acknowledge or respect the institutional racism in selecting the ISP WCS site in West Texas. 
 
-- Fails to acknowledge impacts on all transport routes to the site. I call on NRC to hold in-person DEIS meetings all along the potential routes and to extend the comment period until six months after the COVID-19 crisis ends.
 
More talking points can be found at 
 
and
 
 
 
THANKS-- any questions please contact
 
Diane D'Arrigo
NIRS
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or 
 
Karen Hadden
SEED Coalition
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