Nuclear Regulatory Commission's Inadequate Treatment of Radioactive Waste Transport Risks

Strategic Insights -

The United States Nuclear Regulatory Commission's (NRC) draft Environmental Impact Statement (DEIS) for the Holtec/CISF dry nuclear waste storage facility has been criticized by Beyond Nuclear for its inadequate treatment of highly radioactive waste transport risks. The organization argues that the NRC has failed to take a "hard look" at the transport component of the proposed scheme, as required by the National Environmental Policy Act (NEPA). The NRC cites a 2008 Final Supplemental Environmental Impact Statement on the proposed Yucca Mountain, NV dump as an excuse for not conducting a Holtec-specific transport analysis.

Key Takeaways:

  • The NRC's DEIS fails to adequately address the high-risk transportation of radioactive waste, which is a critical component of the proposed Holtec/CISF scheme.
  • The NRC cites a 2008 DOE document as an excuse for not conducting a Holtec-specific transport analysis, despite the fact that the document was intended to inform the Yucca Mountain, NV dump project, not the Holtec/CISF project.
  • Beyond Nuclear has produced comprehensive route maps for road, rail, and water transport routes that would be used to haul highly radioactive waste across the country.
  • The NRC's DEIS and Holtec's Environmental Report exclude the high risks of transport and fail to be transparent about transport routes, violating NEPA and long-established federal court rulings.
  • The NRC's DEIS represents segmentation, dividing a major federal action into smaller parts to minimize its significance and impact.
  • The State of Nevada has produced a comprehensive map of transport routes based on the same 2008 DOE document that the NRC cites as an excuse for not conducting a Holtec-specific transport analysis.
  • Holtec's Environmental Report accounts for routes to New Mexico from only four of the 131 atomic reactors in the US, ruling out 127 reactors as potential sources of radioactive waste.
  • The shipping routes for radioactive waste are identical or similar across the country, regardless of the destination.

Statistics:

  • 131 atomic reactors in the US (95 still operating, 2 under construction, 34 permanently shut down) (Source: Holtec's Environmental Report)
  • 4 atomic reactors accounted for in Holtec's Environmental Report for transport routes to New Mexico (Source: Holtec's Environmental Report)
  • 127 atomic reactors not included in Holtec's Environmental Report for transport routes to New Mexico (Source: Holtec's Environmental Report)
  • 1 comprehensive map produced by the State of Nevada to inform the Yucca Mountain, NV dump project, used to criticize the NRC's DEIS (Source: Beyond Nuclear)

Sources:

  • Beyond Nuclear's public comment on the NRC's Holtec/ELEA CISF DEIS, Docket ID NRC-2018-0052 (June 27, 2020)
  • Holtec's Environmental Report (available online)
  • State of Nevada's comprehensive map of transport routes based on the 2008 DOE document (available online)
  • 2008 Final Supplemental Environmental Impact Statement on the proposed Yucca Mountain, NV dump (cited by the NRC as an excuse for not conducting a Holtec-specific transport analysis)