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Centralized Storage

With the scientifically unsound proposed Yucca Mountain radioactive waste dump now canceled, the danger of "interim" storage threatens. This means that radioactive waste could be "temporarily" parked in open air lots, vulnerable to accident and attack, while a new repository site is sought.

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Tuesday
Feb072017

Risks of “Routine” or “Incident-Free” Shipments Nonetheless Being Like “Mobile X-ray Machines That Can’t Be Turned Off,” and Risks of Externally Contaminated Shipments

Sample comments you can use to prepare your own for submission to NRC (pasted in below; also posted online here as .pdf and .docx documents):

Risks of  “Routine” or “Incident-Free” Shipments Nonetheless Being Like “Mobile X-ray Machines That Can’t Be Turned Off,” and Risks of Externally Contaminated Shipments

Even “routine” or “incident-free” shipments of irradiated nuclear fuel carry health risks to workers and innocent passers by. This is because it would take so much radiation shielding to completely hold in the gamma radiation, being emitted by the highly radioactive waste, that the shipments would be too heavy to move economically. So NRC has compromised, and “allows” for or “permits” a certain amount of hazardous gamma radiation to stream out of the shipping container.

NRC’s regulations allow for up to 10 millirem per hour (mR/hr) of gamma radiation to be emitted, about six feet (two meters) away from a shipping cask’s exterior surface. That’s about one to two chest X-rays worth of gamma radiation, per hour of exposure.

Since the radiation dissipates with the square root of the distance, this means that  NRC’s regulations “allow” for up to 200 mR/hr, at the surface of the cask’s exterior. That’s 20 to 40 chest X-rays worth of gamma radiation, per hour, which NRC “allows” to stream out, right at the cask’s surface.

NRC has done a cost-benefit analysis – the cost, to human health; the benefit, to the nuclear power industry’s bottom line – and deemed these exposure levels “acceptable” or “permissible.” (“Permissible” or “acceptable” should never be confused with “safe” or “harmless” – exposures to 200 mR/hr, or even 10 mR/hr, still carry health risks. After all, any level of radiation, no matter how small, has long been confirmed to cause cancer. For more information, see: https://web.archive.org/web/20160325141005/http://www.nirs.org/press/06-30-2005/1)

The humans actually harmed by these exposures to hazardous radioactivity – related to the industry’s NRC-approved, unnecessary shipments, for example – might beg to differ! But of course, any negative health impacts associated with irradiated nuclear fuel shipments will not be closely tracked (or tracked at all) by NRC, or any other government agency for that matter. NRC and industry almost always downplay the health risks, and would almost certainly deny any connection between such exposures and negative health outcomes.

Six feet away could affect a person standing beside a train track, as the train goes by. Some real world examples of this situation include the Takoma Metro Station near Takoma Park, Maryland – the Red Line Metro Station platform is right beside the CSX railway, which is targeted for trains to haul irradiated nuclear fuel from the Calvert Cliffs, MD and North Anna, VA nuclear power plants, such as bound for WCS, TX.

Although further than six feet away, residences located immediately adjacent to these same CSX rail lines in Tacoma, D.C. mean that those living there could well be exposed to gamma radiation, although at a lower dose rate (again, the dose rate decreases inversely with the square root of the distance). However, residents can be expected to be present in their homes a lot more often than commuters standing on a Metro platform – including during sleep hours, when trains carrying irradiated nuclear fuel could still go by. And of course, residents along these tracks, would also be commuters standing on the platform, leading to multiple exposures in their daily (and nightly) lives, for years on end during a WCS shipping campaign.

Trains pausing next to commuter platforms or residences will prolong these potentially hazardous exposures. Paused trains – even ones carrying ones carrying hazardous cargos – are commonplace in the U.S. Pauses can sometimes last a long time. Lead cars stuck by paused trains at railroad crossings could mean the occupants of those cars are exposed to gamma radiation. Even a rolling train car would emit a certain dose as it passed by, to lead car occupants stopped nearest the tracks.

Similar situations will arise across the U.S. Innocent passers by, whose daily lives bring them in close proximity to railways or waterways that would be used to ship irradiated nuclear fuel, mean that ordinary people would be exposed to hazardous gamma radiation in some amount greater than zero – perhaps repeatedly, over the course of years during a WCS, TX shipping campaign.

The 200 mR/hr “acceptable” dose rate at the surface of shipping casks would most likely impact workers – locomotive engineers, railway workers, inspectors, security guards, etc.

However, when, in 2003, the Big Rock Point reactor pressure vessel (albeit so-called “low” level radioactive waste, it still serves as a cautionary tale) was shipped by heavy haul truck into Gaylord, Michigan to be loaded onto a train, for its shipment by rail to Barnwell, South Carolina, to be buried in a ditch, neither the nuclear utility, Consumers Power, nor the NRC (nor any other federal or state agency), nor local law enforcement, created a security or safety or health perimeter around the shipping container. As if it were a parade, onlookers were allowed to simply approach the shipping container, walk right up to it, and even touch it. In fact, a parade would probably have had better health, safety, and security precautions in place! (See 2003 written entries, as well as a photo, about this and other incidents that occurred during this single shipment, posted online at: https://web.archive.org/web/20151211005008/http://www.nirs.org/radwaste/hlwtransport/mobilechernobyl.htm). WCS would involve 4,000 irradiated nuclear fuel shipments into the Andrews, TX parking lot dump; and an equal number out, if the waste ever were to leave.

Likewise, Bob Halstead, several years ago, was able to guide a camera crew deep into the heart of a rail yard, just off downtown Chicago, that would be used to temporarily store (albeit, “temporarily” could last for days) train cars holding irradiated nuclear fuel. Security was nowhere to be seen. (Halstead, then serving as transport consultant to the State of Nevada Agency for Nuclear Projects, now serves as the agency’s director.)

Similary, Rick Hind of Greenpeace U.S.A. guided a Wall Street Journal reporter deep into the heart of underground train tunnels under Washington, D.C. The graffiti and art on the walls showed clearly that the tunnels are frequented by human beings. (Hind was showing the reporter how insecure such tunnels, even the nation’s capital, are to potential security risks, even as hazardous train cargos – including chlorine shipments – pass by.)

In these ways, that 200 mR/hr “permissible” dose rate could impact not only workers, but even members of the public.

In this sense, even “routine” or “incident-free” shipments of irradiated nuclear fuel can be considered as similar to mobile X-ray machines that can’t be turned off, a phrase describing the concept first expressed by Lauren Olson, a supporter of NIRS.

To make matters worse, there have been large numbers of shipments, externally contaminated with radioactivity, making their actual dose rates much higher – and thus more hazardous – in serious violation of the already compromised “permissible” or “acceptable” levels.

Areva – a key partner in the WCS proposal – at its home base in France, experienced just such a plague or epidemic of externally contaminated shipments. A full 25% to 33% of Areva’s irradiated nuclear fuel shipments, into its La Hague reprocessing facility, were externally contaminated, for years on end, above “permissible” levels. This amounted to many hundreds of individual shipments, contaminated above “permissible” levels, over the course of several years. On average, the shipments were giving off radiation dose rates 500 times the “permissible” level; in one instance, a shipment was emitting radiation 3,300 times the “acceptable” level.

Environmental watchdogs and journalists revealed this contaminated shipment scandal. See the WISE-Paris write up, Transport Special - Plutonium Investigation n°6/7, posted at http://www.wise-paris.org/ under Bulletins.

But such externally contaminated shipments have happened in the U.S., as well. Halstead documented this in a report prepared for the Nevada State Agency for Nuclear Projects in 1996. It is entitled “Reported Incidents Involving Spent Nuclear Fuel Shipments, 1949 to Present.” 49 “surface contamination” incidents are documented. This report is posted online at: http://www.state.nv.us/nucwaste/trans/nucinc01.htm.

Tuesday
Feb072017

Mobile Chernobyl shipping risks

Sample comments you can use to prepare your own for submission to NRC (pasted in below; also posted online here as .pdf and .docx documents):

Mobile Chernobyl shipping risks

Eunice, New Mexico (four miles from WCS, across the TX/NM border) has the dubious distinction that every single train car load of high-level radioactive waste will pass through on its way into (and, if it ever leaves, out of) WCS. But transport impacts, to import more than half the irradiated nuclear fuel in the U.S. into West Texas, will be felt nation-wide. In that sense, when it comes to radioactive waste transportation, we all live in Eunice, NM.

But a parking lot dump at WCS would only increase safety risks. It would not decrease them. It would multiply transport risks, as it would only be temporary (supposedly). All that highly radioactive waste would have to move again, to a permanent burial site (yet to be identified – that’s a big IF!). And that could be back in the same direction from which it came in the first place!

WCS’s assumption that the dump at Yucca Mountain, Nevada will open someday, to take the high-level radioactive waste away, is inappropriate. The vast majority of Nevadans has expressed its very adamant non-consent for 30 years now, and still vehemently oppose it. This is reflected by bipartisan resistance by elected officials, at both the state government level, as well as the congressional delegation level.

WCS’s assumption that another permanent burial dump will be opened, by someone, somewhere, someday, somehow, is also inappropriate. After all, the search for a national geologic repository has gone on since the 1950s, but has failed. And DOE’s current estimate for the opening of the U.S.’s first repository is 2048, 31 years from now. Except they have no idea where that will be. There is every likelihood that 2048 date will slip into the future as well.

The failed Private Fuel Storage, LLC parking lot dump targeted at the Skull Valley Goshutes Indian Reservation in Utah, likewise assumed the Yucca dump would open. They were, of course, incorrect.

So PFS’s “Plan B” was to “return to sender.” If 40,000 metric tons of irradiated nuclear fuel – the same amount targeted to go to WCS, isn’t that curious?! – what would that “return to sender” policy have looked like?

Maine Yankee was a PFS consortium member. More than 50 rail sized containers of irradiated nuclear fuel would have traveled 5,000 miles round trip, accomplishing absolutely nothing, other than exposing millions of people in numerous states to high-risk shipments.

Another version of this is the fact that permanent burial sites could be located right back in the same direction from which the waste came in the first place. In fact, at one time, DOE was targeting two sites in Maine, seven sites in Vermont, and two sites in New Hampshire, for permanent burial dumps. (See Beyond Nuclear’s backgrounder, re: the NH targets, at: http://static1.1.sqspcdn.com/static/f/356082/24115710/1487366549330/New_Hampshire_dump_final+draft.pdf?token=ZDgyvKfq8uxG4HPqWmvVvXBuwmY%3D).

This game of high-risk, high-level radioactive waste musical chairs, or hot potato, on the roads, rails, and waterways, is unacceptable. It amounts to Radioactive Russian roulette. Multiplying transport risks for no good reason is wrong, and makes no sense.

The Nuclear Assurance Corporation’s Quality Assurance (NAC QA) failures mentioned above are very significant to shipping risks. Shipping casks would be less capable of withstanding severe accidents (such as high-speed crashes, including into immovable objects, like bridge abutments; high-temperature, long-duration fires; deep, long-lasting underwater submersions; drops from tall heights, onto unyielding surfaces, such as bridge foundations; or some combination of all those), as well as intentional attacks (such as with shaped charges, or anti-tank weapon systems – see below) or other powerful explosions (such as explosive cargoes on passing trains, including, nowadays, crude oil “Bomb Trains,” as from the Bakken oil fields in North Dakota).

Adding to these shipping risks, is the potential for barge shipments on surface waters. WCS is supposed to be "mostly rail" -- which can also mean many barges (26 reactors in the U.S. lack direct rail access, meaning barges on surface waters -- the Great Lakes, rivers, seacoasts -- could be used to haul the 100+ ton, rail-sized casks to the nearest rail head). Backgrounders (including more details on the high risks) on these various barge routes (including maps) were originally written for the Yucca dump scheme; however, WCS could just as well involve such barges.

DOE’s Feb. 2002 Yucca Mountain Final Environmental Impact Statement gives a preview of barge shipments that could well be required to ship high-level radioactive waste to WCS, TX. The following barge shipment routes were proposed under the Yucca Mountain plan:

(See NIRS factsheets on barge shipments of deadly high-level radioactive waste on waterways, by state, posted online September 28, 2004):

<https://web.archive.org/web/20160331033728/http://www.nirs.org/factsheets/mdbargefactsheet92804.pdf>

<https://web.archive.org/web/20160331033736/http://www.nirs.org/factsheets/vabargefactsheet92804.pdf>

<https://web.archive.org/web/20160331032838/http://www.nirs.org/factsheets/debargefactsheet92804.pdf>

<https://web.archive.org/web/20160331034044/http://www.nirs.org/factsheets/nybargefactsheet92804.pdf>

<https://web.archive.org/web/20160331020332/http://www.nirs.org/factsheets/mabargefactsheet92804.pdf>

<https://web.archive.org/web/20160327081932/http://www.nirs.org/factsheets/mibargefactsheet92804.pdf>

<https://web.archive.org/web/20160331080128/http://www.nirs.org/factsheets/lamsbargefactsheet92804.pdf>

<https://web.archive.org/web/20160331063817/http://www.nirs.org/factsheets/tnalbargefactsheet92804.pdf>

<https://web.archive.org/web/20160331020303/http://www.nirs.org/factsheets/nemoksbargefactsheet92804.pdf>

<https://web.archive.org/web/20160331030740/http://www.nirs.org/factsheets/cabargefactsheet92804.pdf>

<https://web.archive.org/web/20160331035101/http://www.nirs.org/factsheets/flbargefactsheet92804.pdf>

(However, with something as simple as a rushed NRC rubber-stamp amendment, WCS could apply for, and quickly get, permission to truck in smaller-sized, "Legal Weight Truck" (LWT) casks to WCS. This mix of trains/barges and trucks, would mean even more American communities would be exposed to Mobile Chernobyl risks.)

Dirty Bomb on Wheels security risks would abound. This was made clear by the test of an anti-tank missile against an (empty) irradiated nuclear fuel shipping cask at the U.S. Army’s Aberdeen Proving Ground in Maryland. The June 1998 test targeted a German CASTOR cask. While certified for storage-only in the U.S. (the cask model is deployed at Surry, VA), it is widely used for transport in Europe. CASTORs have thick die cast iron walls, as opposed to thin walled steel casks in the U.S. That is, CASTORs are significantly more robust, more capable to withstand such an attack. However, even the CASTOR, the Cadillac of shipping casks as some have called it, was severely breached by the anti-tank missile. A hole as big around as a grapefruit or softball was blown clean through the side wall. Had irradiated nuclear fuel been inside, the hole would have created the pathway for release of disastrous amounts of hazardous radioactivity – all the more so, if an incendiary attack were combined with the explosive attack. In short, shipping containers were not designed to withstand such attacks. See:

<https://web.archive.org/web/20150908070611/http://www.nirs.org/factsheets/nirsfctshtdrycaskvulnerable.pdf>.

Thursday
Feb022017

SEED Coalition & Public Citizen sample comments, re: WCS, TX centralized interim storage, for submission to NRC environmental scoping proceeding

Karen Hadden of Sustainable Energy & Economic Development (SEED) Coalition and Tom "Smitty" Smity of Public Citizen's Texas Office have provided the following environmental scoping sample public comments, below, you can use to write your own, for submission to the U.S. Nuclear Regulatory Commission (NRC) by its March 13, 2017 deadline.

Karen adds:

Please share!

The NRC scoping letter [sample comments] is the important one to work off of right now. It can be sent as is, edited, or write your own letter [comments].

It's important to ask for a hearing [an NRC public comment meeting] -- in your area -- to address transport risks, and to say how close you are to rail lines or if you cross them daily.

Thanks! We need as many letters as possible and they need to be in by March 13th.

This is more important than travelling to the meetings here [in w. TX & s.e. NM] -- and carries as much weight with NRC.


SAMPLE COMMENTS:

 

Cindy Bladey

Office of Administration

Mail Stop: OWFN-12-HO8

U.S. Nuclear Regulatory Commission,

Washington, DC 20555-0001

 

RE: Docket No. 72-1050; NRC-2016-0231  Waste Control Specialists LLC’s Consolidated Interim Spent Fuel Storage Facility Project

Feb. 2, 2017

Dear Cindy Bladey and NRC,

Waste Control Specialists’ (WCS) application to import tons of spent fuel, high-level radioactive waste, from nuclear reactors around the country and store it in Andrews County for 40 years (or longer) should be halted in order to protect public health and safety, including the health and safety of my constituents.

The Environmental Impact Statement (EIS) for Waste Control Specialists’ license application should include a designation of transportation routes and the array of potential impacts of accidents or terrorism incidents that could occur along those routes. If the license gets approved, deadly waste would be transported through our region for 24 years. Even one small accident would be one too many. Despite assurances that accident damage would be minimal, real life disasters have been known to exceed the worst anticipated scenarios.

A 2014 Texas Commission on Environmental Quality report warns of potential sabotage of radioactive waste shipments, saying that such an incident would most likely occur in a large city rather than a rural area.  Terrorist actions involving radioactive waste in the San Antonio region would be an unimaginable nightmare.

The EIS should look closely into the risk of groundwater contamination at the site, especially since the entire TCEQ Radioactive Materials Division recommended denying a license for “low-level” radioactive waste at the Waste Control Specialists site due to the proximity of groundwater.

The EIS should consider potential impacts from accidents or radioactive waste related terrorist actions along transport routes and at the site, including impacts to people, land and water. In-depth research should examine radiation monitoring and cumulative impacts of multiple facilities near the WCS site, site security, engineering adequacy of the storage pad and seismic stresses, the adequacy of the crane that would move radioactive waste.

The report should include exactly how radioactive waste from a cracked and leaking canister would be handled, as it appears there would be no wet pool or hot cell at the WCS site. It appears that no one knows yet how to transfer waste from dry cask to dry cask. WCS should have to explain how this would be accomplished and not just say they’ll figure it out when the problem arises.

Please know that we don’t consent to becoming a national radioactive waste dumping ground. We should not have to risk contamination of our land, aquifers or air or the health of plants, wildlife and livestock. Human exposure to high-level radioactive waste can lead to immediate death.

Homeowners’ insurance doesn’t cover radioactive contamination. A single rail car could haul waste containing as much plutonium as the bomb dropped on Nagasaki. We’ve had serious train accidents in our region. Two trains have collided head-on in West Texas last year at 65 mph. I understand that cask testing has been conducted for accidents up to 60 mph, but this scenario has already been exceeded. The EIS should address these risks.

The EIS should address the impacts of “interim storage” becoming dangerous permanent de facto disposal, and the waste might never be disposed of in a scientifically viable geologic repository using a reliable isolation system. With political pressure gone, the waste would likely never move again.

Above-ground casks would be exposed to the weathering effects of temperature extremes, and potential wildfires, tornadoes and earthquakes. The EIS should address these issues and answer the following questions: At what point could the waste go critical? What interactions of these circumstances and contact with other radioactive waste and hazardous materials at the WCS site could occur? What are the cumulative impacts of waste at this site and nearby sites on workers, local people and the environment, and how could natural disasters impact add to impacts?

Please host a hearing on the WCS application so that those of us who would be put at risk can address the NRC on this important issue. I would appreciate a written response.

Sincerely,

Your Name:

Your Postal Address:

Your Email:

Your Phone:

Additional Comments:

Tuesday
Jan312017

Urgent! WCS Radioactive Waste Threat Moves Forward...2 NRC meetings [in NM & TX; a 3rd to be held in Rockville, MD]

This action alert comes from Karen Hadden at SEED Coalition in Texas:
Please help spread the word! 
Hi Everyone, Federal register postings are online today - look under Nuclear Regulatory Commission for two postings about WCS at this link: https://www.federalregister.gov/documents/2017/01/30
The WCS license application has been deemed complete, starting the clock for people to 
1) submit scoping comments on the environmental review (March 13 deadline) and to request a public hearing and 
2) to intervene in the licensing process to oppose having the nation’s deadliest radioactive waste dumped on Texas and New Mexico (March 31 deadline - with a requirement to set up a digital ID if you want to file documents electronically).
Tom “Smitty” Smith, Former State Rep. Lon Burnam, Kyle Amato and I are heading to West Texas/ NM to work with people who are concerned about this deadly threat to their backyards. The Waste Control Specialists plan unnecessarily poses risks around the state and the country from transport accidents and potential terrorist actions. 
People can speak up at two NRC meetings that are set to seek comments on the scope of the Environmental Impact Statement for Waste Control Specialists' (WCS’) proposed Consolidated Interim Storage Facility. Comments can also be submitted by mail and electronically, with a deadline of March 13, 2017.  Please come to one or both of the meetings if you can: 
February 13, 2017  Lea County Event Center, 5101 N. Lovington Highway, Hobbs, NM  88240 -  6 PM Open House, 7 PM meeting 

February 15, 2017  James Roberts Center 855 TX-176, Andrews TX  79714    6 PM Open House, 7 PM meeting
This is an opportunity to tell the NRC should consider in their Environmental Impact Statement, and sometimes more importantly, what has been left out that should be considered.  You can look at what they have for environmental reviews here:  https://www.regulations.gov/document?D=NRC-2016-0231-0005  
If you read this you’ll be able to think about what they’re missing and what should be considered. 
Again, comments for this scoping process are due March 13th.  Anyone can comment. 
You may want to consider requesting a public hearing and becoming an intervenor. Please be thinking about how this project threatens you and your family and why it poses risks for you. 
More news will be coming… including dates and times of local organizing meetings in the Feb. 8-11th timeframe in West Texas. 
Another way you can help is to donate money toward our organizing and legal expenses. Checks can be sent to SEED Coalition, 605 Carismatic Lane, Austin, TX  78748. 
We are happy to talk to anyone who’d like to donate in other ways or help with grant funding - Karen Hadden, 512-797-8481 
Thursday
Jan262017

In dangerous collusion with WCS, NRC sets breakneck schedule for rubber-stamping high-level radioactive waste parking lot dump

Maps showing the national and TX-specific routes for commerical irradiated nuclear fuel railway shipments to WCS.On Jan. 26, 2017, the U.S. Nuclear Regulatory Commission (NRC) announced "NRC to Review WCS Application, Announces Hearing Opportunity and Meetings on Scope of Environmental Review."

(Actual federal register links, now posted:

https://www.gpo.gov/fdsys/pkg/FR-2017-01-30/pdf/2017-01966.pdf

https://www.gpo.gov/fdsys/pkg/FR-2017-01-30/pdf/2017-01973.pdf

Also see the WCS application and review website at NRC's website.)

The NRC will accept public comments on the Waste Control Specialists, LLC (WCS) "centralized interim storage" site (de facto permanent parking lot dump) only until March 13, 2017.

In-person meetings will be held in Hobbs, New Mexico on Feb. 13; in Andrews, Texas on Feb. 15; and at NRC's HQ in Rockville, MD after that (supposedly the week after the NM & TX meetings, but the exact date/time has not yet been announced).

NRC has stated:

The NRC’s Jan. 26 letter to WCS sets a schedule for its safety and environmental reviews, with a target of making a licensing decision by the third quarter of fiscal year 2019, assuming WCS provides high-quality responses, on schedule, to any NRC requests for additional information. The public will have 60 days from publication of a notice of docketing in the Federal Register,which will appear shortly, to submit requests for a hearing and petition to intervene in the licensing proceeding for the proposed facility. Details on how to submit those requests and petitions will be in the Federal Register notice. (Emphasis added)

A national coalition of environmental, environmental justice (EJ), public interest and other groups is gearing up to challenge this WCS parking lot dump, just as a national coalition opposed the Private Fuel Storage, LLC (PFS) "centralized interim storage" parking lot dump. PFS was very actively targeted -- by the nuclear power industry and its rubber-stamp friends at NRC -- at the Skull Valley Goshutes Indian Reservation in Utah, from the mid-1990s to the mid-2000s. Despite NRC's rubber-stamp approval of the radioactively racist PFS dump, it was nonetheless stopped by the national coalition (including 437 EJ groups), led by Native Americans, including anti-dump traditional members of the Skull Valley Goshute Indian community, namely Margene Bullcreek and Sammy Blackbear. (More info. on the PFS fight is posted at the NIRS website.)

Having dodged that radioactive bullet, here comes another one (more like a radioactive cannon ball, or even nuclear attack!).

As with the Yucca dump targeted at Western Shoshone Indian land in Nevada (see Beyond Nuclear coverage; see NIRS coverage), so too is WCS an environmental injustice, radioactive racism: Andrews County, Texas is 40% Hispanic/Latin American, with a significant percentage of residents living in poverty. Neighboring communities just across the New Mexico state line (WCS is right on the border, and in fact New Mexico is downstream) have similar demographics.

And yes, as with Yucca, and PFS, WCS raises the specter of Mobile Chernobyls, Fukushima Freeways, Dirty Bombs on Wheels, and Floating Fukushimas (see NIRS coverage; see Beyond Nuclear coverage). Just as with Yucca's "When it comes to radioactive waste transportation, we all live in Nevada," so too with WCS -- "When it comes to radioactive waste transportation, we all live in Andrews, Texas." (See rail route maps, above left; click here for a larger, more legible version of the route map. See also the national railway shipping routes map WCS included in its license application Environmental Report.)

WCS is supposed to be "mostly rail" -- which can also mean many barges (26 reactors in the U.S. lack direct rail access, meaning barges on surface waters -- the Great Lakes, rivers, seacosts -- could be used to haul the 100+ ton, rail-sized casks to the nearest rail head). Backgrounders (including more details on the high risks) on these various barge routes (including maps) were originally written for the Yucca dump scheme; however, WCS could just as well involve such barges:

However, with something as simple as a rushed NRC rubber-stamp amendment, WCS could apply for, and quickly get, permission to truck in smaller-sized, "Legal Weight Truck" (LWT) casks to WCS -- something we'll also have to carefully guard against vigilantly.

For more info. on the risks of "centralized interim storage" (de facto permanent parking lot dumps), see Beyond Nuclear's relevant website section.

As with Yucca, PFS, etc., it will take a determined national grassroots movement effort to stop WCS from becoming a national parking lot dump, and launching unprecedented numbers of Mobile Chernobyls. As Karen Hadden of SEED Coalition has said, this is the fight of a lifetime. [See Karen's action alert from Jan. 31, 2017.] As the saying from the Civil Rights Movement put it, if you see a good fight, jump in!

Our first major deadline is NRC's breakneck rushed deadline of mid-March for public comments on the WCS parking lot dump environmental scoping, precursor to NRC's Draft Environmental Impact Statement. (Which we will also have to comment on down the road.) Beyond Nuclear, and other groups, will circulate sample talking points in the near future, which you can use to write your own to submit to NRC. Stayed tuned!

[Here are links to sample comments, now posted, with more to follow:

Sample comments you can use to write your own:

SEED Coalition & Public Citizen's Texas Office have prepared sample comments you can use to write your own for submission to NRC by the March 13, 2017 deadline;

Public comments previously submitted to the U.S. Department of Energy (DOE) for a proceeding re: Private Initiatives to carry out centralized interim storage can now also be used -- "recycled," so to speak! -- to prepare comments to NRC re: WCS's scheme (the comments to DOE were due Jan. 27, 2017)]

Another big showdown will be at the public meetings themselves, breakneck rushed by NRC for mid-Feb. in West Texas and Southeast New Mexico.

A coalition of groups will also, undoubtedly, be officially intervening against the WCS license, in NRC's rubber-stamp/kangaroo court Atomic Safety (sic) and Licensing Board proceeding, on a large number of health, safety, and environmental contentions. Public intervenors have until the end of March to file, or forever hold their peace.

Shame on NRC for its obvious collusion, as with the breakneck deadlines, designed to overcome and overwhelm (largely volunteer) public resistance. In 2012, the Japanese Parliament concluded that just such collusion -- between regulatory agency, nuclear power industry, and elected officials -- was the root cause of the Fukushima nuclear catastrophe. Such collusion exists in spades, re: the WCS parking lot dump -- involving NRC and DOE, WCS and the nuclear power industry, and TX politicians (including former governor Rick Perry, now poised to become Trump's Energy Secretary, despite his blatant conflict of interest, not to mention the huge costs, risks, and liabilities this would mean for U.S. taxpayers). Such collusion is how radioactive catastrophes happen, and these various "public servants" (serving the public up for dinner, that is, to WCS and the nuclear power industry!) are all too willing to play this high-risk game of radioactive Russian roulette.

[By the way, there is still time to take action against Perry's confirmation as Energy Secretary. Contact both your U.S. Senators, and urge they vote against Perry's confirmation! Do so ASAP, the Senate floor vote could happen any day now! Here is Beyond Nuclear's action alert from a week ago:

Will Rick Perry privatize America's radioactive waste storage?

As reported at Mother Jones. See Beyond Nuclear's exposé on Energy Secretary-nominee Rick Perry's blatant conflict of interest with Waste Control Specialists, LLC, published at CounterpunchTake action ASAP -- sign multiple petitions, and contact your two U.S. Senators, urging them to block Perry's confirmation! Also, submit comments to the U.S. Department of Energy, opposing private permanent parking lot dumps for high-level radioactive waste!]

A particularly egregious example of the corrupting influence of the revolving door between "public service" (government) and industry is John Kotek:

The very person who ran DOE’s “consent-based siting” proceeding, declared WCS itself “consent-based,” rejected the need to get consent from transport corridor communities, and very narrowly construed the definition of “consent” – DOE’s acting assistant secretary in the Office of Nuclear Energy since July 2015, John Kotek — has now shown his true colors. Kotek will now serve at the nuclear power industry’s lobbying and PR HQ in Washington, D.C. – the Nuclear Energy Institute (NEI) — as vice president for policy development and public affairs.

In fact, Kotek "served" as staff director at President Obama's and Energy Secretary Chu's Blue Ribbon Commission on America's Nuclear Future. The bad faith, the collusion, and the high-speed revolving doors and rubber stamps, in the nuclear power/radioactive waste governmental-industrial complex, is embodied in people like John Kotek.

Making NRC's breakneck schedule and high-speed collusion all the more ironic is how long commercial irradiated nuclear fuel remains hazardous: a million years, EPA was forced to admit in 2008, under federal court order, hard won by an environmental coalition in the Yucca Mountain fight. In fact, even a million years is an underestimate, when you consider Iodine-129, as but one example: I-129, an artificial radioactive poison, has a half-life of 15.7 million years, so will remain hazardous (to children, and other living things) for 157 to 314 million years!

Of course, "centralized interim storage" de-linked or un-connected from permanent geologic disposal, as WCS is, makes no sense. It merely multiplies transport risks, as the wastes would have to be moved again in the future, to the permanent dump-site. In fact, that permanent dump-site could well be right back in the same direction from which the wastes came in the first place. This would create a high-stakes game of radioactive musical chairs, or radioactive hot potato, on the roads, rails, and/or waterways! 

This nearly happened at PFS in UT. The PFS scheme called for "interim" storage, for 20-40 years, until the Yucca Mountain dump opened in Nevada. But President Obama and Energy Secretary Chu wisely canceled the scientifically unsuitable, non-consent-based, environmentally unjust/radioactively racist (targeted at Western Shoshone Nation sacred treaty lands) site in 2009-2010. "Plan B" at PFS, if Yucca was not available, was simply to "return to sender."

Maine Yankee is a startling case in point. 50+ giant rail-sized containers of high-level radioactive waste would have been shipped from Wiscasset, ME, through many states, 2,500 miles out to Skull Valley Goshutes Indian Reservation in Utah. Only to be shipped back to ME. 5,000 miles of round-trip Mobile Chernobyl risks, accomplishing absolutely nothing in the end! 

Given such absurdities, the risks of a de facto permanent parking lot dump are all the greater. Once wastes are "consolidated" or "centralized" in one congressional district, good luck ever moving them out, ever again. Right now, the U.S. Representative for Andrews County, TX is blinded by dollar signs, and thinks a parking lot dump at WCS is a good idea. But if a future U.S. Rep. for that district thinks it's high time to move the wastes, as to a permanent dump-site, that would make for an uphill battle. It would be one U.S. Rep. versus 434 others, who would likely be just fine with it staying in West Texas, so long as it doesn't travel through, or get buried permanently in, their congressional district!

As you can see, we need all the help we can get, to stop all this nuclear madness, to borrow a phrase from our founding president, Helen Caldicott. Please help us! Please spread the word! See you on the front lines of the fight for environmental justice, in the battle for a nuclear-free future! Thanks!