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.



Public comments opposing de facto permanent parking lot dump at WCS, TX needed by March 13!

Please note: The March 13th deadline has been extended till April 28th! However, it is still important to get public comments rolling into NRC ASAP. If you have time, please comment more than once -- addressing multiple of the many facets of this issue!

Public comments are needed in opposition to Waste Control Specialists (WCS) in West Texas, which seeks to open a de facto permanent parking lot dump for up to half the commercial high-level radioactive waste in the U.S., upstream of the Ogallala Aquifer, vital drinking and irrigation water supply for numerous High Plains states, from Texas to South Dakota.

The region around WCS has a high proportion of low income, Latin American residents, and is already heavily burdened with nuclear activities (radioactive waste dumping, uranium enrichment, etc.) and dirty fossil fuel industries (widespread, heavily polluting oil extraction and natural gas fracking). WCS would launch unprecedented numbers of high-risk irradiated nuclear fuel train (and even barge) shipments through many states.

Sample comments you can use to write your own:

(Beyond Nuclear sample comments on a variety of inter-related subject matter)

Mobile Chernobyl Shipping Risks (see here for WCS's own map, from its construction and operating licence application to NRC, showing the main line railways nation-wide that would be used to transport irradiated nuclear fuel from atomic reactors to West TX; see here for another map, made by SEED Coalition, which includes some Interstate highway routing that could also be used, if NRC were to rubber-stamp a license amendment by WCS to allow Legal Weight Truck shipments);

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;

Risks of De Facto Permanent Parking Lot Dump at WCS; 

Risks of Loss of Institutional Control if De Facto Permanent Parking Lot Dumps are Abandoned, Containers Fail, and Release Catastrophic Amounts of Hazardous Radioactivity into the Environment;

Why Are These Risks Being Taken?;

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);

Link to instructions on HOW (snail mail, email, as well as online web form) to submit your public comments to NRC by the March 13 deadline [per note above, the deadline has been extended till April 28th]

Please see entries below on Beyond Nuclear's Centralized Interim Storage website section, for more information.


Instructions on HOW to submit public comments to NRC re: WCS, TX centralized interim storage, by March 13 deadline

[Please note: The deadline for public comments has been extended, from March 13th, to April 28th. However, it is important for public comments to be rolling into NRC ASAP. Please consider submitting multiple comments, regarding the various aspects of this multi-faceted risk!]

HOW to submit your public comments:

Per the NRC's Jan. 30, 2017 Federal Register Notice:

You may submit scoping comments by the following methods:

• Email your comments directly to: <>. Comments can be submitted as text in the email(s) itself; any supporting documents can be direclty attached to the email(s). [Although not included in the Federal Register Notice, this email option was communicated to Beyond Nuclear's Kevin Kamps on Feb. 13, 2017 at the Hobbs, NM public meeting by James Park, NRC staff Environmental Review point of contact for this proceeding.]

• Federal Rulemaking Web site: Go to and search for Docket ID NRC–2016–0231. (Click here to be directly linked to the site.) Comments can be submitted via the webform; supporting documents can be attached.

[Address questions about NRC dockets to Carol Gallagher; telephone: 301–415–3463; email:]

• Mail comments to: Cindy Bladey, Office of Administration, Mail Stop: OWFN–12–H08, U.S. Nuclear Regulatory Commission, Washington, DC 20555–0001.

Per the note above, comments had been due by March 13, 2017, to ensure consideration, but the deadline has been extended till April 28th. Please comment ASAP, however, and please comment more than once. The quality and the quantity of comments do matter!


NRC environmental scoping mtg. for public comment on WCS, TX CIS: Thurs., Feb. 23, 1-4pm Eastern; please attend in person, by Webinar, or phone, and make comments!

The U.S. Nuclear Regulatory Commission (NRC) has, at long last, published the announcement for its quickly approaching HQ meeting, at its Rockville, MD HQ, re: WCS, TX's environmental scoping public comment opportunity, to be held on Thursday, February 23, 2017. Please attend in person if you can, or by Webcast/Teleconference Call-In. Please pre-register in advance to make oral public comments for the official record, raising various concerns in opposition to WCS's application.

NRC's announcement is posted at:

Here are those details and additional links:

Date/Time: 02/23/17, 1:00PM - 4:00PM


To conduct a public scoping meeting for the NRC’s Environmental Impact Statement (EIS) for Waste Control Specialist LLC (WCS) license application to construct and operate a consolidated interim storage facility (CISF) for spent nuclear fuel at the WCS site in Andrews County, Texas. At the meeting, the NRC will receive comments from the public on the appropriate scope of issues to be considered in, and the content of the EIS. [more...]

Participation: Category 3


[Here is the Webinar info.:


Webinar Link:
Webinar Meeting Number:None
Webinar Password:None

Here is the teleconference/call-in info.:


Bridge Number: 8006199084
Passcode: 3009542]

[Yes, comments can be submitted orally via the Webcast/Call-in options. Please sign up in advance -- see below -- and do make comments!]

Location [yes, in person attendance is an option, and oral comments can be made there]:

NRC One White Flint North
11545 Rockville Pike
Commission Hearing Room
Rockville MD

NRC Contacts:

James Park

Debbie Miller

From NRC's Public Meeting Schedule: Meeting Details link:

Members of the public who will attend the meeting in person, and those wishing to present oral comments [via Webcast and/or teleconference/call-in] may register in advance by contacting Mrs. Debra Miller at (301) 415-7359, or by email to, ASAP [same day registration should also be provided, as it was for in person sign up last week at meetings in TX and NM]. Those comments may be limited by the time available, depending on the number of persons who wish to speak. Please provide name and company or organization for each attendee. Arrive 30 minutes early to allow time for security registration.

[Please see entries below, for more background details and links to additional information. Please attend by watching the webcast and/or calling in. Please sign up to make comments at the meeting. Additional written comments can be made until March 13th. Legal intervention deadline is March 31st (or forever hold your peace). See entries below for links to more info., sample comments you can use to prepare your own, etc.:


Risks of Loss of Institutional Control if De Facto Permanent Parking Lot Dumps are Abandoned, Containers Fail, and Release Catastrophic Amounts of Hazardous Radioactivity into the Environment

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 Loss of Institutional Control if De Facto Permanent Parking Lot Dumps are Abandoned, Containers Fail, and Release Catastrophic Amounts of Hazardous Radioactivity into the Environment

DOE warned in its Feb. 2002 Final EIS on the proposed Yucca Mountain, Nevada national burial dump, that loss of institutional control would eventually prove catastrophic. Entropy means that things falls apart, over long enough periods of time. DOE was focused on this happening at nuclear power plant sites, if irradiated nuclear fuel was abandoned there forever. But the same is true here. If institutional control is eventually lost at WCS’s high-level radioactive waste parking lot dump, the containers will eventually fail, and catastrophically release their hazardous, high-level radioactive waste contents into the living environment. Hazardous and even deadly fallout would then flow with the winds and the waters, downwind and downstream, over greater and greater distances over time. Remember, high-level radioactive waste remains hazardous, even deadly, for millions of years into the future.

Such impacts could extend to the immediately adjacent and perhaps even underlying, Ogallala Aquifer. The Ogallala can also be considered downwind and downstream. Aquifers directly under or adjacent to WCS could be in direct communication with the Ogallala. Also, downwind or downstream surface level fallout from WCS could eventually find its way into the Ogallala, through natural flow paths (blowing with the winds, flowing with the rains, deposition onto and into soil, downward flow to aquifers). The Ogallala, North America’s largest, provides essential drinking and irrigation water for millions in Texas, New Mexico, Oklahoma, Kansas, Colorado, Nebraska, Wyoming, and South Dakota. As the water protectors at the Standing Rock Sioux Tribe reservation say on the Missouri River in North Dakota, Mni Wiconi, Water Is Life. This was made very clear by recent drinking water contamination disasters in Flint, Michigan; Charleston, West Virginia; the Animas River in Colorado, New Mexico and Utah; and Toledo, Ohio. A radioactive release into or contamination of the Ogallala would be catastrophic.

Making these risks all the worse, NRC has allowed a quality assurance (QA) failure crisis to persist in the U.S. nuclear power industry for years and decades. These QA failures extend not only to on-site storage casks, but also to the shipping cask and away-from-reactor storage cask realm.

Industry and even NRC whistle-blowers called attention to these QA failure risks 17 long years ago, yet little to nothing has been done to correct them. Industry whistle-blower Oscar Shirani questioned the structural integrity of NRC-approved and industry-utilized storage casks sitting still, let alone traveling 60 miles per hour or faster on the railways. Shirani was backed up in his allegations by NRC Midwest Region dry cask storage inspector, Dr. Ross Landsman, who warned “The NRC should stop the production of the casks, but they do not have the chutzpah to do it. This is the kind of thinking that causes space shuttles to hit the ground.”

Such QA failures, shoddy design, and shoddy fabrication, of the storage casks, means that their eventual failure, and release of their deadly hazardous high-level radioactive waste contents, will only happen all the sooner.

Although Shirani and Landsman’s revelations were about Holtec casks (targeted for use at the Eddy-Lea Energy Alliance proposed centralized interim storage site in New Mexico, not far from WCS, TX), NRC’s incompetence at best, or even collusion with industry, when it comes to cask QA violations, extends to other cask models and designs, including NAC and Areva casks to be used at WCS, TX.

Nuclear Assurance Corporation (NAC) container – to be used at WCS -- QA failures are of specific concern. Last autumn, shoddy welding by NAC led to the bottom literally falling out of an irradiated nuclear fuel assembly transfer caddy, allowing the assembly to strike the bottom of the storage pool at Chalk River Nuclear Labs in Ontario, Canada. Such bad welding calls into question the welds on NAC storage and transport containers as well.

At Davis-Besse atomic reactor on the Great Lakes shoreline near Toledo, Ohio, an Areva design Transnuclear NUHOMS storage cask was loaded with irradiated nuclear fuel, despite local environmental interventions to stop it, after it was revealed the walls of inner canister holding the high-level radioactive waste were ground too thin. But violations of technical specifications for the design and manufacture of casks in the U.S. are as rampant as QA violations.

All this boils down to the risk that de facto permanent abandoned of high-level radioactive waste at the surface, at WCS, could lead sooner rather than later to cask failure, and catastrophic radioactivity release.

NRC, in its Nuclear Waste Confidence Draft Environmental Impact Statement, asserted that whether on-site or away-from-reactor (as at WCS), failing dry casks could simply transfer their contents into a brand new replacement cask. But not a single such transfer has ever taken place in the U.S., dating back to the advent of dry cask storage (at the Surry atomic reactor in Virginia) in the mid-1980s. This, despite the fact that numerous dry casks, as at Palisades in MI, are acknowledged by industry and/or NRC to be defective.

NRC asserted in its DEIS that non-existent “Dry Transfer Systems” could be built at some unspecified future date, with no known source of funding, to accomplish this cask-to-cask transfer, when needed. Despite many thousands of public comments expressing concern about such an overly optimistic, science fiction plan, NRC stood by its Dry Transfer System fantasy in its Final EIS (“Nuclear Waste Confidence” had to be changed by NRC to “Continued Storage of Spent Nuclear Fuel,” as critics had effectively changed the phrase to “Nuke Waste Con Game”!)

Frighteningly, DTSs may be a fantasy plan on which NRC and WCS cannot deliver. In that case, abandonment and eventual failure of high-level radioactive waste storage containers at WCS could well lead to the catastrophic releases of hazardous radioactivity that DOE warned about in its Yucca Mountain Final EIS in Feb. 2002!


Risk of De Facto Permanent Parking Lot Dumps

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):

Risk of De Facto Permanent Parking Lot Dumps

What if so-called interim storage (for “only” 20-40 years, which is already a long time, in most people’s books!) becomes much longer term, or even de facto permanent?

What if future replacements for today’s U.S. Representatives from these adjacent congressional districts in NM and TX, decide enough is enough, and the high-level radioactive wastes need to move? Those one or two future U.S. Representatives from here, would then face the daunting challenge of overcoming the inertia, or even active opposition, of the other 433-434 Members of the U.S. House of Representatives, who might be just fine with the high-level radioactive wastes staying at WCS forevermore (it’s not in their congressional district, after all!) – which is how long they remain hazardous by the way.

In 2008, under court order, the U.S. Environmental Protection Agency acknowledged that commercial irradiated nuclear fuel remains hazardous for a million years into the future. This is actually an underestimate. Take Iodine-129, as but one example. Its half-life is 15.7 million years. It will remain hazardous for at least ten half-lives, or 157 million years. I-129 is in high-level radioactive waste, too.

A 2013 U.S. Senate bill – forerunner to current versions of the legislation in Congress – added to the risks of "interim" storage sites becoming de facto permanent parking lot dumps, by stating a preference for co-location of pilot interim storage alongside large-scale, non-priority interim storage, and even the permanent repository (that is, burial dump).

Also, the waiver of any connection or "linkage" between development of centralized interim storage and progress toward opening a repository only increases the risk that stored wastes will simply be allowed to remain in centralized, so-called “interim,” surface facilities indefinitely into the future. In other words, they could become de facto permanent parking lot dumps.

U.S. Senator Jeff Bingaman (D-NM), Chairman of the Energy and Natural Resources Committee, warned against this de-linkage in 2012. In fact, the requirement for a permanent disposal repository being opened and operating was, and still is, essential and foundational in the Nuclear Waste Policy Act, as Amended, the benchmark law on commercial irradiated nuclear fuel management. This was, and still is, a safeguard against interim storage sites becoming de facto permanent surface “disposal,” or parking lot dumps.

Note that linkage requires an operating repository, not just a licensed one, nor just a proposed one by someone, for someday, somewhere, some way. Remarkably, current DOE projections for the opening of a permanent burial dump are by 2048, 31 years from now, although they don’t know who, where, or how!

2048 is 106 years after Enrico Fermi generated the first cupful of high-level radioactive waste of the Atomic Age, in his Chicago Pile-1 at the University of Chicago squash court under the football stadium, on Dec. 2, 1942 as part of the Manhattan Project race for the atomic bomb; 2048 is 99 years after the first civilian, or commercial, irradiated nuclear fuel was generated, at the Shippingport atomic reactor near Pittsburgh, PA. Such remarkable delays in high-level radioactive waste management and disposal are another red flag, warning about WCS’s facility becoming a long-term, or even de facto permanent parking lot dump.