On November 19, 2018, Public Citizen and the Sustainable Energy and Economic Development (SEED) Coalition submitted scoping comments regarding the license application of ISP’s WCS’ Consolidated Interim Storage Facility (CISF) (Docket # NRC-2016-0231) on behalf of Public Citizen members in Texas as well as members of SEED Coalition, many of whom would be particularly affected by this proposed project, either as neighbors near the site or because they live near the rail lines that would carry this risky radioactive cargo through their communities.
A State of Nevada Report regarding the transportation of high-level radioactive waste to the proposed Yucca Mountain repository project led off by stating that it “has the potential to wreak economic, social, and environmental devastation on at least 44 states, including Nevada, hundreds of major cities and thousands of communities across the country through which spent nuclear fuel (SNF) and high-level radioactive waste (HLW) must travel.” The report noted that tens of thousands of shipments of highly radioactive waste would be an “inseparable and dominant component of the federal government’s repository program “and lamented the fact that the Secretary of Energy recommended that “Yucca Mountain be developed as a repository without full disclosure of these transportation impacts and without having assessed the implications of the program for the nation as a whole…”
What began in 1983 as a noble experiment that promised to place science ahead of politics, and fairness, equity, and openness above parochialism has degenerated into a technical and ethical quagmire, where facts are routinely twisted to serve predetermined ends and where “might makes right” has replaced “consultation, concurrence, and cooperation” as the guiding principle for the program. The shoddy and politically driven science, the heavy-handed federal approach, the constant changing of the rules to negate disqualifying conditions and “inconvenient” findings, and the deliberate avoidance of responsibility for considering socioeconomic impacts have created an atmosphere of severe distrust, where the already significant impacts associated with the nuclear nature of the program are further exacerbated and amplified. The result is a massive suite of negative impacts, national in scope, inextricably linked to the Yucca Mountain program, and unprecedented in the history of federal government domestic projects.
Unfortunately, the same politically driven science and heavy-handed federal approach are still in use today as evidenced by the ill-conceived, ill-advised proposals to store spent nuclear fuel in Texas and New Mexico. As with Yucca Mountain, the nation would be put at unprecedented risk by the thousands of shipments of high-level radioactive waste across the country. At least the goal with the failed Yucca Mountain site was a permanent repository. Consolidated interim storage, by contrast, does not move our nation toward permanent disposal. This approach could delay a viable repository, while unnecessarily risking health and safety and creating financial liability. This proposal also creates the very real risk that a interim repository will become a de facto permanent storage site—a use for which it was never intended and would be wholly unsuited.
WCS and their partner, Orano, have formed a joint venture, Interim Storage Partners. Together they seek to import 40,000 tons of spent fuel from nuclear reactors around the country and store it on WCS’ existing low-level radioactive waste site in Andrews County for 40 years (possibly 60–100) or “until a permanent repository is available.” This could mean forever.
Importing high-level radioactive waste would threaten public health, safety and financial well-being. Exposure to radiation can lead to various cancers, genetic damage and birth defects. Human exposure to unshielded high-level radioactive waste is lethal. Homeowners’ insurance doesn’t cover radioactive contamination, so there are risks to property value as well. Public Citizen and SEED Coalition call for the WCS proposal and Holtec’s proposed project for nearby New Mexico be halted immediately. Waste would travel through major cities in Texas and throughout the country in order to reach either or both sites.
Under the Nuclear Waste Policy Amendments Act of 1987, the WCS consolidated interim storage facility cannot legally operate, so the NRC should not even be considering the license application. Yet the applicant is now pushing forward with their proposal, under new corporate ownership of WCS and with a revised application. The comments put forward raise these concerns:
- We Don’t Want Radioactive Waste. We Do Want Public Meetings.
- Inadequate Environmental Review and Emergency Plan
- Protect Public Health, Safety and Financial Well-Being by Denying the License
- Consolidated Interim Storage of High-Level Radioactive Waste Risks Creating a De Facto Permanent Site
- Liability Risks and Inadequate Financial Assurance
- The Presence of Water and Risks to Aquifers Must Be Analyzed
- Texas Does Not Consent to High-Level Radioactive Waste Storage
- Transportation Risks Higher than NRC Acknowledges
- Risk of Terrorist Attacks on Radioactive Waste Transported through Texas’ Major Cities
- Drones and Armor-Piercing Weaponry.
- Cask safety tests are outdated and inadequate
- Environmental Justice Concerns
This application should be dismissed for all the many reasons discussed. Processing an interim waste storage application is illegal until such time as a final repository has been approved or changes are made in federal law. The plan to ship high-level radioactive waste to Texas and store it for decades imperils the health and safety of the people of Texas, creates financial risks and fails to move the nation toward the goal of a permanent repository. Review of the applications for the WCS project in Texas and the Holtec project in nearby New Mexico should be halted and the licenses denied.
To see the full comments submitted click Public Citizen and SEED Comments – Docket # NRC-2016-0231 – without attachments. To see attachments of the Environmental Justice Screens submitted, click Comment Appendix – EJ Screens.