ML18324A259

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Comment (23575) E-mail Regarding WCS-CISF EIS Scoping - 2018 FRN
ML18324A259
Person / Time
Site: Consolidated Interim Storage Facility
Issue date: 10/19/2018
From: Public Commenter
Public Commenter
To:
NRC/NMSS/FCSS
NRC/NMSS/FCSS
References
83FR44922
Download: ML18324A259 (4)


Text

1 WCS_CISFEISCEm Resource From:

Meredith McGuire <info@sg.actionnetwork.org>

Sent:

Friday, October 19, 2018 4:16 PM To:

WCS_CISFEIS Resource

Subject:

[External_Sender] NRC-2016-0231; Docket # 72-1050 May Ma,

RE: Waste Control Specialists LLCs / ISPs Consolidated Interim Spent Fuel Storage Facility Project

Dear May Ma and NRC,

Waste Control Specialists and their partner want to import up to 40,000 tons of spent fuel, high-level radioactive waste, from nuclear reactors around the country and store it on WCS existing site in Andrews County for 40 years (or longer). This project and a similar proposal by Holtec for nearby New Mexico should be halted immediately.

High-level radioactive waste is extremely dangerous. It is a known cause of cancers, genetic damage and birth defects. Human exposure to unshielded high-level radioactive waste can lead to immediate death. Importing high-level radioactive waste would create unnecessary and preventable risks to public health and safety. Homeowners insurance doesnt cover radioactive contamination, so accidents and other mishaps resulting in leakage during transport could result in widespread costly risk to whole communities along the transport route, damaging their financial well-being as well as their health.

Waste would travel through major Texas cities to reach either site. Under the Nuclear Waste Policy Amendments Act of 1987, the WCS facility cannot legally operate, so the NRC shouldnt even be considering the license application. However, NRC is now going forward with new corporate ownership of WCS and a revised application.

We Dont Want It - and We DO Want Public Meetings. Texans dont want dangerous high-level radioactive waste, but the NRC has not heard the voices of many concerned Texans.

There has not been a single public meeting on the revised application. Resolutions opposing the radioactive waste plans and transport were passed by Dallas, Bexar, Nueces and Midland counties and the City of San Antonio, yet NRC has failed to host meetings in any of these

2 locations, even for the original application. The NRC has held only one Texas meeting on the project, and that was in Andrews, hundreds of miles from major cities that would be impacted by rail transport of radioactive waste. By contrast, five NRC meetings were held in New Mexico regarding Holtecs proposal there and twenty-four meetings were held for Yucca Mountain, across the country. This proposal would result in as much transport of radioactive waste across the country, but the public is being given very little opportunity to speak out.

Please extend intervention and public comment deadlines by at least 180 days to allow for public input, and host public meetings in Dallas, Houston, San Antonio, El Paso, Midland and Andrews. Please make all notices and relevant documents available in Spanish, since many people along transport routes and near the proposed storage site speak mainly Spanish and may not understand English well.

Inadequate Environmental Review and Emergency Plan The inadequate WCS Environmental Report should clearly identify transportation routes that would be used across the country and thoroughly examine:

  • Risks to groundwater and the nearby Ogallala Aquifer, which lies beneath eight states, providing drinking water, and water for agriculture, ranching and wildlife.
  • The impacts of temperature extremes, wildfires, flooding, earthquakes, tornadoes, lightning, and shifting ground (as reported in recent Southern Methodist University studies) on radioactive waste casks and canisters.
  • The environmental injustice of dumping high-level radioactive waste on the largely Hispanic West Texas region
  • The adequacy of financial assurances, the stability of the new WCS owner, an equity firm that buys and sells companies, and the ties of partner Orano (with a 51%, share) to the French government. (I thought there were strict regulations against foreign governments having such involvement in U.S. nuclear facilities.)
  • Improved monitoring, security and worker protections are needed and the emergency plan must include effective actions to be taken, not just a notification structure.

It appears there are no viable plans for action should an emergency arise.

Protect Public Health, Safety and Financial Well-Being - Halt This Project. Sending radioactive waste to Texas would risk our health and security, financial disaster, damage to existing businesses, and contamination of land, air and waterways at the site and along transport routes. It is entirely likely that allowing transport to this inadequate Interim site would create an utterly inadequate permanent disposal site, because it is highly likely that the waste will never get moved to a permanent repository. This waste must remain isolated for a

3 million years. Storing it for decades above ground in extreme climate conditions does not meet our nations needs.

The NRC should halt review of the WCS license application for Consolidated Interim Storage in Texas, as well as review of the Holtec project proposed for nearby New Mexico. In the interest of our public health and safety both licenses should be denied.

As a university Professor, who has taught courses on Medical Sociology and Environmental Health for nearly 40 years and co-authored a leading text in those fields, I am sorrowfully aware of all the damage to our own citizens health and lives that has been caused by the U.S. governments failure to apply the Precautionary Principle to ionic radiations impact on Americans - uranium miners, plutonium workers, military personnel near nuclear testing, downwinders and downstreamers from nuclear facilities like the Hanford complex, and workers in nuclear power plants.

The NRC cannot eliminate the dangerous material that has already been created, but it can -

and must - do everything in its power to prevent all needless harm, such as that which would be caused by permitting transport to ANY consolidated Interim nuclear waste site. Your motto should be the same as doctors - Above all, do no harm!

Sincerely, Dr. Meredith B. McGuire, PhD Dept. of Sociology and Anthropology Trinity University, San Antonio, TX 78212-7200 mmcguire@trinity.edu 210-999-8560 Meredith McGuire mmcguire@trinity.edu San Antonio, Texas 78212-7200

Federal Register Notice:

83FR44922 Comment Number:

23575 Mail Envelope Properties (5bca3b784d54a_45153f81049bafe01276b)

Subject:

[External_Sender] NRC-2016-0231; Docket # 72-1050 Sent Date:

10/19/2018 4:15:52 PM Received Date:

10/19/2018 4:15:54 PM From:

Meredith McGuire Created By:

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