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Comment Deadline April 28th, https://www.regulations.gov/docket?D=NRC-2016-0231
Most US high level nuclear waste appears to be kept in open air parking-lot like set-ups around the country. While the US harasses people at the airport over their shoes, etc., this is the real risk and it’s being ignored. The proposed WCS interim storage facility is also open air. It should be clear to any sane person that this is not the way to store nuclear waste, especially in the sweltering Texas heat, and with the risk of terrorist attack.
Spent nuclear fuel conceptual drawing for WCS to NRC
WCS Spent Nuclear Fuel Interim Storage Conceptual Drawing submitted to the US NRC

There was a Webinar on April 6th:”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. 04/06/17 7:00PM – 10:00PM” More info here:
https://www.nrc.gov/pmns/mtg?do=details&Code=20170316
https://adamswebsearch2.nrc.gov/webSearch2/view?AccessionNumber=ML17072A248
San Onofre Cesium 137 vs. Chernobyl by Donna Gilmore SanOnofreSafety
“Chernobyl in a Can”: San Onofre Cesium 137 vs. Chernobyl by Donna Gilmore https://sanonofresafety.org

In the UK, Germany, Japan, Switzerland, and probably every European country with nuclear waste, the spent fuel casks are housed inside of some sort of building. A building would allow secondary monitoring of spent fuel canisters and the potential to filter any leaks. Additionally, a building would help protect from the elements, helping to reduce corrosion, and ideally be resistant to airplane attacks. The Ukraine, and Kazakhstan have open air facilities, built with US help. In the case of the Ukraine, “The Guardian” newspaper has called these “shocking”: https://www.theguardian.com/environment/2015/may/06/nuclear-waste-stored-in-shocking-way-120-miles-from-ukraine-front-line

Most, and perhaps all, US high level nuclear is stored like North Anna Nuclear Power Station, which is near many small airports and the 50 mile fallout zone would impact Richmond Virginia and suburban DC. As seen in the pictures below, these spent fuel casks are huge, and yet only a very thin piece of metal protects the environment from potentially lethal levels of radioactive materials. Don’t be fooled into thinking that those at the bottom are in a building. This is the horizontal storage system sold by French state-owned Areva.
North Anna Nuclear Spent Fuel
NRC spent nuclear fuel horizontal storage
NRC spent fuel canisters

Clearly there is nothing innovative, then, about the spent nuclear fuel conceptual drawing for the WCS Interim Waste Facility as presented to the US NRC. Proposals to insert the casks in the ground would mean increased corrosion rates, increased difficulties in monitoring, increased retrieval difficulties and do not necessarily protect from an airplane crash as they are not deep enough in the ground.

The only decent solution is to store the nuclear waste in a hard-rock facility which remains permanently open and perpetually monitored. The second best is an above ground bunker-like facility, which is permanently open and perpetually monitored.

Additionally the nuclear waste oligopoly needs to be broken and innovation in storage encouraged, instead of being blocked. The storage needs to be non-profit in order to have better storage at lower cost.

Instead, EnergySolutions is trying to buy WCS, which will make ownership even more concentrated.

The US DOJ has an anti-trust lawsuit against WCS and EnergySolutions to try to block the merger, but EnergySolutions owner, Doug Kimmelman, is a large Trump donor.

Holtec casks Diablo Dec. 26 2005 or 2006
Holtec Spent Fuel Casks at Diablo Canyon, California

The majority of current U.S. irradiated spent fuel storage facilities use thin-walled (mostly 1/2” thick) stainless steel canisters that the NRC acknowledges cannot currently be inspected or repaired and are vulnerable to cracking and leaking 16 years after a crack starts.

These “dry storage thin steel canister systems cannot be inspected, maintained, repaired, adequately monitored to avoid radioactive leaks, and the DOE pilot plan has no plan for replacing failing canisters or retrieval of fuel, as required by NWPA.” (Excerpts from Donna Gilmore-San Onofre Safety, 7-31-2016 Comment to the US DOE on “Consent Based Siting”). Additionally, as she points out, “Near real-time radiation monitoring with public access should be required,yet it is not. Read here article and more here: https://miningawareness.wordpress.com/2017/02/13/interim-storage-open-air-parking-lots-of-high-level-nuclear-waste-risk-major-radioactive-leaks-most-canister-systems-do-not-meet-standards-made-of-thin-steel-neither-adequately-inspected-nor-adeq/ And here: https://sanonofresafety.org

Public hearings have been held in New Mexico, Texas and in DC: https://miningawareness.wordpress.com/2017/02/12/dangerous-texas-high-level-radioactive-waste-open-air-parking-lot-dump-public-hearings-on-monday-and-wednesday-public-comment-to-march-13-license-application/

It is noteworthy that Idaho National [Nuclear] Lab lives off of promoting nuclear power and yet doesn’t want nuclear waste, even though that part of Idaho has already been subjected to a nuclear accident and is cool and arid. And, Idaho has a very low population.

The Texas Attorney General has recently filed suit to force a definitive yes-no decision on Yucca Mountain. The Dallas Council reportedly voted against allowing transport of the nuclear waste through Dallas. The Texas AG is pro-nuclear.

An owner of EnergySolutions, Doug Kimmelman, did a fund-raiser for Trump and was a large Trump donor. Energy Solutions is trying to buy WCS. The US DOJ has an antitrust lawsuit ongoing against this merger. Whether or not the DOJ blocks this merger will be a major litmus test of the DOJ’s independence and integrity.
https://miningawareness.wordpress.com/2017/02/13/interim-storage-open-air-parking-lots-of-high-level-nuclear-waste-risk-major-radioactive-leaks-most-canister-systems-do-not-meet-standards-made-of-thin-steel-neither-adequately-inspected-nor-adeq/
https://miningawareness.wordpress.com/2016/12/20/why-is-large-trump-donor-nuclear-waste-king-kimmelman-charging-so-much-to-bury-nuclear-waste-probably-because-hes-a-goldman-sachs-alumnus-duh-comment-on-high-cost-of-burial-of-nuclear-waste/

Even from a statistical point of view they keep discovering that nuclear is more deadly than initially thought. Based on the Oct. 2015 multi-government funded study of nuclear workers, risk appears around 15 times worse than even BEIR VII (ca 2005) thought, maybe even higher: https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks/
Clustered DNA damage, which is (almost) impossible to properly repair, is considered a signature of ionizing radiation: “clustered DNA damage sites, which may be considered as a signature of ionising radiation, underlie the deleterious biological consequences of ionising radiation…ionising radiation creates significant levels of clustered DNA damage, including complex double-strand breaks (DSB)” See: “Biological Consequences of Radiation-induced DNA Damage: Relevance to Radiotherapy“, by M.E. Lomax et. al. Clinical Oncology 25 (2013) 578-585. “The formation of clustered damage distinguishes ionising radiation-induced damage from normal endogenous damage: https://cordis.europa.eu/pub/fp5-euratom/docs/non_dsb_lesions_projrep_en.pdf More here: https://miningawareness.wordpress.com/2016/12/24/on-the-unique-dna-damage-done-by-ionizing-radiation-nuclear-materials-and-on-metting-hultgren-et-al-misleading-the-us-congress-in-this-matter/

Trump large donors Doug Kimmelman who is an owner of EnergySolutions is a former Goldman Sachs investment banker (Goldman Sachs “Alumnus”). Like Holtec, Energy Solutions is privately held so it’s difficult to get information on them, including exact ownership. Holtec wouldn’t even comply with government lawyer requests for the costs of their spent fuel cask production, which the government needed due to lawsuits by utilities.

Energy Solutions Clive Nuclear Waste Dump : (San Onofre Nuclear steam generators were sent to Clive.)
https://miningawareness.wordpress.com/2016/12/20/why-is-large-trump-donor-nuclear-waste-king-kimmelman-charging-so-much-to-bury-nuclear-waste-probably-because-hes-a-goldman-sachs-alumnus-duh-comment-on-high-cost-of-burial-of-nuclear-waste/

NUCLEAR WASTE ANTI-TRUST CASE INVOLVING TRUMP DONOR-FUNDRAISER NEEDS WATCHING
Energy Solutions, owned by Trump large donor Doug Kimmelman, is trying to take-over competitor WCS in clear violation of anti-trust law: “The United States of America, acting under the direction of the Attorney General of the United States, brings this civil antitrust action to enjoin EnergySolutions, Inc. (“ES”), a wholly owned subsidiary of Rockwell Holdco, Inc. (“Rockwell”), from acquiring Waste Control Specialists LLC (“WCS”), a wholly owned subsidiary of Andrews County Holdings, Inc.https://www.justice.gov/atr/case-document/file/911051/download https://www.justice.gov/opa/pr/justice-department-sues-block-energysolutions-acquisition-waste-control-specialists

Donald Trump hopes to cure cash woes with $449,400-per-ticket fundraiserhttps://www.theguardian.com/us-news/2016/jul/11/donald-trump-campaign-donations-california-fundraiser-clinton.

Hearings on making WCS into open air high level waste parking lot: http://www.texasvox.org/wcs-im-late-im-late-important-date/ Reuters reported on 17 March that “Makan Delrahim, a veteran lobbyist on President Donald Trump’s transition team, is expected to be nominated to head the U.S. Justice Department’s Antitrust Division“. http://feeds.reuters.com/~r/Reuters/PoliticsNews/~3/DTQwJPYH-bI/us-usa-trump-antitrust-exclusive-idUSKBN16O2O2

EnergySolutions got one of the earliest Fukushima clean-up contracts, as reported by the Guardian in March of 2012. It had the ALPs water system at Fukushima until at least end of 2014. Even though it was unable to thoroughly clean the water, and suffered many failures, it stayed at Fukushima and contaminated water was stored and sometimes (always?) dumped to the Pacific. It is unclear how many years it was at Fukushima, but it appears to have been there for approximately 2 years. EnergySolutions is trying to get the monopoly on nuclear waste burial in the US, in violation of antitrust law, but it’s for a Trump justice department to enforce and 46 US attorneys were fired by Trump. The Trump Administration thinks lead and mercury are good for people. So, don’t expect improvement. It may get worse. About EnergySolutions: https://miningawareness.wordpress.com/2015/01/05/when-investment-bankers-deal-in-nuclear-waste-for-investment-profit-we-need-to-be-very-scared/

CURRENTLY THE US ALLOWS 15 TIMES MORE RADIATION IN FOOD THAN JAPAN ALL OF THE TIME; CANADA, UK, AUSTRALIA-NZ ALLOW 10 TIMES AND EUROPE AROUND 6 TIMES. BUT WHEN ANOTHER NUCLEAR ACCIDENT OCCURS MORE EXPOSURE IS PLANNED. ONGOING FUKUSHIMA DISCHARGES OF RADIOACTIVE MATERIALS GO INTO THE OCEAN AND AIR CURRENTS – PRIMARILY IN THE DIRECTION OF NORTH AMERICA AND EUROPE VIA THE ARCTIC, BUT SECONDARILY TO THE SOUTHERN HEMISPHERE. DUE TO THE OLD AND SHODDY CONSTRUCTION OF NUCLEAR REACTORS THE WORLD OVER, A NUCLEAR ACCIDENT IS IMMINENT. THEN THERE IS RISK ASSOCIATED WITH THE NUCLEAR WASTE, WHICH IS BURIED OR STORED IN CANISTERS WHICH ARE COSTLY BUT OFTEN CHEAPLY MADE.

READ ABOUT-LINK TO THE CANCER RISKS AND US STANDARDS HERE: https://miningawareness.wordpress.com/2017/01/27/us-officially-allows-radiation-in-drinking-water-1000s-of-times-greater-than-clean-water-act-in-event-of-nuclear-accident-private-interim-nuclear-waste-storage-comment-deadline-today-11-59-pm-et-even/ EUROPEAN STANDARDS LINK FOUND HERE: https://miningawareness.wordpress.com/2017/02/18/russian-nuclear-threat-on-multiple-fronts-landsbergis-to-lukashenka-noose-is-ready-for-you-on-kremlin-chimes/

Regarding Energy Solutions Contract at Fukushima March of 2012: http://www.theguardian.com/environment/2012/mar/14/energysolutions-fukushima-clean-up-contract

On the 21 of May, 2014, Reuters reported the following about the Energy Solutions ALPS (Advanced Liquid Processing System): “A water treatment facility known as the Advanced Liquid Processing System, designed to remove the most dangerous nuclides, was completely shut down again this week. The system has not been fully operational since it was installed nearly two years ago.” http://feeds.reuters.com/~r/reuters/environment/~3/N5wi8D-D4cc/story01.htm

In March 2014 the Japanese Times reported: “Tepco halts ALPS water cleanup system at Fukushima nuke plant“ JIJI, MAR 18, 2014: “Tokyo Electric Power Co. halted the operations of all three advanced radioactive water cleanup systems, collectively called Advanced Liquid Processing System, or ALPS, at the Fukushima No. 1 nuclear plant on Tuesday.http://www.japantimes.co.jp/news/2014/03/18/national/tepco-halts-alps-water-cleanup-system-at-fukushima-nuke-plant. They state: “With its daily processing capacity of 750 tons, ALPS is regarded as a key element in containing the radioactive water crisis at the crippled plant. However, due to a series of problems, Tepco has yet to start full operations

Tepco can’t even investigate why ALPS stopped purifying contaminated water / Too radioactive to study

Here are the Japan Times Titles dealing with Energy Solutions ALPS
AUG 31, 2014
Tepco abandons goal of cleaning up radioactive water with ALPS system
Tokyo Electric Power Co. has given up its goal of completing radioactive water cleanup at its stricken Fukushima No. 1 nuclear plant with its ALPS system within fiscal 2014, informed sources said Sunday. As of Tuesday, 367,000 tons of high-level radioactive water that had … http://www.japantimes.co.jp/news/2014/08/31/national/tepco-abandons-goal-cleaning-radioactive-water-alps-system

AUG 1, 2014
Water treatment to get into full swing at Fukushima No. 1 in December, Tepco claims
Tepco says it will begin full-scale operation in December of its trouble-plagued radioactive water treatment facility at the Fukushima No. 1 nuclear plant after taking steps to improve its performance. Tokyo Electric Power Co. began a test-run of the facility, called the advanced liquid … http://www.japantimes.co.jp/news/2014/08/01/national/water-treatment-get-full-swing-fukushima-1-december-tepco-claims/

JUN 22, 2014
Tepco restarts ALPS water treatment system at Fukushima No. 1
Tokyo Electric Power Co. resumed operations of the problem-plagued radioactive water treatment system at its crippled Fukushima No. 1 nuclear plant. But the multinuclide removal facility, called the advanced liquid processing system, or ALPS, is still in the test stage as its three treatment … http://www.japantimes.co.jp/news/2014/06/22/national/tepco-restarts-alps-water-treatment-system-fukushima-1/

JUN 09, 2014
U.S. firm hired to scrub Fukushima No. 1 water
Tokyo Electric hires a U.S. firm to extract strontium from the radioactive water at the Fukushima No. 1 plant because it can’t get ALPS to work properly. http://www.japantimes.co.jp/news/2014/06/09/national/u-s-firm-hired-to-scrub-fukushima-no-1-water/

MAY 20, 2014
ALPS water cleaner halted again
Tokyo Electric Power Co. said Tuesday it has again suspended its trouble-plagued system for cleaning radiation-tainted water at the Fukushima No. 1 power plant. Tepco put its Advanced Liquid Processing System (ALPS) on standby mode after it found processed water was cloudy instead of … http://www.japantimes.co.jp/news/2014/05/20/national/alps-water-cleaner-halted/

APR 20, 2014
Fukushima No. 1 boss admits plant doesn’t have complete control over water problems
BY YUKA OBAYASHI
The manager of the Fukushima No. 1 nuclear plant admits efforts to control the radioactive water being churned out there are failing because they were planned in haste. http://www.japantimes.co.jp/news/2014/04/20/national/fukushima-no-1-boss-admits-water-woes-out-of-control/

APR 17, 2014
ALPS unit hit by toxic water overflow
Around 1.1 tons of highly radioactive water overflowed from a waste container at the Fukushima No. 1 nuclear complex while the experimental ALPS radiation-filtering system was being cleaned, Tokyo Electric Power Co. has reported. The overflow at the trouble-plagued water treatment system was noticed … http://www.japantimes.co.jp/news/2014/04/17/national/alps-unit-hit-by-toxic-water-overflow/

MAR 25, 2014
Tepco halts Fukushima water cleanup system again
Tokyo Electric Power Co. suspended operations at the advanced radioactive water cleanup system at its crippled Fukushima No. 1 nuclear power plant Monday only some six hours after its resumption. Tepco resumed operations at two units of the Advanced Liquid Processing System, or ALPS, … http://www.japantimes.co.jp/news/2014/03/25/national/tepco-halts-fukushima-water-cleanup-system-again/

MAR 18, 2014
Tepco halts ALPS water cleanup system at Fukushima nuke plant
Tokyo Electric Power Co. halts the operations of all three advanced radioactive water cleanup systems, collectively called Advanced Liquid Processing System, or ALPS, at the Fukushima No. 1 nuclear plant. http://www.japantimes.co.jp/news/2014/03/18/national/tepco-halts-alps-water-cleanup-system-at-fukushima-nuke-plant/

NOV 22, 2013
Three ALPS systems undergoing tests at Fukushima No. 1
BY KAZUAKI NAGATA
Tokyo Electric Power Co. said all three systems of an advanced water processing machine known as ALPS are now in a test operations for the first time simultaneously. The advanced liquid processing system can remove all radioactive materials except for tritium from tainted water, …http://www.japantimes.co.jp/news/2013/11/22/national/three-alps-systems-undergoing-tests-at-fukushima-no-1/

SEP 30, 2013
Tepco resumes water filtration at Fukushima nuke plant
The shutdown of the ALPS water treatment system at the Fukushima No. 1 plant is linked to a rubber mat apparently left in a water tank.http://www.japantimes.co.jp/news/2013/09/30/national/rubber-mat-in-tank-may-have-shut-down-alps/

SEP 28, 2013
Tepco halts trial of water treatment system at Fukushima No. 1 plant
Tokyo Electric Power Co. said Saturday it has halted a trial run of its much-vaunted water treatment system at the Fukushima No. 1 plant just a day after it resumed operations. At around 10:40 p.m. Friday, Tepco detected technical problems with line C of …http://www.japantimes.co.jp/news/2013/09/28/national/tepco-halts-trial-of-water-treatment-system-at-fukushima-no-1-plant/

SEP 26, 2013
Tepco to resume testing on ALPS water filter
BY KAZUAKI NAGATA
Tokyo Electric will resume tests on the ALPS processor and install a new ALPS next year to bring the radioactive water at Fukushima No. 1 to safer levels.
http://www.japantimes.co.jp/news/2013/09/26/national/tepco-to-resume-testing-on-alps-water-filter/

FEB 23, 2013
Fukushima No. 1 water cleaner to be tested
Experts under the Nuclear Regulation Authority conditionally approves the trial of a new device to remove radioactive substances from tainted water at the Fukushima No. 1 complex.
http://www.japantimes.co.jp/news/2013/02/23/national/fukushima-no-1-water-cleaner-to-be-tested/

Just As Above Ground Nuclear Testing was Stopped, So Too Must Leaking of Radionuclides from the Nuclear Fuel Chain Be Stopped.
Nuclear Power Nuclear War Everyday JFK quote