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Comment Deadline extended to November 19, 2018, 11:59 pm: https://www.regulations.gov/docket?D=NRC-2016-0231


https://publications.anl.gov/anlpubs/2012/07/73873.pdf
The French government is trying to get the US taxpayer to help pay for the bailout of their bankrupt government owned nuclear company, Areva, which they renamed Orano, by opening an “interim” nuclear waste dump in Texas. Japanese companies have bought into Orano at 10%, raising the question of if Japanese nuclear waste will come to Texas. Japan tried to send its nuclear waste to bury in Scotland in the 1980s. The Scots stopped them. The US taxpayer already lost an estimated $7.6 billion for the unfinished Areva MOX project in South Carolina.

So, after fleecing the American taxpayer out of billions for a MOX nuclear facility, which will never be completed due to cost overruns, the French government is trying to fleece Americans some more. They hope to do this in conjunction with a private company owned by Reagan’s Secretary of the Navy/former Kissinger staff member John Lehman. Together they call themselves Interim Storage Partners. Recall that Kissinger is a friend advisor to Putin, as well as to Trump.

The proposed interim storage facility is 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. Worse, the metal canister which protects the public from radioactive leaks is only between 1/2 inch and 5/8 inches thick. The concrete support is vented. The canisters are welded shut, which provides more areas for material failure and they cannot be opened and reclosed. 

Double bolted lids with pressure monitors between the lids (like Castor), as well as radiation detectors should be required for high level nuclear waste, as should a much thicker canister.  But, they are not. Casks should be stored in buildings which have filters and cameras and radiation monitors, as in many countries. They generally are not.  

The only thing good which can be said about this project is that we know where to find one of the owners, because it’s France. In the case of the competitor, Holtec, we don’t even know for sure who owns it. Assuming it is Kris Singh, he can go hide in another country, such as his motherland of India. But, it is impossible to hide an entire country.

Spent nuclear fuel conceptual drawing for WCS to NRC
WCS Spent Nuclear Fuel Interim Storage Conceptual Drawing submitted to the US NRC

Areva required a 7.5 billion euros (approximately $8.6 billion bailout) by the French government. See: https://www.bloomberg.com/news/articles/2017-02-03/france-s-next-president-said-to-face-3-billion-nuclear-hangover

The US taxpayer lost an estimated $7.6 billion for the unfinished Areva MOX project. See:
https://www.washingtonpost.com/world/national-security/billions-of-dollars-later-energy-department-pulls-plug-on-partly-built-nuclear-fuel-plant/2018/05/11/aad411da-5532-11e8-b00a-17f9fda3859b_story.html See much more here: http://www.srswatch.org

Areva rebranded itself as Orano: https://miningawareness.wordpress.com/2016/11/25/areva-wants-us-taxpayers-held-liable-for-nuclear-accidents-defective-nuclear-parts-areva-gets-multimillion-contract-for-equipment-at-extra-high-risk-us-nuclear-power-station-despite-ongoing-areva-n/

Who is behind the interim storage scheme?

Orano appears to be approximately 90% French government owned. CEA is part of the French government. Areva was almost completely French government owned. Areva is supposed to be now defunct and renamed Orano.

French State: 45.2 %)
Areva SA (40 %)
JNFL (Japan Nuclear Fuel Limited) (5 %)
MHI (Mitsubishi Heavy Industries) (5 %)
CEA (commissariat à l’Énergie atomique) (4.8 %)
https://fr.wikipedia.org/wiki/Orano

John Lehman is chairman of J.F. Lehman & Company, a private equity investment firm… Lehman was appointed Secretary of the Navy by President Reagan in 1981 and served until 1987… He has served as staff member to Henry Kissinger on the National Security Council, as delegate to the Force Reductions Negotiations in Vienna and as deputy director of the U.S. Arms Control and Disarmament Agency…
https://9-11commission.gov/about/bio_lehman.htm

Subsequent to the Waste Control Specialists’ request to suspend the review of the License Application, its parent (Valhi, Inc.) sold it to J.F. Lehman & Company in January 2018. In addition, Waste Control Specialists and Orano CIS LLC (a subsidiary of Orano USA) formed a joint venture, Interim Storage Partners LLC (ISP), whose purpose is to complete the licensing of, and then construct and operate, the WCS CISF… As a result of the ISP joint venture, the role and responsibilities as Applicant for the license that would permit the Applicant to construct and operate the WCS CISF in Andrews County, Texas is passed from Waste Control Specialists to ISP. However, Waste Control Specialists continues to support the project in much the same way, including providing access to the land for the WCS CISF, operational support, and waste disposal.” https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18166A003

Who pays?

According to the Congressional Research Office: “Under the WCS proposal, DOE would take title to spent fuel at nuclear plant sites, ship it to the Texas site, and pay WCS for storage for as long as 40 years with possible extensions, according to the company. DOE’s costs would be covered through appropriations from the Nuclear Waste Fund, as were most costs for the Yucca Mountain project.https://fas.org/sgp/crs/misc/RL33461.pdf Once the (ratepayer funded) Nuclear Waste Fund is emptied, the cost falls back upon the taxpayer-debt.

In the UK, 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, 1/2 to 5/8 inches thick, protects the environment from potentially lethal levels of radioactive materials. The concrete is vented. 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 (renamed Orano, as part of its bankruptcy-bailout).
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 (Holtec) 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.

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

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 (in particular search for Shimkus within page) See too here: https://sanonofresafety.files.wordpress.com/2015/10/commentshr3053nwpa2017-06-23final.pdf

In canister-based casks, spent fuel assemblies are loaded into baskets integrated into a thin-wall (typically 1/2-inch [1.3-centimeter] thick) steel cylinder, referred to as a caniste“, p. 61 of “Safety and Security of Commercial Spent Nuclear Fuel Storage: Public Report (2006) Chapter: 4.1 BACKGROUND ON DRY CASK STORAGEhttps://www.nap.edu/read/11263/chapter/31#62

Canisters are fabricated from stainless steel with shell thicknesses of 0.5 in. or 0.625 in. Typical canister lengths are 186 in. to 196 in. (4.7 m–5.0 m). ” See: “NDE to Manage Atmospheric SCC in Canisters for Dry Storage of Spent Fuel: An Assessmenthttps://www.pnnl.gov/main/publications/external/technical_reports/PNNL-22495.pdf

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 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.

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 worse than even BEIR VII (ca 2005) thought, maybe even higher: https://miningawareness.wordpress.com/2018/05/09/trump-pruitt-nuclear-hit-job-on-the-epa-american-people-may-increase-radiation-exposure-by-400x-how-quickly-will-everyone-die/

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/

Hearings on making WCS into open air high level waste parking lot: http://www.texasvox.org/wcs-im-late-im-late-important-date/

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. 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/

V. Alternatives To Be Evaluated
The EIS will analyze the environmental impacts of the proposed action, the no-action alternative, and reasonable alternatives. A brief description of each is provided below.
No-Action. The no-action alternative would be to deny the license application. Under this alternative, the NRC would not issue the license and WCS would not construct nor operate the CISF at its site in west Texas. Existing waste handling, storage, and disposal operations at the WCS site unrelated to storage of spent nuclear fuel would continue. This alternative serves as a baseline for the comparison of environmental impacts of the proposed action and the reasonable alternatives.
Proposed action. The proposed action is to issue a license to WCS authorizing the company to construct and operate the CISF. If the NRC approves the license application, it would issue WCS a specific license under the provisions of 10 CFR part 72, and WCS would proceed with the proposed activities as described in its license application and summarized in Section IV.
Alternatives. In its environmental report, WCS identified other potential alternatives involving an alternate CISF location and an alternate storage system design. Other alternatives not listed here may be identified during scoping or through the environmental review process
.” https://www.regulations.gov/document?D=NRC-2016-0231-0005

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