Mobile Chernobyl shipping risks
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):
Mobile Chernobyl shipping risks
Eunice, New Mexico (four miles from WCS, across the TX/NM border) has the dubious distinction that every single train car load of high-level radioactive waste will pass through on its way into (and, if it ever leaves, out of) WCS. But transport impacts, to import more than half the irradiated nuclear fuel in the U.S. into West Texas, will be felt nation-wide. In that sense, when it comes to radioactive waste transportation, we all live in Eunice, NM.
But a parking lot dump at WCS would only increase safety risks. It would not decrease them. It would multiply transport risks, as it would only be temporary (supposedly). All that highly radioactive waste would have to move again, to a permanent burial site (yet to be identified – that’s a big IF!). And that could be back in the same direction from which it came in the first place!
WCS’s assumption that the dump at Yucca Mountain, Nevada will open someday, to take the high-level radioactive waste away, is inappropriate. The vast majority of Nevadans has expressed its very adamant non-consent for 30 years now, and still vehemently oppose it. This is reflected by bipartisan resistance by elected officials, at both the state government level, as well as the congressional delegation level.
WCS’s assumption that another permanent burial dump will be opened, by someone, somewhere, someday, somehow, is also inappropriate. After all, the search for a national geologic repository has gone on since the 1950s, but has failed. And DOE’s current estimate for the opening of the U.S.’s first repository is 2048, 31 years from now. Except they have no idea where that will be. There is every likelihood that 2048 date will slip into the future as well.
The failed Private Fuel Storage, LLC parking lot dump targeted at the Skull Valley Goshutes Indian Reservation in Utah, likewise assumed the Yucca dump would open. They were, of course, incorrect.
So PFS’s “Plan B” was to “return to sender.” If 40,000 metric tons of irradiated nuclear fuel – the same amount targeted to go to WCS, isn’t that curious?! – what would that “return to sender” policy have looked like?
Maine Yankee was a PFS consortium member. More than 50 rail sized containers of irradiated nuclear fuel would have traveled 5,000 miles round trip, accomplishing absolutely nothing, other than exposing millions of people in numerous states to high-risk shipments.
Another version of this is the fact that permanent burial sites could be located right back in the same direction from which the waste came in the first place. In fact, at one time, DOE was targeting two sites in Maine, seven sites in Vermont, and two sites in New Hampshire, for permanent burial dumps. (See Beyond Nuclear’s backgrounder, re: the NH targets, at: http://static1.1.sqspcdn.com/static/f/356082/24115710/1487366549330/New_Hampshire_dump_final+draft.pdf?token=ZDgyvKfq8uxG4HPqWmvVvXBuwmY%3D).
This game of high-risk, high-level radioactive waste musical chairs, or hot potato, on the roads, rails, and waterways, is unacceptable. It amounts to Radioactive Russian roulette. Multiplying transport risks for no good reason is wrong, and makes no sense.
The Nuclear Assurance Corporation’s Quality Assurance (NAC QA) failures mentioned above are very significant to shipping risks. Shipping casks would be less capable of withstanding severe accidents (such as high-speed crashes, including into immovable objects, like bridge abutments; high-temperature, long-duration fires; deep, long-lasting underwater submersions; drops from tall heights, onto unyielding surfaces, such as bridge foundations; or some combination of all those), as well as intentional attacks (such as with shaped charges, or anti-tank weapon systems – see below) or other powerful explosions (such as explosive cargoes on passing trains, including, nowadays, crude oil “Bomb Trains,” as from the Bakken oil fields in North Dakota).
Adding to these shipping risks, is the potential for barge shipments on surface waters. WCS is supposed to be "mostly rail" -- which can also mean many barges (26 reactors in the U.S. lack direct rail access, meaning barges on surface waters -- the Great Lakes, rivers, seacoasts -- could be used to haul the 100+ ton, rail-sized casks to the nearest rail head). Backgrounders (including more details on the high risks) on these various barge routes (including maps) were originally written for the Yucca dump scheme; however, WCS could just as well involve such barges.
DOE’s Feb. 2002 Yucca Mountain Final Environmental Impact Statement gives a preview of barge shipments that could well be required to ship high-level radioactive waste to WCS, TX. The following barge shipment routes were proposed under the Yucca Mountain plan:
(See NIRS factsheets on barge shipments of deadly high-level radioactive waste on waterways, by state, posted online September 28, 2004):
<https://web.archive.org/web/20160331033728/http://www.nirs.org/factsheets/mdbargefactsheet92804.pdf>
<https://web.archive.org/web/20160331033736/http://www.nirs.org/factsheets/vabargefactsheet92804.pdf>
<https://web.archive.org/web/20160331032838/http://www.nirs.org/factsheets/debargefactsheet92804.pdf>
<https://web.archive.org/web/20160331034044/http://www.nirs.org/factsheets/nybargefactsheet92804.pdf>
<https://web.archive.org/web/20160331020332/http://www.nirs.org/factsheets/mabargefactsheet92804.pdf>
<https://web.archive.org/web/20160327081932/http://www.nirs.org/factsheets/mibargefactsheet92804.pdf>
<https://web.archive.org/web/20160331080128/http://www.nirs.org/factsheets/lamsbargefactsheet92804.pdf>
<https://web.archive.org/web/20160331063817/http://www.nirs.org/factsheets/tnalbargefactsheet92804.pdf>
<https://web.archive.org/web/20160331020303/http://www.nirs.org/factsheets/nemoksbargefactsheet92804.pdf>
<https://web.archive.org/web/20160331030740/http://www.nirs.org/factsheets/cabargefactsheet92804.pdf>
<https://web.archive.org/web/20160331035101/http://www.nirs.org/factsheets/flbargefactsheet92804.pdf>
(However, with something as simple as a rushed NRC rubber-stamp amendment, WCS could apply for, and quickly get, permission to truck in smaller-sized, "Legal Weight Truck" (LWT) casks to WCS. This mix of trains/barges and trucks, would mean even more American communities would be exposed to Mobile Chernobyl risks.)
Dirty Bomb on Wheels security risks would abound. This was made clear by the test of an anti-tank missile against an (empty) irradiated nuclear fuel shipping cask at the U.S. Army’s Aberdeen Proving Ground in Maryland. The June 1998 test targeted a German CASTOR cask. While certified for storage-only in the U.S. (the cask model is deployed at Surry, VA), it is widely used for transport in Europe. CASTORs have thick die cast iron walls, as opposed to thin walled steel casks in the U.S. That is, CASTORs are significantly more robust, more capable to withstand such an attack. However, even the CASTOR, the Cadillac of shipping casks as some have called it, was severely breached by the anti-tank missile. A hole as big around as a grapefruit or softball was blown clean through the side wall. Had irradiated nuclear fuel been inside, the hole would have created the pathway for release of disastrous amounts of hazardous radioactivity – all the more so, if an incendiary attack were combined with the explosive attack. In short, shipping containers were not designed to withstand such attacks. See:
February 7, 2017