Beyond Nuclear's written comments to NRC opposing ISP's CISF at WCS, TX
November 4, 2020
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(1.) Beyond Nuclear's 1st set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS -- verbal comments, re: the risks of so-called "routine" or "incident-free" shipments, nonetheless being like Mobile X-ray Machines That Can't Be Turned Off, as well the risks of externally contaminated shipments, submitted Oct. 1, 2020, during NRC's 1st of 4 call-in sessions (see pages 69 to 74, of 142, on the PDF counter).

(2.) Beyond Nuclear's 2nd set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS -- re: Risks of “Routine” or “Incident-Free” Shipments Nonetheless Being Like “Mobile X-ray Machines That Can’t Be Turned Off,” and Risks of Externally Contaminated Shipments, submitted Oct. 5, 2020.

(3.) Beyond Nuclear's 3rd set of public comments on NRC's ISP/WCS CISF DEIS, re: Docket ID NRC-2016-0231, and report number NUREG-2239 -- re: 40-year timeframe is an inappropriately, arbitrarily, and capriciously short scope, submitted Oct. 6, 2020.

(4.) Beyond Nuclear's 4th set of public comments, on NRC's ISP/WCS CISF DEIS, re: Docket ID NRC-2016-0231, and report number NUREG-2239 -- re: large impacts/risks of high-level radioactive waste transportation, lack of shipment route maps, submitted Oct. 6, 2020.

(5.) Beyond Nuclear's 5th set of public comments, on NRC's ISP/WCS CISF DEIS, re: Docket ID NRC-2016-0231, and report number NUREG-2239 -- re: complexity and risk of multiple required cask-to-cask canister transfers, submitted Oct. 6, 2020.

(6.) Beyond Nuclear's 6th set of public comments, on NRC's ISP/WCS CISF DEIS, re: Docket ID NRC-2016-0231, and report number NUREG-2239 -- re: NRC Staff's internal contradictions, submitted Oct. 6, 2020.

(7.) Beyond Nuclear's 7th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS -- re: simply assuming Yucca Mountain, Nevada on Western Shoshone land, will be the permanent repository, is false, indefensible, and a violation of treaty obligations (that is, illegal), submitted Oct. 8, 2020.

(8.) Beyond Nuclear's 8th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS -- re: Environmental Justice (EJ), Environmental Injustice, Environmental Racism, Radioactive Racism, submitted Oct. 8, 2020.

(9.) Beyond Nuclear's 9th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS -- re: the license for Private Fuel Storage, LLC, CISF -- targeted at Skull Valley Goshutes Indian Reservation in Utah -- is not terminated, contradicting NRC Staff assertions to the contrary, submitted Oct. 9, 2020. A version were submitted verbally during the NRC call-in session on Oct. 8, and a version later submitted in written form (see #(15.), below).

(10.) Beyond Nuclear's 10th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS -- re: the Cerro Grande Fire exacerbates the environmental injustice of the ISP/WCS CISF scheme, submitted Oct. 12, 2020.

(11.) Beyond Nuclear's 11th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS -- re: NRC collusion with Holtec & ISP on CISFs rubber-stamps is illegal, dangerous, submitted Oct. 12, 2020.

(12.) Beyond Nuclear's 12th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS -- submitted via Public Citizen Texas Office webform action alert, submitted Oct. 13, 2020.

(13.) Beyond Nuclear's 13th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: woefully inadequate, to nearly nonexistent, treatment of highly radioactive waste transportation risks, including: failure to identify shipping routes associated with 127 of 131 atomic reactors in the U.S.; and failure to address widespread QA violations, submitted Oct. 13, 2020.

(14.) Beyond Nuclear's 14th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, verbal comments submitted on Oct. 6, 2020, during NRC's 2nd of 4 call-in sessions. (See pages 100 to 107 of 128 on the PDF counter.)

(15.) Beyond Nuclear's 15th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, verbal comments submitted on Oct. 8, 2020, during NRC's 3rd of 4 call-in sessions. See Page 86 to Page 90 in the transcript for Beyond Nuclear's comments, submitted by radioactive waste specialist, Kevin Kamps. Please note that a version of these comments was submitted in writing as well -- see #(9.) above.

(16.) Beyond Nuclear's 16th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, verbal comments submitted on Oct. 15, 2020 during NRC's 4th of 4 call-in sessions. See Page 162 to 166 in the transcript for Beyond Nuclear's comments, submitted by radioactive waste specialist, Kevin Kamps.

(17.) Beyond Nuclear's 17th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Mobile Chernobyl shipping risks, submitted Oct. 22, 2020.

(18.) Beyond Nuclear's 18th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Risks of Loss of Institutional Control if De Facto Permanent, Surface Storage, Parking Lot Dumps are Abandoned, Containers Fail, and Release Catastrophic Amounts of Hazardous Radioactivity into the Environment, submitted Oct. 22, 2020.

(19.) Beyond Nuclear's 19th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Risk of De Facto Permanent, Surface Storage, Parking Lot Dump, submitted Oct. 23, 2020.

(20.) Beyond Nuclear's 20th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Stringent Criteria for a Highly Radioactive Waste Geologic Repository; 1,000+ organizations opposed to the Yucca dump targeted at Western Shoshone land in NV, submitted Oct. 23, 2020.

(21.) Beyond Nuclear's 21st set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Why Are These CISF Risks Being Taken? To Offload High-Level Radioactive Wastes' Title (Ownership) and Liability on the Backs of the Public Taxpayer, submitted Oct. 23, 2020. 

(22.) Beyond Nuclear's 22nd set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: our member and supporter's comment on the fallacy of "interim" storage, submitted Oct. 27, 2020. 

(23.) Beyond Nuclear's 23rd set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Stringent Criteria for a Highly Radioactive Waste Geologic Repository; 1,000+ organizations opposed to the Yucca dump targeted at Western Shoshone land in NV.

(24.) Beyond Nuclear's 24th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Beyond Nuclear comments recorded at an NISG Zoom "People's Hearing" on Sept. 16, 2020, and adapted for use as comments in this ISP/WCS CISF DEIS proceeding.

(25.) Beyond Nuclear's 25th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Our objections to NRC's outrageous conduct of this ISP/WCS CISF public comment proceeding.

(26.) Beyond Nuclear's 26th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Responses to NRC's call-in public comment sessions.

(27.) Beyond Nuclear's 27th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Responses to statements made by ISP proponents during the first NRC call-in public comment session on Oct. 1, 2020.

(28.) Beyond Nuclear's 28th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: A Brief History of Irradiated Nuclear Fuel Shipments: Atomic Waste Transport “Incidents” and Accidents the Nuclear Power Industry Doesn’t Want You to Know About.

(29.) Beyond Nuclear's 29th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: A Cautionary Tale: MOBILE MELTDOWN - TMI TRAIN TROUBLES.

(30.) Beyond Nuclear's 30th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Cautionary Tales -- Get the Facts on High-Level Atomic Waste Storage Casks!

(31.) Beyond Nuclear's 31st set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Cessation of Irradiated Nuclear Fuel, and Principles for Safeguarding Nuclear Waste at Reactors (Hardened On-Site Storage, HOSS) are the Preferred Alternatives.

(32.) Beyond Nuclear's 32nd set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's DEIS, re: 129-organization coalition comment letter opposing ISP/WCS's CISF.

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