Current Activities

Unanimous Tucumcari City Commission Passes Resolution Opposing DOE’s Deep Borehole Test

Citing overwhelming public opposition, risks to area resources, and distrust of the Department of Energy (DOE) contractors, on April 25th, 2017, the Tucumcari City Commission unanimously passed a resolution opposing DOE’s proposed Deep Borehole Field Test in Quay County.  Neighboring government bodies also passed resolutions opposing the proposal, including the Quay County Commission, Harding County Commission, and the Union County Commission.

DOE proposed drilling a borehole three miles deep in order to study the crystalline formation at a privately-held site near Nara Visa.  Although the borehole is part of a geologic study, people are very concerned that it could be a precursor for siting a nuclear waste dump there.

The idea grew out of President Obama’s Blue Ribbon Commission on America’s Nuclear Future, which met and held public meetings across the country from March 2010 and January 2012.  Its mission was to “conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle and recommend a new strategy.”  One of its goals was for communities to volunteer or “consent” as a place for America’s growing nuclear waste disposal needs.  https://energy.gov/ne/downloads/blue-ribbon-commission-americas-nuclear-future-report-secretary-energy

Currently, DOE is exploring four sites – one in South Dakota, one in Texas, and two in New Mexico.  The other New Mexico site is located on the Otero Mesa in rural southeastern Otero County.  DOE hired four contractors to gain consent.  The contractors are required to establish community support during Phase I of the project, which ends May 31st.  ENERCON is the contractor in Quay County.  TerranearPMC is the contractor in Otero County.

In Otero County, the Public Land Use Advisory Committee is recommending the Otero County Commission oppose the project during its regular meeting on May 12thhttp://www.alamogordonews.com/story/news/local/community/2017/04/26/pluac-opposes-controversial-borehole-project/100957366/   To support the people opposing the project and sign their petition, please go to https://www.facebook.com/drillnot/

Taking matters into their own hands, the Say NO to the Borehole! group in Quay County held five public meetings in New Mexico and Texas.  https://www.facebook.com/groups/1822548207994770/  ENERCON promised to attend at least two of the group’s public meetings, but only attended the first meeting, claiming hurt feelings over attendees calling them liars.  ENERCON representatives refused to attend any further public meetings held in Quay County.

ENERCON held a meeting last week in Clovis, more than 100 miles from the proposed Nara Visa test site.  At the close of the meeting, the facilitator took an audience poll which revealed approximately three were in favor of the borehole, eight “learned something new,” and the remaining fifty opposed the project.

After the Clovis meeting, Ed Hughs, a Nara Visa native, said, “Even 100 miles away, in a different county, and in a meeting controlled by ENERCON, they still can’t get support.”

 

CCNS Public Scoping Comments to the Nuclear Regulatory Commission about Waste Control Specialists, LLC

CCNS submitted its public scoping comments to the Nuclear Regulatory Commission (NRC) about Waste Control Specialists, LLC (WCS) proposal to construct and operate a Consolidated Interim Storage Facility (CISF) (aka “de facto parking lot dump”) at its Andrews, Texas facility.  The scoping comments are the first step in a National Environmental Policy Act (NEPA) process that NRC is conducting about the proposal.  CCNS described what it believes the “scope” of the draft environmental impact statement should include.  CCNS urged NRC to deny WCS’s application and remand it back to WCS.  We argued that the NEPA process should be “halted until such time as WCS submits an application that addresses the environmental, public health and safety, environmental justice, and short-term and long-term risks as outlined in these comments and those raised in opposition comments submitted by others, including Deborah Reade on March 12, 2017.”

CCNS NRC WCS Scoping Comments 4-28-17

 

Comments due to NMED about WCS Discharge Permit on Tuesday, May 2nd

After nearly four years of start and stop negotiations with Waste Control Specialists (WCS), on March 3rd, the New Mexico Environment Department released a draft permit for the discharges of 170,500,000 gallons per day from the 14,900-acre radioactive and hazardous waste storage and disposal facility located in Texas on the Texas-New Mexico border, five miles east of Eunice, New Mexico.  The main outfall is located approximately 100 yards from the New Mexico state line.  CCNS has prepared a sample public comment letter you can use to submit comments to the Environment Department by 11:59 pm MST on Tuesday, May 2nd.  WCSSamplePublicComments042717

An immediate concern is the discharge volume of approximately 532-acre feet of industrial waste water and storm water that would flow from the dump every day to unnamed ditches in Texas and New Mexico, to the Monument Draw that flows in New Mexico and Texas, and then to the Rio Grande.  The permit contains contingencies for monsoons and flooding; even so, it is a huge volume of water.  NMEDWCSDRAFTGROUNDWATERPERMIT0302017

Texas also regulates the discharge.  http://www.wcstexas.com/pdfs/licenses/(1)%20Texas%20Pollutant%20Discharge%20Elimination%20System%20Permit-Byproduct%20Facility.pdf and http://www15.tceq.texas.gov/crpub/index.cfm?fuseaction=iwr.viewdocument&doc_name=Permit%2004038%2Epdfpdf&doc_id=947295212016237&format_cd=pdf  At one time it required WCS to meet New Mexico water quality standards.  For the past four years, only Texas standards apply.  In 2012, after WCS exceeded the discharge standards, WCS asked the Texas Commission on Environmental Quality to remove the New Mexico standards from the permit because WCS was working with the Environment Department to obtain a discharge permit.

On February 1st, before the Environment Department released the draft permit for public comment, WCS sent a letter asking to withdraw its application.  The Environment Department said no, “particularly given WCS’s actions in securing the removal of New Mexico effluent standards from the applicable Texas surface water permit based on representations to the Texas Commission on Environmental Quality that WCS would obtain a groundwater discharge permit from New Mexico.”  See Exhibit B [NMED February 9, 2017 Letter to WCS] at https://www.env.nm.gov/wp-content/uploads/2017/03/Waste-Control-Specialists-LLCs-Petition-for-Review-and-Notice-of-Appeal-of-the-Ground-Water-Quality-Bureau-of-the.pdf

WCS then petitioned the New Mexico Water Quality Control Commission to reverse the Environment Department’s decision.  Both parties submitted legal pleadings.  https://www.env.nm.gov/general/wqcc-17-01-a/  The Commission meets again on May 9th at the New Mexico Capitol, Room 307, in Santa Fe.  https://www.env.nm.gov/water-quality-control-commission/wqcc-meetings/

In the meantime, WCS is in court this week to oppose the Department of Justice antitrust lawsuit.  Last week, WCS asked the Nuclear Regulatory Commission to temporarily suspend review of its application for a 40-year license to build and operate a consolidated interim storage facility for 44,000 tons of plutonium fuel from nuclear power plants.  WCS Asks NRC to Pause License Application Review for High-Level Irradiated Waste Storage

Joni Arends, of CCNS, said, “Is this the type of privately-held corporation we want to be releasing its waste and storm waters into New Mexico?”

 

WCS Asks NRC to Pause License Application Review for High-Level Irradiated Waste Storage

CCNS anticipates that NRC will grant the WCS request.  Public comments are currently due on April 28th about the scope of the environmental impact statement.  We anticipate that the process will be halted.  We’ll let you know as soon as we know.

Waste Control Specialists (WCS) has too many irons in the fire and it appears they are getting burned.  On Tuesday, WCS, a privately owned corporation that operates a 14,900-acre dump on the Texas-New Mexico border, requested the Nuclear Regulatory Commission (NRC) to temporarily suspend the review of its license application for the storage of about half of the commercial irradiated fuel generated by nuclear power plants. Citing the costs associated with the NRC public participation process; the proposed sale of WCS to another waste storage and disposal company, EnergySolutions in Utah; and the upcoming trial in which the Department of Justice is challenging the proposed sale on antitrust grounds, WCS took a step back from their proposed license application to build a de facto permanent parking lot dump for up to 40,000 metric tons of irradiated fuel.  Many New Mexicans, and people in other states along the proposed transportation routes, oppose the proposals.

In the letter to the NRC, WCS President Rod Baltzer wrote, “WCS expects to go forward with this project at the earliest possible opportunity after completion of the sale.  However, due to the substantially increased application review and related costs, WCS must focus its limited financial resources on those expenditures necessary to safely run and maintain its currently licensed facilities, proceed through the trial set for April 24th, and complete the sale to EnergySolutions.”   FinalWCSSuspensionRequestToNRC041817 and FinalWCSCISFSuspensionPressRelease041817. In federal filings, WCS reported operating losses of $26.5 million in 2015 and $17.9 million in the first six months of 2016. 

In addition, just 40 miles away in New Mexico, the private nuclear company, Holtec, submitted its license application to the NRC on March 31st for a de facto permanent parking lot dump for up to 120,000 metric tons of irradiated fuel.  https://holtecinternational.com/2017/03/30/the-hi-store-consolidated-interim-storage-cis-program-reaches-a-major-milestone/

Both corporations state that the sites would not receive the highly radioactive waste unless and until federal law is changed.  Current law prohibits the Department of Energy from paying for transportation or storage at private parking lot dumps or for taking title to the waste.

Rose Gardner is a small business owner in Eunice, New Mexico who actively leads the efforts to oppose the proposed nuclear projects in the area.  She said, “Strong citizen opposition to the WCS proposal to bring irradiated commercial fuel to our area made it too expensive for WCS to proceed.  Similarly, strongly resistance to the Holtec proposal is needed.”

She continued, “We also need to tell Congress not to change the law.  The only way these proposals would work is for Congress to change the law so that taxpayer bailouts are doled out to the privately held WCS and Holtec corporations.”

 

NRC Extends Public Comment Period for High-Level Irradiated Waste Storage at WCS to April 28th

Southeastern New Mexico and West Texas are under threat for the storage of all of the nation’s existing irradiated commercial fuel from nuclear power plants and all that would be generated in the next 30 years or longer at two de facto permanent parking lot dumpsites.  On the Texas – New Mexico border, five miles east of Eunice, New Mexico, on a 14,900 acre-dumpsite, Waste Control Specialists (WCS) submitted an application to the Nuclear Regulatory Commission (NRC) for a 40-year license to store more than half of the commercial irradiated fuel in the U.S.  Just 40 miles away in New Mexico, the private nuclear company, Holtec, submitted its application last month for a de facto permanent parking lot dump for up to 120,000 metric tons of irradiated fuel.  Many New Mexicans, and people in other states, oppose the proposals.

While the NRC is reviewing the WCS application, it is beginning a National Environmental Policy Act (NEPA) process by soliciting comments about what the environmental impact statement should contain.  Generally, the statements examine impacts to surface and ground water, soil, air, transportation, geology, socioeconomics, historic and cultural resources, and threatened and endangered species, among other issues.

The scope of the draft environmental impact statement should include the impacts to the following aquifers:  the Dockum, Ogallala, Pecos Valley, and Edwards-Trinity.

There are many concerns about the transportation of irradiated nuclear fuel across the United States on water, rail and roads, sometimes referred to as “Mobile Chernobyls” or “Floating Fukushimas.”  Since the only rail line to WCS goes through Eunice, all of the waste would go through that New Mexico community.  It is estimated that irradiated fuel would be transported for 24 years or longer if both sites operate, since they could handle all of the irradiated fuel produced for several more decades.

Proposed transportation maps are available at:  http://static1.1.sqspcdn.com/static/f/356082/27450667/1486998445013/Rail-Transport+routesWCS-1.pdf?token=wgGRSYLr7EbqxLd54LrQ0V8Jd4s%3D and http://static1.1.sqspcdn.com/static/f/356082/27010289/1462420316290/5+4+16+WCS+Transportation+Maps.jpg?token=fdXd0O9cuEa7l77eBIMXkEv0ih4%3D  and water transportation routes by state, https://web.archive.org/web/20151101154823/http://www.nirs.org/fukushimafreeways/watertransport.htm  Please share these maps with family and friends who live along the routes.

NRC recently extended the public comment period about what issues they should address in the statement to Friday, April 28th.  CCNS has prepared a sample public comment letter for you to use.  It details many of the important issues. WCSNRCComments041417   *Please note* – “The NRC cautions you not to include identifying or contact information that you do not want to be publicly disclosed in your comment submission.  The NRC posts all comment submissions at http://www.regulations.gov as well as entering the comment submissions in ADAMS [the NRC’s Agencywide Documents Access and Management System].”  82 Fed. Reg. 8771, January 30, 2017.  Please modify as you wish, but please be sure to submit your comments to WCS_CISF_EIS@nrc.gov before the Friday, April 28, 2017 11:59 pm Eastern time (9:59 pm Mountain time) deadline.  THANK YOU! 

The WCS application also states that the site would receive no irradiated fuel unless and until federal law is changed.  Current law prohibits the Department of Energy (DOE), the federal agency responsible for irradiated fuel, from paying for transportation or storage at a private parking lot dump or for taking title to the waste.  Please contact your congressional representatives and urge them to oppose changes in the law that would allow taxpayer funding for parking lot dumps.  Here is the main switchboard number for Congress – the Senate and House – in Washington, DC – (202) 225-3121.

 

New Mexico and Texas Targeted for Consolidated Storage of All the Plutonium Fuel from Nuclear Power Plants

Southeastern New Mexico and West Texas are targeted for the construction and operation of two de facto parking lot dumps for all of the nation’s existing irradiated plutonium fuel, also known as high-level radioactive waste, and all that would be generated in the next 30 years.  Last week, Holtec International, a private nuclear company, submitted its application to the Nuclear Regulatory Commission (NRC) for a 40-year license to store 100,000 metric tons of commercial fuel at a Highway 62 site, located halfway between Carlsbad and Hobbs, and 15 miles north of the Waste Isolation Pilot Plant (WIPP).  https://holtecinternational.com/2017/03/30/the-hi-store-consolidated-interim-storage-cis-program-reaches-a-major-milestone/  In January, Waste Control Specialists submitted its application to store more than half of the commercial fuel on its 14,900-acre dumpsite on the Texas – New Mexico border, five miles east of Eunice, New Mexico.  http://www.wcstexas.com/wp-content/uploads/2017/01/NRC.WCS_.1.27-1.pdf

Many New Mexicans and Texans oppose the proposals.  The vast majority of the nation’s nuclear power plants are located in the east.  Transportation of the fuel by ship, rail and highway creates radiation risks to those living along the routes.  The emergency preparedness and response required for a radiation release is lacking.  It is estimated that a small accidental release of radiation could minimally contaminate 42-square miles and cost $9.5 billion to cleanup contamination in a large city, and $620 million in a rural area.

Proposed transportation maps are available at:  http://static1.1.sqspcdn.com/static/f/356082/27450667/1486998445013/Rail-Transport+routesWCS-1.pdf?token=wgGRSYLr7EbqxLd54LrQ0V8Jd4s%3D and http://static1.1.sqspcdn.com/static/f/356082/27010289/1462420316290/5+4+16+WCS+Transportation+Maps.jpg?token=fdXd0O9cuEa7l77eBIMXkEv0ih4%3D  and water transportation routes by state, https://web.archive.org/web/20151101154823/http://www.nirs.org/fukushimafreeways/watertransport.htm

NRC calls the proposed parking lot dumps “consolidated interim storage facilities.”

On February 21, 2017, Bexar County, Texas passed a resolution opposing the proposals.  San Antonio is the county seat and it passed a similar resolution.  The Bexar resolution states, “Bexar County does not support or consent to consolidated interim storage of radioactive waste in Texas and nearby New Mexico, or the transportation of high-level radioactive waste on our railways or highways for the purpose of consolidated storage or permanent disposal of high-level radioactive waste in Texas or New Mexico.”  Bexar County Resolution – Feb 21 2017-1 The Commissioners Court of Dallas County Dallas Rad Waste Transport FINAL 4-4-17 and the Texas Democratic Party have passed similar resolutions.

In New Mexico, Governor Susana Martinez offered support.  State Representative James Townsend, who represents Artesia, said, “I don’t believe the community or the state will allow something to occur that they don’t believe is safe.  Look at WIPP’s track record.  Overall, we have had a very good track record, and I believe this facility will perform equally.”  https://www.nmlegis.gov/Members/Legislator?SponCode=HTOWJ

In contrast, Senator Tom Udall said New Mexico has already contributed to the nation’s waste disposal problem.  He continued, “Any future nuclear waste mission in New Mexico would need broad support throughout the state, as well as an independent scientific analysis ensuring its safety before I would consider supporting it.”  https://www.tomudall.senate.gov/

 

Over 120 Nations Negotiating Historic International Treaty to Ban Nuclear Weapons

This week at the United Nations in New York, a majority of the world’s governments, together with international organizations and civil society, led by the International Campaign to Abolish Nuclear Weapons (ICAN), http://www.icanw.org/, gathered to begin negotiations on a treaty to ban nuclear weapons.  The treaty process is supported by the United Nations, over 120 governments, the International Committee of the Red Cross and Red Crescent, https://www.icrc.org/en/document/speech-icrc-president-nuclear-weapons-prohibition-treaty-negotiations, the Pope, http://w2.vatican.va/content/francesco/en/messages/pont-messages/2017/documents/papa-francesco_20170323_messaggio-onu.html, and other faith-based leaders, over 3,000 scientists, https://futureoflife.org/nuclear-open-letter/, and civil society.  The UN defines civil society as the “third sector” of society, along with government and business, and comprises non-governmental organizations and institutions.

Recognizing the humanitarian impact of and suffering from the use of nuclear weapons is incalculable, the treaty process began, despite opposition from the nuclear weapons states.  On Monday, the U.S., United Kingdom, France and a number of Eastern European allies held a protest outside of the United Nations.  http://nuclearsecurityworkinggroup.org/united-states-and-allies-protest-u-n-talks-to-ban-nuclear-weapons/

In New Mexico, the incalculable humanitarian impact is evident for those exposed to radiation from the first atomic bomb test at the Trinity Site in the early morning hours of July 16, 1945.  https://www.trinitydownwinders.com/  The U.S. has not recognized their suffering and has not provided the medical care and compensation received by the Nevada Test Site Downwinders through the federal Radiation Exposure Compensation Act (RECA).

In support of the ban treaty, Downwinders from around the world spoke about the harm done, including those from Japan, the Republic of the Marshall Islands, Maralinga in Australia, and others. http://www.reachingcriticalwill.org/images/documents/Disarmament-fora/nuclear-weapon-ban/reports/NBD1.3.pdf p.4.

On Tuesday, the Alliance for Nuclear Accountability made a presentation about the proposed 11 percent increase to the U.S. nuclear weapons budget to “modernize” weapons and infrastructure.  http://www.reachingcriticalwill.org/images/documents/Disarmament-fora/nuclear-weapon-ban/reports/NBD1.3.pdf p. 3.   

Ray Acheson, a project director for the Women’s International League for Peace and Freedom, explained the work of the International Campaign to Abolish Nuclear Weapons.  She said, “While it may seem daunting, fulfilling this task is fully within our means.  In theory, it is an obvious thing to ban something so abhorrent.  We have banned chemical and biological weapons, landmines and cluster munitions, and we even preemptively banned blinding laser weapons.  We did this even without the support of users and producers of some of these weapons.”

Acheson continued, “We are motivated by the catastrophic humanitarian consequences of nuclear weapons, the risk of their use, and the deplorable waste of resources currently being sunk into the on-going arms race.  We understand the global injustice these weapons represent, and we are morally, ethically, and legally compelled to categorically prohibit these weapons of mass destruction once and for all.”

To follow the Campaign on social media, use hashtag  #nuclearban and the Twitter accounts  @RCW_ and @nuclearban.

 

Two April 1st Peaceful Demonstrations at White Sands Missile Range Entrances to Support Trinity Downwinders

Please join the Tularosa Basin Downwinders Consortium at two White Sands Missile Range entrances during the Trinity Site open house on Saturday, April 1st to support those who have been negatively affected by radiation exposure from the first atomic test there on July 16, 1945.  The Army opens the Trinity Site twice a year for people from around the world to visit the radioactively contaminated site.  http://www.wsmr.army.mil/PAO/Trinity/Pages/Home.aspx  Beginning at 7:30 am, the Consortium will gather at the Tularosa Gate, located on the Tulie Gate Road, west of the Tularosa High School, for a one-hour peaceful demonstration.  Beginning at 9 am, they will gather at the Stallion Range Station, east of San Antonio on Highway 380, for a three-hour peaceful demonstration.  Please bring your own water, chair, hat, and a poster or sign.

On July 16, 1945, just before dawn, the U.S. government conducted the first test explosion of a plutonium bomb at the Trinity Site.  Without warning, the 40,000 people living in the immediate vicinity were engulfed in a radioactive cloud that continued to rain down radioactive particles for days, weeks and months.  The government packed their bags, turned their backs and walked away.  For 72 years it has taken no responsibility for the health repercussions to the People.

The Consortium will provide information about their new Health Impact Assessment that documents the harm done to the People living downwind of the Trinity Site and their efforts to ensure that the Trinity Downwinders are included in the proposed amendments to the Radiation Exposure Compensation Act (RECA).  In 1990, Congress passed RECA to provide medical care and compensation to those living downwind of the Nevada Test Site, another location used for testing nuclear weapons aboveground.  RECA was amended in 2000.  The Trinity Downwinders have never been included even though over $2 billion has been paid in claims.  https://www.justice.gov/civil/common/reca, https://www.justice.gov/civil/awards-date-03232017

The Consortium has documented the harm in its new Health Impact Assessment, entitled, “Unknowing, Unwilling and Uncompensated:  The Effects of the Trinity Test on New Mexicans and the Potential Benefits of the Radiation Exposure Compensation Act (RECA) Amendment.”  https://www.trinitydownwinders.com/health-impact-assessment

Tina Cordova, a co-founder of the Consortium, said, “Seventy-two years have passed.  Now is the time for the U.S. Government to recognize those who were unknowing, unwilling, uncompensated, innocent participants in the world’s largest science experiment, who have been suffering in silence ever since the bomb was detonated.  Our organization is revealing the rest of the story and the People are being made aware of the complete legacy of Trinity.”

For more information, please contact Tina Cordova at 505-897-6787 or by email to tcordova@queston.net.  For information about the Tulie Gate gathering, please contact Kathy Tyler at 575-585-2896.  For information about the Stallion Range Gate gathering, please contact Louisa Lopez at 575-835-8146.

 

DOE Proposes a 53 Percent Increase in Waste Storage at LANL’s Plutonium Facility

Proposing to increase the generation and storage of hazardous and radioactive waste by 53 percent at the Plutonium Facility at Los Alamos National Laboratory (LANL), the Department of Energy (DOE) submitted a request to the New Mexico Environment Department to modify the hazardous waste permit, naming it “Revision 0” in anticipation of having to resubmit it.  The Plutonium Facility was recently reopened.  It is the only place in the United States for the manufacture of plutonium triggers, or cores, for nuclear weapons.  For a number of years it was closed in order to address security and safeguard issues; long-neglected maintenance; and the increased seismic risk on the Pajarito Plateau, where LANL is located.

DOE wants to store 94,545 gallons of waste in three units at the Plutonium Facility.  One is an outdoor carport on a concrete pad, and the other two are in rooms in the basement.  http://permalink.lanl.gov/object/tr?what=info:lanl-repo/eprr/ESHID-602143-01

Unfortunately, there are a number of errors in the request.  For example, DOE states the classification of the request is a Class 2, which requires a public comment period.  However, it is clear that the classification should be a Class 3 because DOE is asking to increase its storage capacity at the Plutonium Facility by 53 percent.  http://permalink.lanl.gov/object/tr?what=info:lanl-repo/eprr/ESHID-602143-01 p. 13.

A Class 3 request requires a public comment period, as well as an opportunity to request a public hearing and judicial review of the final decision.  A public hearing is necessary because of the age of the Plutonium Facility, which was built more than 50 years ago; and the on-going public health concerns about the inadequate ventilation system for containing respirable particles of plutonium in emergency situations, among other issues.

The Environment Department has not released a draft permit for public comment.  Nevertheless, CCNS has prepared a sample public comment letter for you to use to the Environment Department to urge them to determine that the proposed permit modification is a Class 3, requiring more opportunities for public participation.  f DOE TA-55 permit mod request 3-17-17

The question DOE has not answered is why does LANL continue to generate hazardous, toxic and radioactive waste associated with manufacture of plutonium triggers for nuclear weapons.  This question is extremely timely given that the United Nations will begin negotiations for a new international treaty prohibiting nuclear weapons.  Two sessions of negotiations will take place in New York.  The first session runs from Monday, March 27th to Friday, March 31st and the second, from June 15th to July 7th.  For more information, visit http://nuclearban.org/

 

Comments Due Monday, March 13th to NRC about Storage of High-Level Waste at WCS

Southeastern New Mexico and West Texas are targeted for the storage of all of the nation’s existing irradiated fuel and all that would be generated in the next 30 years at two de facto permanent parking lot dump sites.  On the Texas – New Mexico border, five miles east of Eunice, New Mexico, on a 14,900 acre-dumpsite, Waste Control Specialists is asking the Nuclear Regulatory Commission (NRC) for a 40-year license to store more than half of the commercial irradiated fuel in the U.S.  Just 40 miles away in New Mexico, the private nuclear company, Holtec, is expected to submit its application in late March for a de facto permanent parking lot dump for 100,000 metric tons of irradiated fuel.  Many New Mexicans oppose the proposals.

The NRC term for a permanent parking lot dump is a “consolidated interim storage facility,” or a CISF.  https://www.federalregister.gov/documents/2017/01/30/2017-01966/waste-control-specialists-llcs-consolidated-interim-spent-fuel-storage-facility-project

At the same time NRC is reviewing the WCS application, it will prepare an environmental impact statement to examine impacts to surface and ground water, transportation, geology, soil, air, socioeconomics, historic and cultural resources and threatened and endangered species, among other issues.  You are invited to provide comments to NRC about what issues should be addressed in the statement, with comments due on Monday, March 13th to WCS_CISF_EIS@nrc.gov.  A sample public comment letter for you to use is available by clicking this link…  WCS_NRC_Scoping_Comments031017  *Please note* – “The NRC cautions you not to include identifying or contact information that you do not want to be publicly disclosed in your comment submission.  The NRC posts all comment submissions at http://www.regulations.gov as well as entering the comment submissions in ADAMS [the NRC’s Agencywide Documents Access and Management System].”  82 Fed. Reg. 8771, January 30, 2017.  Please modify as you wish, but please be sure to submit your comments to WCS_CISF_EIS@nrc.gov before the Monday, March 13, 2017 11:59 pm Eastern time (9:59 pm Mountain time) deadline.  THANK YOU! 

The scope of the draft environmental impact statement should include the impacts to the following aquifers:  the Dockum, Ogallala, Pecos Valley, and Edwards-Trinity. 

There have been concerns about the transportation of irradiated nuclear fuel across the United States on water, rail and roads, such as the interstate highway system, including questions about emergency preparedness and response capabilities.  The shipments are allowed to travel on all transportation routes. While the vast majority of the nation’s more than 100 nuclear power plants are located in the east, the only rail access to the WCS site is through Eunice, New Mexico, so all shipments would come through southeastern New Mexico over the proposed 24 years of operations.  http://static1.1.sqspcdn.com/static/f/356082/27450667/1486998445013/Rail-Transport+routesWCS-1.pdf?token=wgGRSYLr7EbqxLd54LrQ0V8Jd4s%3D and http://static1.1.sqspcdn.com/static/f/356082/27010289/1462420316290/5+4+16+WCS+Transportation+Maps.jpg?token=fdXd0O9cuEa7l77eBIMXkEv0ih4%3D  and water transportation routes by states, https://web.archive.org/web/20151101154823/http://www.nirs.org/fukushimafreeways/watertransport.htm

The statement should include specific designation of water, rail and road transportation routes and the array of potential impacts of accidents and/or terrorism incidents along the routes and at the dumpsite.  A 2014 Texas Commission on Environmental Quality report warned of potential sabotage of radioactive waste shipments and suggested that such an incident would most likely occur in a large city rather than in a rural area.