The League of Women Voters of Tarrant County opposes the transportation of high-level nuclear waste through our county. We also oppose the licensing of a high-level nuclear waste (HLW) storage facility at the existing low-level storage facility in Andrews County, Texas, which is operated by Waste Control Specialists, now known together with a partner, as Interim Storage Partners (ISP). “The Andrews County site proposes the eventual storage of 40,000 metric tons of spent nuclear fuel (SNF) and Greater–Than–Class C waste, along with a small quantity of spent mixed-oxide fuel, over 20 years.” 1 “The Nuclear Regulatory Commission (NRC) estimates approximately 425 canisters, which will be surrounded by casks, would be shipped each year for an estimated 20 years,” 2. A similar project in New Mexico would ship an estimated 500 canisters per year for 20 years and store 173,600 metric tons of HLW.
The NRC has scheduled four webinars in early October in place of in-person public hearings on the ISP’s Environmental Impact Statement (EIS). The only public hearing thus far was in Andrews, Texas, early in the process. We recommend that the NRC hold in-person public hearings in several areas impacted by the Interim Storage proposal, including one in Tarrant County, once COVID-19 is under control. This would mean postponing the deadline for comments from November 3, 2020, to allow for adequate public input on this important matter. Access by technology/media is also a way to alert residents, but it is not always available or workable for many U.S. citizens, especially low-income people who may be most impacted by the proposed facilities and transport. In addition, most residents of the areas impacted by the transportation of the high-level nuclear waste (HLW) have not been adequately informed about the potential impacts, since the Environmental Impact Statement (EIS) touches only briefly on the issue.
Transport of massive amounts of (HLW) in thousands of shipments across the country is unprecedented. “For decades, small-scale shipments of SNF have occurred. However, transporting large quantities of SNF and HLW has not been done and will require significant planning and coordination by the Department of Energy (DOE), the agency responsible for waste transportation under the Nuclear Waste Policy Act (NWPA).” 3
“Shipments would be transported across the U.S. to Monahans, Texas, using rail lines”, 4 probably those operated primarily by the Union Pacific Railroad.
According the Safe and Secure Transportation of Spent Nuclear Fuel (SNF) and High-Level Radioactive Waste (HLRW) to the Proposed Geological Repository at Yucca Mountain, Nevada, “Effective response to a transportation accident or incident involving SNF is enhanced through Federal requirements and resources, including financial assistance to States and localities for emergency response planning and training. DOE maintains regional emergency management field offices that can dispatch qualified response teams to an incident involving nuclear material, but first responders are primarily local fire departments and law enforcement agencies. (In the event of a radiation emergency, emergency response is typically handled by the appropriate state radiation control agency and first responders are trained to stay clear and call the state radiation control officer.) PHMSA’s (Pipelines and Hazardous Materials Safety) hazard communication requirements (shipping papers, package marking and labeling, and vehicle placarding) inform these responders of the hazards involved. For shipments of SNF, coordination with local responders is also enhanced by the NRC’s physical protection requirements that provide for advance notification to the State governor (or his representative) of each shipment to or through the State and advance arrangements with local law enforcement agencies for response to an emergency or a call by escorts for assistance. Local emergency response capabilities are strengthened by PHMSA’s planning and training grants to States, who in turn pass at least 75 percent of the grants through to local communities.” 5 . The EISs for Holtec and Interim Storage Partners make no mention of accident response or the source of funding that would be required. Adequate accident response plans and requisite funding should be part of the EISs and subject to public review, particularly by communities along the transportation routes and near the waste storage sites.
The NRC defines high-level nuclear waste as the spent nuclear fuel rods (SNF) from nuclear power plants. SNF is a misnomer. The rods are very radioactive and each train car load would contain more Cesium than was released with the Chernobyl disaster and more plutonium than was in the Atom bomb that hit Nagasaki, Japan. 6 The nuclear waste rail cars are readily identifiable, given their huge dumbbell-like shape, size, and weight, making them a potential terrorist target.
Why Should Tarrant County Be Concerned?
Most nuclear power plants, where the nuclear waste will originate, are East of the Mississippi River. Union Pacific tracks run through the middle of Tarrant County, from north to south and from east and west. The NRC defines the exposed population as a band approximately 0.5 miles on either side of the transportation route. 7 We assume this is because the containers continuously emit a small amount of radioactivity, and even minor accidents, slow-moving rail cars, or stopped rail cars, would increase emissions.
In Tarrant County, this exposed population area includes portions of downtown Fort Worth, including City Hall and the Convention Center, Arlington Library, Arlington City Hall, Arlington Police Department, Watauga Library and City Hall, 19-schools, 2-universities, and Colonial Country Club, as well as residential, commercial, and industrial properties. The railroad in Arlington and Benbrook crosses several major streets, which results in train stoppages and opportunities for accidents.
Tower 55, a major railroad intersection where trains from the north would turn west, holds vital national and international significance, connecting freight and passenger travel between the West Coast, Southeast, Midwest, Gulf Coast, Mexico, and Canada. Over 100 trains pass through Tower 55 each day, sometimes causing delays.
Just southwest of downtown Fort Worth, in the middle of a booming commercial and high-end residential area, lies one of Union Pacific’s main railyards, the Davidson Yard. The rail yard is next to the Clear Fork of the Trinity River (a major water source), a large gas well pad, and across the Trinity River from Colonial County Club. Bike and pedestrian paths line the Trinity River in this location, and residential and commercial uses are within the 0.5-mile radius. It is likely that some of the casks would sit in the Davidson Yards awaiting free track towards Monahans.
In addition to the 0.5-mile radius, the NRC identifies a fifty-mile radius as the area of influence 8 , presumably because of the possibility of a major accident or terrorist attack. This would include much of the Dallas-Fort Worth Metroplex, the fourth largest metropolitan area in the U.S., with a 2019 population of 7,573,136. Unfortunately, with nuclear radiation, unlike with a pandemic, a mask won’t help, sequestering in your home won’t help, and a ventilator won’t help.
Rail accidents happen. A cask carrying low-level waste that was headed to Andrews caught on fire in the Chicago area in June 2020. Fortunately, no release of radioactivity was reported in that accident. We recommend funding for hardened storage at existing nuclear power plants until a permanent waste site is approved. We further recommend that transportation routes for HLW do not travel through high-population areas like the Dallas-Fort Worth Metroplex. Transporting large amounts of HLW through highly populated areas is an acceptable risk.
Resolutions opposing consolidated interim storage of this waste, and its transport through local communities, have been passed by Bexar, Dallas, Nueces, El Paso and Midland Counties and the cities of San Antonio, Midland and Denton, as well as the Midland Chamber of Commerce. The City of Arlington provided comments to the NRC outlining its objections. The City of Benbrook sent a letter to the NRC. We would expect no less from Tarrant County and Fort Worth.
1 Environmental Impact Statement Abstract https://www.nrc.gov/reading-
rm/doc-2 Interim Storage Partners’ EIS, chapter 2-11, page 77,
3 US Nuclear Waste Technical Review Board 2019 Report to Congress
4 Interim Storage Partners’ EIS, chapter 2-11, page 77,
6 Dr. Resnikoff radwaste [at] rwma.com from Kevin Kamp at Beyond Nuclear.
Computation upon request.
7 Spent Fuel Transportation Risk Assessment, p. 19
8 Final Impact Statement Yuca Mt., CR 14,
https://www.nrc.gov/docs/ML0326/ML032691306.pdf (This actually used a 3-
county region, which would be close to 40-50 miles.)