Submitted via <holtec-cisfeis@nrc.gov>
Dear Holtec-CISFEIS Resource and NRC Staff,
This is my 25th set of public comments in this proceeding.
I submit these comments on behalf of our members and supporters, not only in New Mexico, near the targeted Holtec/ELEA Laguna Gatuna site, but across New Mexico, and the rest of the country, along road, rail, and waterway routes that would be used for high risk, highly radioactive waste shipments to Holtec's CISF, as well as to Yucca Mountain, Nevada, on Western Shoshone land -- illegally and improperly assumed by Holtec, as well as NRC, to someday become a permanent disposal repository.
Due especially to the numerous problems I have experienced submitting public comments via this <holtec-cisfeis@nrc.gov> email address, please acknowledge receipt of these comments, and please provide me with confirmation of their proper placement in the official public record for this proceeding.
The following subject matter, re: Holtec's corporate character and integrity (or, more precisely, the lack thereof) has gotten little to no attention in NRC's Holtec CISF DEIS, a far cry from NEPA's legally binding "hard look" requirement. How can NRC approve this license application, entrusting the handling, transport, and storage of up to 173,600 metric tons of forever hazardous highly radioactive waste, to a company as crooked, untrustworthy, and even criminal as Holtec?
Following are two annotated bibliographies. The first focuses on Holtec International itself. The second focuses on SNC-Lavalin, Holtec's consortium partner in nuclear power plant decommissioning and irradiated nuclear fuel management. It is the latter subject matter that makes Holtec's partnership with SNC-Lavalin relevant to this CISF DEIS. If Holtec and SNC-Lavalin are partners in managing irradiated nuclear fuel storage on-site at decommissioning nuclear power plants, then this is directly relevant to that irradiated nuclear fuel's at-reactor on-site storage and handling in preparation for transport to the CISF in NM. The condition of the irradiated nuclear fuel itself, as well as the containers it is stored/transported in, could suffer, dangerously so, in the hands of companies as prone to incompetent mismanagement, or even malicious corner cutting and lawlessness, as Holtec and SNC-Lavalin.
As but one example, Holtec's "Start Clean/Stay Clean"-"Return to Sender" policy of returning problem containers to the nuclear power plant site where they originated, means that where Holtec and SNC-Lavalin are in charge of decommissioning and high-level radioactive waste management -- such as at Oyster Creek NJ and Pilgrim MA already, and as proposed at Indian Point NY as well as Palisades and Big Rock Point MI -- the two companies would then be in charge of transporting the problem containers back, and then receiving them for likely emergency handling and continued storage at the nuclear power plant sites. That is why the "Skeletons in SNC-Lavalin's Closet" annotated bibliography is included as well, under Holtec's own, below. Holtec's judgment is clearly suspect, partnering with a company like SNC-Lavalin. But the same can be said about SNC-Lavalin, for partnering with a company as crooked as Holtec. Neither company can be trusted to properly manage any amount of forever deadly irradiated nuclear fuel, let alone 173,600 metric tons worth (still nearly twice the amount that currently exists in the United States). In a very real and frightening sense, Holtec and SNC-Lavalin could become partners in crime.
And another example is bribery. While Holtec's and its CEO Krishna Singh's serial bribery schemes are serious enough, in a certain sense they pale in comparison to SNC-Lavalin's bribery schemes. Whereas Holtec and its CEO Krishna Singh were implicated in a $55,000 bribe at TVA's Browns Ferry nuclear power plant in Alabama, a crime which got Holtec barred from doing business with TVA for 60 days, and fined $2 million, SNC-Lavalin executive Sami Bebawi was sentenced to 8.5 years in prison after being convicted of various fraud and corruption charges. SNC-Lavalin was fined $280 million for its fraud and corruption. And SNC-Lavalin's bribery, kick back, and embezzlement schemes involved not millions, not tens of millions, but sometimes hundreds of millions of dollars. Such criminality earned SNC-Lavalin an unprecedented decade-long debarment from doing any business with the international World Bank affiliated network, as stated in this April 17, 2013 press release <https://www.worldbank.org/en/news/press-release/2013/04/17/world-bank-debars-snc-lavalin-inc-and-its-affiliates-for-ten-years>:
“The World Bank Group today announced the debarment of SNC-Lavalin Inc. - in addition to over 100 affiliates - for a period of 10 years following the company’s misconduct in relation to the Padma Multipurpose Bridge Project in Bangladesh, as well as misconduct under another Bank-financed project.” SNC-Lavalin Inc. is a subsidiary of SNC-Lavalin Group.
In fact, the scandals swirling around SNC-Lavalin nearly toppled the Canadian prime minister, as documented below. The inclusion of SNC-Lavalin related documentation is therefore justified in this public comment, considering the questions it raises about Holtec's integrity and character to partner with such a firm, but also because SNC-Lavalin will directly or indirectly be involved with irradiated nuclear fuel storage, transport, handling, and other management activities, back and forth from nuclear power plant sites and the Holtec CISF in NM.
Incredibly enough, racketeering charges have recently been brought forward by U.S. Attorneys, against nuclear power firms and elected officials in Ohio and/or Illinois, and fraud and conspiracy charges have been brought against nuclear power executives in South Carolina. Such racketeering in illegal schemes by Holtec and SNC-Lavalin is not only a possibility, it is a likelihood, judging by both companies' past behavior, as documented in the annotated bibliographies below. NRC should not be a complicit party in such potential RICO violations, as by rubber-stamping the Holtec CISF license. It is mind boggling that NRC is even considering approving Holtec's proposal to acquire ownership of, and/or take over management of, up to 173,600 metric tons of irradiated nuclear fuel, given its documented track record.
Both Holtec and SNC-Lavalin have engaged in serious criminality and other malicious behaviors. How can NRC trust a word either Holtec or SNC-Lavalin say, including in the Holtec CISF license application, such as the Environmental Report, upon which the NRC DEIS is based in the first place? For this reason of lack of corporate character and integrity, under the laws and regulations NRC is mandated to carry out and enforce, to protect public health, safety, the environment, and the common defense, NRC should not approve Holtec's CISF license application. A genuine "hard look" by NRC under NEPA would have reached this conclusion. As one of the news article headlines below puts it, Holtec is "too radioactive" to be trusted with the authority to carry out such high risk highly radioactive waste activities.
References: