A request was made that a group sign on letter be circulated so that organizations could, by signing on, provide comments in that way to the U.S. Nuclear Regulatory Commission (NRC) re: its Holtec International/Eddy Lea Energy Alliance consolidated interim storage facility Draft Environmental Impact Statement. Karen Hadden of SEED Coalition in Texas volunteered to draft the group sign on letter (thanks Karen!), based on work already done by Nuclear Issues Study Group in New Mexico, with their permission and go-ahead (thanks NISG!). Diane D'Arrigo of NIRS and myself did some minor editing (thanks Dee!), and the resultant group sign on letter is below.

We hope your organization will sign on. To sign your group on, simply email me back at <kevin@beyondnuclear.org> with the following information:

I'll compile the list of groups signed on, and will be sure to submit it to NRC by the deadline (Tues., Sept. 22, 2020, 11:59pm Eastern). The deadline for you to sign your organization on to this coalition letter/comment is close of business (5:00pm Eastern) on Sept. 22nd.

Please consider signing your group on, and please spread this alert to your networks. Thank you.

Sincerely,

Kevin Kamps, Beyond Nuclear & Don't Waste Michigan

P.S. This group sign on letter/comment is for organizations only. However, if you would like to submit comments as an individual, here are links where you can send in webforms, as an individual, prepared by NIRS and SEED Coalition:

Submitted via: <Holtec-CISFEIS@nrc.gov>

Subject: Docket ID NRC-2018-0052, Draft Environmental Impact Statement, Public Comment 

Dear NRC Commissioners and Staff, 

This public comment is in response to the Draft Environmental Impact Statement (Docket ID NRC-2018-0052) regarding Holtec International’s application for a license to build and operate a “Consolidated Interim Storage Facility [CISF] for Spent Nuclear Fuel and High Level Waste” (NUREG-2237).

The undersigned organizations oppose Holtec’s proposal and ask that the NRC halt its licensing in order to protect public health and safety, the environment and our economy. It appears from the Draft Environmental Impact Statement and other license application documents that there would be no dry cask transfer facility (Dry Transfer System, DTS) at the proposed site, which means there would be no way to repackage waste. The site is not designed for long term disposal, but a dangerous de facto permanent site could result if waste casks or canisters are damaged or corroded and cannot be moved. Consolidated Interim Storage in Texas is also unacceptable. Our groups support and adopt the comments raised by the Nuclear Issues Study Group based in Albuquerque, New Mexico, which are as follows:

1) New Mexico Does Not Consent The motto of the Nuclear Regulatory Commission is “Protecting People and the Environment,” yet the NRC’s Draft Environmental Impact Statement (DEIS) on the Holtec project does neither. Instead, the NRC’s inadequate Draft EIS puts people, wildlife and precious water resources at significant and potentially, deadly risk by failing to heed the concerns of the community. We join the All Pueblo Council of Governors, New Mexico Governor Michelle Lujan Grisham, New Mexico State Land Commissioner Stephanie Garcia Richard, more than a dozen county and city governments, the Alliance for Environmental Strategies, the New Mexico Cattle Growers Association, the Permian Basin Coalition of Land & Royalty Owners and Operators, the Nuclear Issues Study Group, and the more than 30,000 residents who commented during the NRC's 2018 environmental scoping period in vehemently opposing bringing the nation’s high level radioactive waste from nuclear power plants through our communities to New Mexico.

We do not consent to New Mexico becoming a nuclear wasteland for millions of years. 

2) Cumulative Impacts The DEIS is inadequate because it fails to consider cumulative impacts from the damage the nuclear industry has already inflicted on New Mexicans for the past 75 years: uranium mining and milling in the northwest on indigenous Diné and Pueblo lands, including the 1979 Church Rock Disaster; radioactive contamination to Tewa lands and people since the Manhattan Project in the Los Alamos area; fallout on downwinders from the Trinity Test in the Tularosa Basin; the Waste Isolation Pilot Plant, which has already accidentally released dangerous amounts of radiation and now wants to expand; the URENCO uranium enrichment plant in Eunice; the world’s largest nuclear warhead stockpile on the edge of Albuquerque; and the toxic threat to Albuquerque’s aquifer by the Mixed Waste Landfill. 

Rather than adding 173,600 metric tons of high-level radioactive waste to a state that has already been grossly overburdened, the United States should be directing its resources towards: cleaning up the contamination already present in New Mexico communities; just compensation; and holistic community health studies. The DEIS also fails to account for cumulative impacts from the other proposal for Consolidated Interim Storage, approximately forty miles east at the current Waste Control Specialists low-level radioactive waste dump in Andrews County, Texas, very near Eunice, New Mexico.

3) Environmental Racism It’s no coincidence that the United States wants to make New Mexico a nuclear wasteland. It ranks as one of the poorest states and is a majority minority state, with more Black, Indigenous, People of Color (BIPOC) residents than white residents. For the NRC to determine that nuclear waste which will threaten life for millions of years would have “small” or “no environmental impact” is a blatant violation of environmental justice principles and is environmental racism in action. We do not give our own government license to allow a private industry to further contaminate New Mexicans' home or to expand the massive nuclear burden New Mexicans already bear. 

4) Threats to Cultural Properties & Historic Sites Holtec International and the NRC would have us believe that the site is a desolate, uninhabited place with “no historic value or significance.” This statement is completely false and without merit. The site is located near or on two lagunas or playa lakes: Laguna Gatuna and Laguna Plata. Laguna Plata is an archaeological district that has been extensively studied for decades. Two sites near Laguna Gatuna, where the nuclear waste is proposed to be stored, are listed on the National Register of Historic Places. Archaeologists have found a plethora of evidence of the Jornada Mogollon people, dating from 200 AD, 700 AD, and 1200 AD. More than 200 archeological sites are located within six miles of the proposed nuclear waste dump. Laguna Gatuna, while often dry, fills with water after monsoon rains, attracting a variety of wildlife and hunters for millenia. The Hopi and Mescalero Apache nations have identified the area as culturally significant to them, and the Hopi nation has informed the NRC that traditional cultural properties could be adversely affected if this project proceeds. The site where Holtec wants to dump tens of thousands of tons of radioactive waste has profound historic value and significance.

5) Threats to Water & Wildlife The impact of this forever deadly nuclear waste would have devastating consequences on wildlife including threatened species that rely on the lagunas for drinking water and the surrounding area as a critical habitat, including the Lesser Prairie Chicken, and the Dunes Sagebrush Lizard. Agencies such as U.S. Fish & Wildlife, New Mexico Game & Fish, the U.S. Environmental Protection Agency (EPA) and the New Mexico Environment Department (NMED) have all gone on record attesting to the significance of Laguna Gatuna for migratory birds, and have argued that it should be designated permanently as a Water of the United States (WOTUS), which would make it eligible for protection under the Clean Water Act. 

6) Threats from Transporting Irradiated Nuclear Fuel  Not only New Mexico would be adversely impacted by the Holtec project: all communities along the transportation routes between nuclear power plants and Holtec's proposed CISF site would be threatened by radiation from the rail cars, and from the devastating financial and environmental damage if an accident or act of malice should occur. Studies have shown that one accident is likely to occur for every 10,000 shipments. It is irresponsible and dangerous for NRC to avoid adequate inclusion (a "hard look," as legally required by the National Environmental Policy Act, NEPA) of these mammoth risks and liabilities in its DEIS for Holtec’s application. 

For all the above reasons and more, we declare that the DEIS for Holtec’s application is inadequate and further that the license for a high-level radioactive waste storage facility should be denied. In conclusion, high-level nuclear waste from nuclear power plants around the U.S. should not be brought to New Mexico – it should be isolated on or near the current nuclear power plant site, in Hardened On-Site Storage (HOSS), until there is an environmentally just and scientifically sound option available.

Sincerely,

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