Environmental legal interventions opposing Holtec/ELEA CISF

Overview of Environmental Coalition Contentions Opposing Holtec/ELEA’s CISF, and the NRC ASLB Licensing Proceeding [.docx format, with links to more documentation]

Overview of Environmental Coalition Contentions Opposing Holtec/ELEA’s CISF, and the NRC ASLB Licensing Proceeding [.pdf format]

See below for more detail on filings in this licensing proceeding:

By the U.S. Nuclear Regulatory Commission (NRC) deadline of September 14, 2018, four allied environmental efforts filed requests for hearing, and petitions to intervene, in opposition to Holtec International/Eddy-Lea [Counties] Energy Alliance's license application to construct and operate a centralized interim storage facility (CISF) for 173,600 metric tons of commercial irradiated nuclear fuel, and highly radioactive Greater-Than-Class-C so-called "low-level" radioactive waste. The CISF is targeted midway between Hobbs and Carlsbad, New Mexico.

(1.) Beyond Nuclear request for hearing, and petition to intervene. Beyond Nuclear is represented by legal counsel Diane Curran of Washington, D.C., and Mindy Goldstein of Emory University, Turner Environmental Law Clinic, Atlanta, GA. (On Sept. 18, Beyond Nuclear's legal counsel also filed an Errata re: its request for hearing and petition to intervene.)

Beyond Nuclear motion to dismiss both the Holtec/ELEA CISF, as well as the Waste Control Specialists, LLC/Interim Storage Partners CISF, license application proceedings. (On Sept. 18, Beyond Nuclear's legal counsel also filed an Errata re: its Motion to Dismiss.)

(2.) Legal intervention by an environmental coalition (Citizens for Alternatives to Chemical Contamination, MI; Citizens’ Environmental Coalition, NY; Don’t Waste Michigan; Nuclear Energy Information Service, IL; Nuclear Issues Study Group, NM; Public Citizen (DC, TX); San Luis Obispo Mothers for Peace, CA), with Terry Lodge of Toledo, Ohio serving as legal counsel.

Expert witness declaration by James David Ballard, Ph.D., Professor, Criminology and Justice Studies, California State University, Northride, "Holtec HI-STORM UMAX Interim Storage Facility (a.k.a. CISF): Human-Initiated Events (HIE), Transportation of the Inventory, and Storage of Highly Radioactive Waste Materials."

The coalition put out a press release.

Coalition member Public Citizen also put out a press release.

(3.) PETITION TO INTERVENE AND REQUEST FOR ADJUDICATORY HEARING BY SIERRA CLUB; Wally Taylor, attorney for petitioner.

(4.) Petition to Intervene and Request for Hearing, Alliance for Environmental Strategies, Nancy L. Simmons, Counsel for the Petitioner.

Update on September 14, 2018 by admin

PETITION TO INTERVENE AND REQUEST FOR HEARING OF NAC [NUCLEAR ASSURANCE CORPORATION] INTERNATIONAL, INC.

[Please note that NAC is a partner in the WCS/ISP CISF, targeted at Texas. Beyond Nuclear, and a broad coalition of environmental and justice groups, strongly oppose, and have legally intervened against, NAC et al.'s license application, to "temporarily store" 40,000 metric tons of commercial irradiated nuclear fuel in West Texas!]

Update on September 24, 2018 by admin

Holtec International’s Answer Opposing Beyond Nuclear Motion to Dismiss Licensing Proceeding for HI-STORE Consolidated Interim Storage Facility;

INTERIM STORAGE PARTNERS LLC’S RESPONSE OPPOSING BEYOND NUCLEAR, INC.’S UNAUTHORIZED SEPTEMBER 14, 2018 FILING [Beyond Nuclear, of course, takes issues with ISP's characterization of our filing as "unauthorized"! We assert and allege their CISF proposal is unauthorized!]

NRC STAFF’S RESPONSE TO MOTIONS TO DISMISS LICENSING PROCEEDINGS.

Update on September 29, 2018 by admin

Beyond Nuclear filed a Motion for Leave to Reply on 9/28/18.

On 9/28/18, Beyond Nuclear also filed a Reply to NRC staff's, Holtec's, and ISP's Responses.

Update on October 9, 2018 by admin

NRC STAFF’S CONSOLIDATED RESPONSE TO PETITIONS TO INTERVENE AND REQUESTS FOR HEARING FILED BY: ALLIANCE FOR ENVIRONMENTAL STRATEGIES, BEYOND NUCLEAR, INC., DON’T WASTE MICHIGAN, ET AL., NAC INTERNATIONAL INC., AND THE SIERRA CLUB;

Holtec International’s Answer Opposing Beyond Nuclear Inc. Hearing Request and Petition to Intervene on Holtec International’s HI-STORE Consolidated Interim Storage Facility Application;

Holtec International’s Answer Opposing Beyond Nuclear’s Motion for Leave to Reply to Holtec International, Interim Storage Partners LLC, and NRC Staff Responses to Beyond Nuclear’s Motion to Dismiss;

Holtec International’s Answer Opposing the Don’t Waste Michigan, Citizens’ Environmental Coalition, Citizens for Alternatives to Chemical Contamination, Nuclear Energy Information Service, Public Citizen, Inc., San Luis Obispo Mothers for Peace, and Nuclear Issues Study Group Petition to Intervene and Request for an Adjudicatory Hearing on Holtec International’s HI-STORE Consolidated Interim Storage Facility Application;

Holtec International’s Answer Opposing Sierra Club’s Petition to Intervene and Request for Adjudicatory Hearing on Holtec International’s HI-STORE Consolidated Interim Storage Facility Application;

Holtec International’s Answer Opposing NAC [Nuclear Assurance Corporation] International Inc’s Petition to Intervene and Request for Hearing on Holtec International’s HI-STORE Consolidated Interim Storage Facility Application;

Holtec International’s Answer Opposing Fasken Land and Minerals, Ltd.’s and Permian Basin Land and Royalty Owners’ Motion for Leave to Reply to Holtec International and NRC Staff Responses to Motion to Dismiss;

Holtec International’s Answer Opposing Alliance [for] Environmental Strategies’ [AFES] Petition to Intervene and Request for Adjudicatory Hearing on Holtec International’s HI-STORE Consolidated Interim Storage Facility Application.