Additional Background Information, on demanding public comment mtgs. across US on transport routes to CISFs

ADDITIONAL BACKGROUND INFORMATION

This spring, the U.S. Nuclear Regulatory Commission (NRC) opened its public comment period on the Holtec International/Eddy-Lea Energy Alliance (Holtec/ELEA) Draft Environmental Impact Statement (DEIS). The Holtec/ELEA consolidated interim storage facility (CISF) for commercial irradiated nuclear fuel and other highly radioactive waste (such as Greater-Than-Class-C "low-level" radioactive waste), if constructed and operated, would "temporarily store" (for 40 years, 120 years, 300 years, or perhaps even de facto permanently) up to 173,600 metric tons of high-level radioactive waste (HLRW). But this of course would entail shipping such wastes, from the nuclear power plant sites where they are currently located, across most states in the Lower 48, to southeastern New Mexico. (90% of reactors and HLRW are in the eastern half of the U.S. 75% are east of the Mississippi River.)

On March 20, 2020, NM's U.S. congressional delegation made similar demands of NRC, within the unwilling "host" state itself. We are fortunate that NM's delegation is so strong and active on this critical fight. Such congressional demands are usually taken seriously by NRC, even when the agency attempts to ignore citizens' concerns.

And in fact, on April 21st, NRC announced a 60-day extension to its previously announced, arbitrarily short (merely 60-day) deadline for public comments. Thus, the previous May 22nd deadline was extended till July 21st. Later, another two months were added, so the current deadline is September 22nd. However, despite the pandemic emergency, NRC's countdown clock for public comments continues to tick away, despite calls, as from Congressional Democrats, and concerned citizens and watchdog group that no deadline apply during the pandemic. Thus, we must take action now.

(See also this announcement, by NRC, regarding one of the 60-day extensions.)

And despite the nationwide high-level radioactive waste transport risks (Mobile Chernobyls on the rails and roads, Dirty Bombs on Wheels in terms of security risks, Floating Fukushimas in terms of barge shipments on waterways, and even Mobile X-ray Machines That Can't Be Turned Off risks of "routine," hazardous gamma- and neutron-radiation emissions, even during "incident-free" shipments), NRC has planned only five public comment meetings, exclusively in New Mexico (these planned meetings are currently postponed due to the pandemic). What about the 44 other states (or more) that would see NM-bound HLRW shipments roll through by truck, train, or barge? Why doesn't NRC plan to hold meetings along transport routes?

It appears that NRC has bowed to pressure from CISF proponent and partner John Heaton of Eddy-Lea Energy Alliance. Heaton was even quoted in the NM press calling for the unwilling "host" state in-person public comment meetings to be replaced by mere webinars; but the NM US congressional delegation will not back down from its demand for in-person public comment meetings, once safe to do so. NRC dare not deny that demand.

But NRC, in its April 21st letter, added but a single webinar public comment opportunity, for the rest of the country outside NM along the high-risk transport routes! It was held on June 23rd.

A second webinar/call-in only public comment meeting was held July 9th.

Incredibly, under pressure from Holtec and ELEA, NRC has reneged on its promise to NM's US Congressional delegration, to hold five in-person public comment meetings. In August 2020, NRC announced it will not hold any in-person meetings. It has added four additional webinar/call-in only meetings, scheduled for August 20, 25, 26, and Sept. 2. It is now rushing toward the Sept. 22nd deadline, at which point it will end the public comment period, despite the pandemic emergency (taking full advantage, and under the guise of, the pandemic emergency.)

Thus, NRC currently plans zero in-person public comment meetings, in 45 or more states, including NM, thus impacted!

What states, cities, and U.S. congressional districts, you ask? NRC, in its Holtec DEIS, has cited a 2008 DOE Final Supplemental EIS re: Yucca transport routes. The State of NV Agency for Nuclear Projects' has carefully -- and helpfully! -- analyzed that very document. See its road and rail route maps, and shipment numbers, here:

• Nevada Agency for Nuclear Projects - Representative Transportation Routes to Yucca Mountain and Transportation Impacts (Cask Shipments by State) - Fred Dilger PhD
• Nevada Agency for Nuclear Projects - Cities Potentially Affected by Shipments to Yucca Mountain (pdf-2.45M)
• Nevada Agency for Nuclear Projects - States Potentially Affected by Shipments to Yucca Mountain with Congressional Districts (pdf-7.05M)
• Nevada Agency for Nuclear Projects - Congressional Districts Potentially Affected by Shipments to Yucca Mountain - 115th Congress (pdf-882K)

For its part, NRC has not provided a single route map in its DEIS! And for its part, Holtec provided a sole route map in its license application Environmental Report. But Holtec's route map accounts for only four (one in Maine; three in southern California) of the 119 atomic reactors in the U.S.! NRC is being even more secretive than Holtec, in the attempt to keep the impacted public in the dark across the country!

As if road and rail routes weren't enough to worry about already, check out potential barge routes on surface waters from coast to coast!

Two decades ago, during the U.S. Department of Energy's (DOE) Yucca Mountain, Nevada HLRW dump DEIS (targeted at Western Shoshone land), over the course of a hard-won 199-day public comment period, DOE ultimately held two-dozen public comment meetings, including in a dozen states outside of NV.

On March 25, 2020, 50 anti-nuclear, environmental, EJ, social justice, and public interest groups also wrote NRC, urging that this Holtec DEIS have the equivalent 199-day public comment period, and have an equal number of public comment meetings, including along transport routes outside of NM, as Yucca did 20 years ago, including outside of NV. Currently, even NRC's now-extended 120-day public comment period, ending July 21st, falls far short of the requested duration. The 50-group coalition also called for the public comment proceeding to be kept open throughout the pandemic, for all the called-for, in-person public comment meetings to still take place once safe to do so, and for the 199-day public comment deadline clock to not commence until the Centers for Disease Control (CDC) announces an end to the national pandemic emergency.

Instead, NRC plans to let the clock run during, and despite, and under cover of, the deadly pandemic.

Our coalition's requests are very reasonable. After all, Holtec's CISF represents 2.5 times more HLRW than the Yucca scheme (173,600 metric tons, versus 70,000 MT).

But we are also being backed up by 24 Democratic U.S. Senators (including five who were campaigning for the presidency up until recently -- and including one, Kamala Harris, who is now Joe Biden's V.P. running mate); see their April 8th letter to OMB, here.

And we are being backed up by 14 Democratic U.S. House of Representatives committee chairmen; see their April 1st letter to OMB, here.

Given all that, please help us secure more in-person public comment meetings, by urging both your U.S. Senators, and your U.S. Representative, to demand one from NRC in your state/congressional district, once safe to do so. At the same time, urge your Congress Members to demand NRC keep the public comment period open indefinitely, and to only start the 199-day public countdown clock once the pandemic emergency is over, and in-person public comment meetings are once again safe to hold.

You can call your U.S. Congress Members' D.C. offices via the U.S. Capitol Switchboard at (202) 224-3121. You can also email, webform, fax, and/or snail mail your request to your Congress Members' D.C. and/or in-state/district offices. Here is a sample script you can use as is, or feel free to edit it:

"Dear Senator/Representative X, please contact NRC and demand that a Holtec CISF DEIS public comment meeting be held in our state/district, once safe to do so. Also demand that the public comment period be kept open indefinitely, and that a 199-day public comment period countdown clock commence only after it is safe to once again hold in-person public comment meetings. Given the high risks of high-level radioactive waste trains, trucks, and barges, and the fact that Holtec's CISF would ship and store 2.5 times the HLRW volume as the Yucca Mountain dump scheme in Nevada, targeted at Western Shoshone land (173,600 metric tons, versus 70,000 MT), it is only proper that NRC hold an equal number of meetings along transport routes, and an equally long comment period, as did DOE on Yucca 20 years ago. As it stands, NRC's still too short 180-day comment period ends on September 22nd, and only five meetings were to have been held, all in the unwilling 'host state' of New Mexico. Now, however, NRC has reneged on even that promise; under pressure by Holtec, NRC will hold only webinar/call-in meetings, in its rush to end the public comment period on Sept. 22. Given the accident and attack risks of Mobile Chernobyls, Dirty Bombs on Wheels, and Floating Fukushimas, and even the 'incident-free' Mobile X-ray Machines That Can't Be Turned Off risks of 'routine' shipments, adequate time and numbers of meetings for public comment are vitally needed. And given the environmental justice burden that high-level radioactive waste shipments would represent -- as attested to by none other than Mustafa Ali, former head of EJ at US EPA, on Democracy Now! last September -- public comment meetings must be held in transport corridor communities nationwide, including in our state. Please demand this of NRC, on behalf of your constituents."

You can look up your U.S. Senators' email/webform contact info., their fax number(s), and/or their postal addresses, for their various offices, by clicking through links, here.

Likewise, you can look up your U.S. Rep.'s email/webform contact info., their fax number(s), and/or their postal address, here.

Please spread the word! Working together, we can win the two-dozen, in-person public comment meetings, in not only NM, but also a dozen states outside NM, that we are due, based on the hard-won DOE/Yucca precedent set 20 years ago! Thank you for taking action to defend Mother Earth!