How to submit your public comments by the July 30th, 2018 deadline

HOW TO SUBMIT YOUR PUBLIC COMMENTS BY THE CURRENT JULY 30TH (EXTENDED FROM THE ORIGINAL MAY 29TH), 2018 DEADLINE:

Please include “Docket ID NRC–2018–0052” in your comment submission, such as in the subject line of your e-comments or snail-mailed hard copy comments.

(Another convenient, efficient, quick and easy way to submit comments is via Public Citizen's webform, here.)

An email option for submission of public comments was added on May 3rd. Thanks to Joni Arends of CCNS (Concerned Citizens for Nuclear Safety, Santa Fe, NM) requesting it (see note at bottom*) at the May 1st Hobbs, NM public comment mtg., NRC granted the request:

Here's the official NRC email address for folks to submit comments directly to NRC:

Holtec-CISFEIS Resource <Holtec-CISFEIS@nrc.gov>

You can also submit written comments electronically via the Federal Rulemaking website: Go to
http://www.regulations.gov and search for Docket ID NRC–2018–0052, then follow the instructions given there. (**See note below.)

Submit written comments via snail mail, by sending them to: May Ma; Office of Administration; Mail Stop: TWFN-7-A60M; U.S. Nuclear Regulatory Commission; Washington, DC 20555-0001.

Notes:

[*The only reason NRC even has an email option for submitting public comments is because Joni Arends of CCNS -- Concerned Citizens for Nuclear Safety -- requested it, at the Hobbs, NM NRC public comment meeting on May 1st. Thank you Joni! And the reason Joni requested it, was because her friends and colleagues had encountered so much difficulty with the regulations.gov site, even at that point. In the year 2018, the public should not have to ask for an NRC email address to be provided, as one way for submission of public comments. And in the year 2018, NRC's regulations.gov site should not be out of order for two solid weeks, and counting! The question is, does NRC stand for Nobody Really Cares, or No Remaining Credibility -- or both at the same time?!] 

[**Update on June 14, 2018: Outrageously, NRC's regulations.gov site, re: this subject matter docket, had not worked, from May 18th to June 7th! It had been spotty even weeks before that, as indicated in the note* above. Beyond Nuclear, and other groups, called this to NRC's attention multiple times, beginning with Joni Arends of CCNS on May 1st as noted above, and again on May 22nd (Beyond Nuclear via emails, Nuclear Issues Study Group's Cody Slama via verbal testimony at the NRC public comment meeting in ABQ, NM), as well as again on May 31st (Beyond Nuclear emails to NRC staff). NRC's response was, for weeks on end, essentially, that's not our department, and there are other ways to submit your comments -- or even outright denial that there was even a problem. This was a real outrage. NRC cannot get away with being this irresponsible. NRC itself has held up regulations.gov as a gold standard way of submitting public comment. Only it was not working at all for a solid three weeks?! On June 7th, 2018, it was finally confirmed that the regulations dot gov site is working again, as it was supposed to be the whole time. If you do encounter any problems using the Regulations.gov site, please let Beyond Nuclear staffer Kevin Kamps know ASAP at kevin@beyondnuclear.org, or (240) 462-3216, so that Beyond Nuclear can continue to hold NRC's feet to the fire!

In an effort to get NRC to do its job, and grant the public unfettered rights and means to submit comments on the environmental scoping, a coalition of environmental groups (Beyond Nuclear, Don't Waste Michigan, Nuclear Information and Resource Service, and Nuclear Issues Study Group, represented by legal counsel) submitted a letter to NRC on June 12th, demanding NRC fix the Regulations.gov website once and for all, or else offer an alternative; and extend the current July 30th public comment deadline till October 30th. We'll keep you posted here as to how that develops! If NRC cannot even guarantee that its public comment webform works, how can we trust this agency to safeguard, secure, and contain forever deadly highly radioactive waste?!]

4/9/18: NRC to hold public meetings in New Mexico on proposed Holtec consolidated interim storage spent fuel facility

See the NRC OPA press release.

Sample comments you can use to write your own for submission to NRC in opposition to Holtec's CISF in s.e. NM

Sample comments you can use to prepare you own, for submission to the U.S. Nuclear Regulatory Commission (NRC). See how to submit public comments, by the May 29, 2018 environmental scoping period deadline, below.

We need to generate a large number of quality comments to NRC, just like we did over a year ago in opposition to a similar Centralized Interim Storage Facility (CISF, a.k.a. MRS, short for Monitored Retrievable Storage site) targeted at Andrews Co., w. TX, just 38 miles from the s.e. NM Holtec/ELEA site.

This week's Beyond Nuclear sample comments are focused on Mobile Chernobyl shipping risks.

Here they are, in PDF format, and in Word (.docx) format.

Feel free to use them in any way that is helpful to you -- including copying them in their entirety. You can also use them to help shape your ideas to express in your own words.

(In future weeks, additional sample comments will be provided by Beyond Nuclear, covering a multiplicity of the multi-faceted high risks of the Holtec/ELEA CISF/MRS proposal. Watch for them, to help you submit your own version to NRC by the deadline!)

See also:

Nuclear Watch New Mexico has posted 2-page and 4-page long sample comments on its No High-Level Waste to New Mexico website section.

HOW TO SUBMIT YOUR PUBLIC COMMENTS BY THE MAY 29, 2018 DEADLINE:

Please include “Docket ID NRC–2018– 0052” in your comment submission, such as in the subject line of your e-comments or snail-mailed hard copy comments.

Submit written comments electronically via the Federal Rulemaking website: Go to
http://www.regulations.gov and search for Docket ID NRC–2018–0052, then follow the instructions given there.

Submit written comments via snail mail, by sending them to: May Ma; Office of Administration; Mail Stop: TWFN-7-A60M; U.S. Nuclear Regulatory Commission; Washington, DC 20555-0001.

Submit verbal comments at NRC public meetings:

A national phone in/webinar for public comments on Wednesday, April 25, from 7-9pm Eastern Time (call-in number/webinar sign-up instructions will be circulated, as soon as NRC provides them; those who live in the Washington, D.C. area could also attend this meeting, to be held at NRC HQ in Rockville, MD, located at 11555 Rockville Pike, to provide verbal comments in person);

Those who live near enough to s.e. NM could provide verbal comments by attending in person (no phone-in or webinar being provided by NRC):

4-7pm Mountain Time, April 30, at Eastern New Mexico University, Roswell Campus, Union Building, Room 110, 48 University Blvd., Roswell, NM;

7-10pm Mountain Time, May 1, at the Lea County Event Center, 5101 N. Lovington Highway, Hobbs, NM;

7-10pm Mountain Time, May 3, at the Eddy County Fire Service, 1400 Commerce St., Carlsbad, NM.

NRC poised to begin Holtec/ELEA CISF/MRS licensing proceeding

Thanks to Don Hancock of Southwest Research and Information Center (SRIC) in Albuquerque, New Mexico for watch-dogging the twists and turns. The U.S. Nuclear Regulatory Commission (NRC) is now poised to proceed with environmental scoping, as well as the legally contested licensing proceeding, for the Centralized Interim Storage Facility/Monitored Retrievable Storage targeted at southeastern New Mexico by Holtec International and the Eddy-Lea [Counties] Energy Alliance.

Here is the official Federal Register (FR) Notice regarding environmental scoping, published on Friday, March 30, 2018.

As reported by Don Hancock today (Thursday, March 29, 2018):

[Linked above] is the...Federal Register notice that starts the 60-day public scoping period.

The scoping period starts [March 30] and runs through May 29 - I did check those dates with Jill Caverly, the [NRC] contact person in the FR notice.

The scoping meeting dates are not listed in the FR and won't be in the FR until next Friday [April 6, 2018], but are as I was told before and listed below. They will likely be posted on the NRC website on Monday [April 2, 2018] or Tuesday [April 3, 2018] and a [NRC] press release with the information will go out then.

Jill also confirmed that there will be a court reporter in Roswell, so people also can make scoping comments there.

For our information about how people submit comments:

By mail:

May Ma
Office of Administration
Mail Stop: TWFN-7-A60M
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

By email:
The notice includes two ways, the "official" way won't accept comments until tomorrow [Friday, March 30, 2018]. So I'm checking about the other option(s).

Here is the way to submit written comments online, per the March 30, 2018 Federal Register Notice:

Federal Rulemaking website: Go to
http://www.regulations.gov and search
for Docket ID NRC–2018–0052.

And here are those dates Don Hancock mentioned above:

The formal announcement will [likely] be in Friday [April 6] Federal Register [Notice, as Don Hancock reported above].

The Dates [for NRC environmental scoping public comment meetings]: Monday, April 30 - Open House in Roswell from 4 to 7 [please note that all times are in Mountain Time]

Tuesday, May 1 - Open House in Hobbs from 6-7; 7-10 scoping comments

Thursday, May 3 - Open House in Carlsbad from 6-7; 7-10 scoping comments.

There will also be a phone in/webinar for public comments on Wednesday, April 25

The scoping comment period will be for 60 days. [It began March 30th, and will end May 29th]

The [legal] intervention notice won't be out until probably April 6 for a 60-day timeframe to file interventions/contentions.

Beyond Nuclear plans on sending a representative (Radioactive Waste Watchdog Kevin Kamps) to southeastern New Mexico, to take part in the environmental scoping public comment meetings.

ASAP, Beyond Nuclear will prepare and share sample public comments, of varying lengths and detail, that you can use to prepare and submit your own to NRC.

Beyond Nuclear also plans to legally intervene against the Holtec/ELEA CISF/MRS site. Beyond Nuclear's legal counsel are Diane Curran of Harmon, Curran, Spielberg + Eisbenberg, LLP of Washington, D.C. and Mindy Goldstein of Emory University's Turner Environmental Law Clinic in Atlanta, GA.

Orano [Areva], WCS Aim to Revive Spent Fuel Storage Project

As reported by the ExchangeMonitor. (Note that Orano is the new name for Areva -- apparently trying to shed the many negative connotations associated with its old name. Just as Areva was a rebranding from Cogema, in the 1990s!)

Waste Control Specialists, LLC (WCS) requested the U.S. Nuclear Regulatory Commission (NRC) suspend its licensing proceeding to process an application for WCS to construct and operate a so-called "centralized" or "consolidated interim storage facility" (CISF) in Andrews County, west Texas last year. This, after a federal judge ruled in favor of the U.S. Department of Justice, blocking a proposed merger between WCS and its rival EnergySolutions of Utah. The DOJ argued, and the judge agreed, the merger would violate anti-monopolization laws, specifically regarding so-called "low-level" radioactive waste disposal, in the U.S.

This left WCS essentially bankrupt, prompting it to request NRC to suspend its license application proceeding on the CISF.

NRC ultimately did suspend the proceeding. However, it took its sweet time in doing so. In fact, the night before a legal intervention deadline for groups like Beyond Nuclear to either speak or forever hold our peace, NRC issued a very short emailed statement, assuring potential intervenors the proceeding would be officially suspended. Groups like Beyond Nuclear feared that not intervening, while NRC's drop dead deadline passed, could be used to bar intervenors from ever intervening again -- for having missed the deadline. Legal interventions involve an immense amount of work, a heavy burden on not only non-profit environmental groups like Beyond Nuclear, but also all-volunteer grassroots groups, such as those in the vicinity of WCS, being targeted for this environmental injustice. Agonizingly, NRC left groups like Beyond Nuclear in limbo -- having to do the work anyway, even though the proceeding would, in the end, actually be suspended. NRC's very own behavior in this regard, above and beyond the WCS scheme, is itself an environmental injustice.

But on Jan. 26, 2018, J.F. Lehman & Company bought WCS. And now, it appears, WCS and Areva/Orano/Cogema are ready to hit the play button again on NRC's licensing proceeding.

We will now face two simultaneous highly radioactive waste de facto permanent surface storage parking lot dump NRC licensing proceedings at the same time. The NM site aims for 120,000 metric tons. The TX site, 40,000 metric tons. At 160,000 metric tons, that would be twice as much irradiated nuclear fuel than currently exists in the US. And it dwarfs what is targeted for burial at Yucca Mountain, NV under current law (70,000 metric tons). The NM and TX sites are only 38 miles apart. The scheme is to turn that area into a Nuclear Sacrifice Zone.