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Centralized Storage

With the scientifically unsound proposed Yucca Mountain radioactive waste dump now canceled, the danger of "interim" storage threatens. This means that radioactive waste could be "temporarily" parked in open air lots, vulnerable to accident and attack, while a new repository site is sought.

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Friday
Feb112022

Updated action alert, extended sign-on deadline, re: Request to Withdraw, Revise and Re-Publish Request for Information on Using a Consent-Based Siting Process to Identify Federal Interim Storage Facilities, 86 Fed. Reg. 68,244 (Dec. 1, 2021)

Thank you very much to the following organizations and individuals who have already signed-on to this letter --

Organizations: Beyond Nuclear; Citizens Awareness Network; Citizens Resistance at Fermi Two; Council on Intelligent Energy & Conservation Policy; Don’t Waste Arizona; Earthkeeper Health Resources; Hudson River Sloop Clearwater; Multicultural Alliance for a Safe Environment; National Nuclear Workers for Justice; Northeastern New Mexicans United Against Nuclear Waste; Nuclear Energy Information Service; Nuclear Information and Resource Service; Nuclear Watch South; Nukewatch; On Behalf of Planet Earth; Portsmouth/Piketon Residents for Environmental Safety and Security; Southwest Research and Information Center; Vermont Yankee Decommissioning Alliance.

Individuals: Alice Evans; Stephanie Bilenko; Kathleen Russell.

Beyond Nuclear's legal counsel, Diane Curran, has drafted a letter to DOE, re: Request to Withdraw, Revise and Re-Publish Request for Information on Using a Consent-Based Siting Process to Identify Federal Interim Storage Facilities, 86 Fed. Reg. 68,244 (Dec. 1, 2021)

See the text of the request letter, here.

In short, the letter requests DOE start this public comment proceeding over again, because its rollout has been so fatally flawed thus far. The letter requests a re-do: withdrawal, revision, and re-publication of the Request for Information.

Diane Curran and Beyond Nuclear are seeking endorsements from other organizations and individuals. Please consider signing onto this letter with us. The sign on deadline has now been extended, till Monday, February 14th, at 12pm Noon Eastern Time.

To sign on as an organization, please send your complete contact information to <kevin@beyondnuclear.org>.

Native American NGOs in particular are encouraged to consider signing on. This is because DOE has the responsibility, under law, to undertake government-to-government consultation with Native American tribal governments, and has utterly failed to do so adequately in this proceeding. In this regard, DOE is repeating its own past, infamous environmental justice violations, when it targeted scores of Native American reservations with Monitored Retrievable Storage sites, now called Consolidated Interim Storage Facilities.

Also, re: the section labeled DESCRIPTION OF BEYOND NUCLEAR AND OTHER ORGANIZATIONS REQUESTING EXTENSION, please include a short summary about the following:

DESCRIBE NAME AND PURPOSE OF ORGANIZATION, ANY INVOLVEMENT ORGANIZATION HAS HAD IN THIS PROCESS OR RELATED PROCESSES – SUCH AS SUBMISSION OF COMMENTS ON 2015 FED. REG. NOTICE, COMMENTS ON 2017 DRAFT REPORT, PARTICIPATION IN MEETINGS, ANYTHING ELSE?

Here is how Beyond Nuclear has answered that question, to serve as a model in writing your own group's description:

Beyond Nuclear is a nonprofit, nonpartisan membership organization that aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to protect public health and safety, prevent environmental harms, and safeguard our future. Beyond Nuclear advocates for an end to the production of nuclear waste and for securing the existing reactor waste in hardened on-site storage until it can be permanently disposed of in a safe, sound, and suitable underground repository. For more than 10 years, Beyond Nuclear has worked toward its mission by regularly intervening in U.S. Nuclear Regulatory Commission (“NRC”) licensing proceedings for the proposed Holtec International and Interim Storage Partners, L.L.C. (“ISP) consolidated interim storage facilities. Beyond Nuclear has appealed NRC’s issuance of the ISP license for violating the Nuclear Waste Policy Act in Don’t Waste Michigan, et al. v. NRC, No. 21-1048. The case is pending.

ANY AND ALL involvement in past related proceedings is helpful for including in your group's description.

Individuals who would like to endorse this letter are also welcome to do so. Please email <kevin@beyondnuclear.org> by the extended deadline -- 12pm Noon ET, Mon., Feb. 14. Please include your name and full contact info., as well as a short summary of any past involvement in related proceedings, as well.

Thanks for considering signing onto this! Please spread the word!

Wednesday
Feb092022

Please sign on to Beyond Nuclear's request to DOE for a do-over on its Request for Information re: "Consent-Based Siting" for Federal CISFs, and a 90-day extension to the comment period!

Beyond Nuclear's legal counsel, Diane Curran, has drafted a letter to DOE, re: a Request for Revision and Re-Publication of Request for Information on Using a Consent-Based Siting Process to Identify Federal Interim Storage Facilities, 86 Fed. Reg. 68,244 (Dec. 1, 2021).

See the draft request letter here.

In short, the letter requests DOE start this public comment proceeding over again, because its roll out has been so fatally flawed thus far. The letter requests a re-do, and another 90-day public comment period, beyond the current March 4, 2022 public comment deadline.

Diane Curran and Beyond Nuclear are seeking endorsements from other organizations and individuals. Please consider signing onto this letter with us. The sign on deadline is this Friday, February 11th, at 3pm Eastern Time. [This deadline for signing on has now been extended till noon Eastern on Monday, Feb. 14th.]

To sign on as an organization, please send your complete contact information to <kevin@beyondnuclear.org>.

Also, re: Page 2, Section I, in the draft letter, DESCRIPTION OF BEYOND NUCLEAR AND OTHER ORGANIZATIONS REQUESTING EXTENSION, please include a short summary about the following:

DESCRIBE NAME AND PURPOSE OF ORGANIZATION, ANY INVOLVEMENT ORGANIZATION HAS HAD IN THIS PROCESS – COMMENTS ON 2015 FED. REG. NOTICE, COMMENTS ON 2017 DRAFT REPORT, PARTICIPATION IN MEETINGS, ANYTHING ELSE?

Here is how Beyond Nuclear has answered that question, to serve as a model in writing your own group's description:

Beyond Nuclear is a nonprofit, nonpartisan membership organization that aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to protect public health and safety, prevent environmental harms, and safeguard our future. Beyond Nuclear advocates for an end to the production of nuclear waste and for securing the existing reactor waste in hardened on-site storage until it can be permanently disposed of in a safe, sound, and suitable underground repository. For more than 10 years, Beyond Nuclear has worked toward its mission by regularly intervening in U.S. Nuclear Regulatory Commission (“NRC”) licensing proceedings for the proposed Holtec International and Interim Storage Partners, L.L.C. (“ISP) consolidated interim storage facilities. Beyond Nuclear has appealed NRC’s issuance of the ISP license for violating the Nuclear Waste Policy Act in Don’t Waste Michigan, et al. v. NRC, No. 21-1048. The case is pending.

ANY AND ALL involvement in past related proceedings is helpful for including in your group's description.

Individuals who would like to endorse this letter are also welcome to do so. Please email <kevin@beyondnuclear.org> by the Friday, Feb. 11, 3pm ET deadline [this deadline has now been extended till 12pm Noon ET, Mon., Feb. 14] with your name and full contact info., as well as a short summary of any past involvement in related proceedings, as well.

Thanks for considering signing onto this! Please spread the word!

Tuesday
Feb082022

Coalition comment letter to DOE, re: "consent-based siting" for federal consolidated interim storage facilities -- open for organizational sign-ons

Beyond Nuclear has prepared comments intended for organizations to sign onto in coalition, for submission by the current March 4, 2022 deadline to the U.S. Department of Energy, re: its Request for Information on "consent-based siting" for federal consolidated interim storage facilities.

See the coalition comments letter, here:

In PDF format;

In Pages word processing format.

To sign your organization onto these coalition comments, please email <kevin@beyondnuclear.org> by 12pm Noon Eastern Time on Friday, March 4th, at the absolute latest. Please email the following information:

Person's name; person's title, if any; organization's name; city; state.

Beyond Nuclear will compile the full list of organizational endorsers, and submit the coalition comments by DOE's current 5pm ET deadline on March 4th.

Please note that Beyond Nuclear is preparing a request to DOE to extend its deadline, but this is not guaranteed. If and when DOE extends the deadline, Beyond Nuclear will likewise extend the deadline for groups to sign onto the coalition comments. In any event, we will meet the deadline, with as many groups signed on as possible.

Thanks for considering signing your organization on! And please spread the word to your networks!

Monday
Feb072022

INITIAL BRIEF OF PETITIONERS FASKEN LAND AND MINERALS, LTD. and PERMIAN BASIN LAND AND ROYALTY OWNERS

Fasken and PBLRO have filed their Initial Brief with the 5th Circuit U.S. Court of Appeals in New Orleans, in opposition to the U.S. Nuclear Regulatory Commission's approval of the license for Interim Storage Partner's consolidated interim storage facility in Andrews County, Texas.

See the Brief, here.

The State of TX also filed its federal appeal with the same court on Feb. 7, 2022.

Monday
Feb072022

Brief filed by State of Texas petitioners opposed to ISP in 5th Circuit

See the brief here.

It was filed by State of Texas petitioners opposed to the U.S. Nuclear Regulatory Commission license approval for Interim Storage Partners' consolidated interim storage facility in Andrews County, TX. These petitions include the governor of TX, the attorney general of TX, and the TCEQ (Texas Commission on Environmental Quality).

The filing was made to the 5th Circuit U.S. Court of Appeals, HQd in New Orleans, LA.

In addition to the State of TX, Fasken Land and Minerals, Ltd., and Permian Basin Land and Royalty Owners, have also appealed the NRC's license approval for ISP's CISF in the 5th Circuit Court of Appeals.

Beyond Nuclear, and a broad environmental coalition, have challenged ISP's license, in the D.C. Circuit Court of Appeals.

The State of New Mexico has challenged NRC's licensing of ISP, in both federal district court in NM, as well as in the 10th Circuit Court of Appeals, HQd in Denver, CO. ISP's CISF would be located just 0.37 miles from the NM state line, and upstream.