The solitary transport route map in Holtec's license application Environment Report, which accounts for only four of the 129 atomic reactors in the U.S.See the DEIS posted online, as well as how/where to submit your comments (see bold, italicized section), at this link.
(You can E-mail comments to: Holtec-CISFEIS@nrc.gov.)
The current public comment deadline is September 22nd, 2020 (it had previously been July 22nd, 2020, but has been extended by two months).
*Please include the Docket Number -- Docket ID NRC-2018-0052 -- in your email subject line, as well as in the text of your emailed comments.*
Despite the ongoing pandemic national emergency, the U.S. Nuclear Regulatory Commission (NRC) public comment period on its Holtec irradiated nuclear fuel Consolidated Interim Storage Facility (CISF) Draft Environmental Impact Statement (DEIS) is ticking down to the current Sept. 22nd deadline.
It's important we begin the submission of large numbers of quality comments, even while we seek more time, as well as more meetings along transport routes (please urge your Members of Congress to demand in-person public comment meetings in your congressional district/state, once safe to do so.)
Your comments can be as short, or as long, as you would like to make them. You can also submit multiple installments of comments to NRC, if you choose to do it that way.
Choose one or more ideas below, and use them to prepare your own comments, in your own words (also feel free to cut and paste them verbatim, but if you quote from the op-eds or letter to editor in point #1 immediately below, please do provide attribution to the original author(s)).
*Please include the Docket Number -- Docket ID NRC-2018-0052 -- in your email subject line, as well as in the text of your emailed comments.*
For some ideas on comments you could submit, consider:
*See two-dozen sets of comments, submitted by Beyond Nuclear to NRC, you can use to help write you own for submission to the agency by the Sept. 22nd deadline -- click the link here*
(1) The views of grassroots New Mexicans who oppose this de facto permanent, surface storage, parking lot dump in their state. See Laura Watchempino of Multicultural Alliance for a Safe Environment's, and Albuquerque resident Sam Weisberg's, op-eds, and Janet Greenwald of Citizens for Alternatives to Radioactive Dumping's letter to the editor, recently published in the Albuquerque Journal.
(2) You could also comment that NRC's time-limited focus on just 40 years of "temporary storage" is inappropriately, arbitrarily short, given Holtec's own admission in its license application to NRC that "interim storage" could persist for 120 years; in response to a Request for Information from DOE, Holtec admitted a CISF could operate for 300 years; and in NRC's own 2014 Continued Storage of Spent Nuclear Fuel Rule and Generic EIS, the agency acknowledged away-from-reactor ISFSIs (Independent Spent Fuel Storage Installations) could go on indefinitely (that is, forevermore). Institutional control could be lost over such long time periods. Failed containers could release catastrophic amounts of hazardous radioactivity directly into the surface environment, to blow downwind, flow downstream, bioconcentrate up the food chain, and harm people down the generations.
(3) You could also protest NRC's woefully inadequate, to nearly non-existent, treatment of highly radioactive waste transport risks. This violates the long-established legal requirement under the National Environmental Policy Act (NEPA) that NRC take a "hard look" at the Holtec CISF proposal, including its inextricably linked high-risk transportation component, impacting most states in the Lower 48. (See the 2017 transportation route and shipment number documents posted online by the State of Nevada Agency for Nuclear Projects, its analysis of the same 2008 U.S. Department of Energy document that NRC itself cites as its excuse for not having to do a Holtec-specific transport analysis in 2020!)
Also see route maps for potential barge shipments into ports on bays, rivers, harbors, lakes, and seacoasts across the country.
For its part, Holtec's Environment Report accounts for routes to NM from only four of our country's total of 129 atomic reactors -- three at San Onofre, CA and one at Maine Yankee -- but NRC's DEIS didn't even include this sole, inadequate map! (See Holtec's solitary map, linked here, as well as reproduced above left. Compare it to this more comprehensive map, produced by the State of NV re: the Yucca dump targeting Western Shoshone land, based on the same 2008 DOE Final Supplemental EIS that NRC cites in its 2020 Holtec DEIS.)
NRC's DEIS, and Holtec's ER, essentially excluding the high risks of transport, and not even being transparent about transport routes, represents segmentation (the dividing up of a major federal action into smaller parts, so that the proposal doesn't seem so significant or impactful after all). This is a violation of NEPA, as long ruled so by the federal courts.
(4) Another comment could be that inner canisters will have to be transferred (from on-site storage dry casks, to radiation shielding/transfer casks, to transport/shipping casks, to transfer casks, to CISF storage pits (and then, if and when high-level radioactive wastes are exported to a permanent repository, the reverse process) multiple times. Yet, NRC is not requiring Dry Transfer Systems (DTS), so there will be no way to deal with failed fuel or containers, as well as leaks or contamination. (And expert witness Bob Alvarez, a former senior advisor to the U.S. Energy Secretary, has testified in these CISF proceedings that under DOE's latest Yucca dump plans, targeting Western Shoshone land in NV, high-level radioactive wastes can only be buried in TADs -- standardized Transport, Aging, and Disposal containers specially designed for use at the Yucca dump. This would require dividing up the contents of 10,000 containers at Holtec into 80,000 smaller TADs. Nowhere is this addressed in the Holtec ER, nor the NRC DEIS. And yet both Holtec and NRC assume Yucca will be the ultimate dump, itself an outrage -- see sample talking point #6, below. But that repackaging process carries significant risks and potential impacts for health, environment, and safety, and yet could not be done without a DTS. The entire complex, high risk subject matter area is missing from NRC's Holtec CISF DEIS, another violation of NEPA's "hard look" requirement, and even a violation of the Atomic Energy Act, given the inherent, large safety risks.)
(5) Yet another comment idea is to point out NRC staff's internal contradiction: it is willing to overlook this CISF's violation of the Nuclear Waste Policy Act of 1982, as Amended (which prohibits the U.S. Department of Energy from taking ownership of commercial irradiated nuclear fuel at an interim site in the absence of an open permanent repository), while citing in the DEIS that the lack of a legally-binding decision by DOE and Congress re: highly radioactive Greater-Than-Class-C "low-level" radioactive waste, means NRC will choose to refrain from reviewing that aspect of the proposal any further at this time. NRC is talking out both sides of its mouth, to the benefit of license applicant Holtec, and to the disadvantage of the public interest! And the double standard re: rule of law is also outrageous NRC behavior. NRC must obey, and not violate, all federal laws, including the Nuclear Waste Policy Act of 1982, as Amended. To violate that law is itself a violation of the Administrative Procedure Act. (See this April 27, 2020 Beyond Nuclear press release for more info.)
(6) Holtec and NRC assume that the Yucca Mountain dump in Nevada, targeting Western Shoshone Indian land, will open, allowing re-export of irradiated nuclear fuel from NM to NV for permanent disposal. It's how Holtec and NRC attempt to justify calling the CISF "interim" or temporary. But the Yucca dump should not, and will not, happen, for a long list of reasons. This includes the Yucca dump's illegality (it would violate the Treaty of Ruby Valley of 1863, signed by the U.S. government with the Western Shoshone Indians), as well as the environmental injustice of opening the national high-level radioactive waste dump in the same state that "hosted" nuclear weapons testing for several decades on end, resulting in disastrous radioactive fallout and health damage downwind. But it also includes Yucca's flagrant scientific unsuitability, as well as the fact that well over a thousand environmental groups have been actively opposing the scheme for 33 years. Holtec and NRC are entirely unjustified in assuming the Yucca dump will open someday, or year, or decade, or century. In fact, NRC's doing so reveals its bias in the Yucca Mountain licensing proceeding, in which it is supposed to be a neutral safety regulator, only sitting in judgment of the Yucca site's capability of meeting regulations, not advocating for its opening even in the face of its clear unsuitability. For this reason, there is a very high risk that the Holtec CISF in NM will become de facto permanent surface storage, a parking lot dump, risking catastrophic releases of hazardous radioactivity directly into the environment when containers ultimately fail over a long enough period of time, due to loss of institutional control. (See point #2 above.)
(7) Check out the following Overview of Environmental Coalition Contentions Opposing Holtec/ELEA’s CISF, and the NRC ASLB Licensing Proceeding, for ideas on NRC Holtec CISF DEIS public comments that could be submitted, or at least subject matter ideas to consider for comments. As you'll see, the voluminous 40+ contentions submitted by numerous official intervenors to the NRC Atomic Safety and Licensing Board, opposed to Holtec's CISF, we have tried to summarize in 20 one-line sentences. So in that sense, it's a topic summary. Subject matter areas, to consider making comments about at this DEIS stage. Because the NRC staff has done little to nothing about any of it, even though we've been bringing these things up since the NRC environmental scoping stage in 2018, as well as throughout the Atomic Safety and Licensing Board (ASLB) licensing proceeding, for a couple long years now.
Beyond Nuclear created the document in mid- to late-December 2018, in anticipation of the in-person ASLB oral argument pre-hearings that then took place in late January 2019 in ABQ, NM, which had just been announced, as part of media work and public education efforts, to help reporters and concerned citizens get up to speed, so they could wrap their heads around the broad and deep interventions our coalition had mounted in opposition to Holtec's CISF.
Here are links to a .Docx (with hot links to more documentation), and to a .pdf, versions of this document:
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]
And now here are those 20 one-sentence summaries (see sub-points (a) through (t), below) for 40 contentions/objections filed against Holtec's CISF in the NRC ASLB licensing proceedings --
Overview of Environmental Coalition Contentions Opposing Holtec/ELEA’s CISF, and the NRC ASLB Licensing Proceeding:
As detailed in the environmental coalition filings,
< http://www.beyondnuclear.org/centralized-storage/2018/9/17/environmental-legal-interventions-opposing-holtecelea-cisf.html>
the dozens of contentions filed on September 14, 2018 include the following categories (some of the contentions were raised by multiple intervenors; the total number of contentions filed adds up to 40):
(a) impacts on Native American and other historic and pre-historic properties on the site;
(b) insufficient assurances of financing for construction, operation, and decommissioning;
(c) underestimation of so-called “low-level” radioactive waste volumes that would be generated;
(d) improper reliance on NRC generic Environmental Impact Statement presumptions;
(e) natural gas fracking and potash mining beneath the site;
(f) cumulative risks of future reprocessing (plutonium extraction);
(g) the public health threat from the “Start Clean/Stay Clean” philosophy’s risks of shipping damaged, leaking, or contaminated casks back to the atomic reactor of origin;
(h) incomplete and inadequate disclosure of transportation routes (road, rail, and waterway), and inadequate analyses of the substantial risks of these shipments through most states, over decades;
(i) inconsistent predicted lengths for “interim storage” period, from 40 to 100, 120, or even 300 years, timeframes that could dangerously exceed the design and service life of the containers;
(j) unmet safety and security risk analyses for the scale of transport and storage proposed;
(k) troubling geological formations and conditions beneath the site;
(l) no compelling purpose and need for the CISF;
(m) risk of the CISF becoming a de facto permanent surface storage “parking lot dump”;
(n) Holtec’s improper reliance on the Blue Ribbon Commission for America’s Nuclear Future’s 2012 Final Report;
(o) earthquake risks at the site;
(p) impacts on endangered and threatened species, such as the dunes sagebrush lizard;
(q) questionable credibility of sub-contractors used in the preparation of the license application, reflected in the poor quality of the submitted documents, and charges of major fraud against Tetra Tech related to a massive radioactive contamination incident in San Francisco, CA;
(r) thermal concerns associated with corrosion of the containers;
(s) groundwater and brine concerns at the site, including threats of radioactive contamination reaching area drinking and irrigation water aquifers downstream;
(t) risks of high burnup irradiated nuclear fuel degradation and failure.
(8) Whistleblowers -- namely Oscar Shirani at Commonwealth Edison/Exelon, and Dr. Ross Landsman at NRC -- first revealed widespread quality assurance violations by Holtec in the design and fabrication of its containers in the early 2000s. Neither Holtec nor NRC have rectified this problem much, or at all, since. Thus, Shirani questioned the integrity of Holtec containers sitting still, going zero miles per hour, let alone 60 miles per hour down the railroad tracks, subject to the extreme forces of severe accidents. Landsman compared NRC's decision making to that of NASA's, which led to Space Shuttles hitting the ground. See a summary of their QA violation whistle-blowing, here.
Holtec CEO Krishna Singh also attempted to bribe Shirani and Landsman into silence. They refused and rejected his bribe offer, and continued to blow the whistle.
Singh was implicated in a $55,000 bribe made to a Tennessee Valley Authority Browns Ferry nuclear power plant official in Alabama, made to secure a contract there.
When asked on a tax break application form, under oath, by a State of NJ agency, Krishna Singh answered that Holtec had never been banned nor barred from doing business with a federal agency or state government. This was a lie. Holtec had been banned and barred from doing business with TVA, after the bribergy scandal at Browns Ferry. Singh's falsehood on the tax break application form was uncovered by ProPublic and WNYC in May 2019. It has led to a major scandal in New Jersey (Holtec's home base), with ongoing investigations. Singh's lie secured a $260 million tax break for Holtec, which was used to build a brand new, major manufacturing plant in Camden, NJ, which bears Singh's name. Should a company like Holtec, and a CEO like Krishna Singh, be entrusted with 173,600 metric tons of highly radioactive irradiated nuclear fuel? The rogue behaviors they have exhibited would make that a resounding NO! Learn more about the many skeletons in Holtec's and Singh's closets, here.
(9) See Beyond Nuclear's, and many other groups', extensive comments submitted by July 30, 2018, in opposition to Holtec's CISF, during NRC's environmental scoping phase. As mentioned above, NRC has largely to entirely ignored most to all of these previous comments, so we need to repeat them loudly and forcefully again now!
(10) Environmental justice. Holtec is targeting southeastern NM, where many of the surrounding communities in the area are majority Hispanic. The Mescalero Apache Indian Reservation (itself previously targeted for a CISF!) is not far away. While a lot of money has been made in the Permian Basin from fossil fuel and nuclear industries, that wealth is not equitably distributed nor shared with the local population. Thus, there are very significant environmental justice issues of low income and/or people of color communities in southeastern NM being targeted for this dump. As shown by this remarkable map by Deborah Reade of Santa Fe, NM, southeastern NM, and the rest of the state, bears a tremendous pollution burden from these fossil fuel (concentrated in the Permian Basin, in NM's southeastern corner) and nuclear (throughout NM, but with a particular concentration of significant polluting facilities in/near the southeastern corner) and other hazardous industries. The trickery employed in Holtec's Environment Report and NRC's DEIS, in order to find no EJ impact, is to only compare southeastern NM (and only out to a radius of 50 miles from the Holtec CISF site), with the rest of the State of NM. But of course, comparing s.e. NM near Holtec to the country as a whole, would show a much greater concentration of Hispanics and Native Americans, than is typical of the rest of the country as a whole. NRC's 50-miles out from Holtec's CISF radius focus, and then only in comparison to the rest of the State of NM, blinds it to the bigger picture of the country as a whole. Combined with the fact that NM as a whole ranks towards the very bottom of all 50 states on many socio-economic indicators, NRC's willful blindness to the EJ impacts of the Holtec CISF proposal is an outrage. NRC's own behavior is an EJ violation, as is Holtec's CISF proposal to begin with!
This is further underscored by the experience of Alliance for Environmental Strategies in the NRC ASLB licensing proceeding. AFES is a largely Hispanic EJ group in s.e. NM. It intervened against the Holtec CISF, raising EJ contentions. Incredibly, the ASLB and NRC never even clearly acknowledged or recognized AFES's legal standing to bring such contentions. But both ASLB and NRC rejected AFES's EJ contentions outright. Such ASLB and NRC behavior is, in itself, an EJ violation!
Additional sample comments and talking points you can use to write your own for submission to NRC by the current September 22, 2020 deadline, will be posted here ASAP. See Updates, posted below.
See the DEIS posted online, as well as how/where to submit your comments (see bold, italicized section), linked here.
(You can E-mail comments to: Holtec-CISFEIS@nrc.gov.)
Learn more about CISFs at our Centralized Storage website section.
Learn more about the risks of high-level radioactive waste transportation -- Mobile Chernobyls, Dirty Bombs on Wheels, Floating Fukushimas, Mobile X-ray Machines That Can't Be Turned Off -- at our Waste Transportation website section. This includes the risks of severe accidents (such as long-duration, high-temperature fires; long-duration, deep-underwater submersions; high-speed crashes into immovable objects; crushing loads; etc.), as well as intentional attacks, and even the gamma- and neutron-radiation emissions from "routine" or "incident-free" shipments.
Update on May 7, 2020 by
admin
A colleague has spotted a significant error in the Overview attached to both the Holtec and the ISP/WCS NRC DEIS documents. (ISP/WCS is a second CISF, targeted at west Texas, just 39 miles from Holtec's CISF in NM.) NRC states that the Private Fuel Storage CISF license at the Skull Valley Goshutes Indian Reservation in Utah has been terminated. This is false. In fact, the DEIS documents themselves do not even make this assertion. Thus, NRC's CISF DEIS Overviews are inaccurate, and ignorant of its agency's own licensing decisions. And most significantly, if Holtec/ELEA, ISP/WCS, and the nuclear power utilities, were serious, sincere, and honest about these CISFs being entirely private dumps, then why not use the license already rubber-stamped by NRC at PFS more than a decade ago? It's because the actual goal is to transfer title/ownership, and liability, for high-level radioactive wastes, onto the U.S. Department of Energy (DOE) -- that is, federal taxpayers. Which is illegal, a violation of the Nuclear Waste Policy Act of 1982, as Amended. This illegality is the heart of Beyond Nuclear's lawsuit against both CISFs. Don't Waste MI et al. (a seven-group national grassroots environmental coalition), Sierra Club, and Fasken Oil, have also challenged this violation of the NWPA represented by both these CISF schemes. In fact, this glaring NRC error can serve as the basis for yet another comment idea, for submission to NRC, in both CISF DEIS proceedings!
Please note, the Holtec container-based PFS scheme was and still is extraordinarily objectionable in and of itself. A groundswell of resistance has opposed it since the 1990s. NRC's rubber-stamp of the PFS scheme earned the agency the appellation "Nuclear Racism Commission."
Update on May 10, 2020 by
admin
Updated - Sunday, May 10, 2020
This is a reason that the Holtec/ELEA CISF targeted at NM is one environmental justice burden too many. So too the WCS/ISP CISF targeted at the NM border at Eunice, just a mile or so into TX. NM has suffered enough from the nuclear industry already.
NM has too long shouldered too many EJ burdens -- nuclear, fossil fuel, and other hazards. For this reason alone, the Holtec/ELEA CISF is a non-starter, as yet another, major, EJ violation. So too is the WCS/ISP CISF in TX, a mile or so from the NM border at Eunice.
Update on May 12, 2020 by
admin
Early Holtec UMAX-prototype ISFSI storage license at Humboldt Bay, CA renewed by NRC for 40 more years
Updated - Tuesday, May 12, 2020
Originally, Holtec's underground or sub-grade ISFSI design -- a prototype of its current UMAX design -- was a seismic design -- given that Humboldt Bay nuclear power plant is on or near more than one earthquake faultline, including the San Andreas.
But Holtec not long after started to market its underground or sub-grade dry cask storage designs -- including its current UMAX design -- as a
security design. Holtec did this after the 9/11 terrorist attacks, including in response to calls for Hardened On-Site Storage (HOSS), which began in April 2002, as a common sense alternative to the Yucca Mountain, NV dump proposal, targeting Western Shoshone land, and also as an alternative to CISFs (at the time,
targeting the Skull Valley Goshutes in UT, the so-called Private Fuel Storage, LLC CISF.)
This news headline is a reminder of something Don Hancock of Southwest Research and Info. Ctr. in ABQ, NM said several years ago now: If the waste storage is so safe and secure at the nuclear power plant sites, as NRC keeps affirming, and as Holtec of course keeps saying, well, then, what's the need to move it to the CISF in NM?!
Both NRC and Holtec are talking out both sides of their mouths!
For one thing, the Holtec canister itself is of questionable structural integrity, due to widespread quality assurance violations with design and fabrication. We've known this since Jan. 2003, thanks to industry and NRC whistleblowers. The industry whistleblower, Oscar Shirani, was made to pay for his whistleblowing. He was blacklisted from work in the U.S. nuclear power industry for the rest of his life.
The UMAX sub-grade pit design itself has security flaws, despite Holtec's marketing to the contrary.
And of course the near-drop of a fully loaded 50-ton canister at San Onofre, CA in August 2018 -- also brought to light thanks to a courageous whistleblower, which cost him his job -- shows that not just the design of the UMAX ISFSI (Independent Spent Fuel Storage Installation), but also its interwoven operation, is flawed and problematic, dangerously so.
Yet another nuclear power plant with the UMAX design installed for its dry cask storage -- still operating, unfortunately, unlike the shutdown Humboldt Bay and San Onofre nuclear power plants in CA -- is Callaway, MO.
Update on June 11, 2020 by
admin
June 11, 2020 message from Leona Morgan, NISG (Nuclear Issues Study Group), ABQ, NM:
Hey folks,
If you’re not on our email list, here is the info for our webinar series starting tonight on our Facebook page at 6pm, and every Thursday until July 16th starting at 6pm. You do not need a fb account to join:
https://www.facebook.com/NuclearIssuesStudyGroup/.
We sent out our sample letter today as well. We had a minor hiccup, Thanks Don for your assistance with catching that!
Remember to add your personal comments in Paragraph 2 and sign your name at the end.
Hope you all enjoy the show!
~leona
Update on June 23, 2020 by
admin
As part of the 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), opposing the Holtec/ELEA CISF, the following expert witness declaration was submitted.
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."
Ballard's concerns were also raised by Don't Waste MI, et al., as public comment, at the NRC's Holtec CISF environmental scoping stage in 2018.
In its Holtec CISF DEIS, NRC has responded to very few or none of the concerns raised in Ballard's expert declaration. Therefore, it is appropriate to repeat the concerns at this DEIS stage.
Update on June 27, 2020 by
admin
As submitted to NRC on June 27, 2020:
Dear NRC Staff,
NRC's collusion and complicity in rubber-stamping license application approvals for CISFs -- both Holtec/ELEA's in NM, as well as ISP/WCS's in TX -- is objectionable. The U.S. Nuclear Regulatory Commission is supposed to protect public health, safety, security, and the environment. As the country's nuclear safety regulatory agency, NRC is not a policy setting agency, and is not supposed to promote nuclear power industry schemes, such as these CISFs.
Yet, at its late 2015 Division of Spent Fuel Management RegCon (Regulatory Conference), NRC's Tony Hsia, Acting Director of the Division of Spent Fuel Management, in his closing remarks, concluded the two-day symposium with no less than a pep rally cry. He passionately called for industry and NRC (as well as DOE, and other nuclear establishment players) to work together ("[If we] all work together, we can make it [centralized interim storage] happen!"), to open de facto permanent, surface storage, parking lot dumps, such as at Interim Storage Partners/Waste Control Specialists, LLC in Andrews County, TX, and/or Holtec International/Eddy-Lea Energy Alliance, near WIPP in NM. He even pumped his fist in the air when he did so. Such advocacy in favor of the proposed CISFs, by a senior NRC manager, was incredibly inappropriate.
Such schizophrenic safety regulation/industry promotion imbalance is what led to the demise of the U.S. Atomic Energy Commission by the mid-1970s. Stringent safety regulation and unbridled industry advocacy are mutual exclusive, of course. NRC rose from AEC's ashes with the clear mandate to "protect people and the environment," as the NRC logo puts it. DOE was given the nuclear advocacy role, embodied in its unbridled Office of Nuclear Energy (ONE). NRC has violated its mandate. It has strayed very far into the policy setting and industry advocacy arena.
NRC Staff, as well as the Atomic Safety and Licensing Board Panel, and even the NRC Commissioners, have done so ever since Tony Hsia's incredibly inappropriate pep rally cheer in favor of CISF licensing in late 2015. NRC's complicity and collusion with Holtec/ELEA and ISP/WCS is not only immoral and illegal, it is very dangerous.
The Japanese Parliament concluded that the root cause of the Fukushima Daiichi nuclear catastrophe was collusion between regulator, industry, and government officials. It was the reason the three reactors, that melted down and exploded, were so very vulnerable to the earthquake and tsunami that struck them on 3/11/11 in the first place. Such dangerous collusion exists in spades in the U.S., as on radioactive waste, as between NRC (Staff, Licensing Board Panel, and Commissioners) and Holtec/ELEA, re: the proposed CISF in NM.
These comments are submitted on behalf of our members and supporters in NM and TX, and across the U.S. along impacted Mobile Chernobyl transport routes.
Please acknowledge receipt of these comments. Thank you.
Sincerely,
Kevin Kamps
Radioactive Waste Specialist
Beyond Nuclear
7304 Carroll Avenue, #182Takoma Park, Maryland 20912
Cell: (240) 462-3216
kevin@beyondnuclear.orgwww.beyondnuclear.orgBeyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.
Update on June 29, 2020 by
admin
A June 29, 2020 article in the Albuquerque Journal, "Wind energy powering ahead in New Mexico; Government, industry tout potential across the West," provides yet another argument against Holtec. Wind generation creates many times more jobs than the consolidated interim storage facility would; wind power could happen there instead, in that very same area, instead of a high-level radioactive waste dump.
Update on July 1, 2020 by
admin
Thank you to Michael Keegan of Don't Waste Michigan for circulating this:
Transcript of the Proceeding from 6/23/2020 Holtec DEIS Public Comment Meeting --
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20180A000
| Document Title: |
Transcript of Proceedings - Public Online Webinar for the Draft Environmental Impact Statement for the Proposed Holtec Hi-Store Consolidated Interim Storage Facility, June 23, 2020, Pages 1-202 |
| Document Type: |
Meeting Transcript |
| Document Date: |
06/23/2020 |
Update on July 1, 2020 by
admin
As posted by Nuclear Issues Study Group (NISG) in New Mexico:
We Are NOT A Wasteland!
Episode 3: Derailing Environmental Racism
Join our livestream on Thursday, July 2nd at 6pm (MDT).
Click here at 6pm (MDT) Thursday evening to be connected to our social media page for an awesome program focusing on environmental justice and transportation concerns regarding Holtec's dangerous plan.
On Episode 3: Derailing Environmental Racism, we’ll hear from Dr. Myrriah Gómez who is Nuevamexicana from the Pojoaque Valley examining the effects of the nuclear industry on people of color in New Mexico and will be speaking about environmental justice and the proposed Holtec dump.
Diane D’Arrigo, as our second guest, has closely followed so-called “low-level” nuclear waste issues for decades and the national and international moves to deregulate nuclear waste. Diane will explain the dangers of transporting high-level radioactive waste to the proposed Holtec site in New Mexico.
This week, we will feature music from Albuquerque artist Zack Freeman and live art workings from Thea Gahr of Justseeds Artist Collective.
About the web series... T he Nuclear Issues Study Group is excited to announce our six part series of live-streamed online events to educate and inspire resistance to the LARGEST proposed high-level radioactive waste dump on earth. Two private companies: Holtec International and Waste Control Specialists/Interim Storage Partners have each applied for a license to transport all of the waste from every nuclear power plant in the country and dump it in New Mexico and Texas. The Nuclear Regulatory Commission (NRC) has released a Draft Environmental Impact Statement (DEIS) for both proposals. Public comments on the DEIS for Holtec have just been extended to September 22 and for WCS on September 4th. The NRC has an online public meeting scheduled July 9 (see the comments of this page for details on attending).
This 6 part series will run through September 10, 2020 and explore different aspects of the issue including: environmental racism and environmental justice concerns, impacts to wildlife, water, air, and land, concerns for public health and transportation, and economic impact. Click here to watch previous episodes.
Save the Dates! We’ll continue our web series monthly through the close of the comment period: July 16, August 6, and September 10 (each starting at 6pm Mountain Daylight Time). Please note that these are NEW DATES.
We will hear from community leaders, artists, activists, and more. Each episode will feature live music and art...essential tools of social change!
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Live Art from Episode 2, by Jazmin Ontiveros Harvey
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| “Listening to stories by Rose Gardner and others on episode two of We are Not a Wasteland inspired this image depicting nuclear waste traveling across state lines to our home state of New Mexico...and the faceless men behind it.”
-Jazmin Ontiveros Harvey
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HOLTEC DRAFT ENVIRONMENTAL IMPACT STATEMENT PUBLIC COMMENT PERIOD
NEW DEADLINE: SEPTEMBER 22, 2020
The U.S. Nuclear Regulatory Commission (NRC) has extended the deadline for public comments. We ask you to submit written comments or oral comments during the next public comment webinar or when in-person hearings are scheduled.
We prepared a sample letter for you to use in both English and Español. You can copy and paste into a new email, personalize with your own comments, and send to: Holtec-CISFEIS@nrc.gov with Subject Line: Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment before September 22.
NEXT PUBLIC COMMENT MEETING on July 9, 2020
NRC will hold a second Public Comment Meeting as a national webinar on Thursday, July 9 starting at 3pm (MDT). Listen to arguments from both proponents and opponents of the proposed dump. NISG encourages everyone to voice your concerns and opposition against this dangerous proposal which affects everyone.
Click here and then click on "Register" to register for online July 9th public meeting. We will send a reminder with a call-in phone number and simple talking points before the webinar. If you plan to make oral comments, please email: Antoinette.Walker-Smith@nrc.gov by July 8th to secure time to speak during that meeting.
Update on July 16, 2020 by
admin
Action alert circulated by NISG on July 16, 2020:
CALL TO ACTION: SEND COMMENTS
RE: Draft Environmental Impact Statement (DEIS)
on Holtec's Proposal to Build the World's Largest Radioactive Waste Dump in New Mexico
PUBLIC COMMENT PERIOD DEADLINE: SEPTEMBER 22, 2020
The U.S. Nuclear Regulatory Commission (NRC) has extended the deadline for public comments. We ask you to submit written comments to send the NRC before the deadline as this impacts EVERYONE.
NISG has prepared a sample letter for you to use in both English and Spanish to send written comments. You can also use our handy shortcut to send comments to NRC (with cc: to NISG). Click: English or Español [if those links don't open for you, see links below, at bottom of this message] to SEND YOUR COMMENTS NOW! Whether you use our sample letter or write your own comments, WE ARE ASKING EVERYONE to tell NRC that WE DO NOT CONSENT by emailing NRC before September 22, 2020. Send comments to: Holtec-CISFEIS@nrc.gov with Subject Line: Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment.
Update on DEIS Hearings
There are no in-person hearings scheduled yet due to Covid-19 and we are requesting that NRC hold off until there is a vaccine available and to keep the public comment period open until that time.
The NRC held two online Public Comment Meetings on June 23rd and July 9th. We listened to arguments from both proponents and opponents of the proposed dump. By our count, the first meeting had 34 folks opposed to the waste dump and 24 supporting, and our tally for the second meeting was 34 opposed and 7 supporting, for a total of 68 opposing, and 31 supporting Holtec's proposal. Click here to read the transcripts from the June 23rd NRC meeting.
[Link to NISG Call to Action in English, which includes Sample Comment Letter in English, posted online here]
{Link to Holtec Sample Letter, en Espagñol, aqui}
Update on July 19, 2020 by
admin
Transcript of July 9th NRC public comment meeting on the DEIS.
By Beyond Nuclear's count, dump opponents dominated dump proponents at the microphone by a count of 34 to 6.
At the previous June 23rd public comment session, by Beyond Nuclear's count, dump opponents outnumbered dump proponents by a count of 35 to 24.
So the grand total of oral public comments at the microphone are: 69 dump opponents, compared to 30 dump proponents.
In 2018, during the environmental scoping public comment phase, dump opponents outnumbered dump proponents at every single one, of several, oral public comment sessions.
In terms of written comments during the environmental scoping stage, more than 35,000 comments were submitted, the vast majority opposed to the dump.
