[113-organization coalition comment letter, to NRC, re: DEIS, opposing Holtec's CISF in NM] Beyond Nuclear's 30th set of public comments, re: Docket ID NRC-2018-0052, re: NRC's Holtec/ELEA CISF DEIS
Dear Friends and Colleagues,
Wow! 113 groups! To borrow a phrase, what a "critical mass"!
Thank you very much for signing your group onto this public comment letter to the U.S. Nuclear Regulatory Commission (NRC), re: the agency's Draft Environmental Impact Statement (DEIS), expressing opposition to the Holtec International/Eddy Lea Energy Alliance irradiated nuclear fuel consolidated interim storage facility (CISF) targeting southeastern New Mexico. See the coalition comment letter, as submitted to NRC, below.
The organizational coalition sign-on comment letter, below, is also posted online, here:
Sorry it's taken me this long to even acknowledge receipt of your sign-on for almost all of you. Meeting last night's comment deadline has meant a blizzard of busy-ness for the past many days!
I did submit the coalition comment letter before last night's midnight deadline, so it should now be an official public comment included in the NRC docket. I've yet to receive confirmation of receipt from NRC, so will keep after them until I get it!
As many of you probably already know, there is "no rest for the weary" -- we now face a Nov. 3 deadline (yep, Election Day!) for public comments on the Interim Storage Partners/Waste Control Specialists (ISP/WCS) CISF, targeting Andrews County, west Texas, very near Eunice, NM. Call-in NRC verbal comment submission sessions are scheduled for Thurs., Oct. 1 (6-9pm Eastern); Tues., Oct. 6 (2-5pm Eastern); Thurs., Oct. 8 (6-9pm Eastern); and Thurs., Oct. 15 (11am-2pm Eastern). Please attend one or more of these sessions, and provide public comment. And please spread the word.
See Beyond Nuclear's Centralized Storage website section for more details (you'll need to scroll down a little, to get to the ISP/WCS CISF, TX-related posts), including how to submit comments to NRC re: ISP's CISF at WCS, TX, sample comments you can use to prepare your own, etc.
You can also submit individual comments against the ISP/WCS CISF in TX, using the webform/sample letter at this website: http://nonuclearwasteaqui.org/
And keep an eye out, in the not too distant future, for yet another group comment letter, similar to the Holtec/ELEA, NM one you just signed onto, only this time, re: the ISP CISF at WCS, TX.
The two dumps are just 40 miles apart across the NM/TX state line. This is an environmentally unjust (radioactively racist) attempt to turn southeast NM/west TX into a nuclear sacrifice zone for the rest of the country. At a grand total of 213,600 metric tons of commercial irradiated nuclear fuel and other highly radioactive waste (such as Greater-Than-Class-C "low" level radioactive waste), the Holtec/ELEA, NM (173,600 MT) and ISP/WCS, TX (40,000 MT) dumps would be three times larger than the proposed Yucca Mountain, NV permanent geologic repository (70,000 MT), targeting Western Shoshone land, in violation of the "peace and friendship" Treaty of Ruby Valley of 1863. This also would mean three times the inbound-to-CISF transport risks, as compared to Yucca, for "just" the inbound shipments from atomic reactors to the CISFs in NM/TX. Of course, the 213,600 MT of irradiated nuclear fuel would supposedly still then leave the CISFs again some decade (or century) in the future -- they are actually planning to send it to the long-cancelled, illegal, unsuitable, non-consent based Yucca dump! -- which would mean multiplying the Mobile Chernobyl transport risks.
Thanks once again, very much, for signing your group onto the coalition Holtec comment letter to NRC. 113 groups is a very strong showing! And thanks once again to Nuclear Issues Study Group of ABQ, NM, for providing the original sample letter template/language, that Karen Hadden of SEED Coalition used to compose the national group sign-on letter, that Diane D'Arrigo of NIRS and I helped provide minor edits on. It was a good team effort all the way around!
Sincerely,
Kevin Kamps, Beyond Nuclear & Don't Waste Michigan
---------- Forwarded message ---------
From: Kevin Kamps <kevin@beyondnuclear.org>
Dear Holtec-CISFEIS Resource and NRC Staff,
This is Beyond Nuclear's 30th set of public comments in this proceeding.
I submit these comments on behalf of a coalition of 113 environmental, environmental justice, and public interest organizations, with combined memberships and supporters comprising millions of individuals nationwide.
Due especially to the numerous problems I have experienced submitting public comments via this <holtec-cisfeis@nrc.gov> email address, please acknowledge receipt of these comments, and please provide me with confirmation of their proper placement in the official public record for this proceeding.
The organizational coalition sign-on comment letter, below, is also posted online, here:
Submitted via: <Holtec-CISFEIS@nrc.gov>
Subject: Docket ID NRC-2018-0052, Draft Environmental Impact Statement, Public Comment
Dear NRC Commissioners and Staff,
This public comment is in response to the Draft Environmental Impact Statement (Docket ID NRC-2018-0052) regarding Holtec International’s application for a license to build and operate a “Consolidated Interim Storage Facility [CISF] for Spent Nuclear Fuel and High Level Waste” (NUREG-2237).
The undersigned organizations oppose Holtec’s proposal and ask that the NRC halt its licensing in order to protect public health and safety, the environment and our economy. It appears from the Draft Environmental Impact Statement and other license application documents that there would be no dry cask transfer facility (Dry Transfer System, DTS) at the proposed site, which means there would be no way to repackage waste. The site is not designed for long term disposal, but a dangerous de facto permanent site could result if waste casks or canisters are damaged or corroded and cannot be moved.
Consolidated Interim Storage in Texas is also unacceptable. Our groups support and adopt the comments raised by the Nuclear Issues Study Group based in Albuquerque, New Mexico, which are as follows:
1) New Mexico Does Not Consent The motto of the Nuclear Regulatory Commission is “Protecting People and the Environment,” yet the NRC’s Draft Environmental Impact Statement (DEIS) on the Holtec project does neither. Instead, the NRC’s inadequate Draft EIS puts people, wildlife and precious water resources at significant and potentially, deadly risk by failing to heed the concerns of the community. We join the All Pueblo Council of Governors, New Mexico Governor Michelle Lujan Grisham, New Mexico State Land Commissioner Stephanie Garcia Richard, more than a dozen county and city governments, the Alliance for Environmental Strategies, the New Mexico Cattle Growers Association, the Permian Basin Coalition of Land & Royalty Owners and Operators, the Nuclear Issues Study Group, and the more than 30,000 residents who commented during the NRC's 2018 environmental scoping period in vehemently opposing bringing the nation’s high level radioactive waste from nuclear power plants through our communities to New Mexico. We do not consent to New Mexico becoming a nuclear wasteland for millions of years.
2) Cumulative Impacts The DEIS is inadequate because it fails to consider cumulative impacts from the damage the nuclear industry has already inflicted on New Mexicans for the past 75 years: uranium mining and milling in the northwest on indigenous Diné and Pueblo lands, including the 1979 Church Rock Disaster; radioactive contamination to Tewa lands and people since the Manhattan Project in the Los Alamos area; fallout on downwinders from the Trinity Test in the Tularosa Basin; the Waste Isolation Pilot Plant, which has already accidentally released dangerous amounts of radiation and now wants to expand; the URENCO uranium enrichment plant in Eunice; the world’s largest nuclear warhead stockpile on the edge of Albuquerque; and the toxic threat to Albuquerque’s aquifer by the Mixed Waste Landfill. Rather than adding 173,600 metric tons of high-level radioactive waste to a state that has already been grossly overburdened, the United States should be directing its resources towards: cleaning up the contamination already present in New Mexico communities; just compensation; and holistic community health studies. The DEIS also fails to account for cumulative impacts from the other proposal for Consolidated Interim Storage, approximately forty miles east at the current Waste Control Specialists low-level radioactive waste dump in Andrews County, Texas, very near Eunice, New Mexico.
3) Environmental Racism It’s no coincidence that the United States wants to make New Mexico a nuclear wasteland. It ranks as one of the poorest states and is a majority minority state, with more Black, Indigenous, People of Color (BIPOC) residents than white residents. For the NRC to determine that nuclear waste which will threaten life for millions of years would have “small” or “no environmental impact” is a blatant violation of environmental justice principles and is environmental racism in action. We do not give our own government license to allow a private industry to further contaminate New Mexicans' home or to expand the massive nuclear burden New Mexicans already bear.
4) Threats to Cultural Properties & Historic Sites Holtec International and the NRC would have us believe that the site is a desolate, uninhabited place with “no historic value or significance.” This statement is completely false and without merit. The site is located near or on two lagunas or playa lakes: Laguna Gatuna and Laguna Plata. Laguna Plata is an archaeological district that has been extensively studied for decades. Two sites near Laguna Gatuna, where the nuclear waste is proposed to be stored, are listed on the National Register of Historic Places. Archaeologists have found a plethora of evidence of the Jornada Mogollon people, dating from 200 AD, 700 AD, and 1200 AD. More than 200 archeological sites are located within six miles of the proposed nuclear waste dump. Laguna Gatuna, while often dry, fills with water after monsoon rains, attracting a variety of wildlife and hunters for millenia. The Hopi and Mescalero Apache nations have identified the area as culturally significant to them, and the Hopi nation has informed the NRC that traditional cultural properties could be adversely affected if this project proceeds. The site where Holtec wants to dump tens of thousands of tons of radioactive waste has profound historic value and significance.
5) Threats to Water & Wildlife The impact of this forever deadly nuclear waste would have devastating consequences on wildlife including threatened species that rely on the lagunas for drinking water and the surrounding area as a critical habitat, including the Lesser Prairie Chicken, and the Dunes Sagebrush Lizard. Agencies such as U.S. Fish & Wildlife, New Mexico Game & Fish, the U.S. Environmental Protection Agency (EPA) and the New Mexico Environment Department (NMED) have all gone on record attesting to the significance of Laguna Gatuna for migratory birds, and have argued that it should be designated permanently as a Water of the United States (WOTUS), which would make it eligible for protection under the Clean Water Act.
6) Threats from Transporting Irradiated Nuclear Fuel Not only New Mexico would be adversely impacted by the Holtec project: all communities along the transportation routes between nuclear power plants and Holtec's proposed CISF site would be threatened by radiation from the rail cars, and from the devastating financial and environmental damage if an accident or act of malice should occur. Studies have shown that one accident is likely to occur for every 10,000 shipments. It is irresponsible and dangerous for NRC to avoid adequate inclusion (a "hard look," as legally required by the National Environmental Policy Act, NEPA) of these mammoth risks and liabilities in its DEIS for Holtec’s application.
7) Holtec’s Project is Illegal Finally, under current U.S. law, this project is illegal. The Nuclear Waste Policy Act of 1982, as Amended, does not allow the federal government to take title to the high-level radioactive waste (commercial irradiated nuclear fuel) until a permanent geologic repository is operating. So the federal government cannot pay for transportation and storage of the waste as Holtec wants. Legally, the license cannot be issued until a permanent repository is operating.
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For all the above reasons and more, we declare that the DEIS for Holtec’s application is inadequate and further that the license for a high-level radioactive waste storage facility should be denied. In conclusion, high-level nuclear waste from nuclear power plants around the U.S. should not be brought to New Mexico – it should be isolated on or near the current nuclear power plant site, in Hardened On-Site Storage (HOSS), until there is an environmentally just and scientifically sound option available.
Sincerely,
Alaska's Big Village Network
Nikos Pastos, Environmental Sociologist, Anchorage, AK
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Alliance for Environmental Strategies
Rose Gardner, Co-Founder, Eunice, NM
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Alliance for a Green Economy (AGREE)
Jessica Azulay, Executive Director, Syracuse, NY
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Alliance to Halt Fermi 3
Keith Gunter, Board Chair, Livonia, MI
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Atlanta Grandmothers for Peace
Bobbie Paul, Treasurer, Atlanta, GA
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Baltimore Phil Berrigan Memorial Chapter Veterans for Peace
Ellen E. Barfield, Co-Founder & Coordinator, Baltimore, MD
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Beyond Nuclear
Kay Drey, President of the Board of Directors, & Kevin Kamps, Radioactive Waste Specialist, Takoma Park, MD
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Cape Downwinders
Diane Turco, Director, South Harwich, MA
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Citizen Action New Mexico
Dave McCoy, J.D., Executive Director, Albuquerque, NM
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Citizen Power, Inc.
David Hughes, President, Pittsburgh, PA
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Citizens for Alternatives to Chemical Contamination
Chance Hunt, Chairman of the Board, Lake, MI
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Citizens for Alternatives to Radioactive Dumping (CARD)
Janet Greenwald, Dixon, NM
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Citizens Awareness Network
Deb Katz, Executive Director, Shelburne Falls, MA
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Citizens' Environmental Coalition
Barbara Warren, Executive Director, Cuddebackville, NY
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Citizens' Resistance at Fermi Two (CRAFT)
Jesse DeerInWater, Community Organizer, Redford, MI
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Climate Justice Committee of CNY Solidarity Coalition
Katherine Burns, Chairperson, Syracuse, NY
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Coalition Against Nukes
Laura Lynch, Campaign Coordinator, New York, NY
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Coalition for a Nuclear Free Great Lakes
Michael J. Keegan, Chairperson, Monroe, MI
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Coalition on West Valley Nuclear Wastes
Joanne Hameister, Contact, Springville, NY
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Concerned Citizens of Lacey Coalition
Paul Dressler & Ron Martyn, Co-Chairs, Lacey Township, NJ
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Concerned Citizens for Nuclear Safety
Joni Arends, Co-Founder & Executive Director, Santa Fe, NM
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Concerned Citizens for SNEC Safety (CCSS)
Ernest Fuller, Vice Chairman, Saxton, PA
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Connecticut Coalition Against Millstone
Nancy Burton, Director, Redding, CT
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Council on Intelligent Energy & Conservation Policy (CIECP)
Michel Lee, Esq., Chairman, Scarsdale, NY
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Crabshell Alliance
Regina Minniss, Treasurer, Baltimore, MD
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Don't Waste Arizona
Stephen Brittle, President, Phoenix, AZ
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Don't Waste Michigan
Alice Hirt, Co-Chair, Holland, MI
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Eco-Logic, WBAI FM
Ken Gale, Producer, New York, NY
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Ecological Options Network
Mary Beth Brangan, Co-Director, Bolinas, CA
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Energía Mía
Alice Canestaro-Garcia, Communications Manager, San Antonio, TX
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Environmental Justice Taskforce of the Western New York Peace Center
Charley Bowman, Chair, Buffalo, NY
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Fairewinds Energy Education
Maggie Gundersen, Founder, Charleston, SC
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Food & Water Action
Mitch Jones, Policy Director, Washington, D.C.
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Freshwater Future
Kristy Meyer, M.S., Associate Director, Petoskey, MI
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Friends of Bruce
Eugene Bourgeois, Inverhuron, Ontario, Canada
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GA WAND (Georgia Women's Action for New Directions)
Cee'Cee' Anderson, Atlanta, GA
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Green State Solutions
Mike Carberry, Founding Director, Iowa City, IA
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Greenaction for Health and Environmental Justice
Bradley Angel, Executive Director, San Francisco, CA
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Healthy Environment Alliance of Utah
Scott Williams, M.D., M.P.H., Executive Director, Salt Lake City, UT
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Heart of America Northwest
Peggy Maze Johnson, Board Member, Seattle, WA
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Hudson River Sloop Clearwater, Inc.
Manna Jo Greene, Environmental Director, Beacon, NY
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Indian Point Safe Energy Coalition (IPSEC)
Margo Schepart & Judy Allen, Steering Committee Members, Yorktown Heights & Putnam Valley, NY
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Indigenous Rights Center.Org
Norman Patrick Brown and Peter Clark, Directors, Albuquerque, NM
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League of Women Voters of Buffalo/Niagara
Joan T. Parks, President, Buffalo, NY
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Lone Tree Council
Terry Miller, Chair, Bay City, MI
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Los Angeles Alliance for Survival
Jerry Rubin, Director, Santa Monica, CA
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Manhattan Project for a Nuclear-Free World
Mari Inoue, Co-Founding Member, New York, NY
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Michigan Stop the Nuclear Bombs Campaign
Vic Macks, Steering Committee, St. Clair Shores, MI
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Multicultural Alliance for a Safe Environment (MASE)
Susan Gordon, Coordinator, Albuquerque, NM
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National Nuclear Workers for Justice (NNWJ)
Vina Colley, Co-Founder, Portsmouth, OH
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Native Community Action Council
Ian Zabarte, Secretary, Las Vegas, NV
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Network for Environmental & Economic Responsibility of United Church of Christ
Donald B. Clark, Convener
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Nevada Nuclear Waste Task Force
Judy Treichel, Executive Director, Las Vegas, NV
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New Mexico Interfaith Power and Light
Sister Joan Brown, Rochester Franciscan Sisters, Albuquerque, NM
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New York Congressional District-16 Indivisible Environment Committee
Iris Hiskey Arno and Natalie Polvere, co-chairs, Bronx and Westchester, NY
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North American Water Office
George Crocker, Executive Director, and Lea Foushee, Environmental Justice Director, Lake Elmo, MN
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Northeast New Mexicans United Against Nuclear Waste
Ed & Patty Hughs, Members, Quay County, NM
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Northwatch
Brennain Lloyd, Project Coordinator, North Bay, Ontario, Canada
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Nuclear Age Peace Foundation
Rick Wayman, CEO, Santa Barbara, CA
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Nuclear Energy Information Service (NEIS)
David A. Kraft, Director, Chicago, IL
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Nuclear Free World Committee of the Dallas Peace and Justice Center
Mavis Belisle and Lon Burnam, Co-Chairs, Dallas, TX
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Nuclear Information and Resource Service (NIRS)
Diane D'Arrigo, Director, Radioactive Waste Project, Takoma Park, MD
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Nuclear Issues Study Group (NISG)
Leona Morgan, Coordinator, Albuquerque, NM
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The Nuclear Resister
Jack & Felice Cohen-Joppa, Coordinators, Tucson, AZ
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Nuclear Watch New Mexico
Jay Coghlan, Executive Director, Santa Fe, NM
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Nuclear Watch South
Glenn Carroll, Coordinator, Atlanta, GA
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Nukewatch
John LaForge & Kelly Lundeen, Co-Directors, Luck, WI
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NYC Safe Energy Campaign
Ken Gale, Founder, NYC, NY
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Oak Ridge Environmental Peace Alliance
Kevin Collins, President, Knoxville, TN
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Occupy Bergen County
Sally Jane Gellert, Bergen County, NJ
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On Behalf of Planet Earth
Sheila Parks, EdD, Founder, Watertown, MA
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Partnership for Earth Spirituality
Sister Marlene Perrotte, Albuquerque, NM
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Peace Action of Wisconsin
Pamela Richard, Office Manager, Milwaukee, WI
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The Peace Farm
Lon Burnam, Convenor, Amarillo, TX
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PeaceWorks Kansas City
Chris Mann, Henry Stoever, & Sunny J. Hamrick, Co-Chairs, Kansas City Metro Area, KS & MO
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Physicians for Social Responsibility (PSR), National
Jeff Carter, Executive Director, Washington, D.C.
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Physicians for Social Responsibility - Kansas City
Ann Suellentrop, Project Director, Kansas City, KS
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Physicians for Social Responsibility - Los Angeles
Denise Duffield, Associate Director, Los Angeles, CA
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Port Hope Community Health Concerns Committee
Faye More, Chair, Port Hope, Ontario, Canada
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Portsmouth/Piketon Residents for Environmental Safety & Security (PRESS)
Vina Colley, President, Portsmouth, OH
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Proposition One Campaign for a Nuclear-Free Future
Ellen Thomas, Tryon, NC & Washington, D.C.
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Protect Andrews
Elizabeth Padilla, Director, Andrews, TX
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Public Citizen, National
Tyson Slocum, Director, Energy Program, Washington, D.C.
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Public Citizen Texas Office
Adrian Shelley, Texas Office Director, Austin, TX
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Redwood Alliance
Michael Welch, Volunteer, Arcata, CA
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Safe Energy Rights Group (SEnRG)
Nancy Vann, President, Peekskill, NY
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San Clemente Green
Gary Headrick, Co-Founder, San Clemente, CA
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San Francisco Bay Physicians for Social Responsibility (PSR)
Robert M. Gould, M.D., President, San Francisco, CA
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San Luis Obispo (SLO) Mothers for Peace
Molly Johnson, Member of the Board, San Luis Obispo, CA
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Shut Down Indian Point Now
Catherine Skopic, Chair, New York City, NY
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Sierra Club
Wallace L. Taylor, Counsel, Cedar Rapids, IA
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Sisters of Mercy
Sister Marlene Perrotte, Albuquerque, NM
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Snake River Alliance
Holly Harris, Executive Director, Boise, ID
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SouthWest Organizing Project (SWOP)
Alejandria Lyons, Environmental Justice Organizer, Albuquerque, NM
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Stand Up/Save Lives Campaign
Maureen Headington, President, Burr Ridge, IL
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Straits Area Concerned Citizens for Peace, Justice and the Environment
David & Anabel Dwyer, Members, Mackinaw City, MI
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Sustainable Energy and Economic Development (SEED) Coalition
Karen Hadden, Executive Director, Austin, TX
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Syracuse Cultural Workers
Andy Mager, Sales Manager and Social Movements Liaison, Syracuse, NY
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Syracuse Peace Council
Carol Baum, Organizer, Syracuse, NY
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Tennessee Environmental Council
Don Safer, Board Member, Nashville, TN
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Tewa Women United, Environmental Health and Justice Program
Beata Tsosie, Coordinator, Española, NM
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Three Mile Island Alert, Inc.
Eric Epstein, Chairman, Harrisburg, PA
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Toledo Coalition for Safe Energy
Terry Lodge, Convenor, Toledo, OH
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Tri-Valley CAREs (Communities Against a Radioactive Environment)
Marylia Kelley, Executive Director, Livermore, CA
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Tularosa Basin Downwinders Consortium
Tina Cordova, Co-Founder, Albuquerque, NM
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Uranium Watch
Sarah Fields, Program Director, Monticello, UT
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Valley Watch, Inc.
John Blair, President, Evansville, IN
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Vermont Yankee Decommissioning Alliance (VYDA)
Debra Stoleroff, Steering Committee Chair, Montpelier, VT
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Veterans for Peace, Santa Fe, NM Chapter
Ken Mayers, Chapter Secretary, Santa Fe, NM
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Wheeler Peak Progressives
Janet Warner, Angel Fire, NM
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Western New York Environmental Alliance
Linda Schneekloth, Buffalo, NY
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Women Changing the World
Cee'Cee' Anderson, Atlanta, GA
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Women's International League for Peace and Freedom (WILPF)-U.S.
Darien De Lu, Board of Directors President, Sacramento, CA
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Kevin Kamps
Radioactive Waste Specialist
Beyond Nuclear
7304 Carroll Avenue, #182
Takoma Park, Maryland 20912
Beyond 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.
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