With a short two-page letter, the U.S. Nuclear Regulatory Commission (NRC) has announced the commencement of the Holtec International/Eddy-Lea [Counties] Energy Alliance (Holtec/ELEA) highly radioactive irradiated nuclear fuel centralized interim storage facility (CISF) licensing proceeding. Such a flippant document could doom New Mexico to a hazardous radioactive legacy beyond the worst nightmares, forevermore.
The Holtec/ELEA CISF is targeted at southeastern New Mexico, midway between the cities of Hobbs and Carlsbad (just over 30 miles from each).
The location is very near the Waste Isolation Pilot Plant (WIPP), the Department of Energy's (DOE) dump for military trans-uranic wastes, such by such radioactive poisons as plutonium, americium, etc.
(WIPP, which began its dumping operations in 1999, had a serious radioactivity leak into the environment on Valentine's Day, 2014. Such a leak had previously been considered impossible, before it actually happened. Nearly two-dozen workers suffered inhalation doses of ultra-hazardous plutonium and americium. The burst of a single waste barrel in the WIPP underground completely shut the dump down for three years. The recovery price tag is a whopping $2 billion -- with a B!)
NRC's "docketing" of Holtec/ELEA's application, and finalization of its "completeness review," starts the clock on some brutally short, hyper-strict and unforgiving deadlines under NRC's punishing (for the concerned public, anyway), Byzantine regulations.
45 days from now, environmental scoping comments are due.
This will include three NRC public meetings in southeast New Mexico, two of which will include the opportunity for public comments to be delivered verbally, in person. The first meeting of all will likely be a "poster session" (a getting to know you "cocktail party without the alcohol," as Michael Keegan of Coalition for a Nuclear-Free Great Lakes has described such NRC meetings), at which verbal comments for the official record will NOT be accepted by NRC. These three meetings are rumored to be scheduled for the third week of April.
In addition, environmental scoping public comments can be submitted electronically and online, as via the U.S. federal government's Regulations.gov website. Such written comments will be accepted by NRC starting immediately, and continuing for 45 days.
However, as of press time, NRC has not published its Federal Register Notice, which will provide the details re: the public comment meetings in S.E. NM, the ways to submit written comments, etc. As soon as it does, Beyond Nuclear will spread the word far and wide.
60 days from now, a much more significant deadlines ends: legal interventions opposing the Holtec/ELEA CISF license application are due. As laid out in an April 5, 2017 press statement, issued when Holtec/ELEA announced the submission of their construction and operating license application to NRC in spring 2017 at a Capitol Hill press conference, Beyond Nuclear is adamantly opposed. Beyond Nuclear plans to intervene against Holtec/ELEA's application, as do a broad array of local grassroots, state-wide, regional, and national environmental, anti-nuclear, public interest, and environmental justice ogranizations.
Beyond Nuclear's legal counsel include Diane Curran of Harmon, Curran, Spielberg + Eisenberg in Washington, D.C., and Mindy Goldstein, director of the Turner Environmental Law Clinic at Emory University in Atlanta, GA. Curran and Goldstein also represented Beyond Nuclear, and a large coalition of environmental groups, in the successful 2012 lawsuit New York v. NRC, which overturned NRC's bogus Nuclear Waste Confidence policy.
NRC's letter commencing the Holtec/ELEA CISF licensing proceeding states:
The license application seeks NRC approval to store up to 8,680 metric tons uranium of commercial spent nuclear fuel in the HI-STORM UMAX Canister Storage System for a 40-year license term.
But this is a deception, a bait-and-switch -- a nuclear industry and complicit NRC speciality (spinning the splitting of the atom). Holtec has long made clear it intends to ultimately store up to 120,000 metric tons of commercial irradiated nuclear fuel at the ELEA CISF in NM. The 8,680 metric ton low ball deception seems to be an attempt to get the camel's nose under the tent -- and then through later license amendments, to be rubber-stamped by the rogue NRC, to keep increasing the limit over time.
The same can be said of the 40-year license term. The CEO of Waste Control Specialists, LLC (WCS), another CISF targeted at the New Mexico-Texas state line just 38 miles from Holtec/ELEA, openly admitted at a public meeting a year ago that WCS could store irradiated nuclear fuel for 100 years. Likewise, if there is nowhere to take the irradiated nuclear fuel away to, the highly radioactive waste stored at Holtec/ELEA in NM could stay for decades (or centuries, or millenia) longer than originally planned. There is a very real risk that these so-called centralized "interim storage" sites could become, by default, de facto permanent surface storage "parking lot dumps." Only the "parking" could become a forevermore dead end.
Holtec's previous target for such a CISF was the Skull Valley Goshutes Indian Reservation in western Utah. Despite the Nuclear RACISM Commission's rubber-stamping of that license, the dump was ultimately stopped anyway, thanks to a nationwide environmental justice coalition, led by Margene Bullcreek and Sammy Blackbear -- traditional Skull Valley Goshutes who opposed the dump, at great personal cost. That dump was called "Private Fuel Storage, LLC," or PFS for short. See the Nuclear Information and Resource Service (NIRS) website section devoted to the Skull Valley/PFS CISF issue, for more information.
A similar national environmental justice movement, led by the targeted locals, will be needed to halt Holtec/ELEA. But we're off to a good start. AFES (the Alliance for Environmental Strategies), led by Rose Gardner of Eunice, NM and Noel Marquez of Artesia, NM, are gearing up to fight off Holtec/ELEA. They are joined by allies from across NM, and TX, as well as across the country.
Holtec/ELEA is targeted at a region with a large percentage (in some local areas, a majority) of Hispanic American residents. The region is already heavily polluted by fossil fuel (oil extraction, natural gas fracking, and associated waste disposal) and nuclear (uranium enrichment, WIPP, and "low-level" radioactive waste disposal at WCS) industries. Although a lot of money flows through this energy intensive area, and "average" incomes are relatively high, it is far from evenly distributed -- there are significant issues of poverty in certain communities, especially in those of people of color. In short, this is a text book example, yet again, of environmental injustice. Or, in the case of the Holtec/ELEA scheme, radioactive racism.
As mentioned, the WCS CISF is but 38 miles away from Holtec/ELEA. Thus, these two facilities are seeking to turn the area into a "Nuclear Sacrifice Zone."
(As shown by the New Mexico Threats Map, prepared by Sacred Trust NM, the "Land of Enchantment" suffers plenty enough already from: high concentrations of oil and gas wells (which emit technically enhanced naturally occuring radioactive material, TENORM); existing and proposed Superfund sites; brownfields; coal mines and coal-fired power plants (which also emit TENORM); sites contaminated with depleted uranium and nuclear materials; sites contaminated with hazardous materials; active landfills; historic and current accidental releases from petroleum tanks; a large number of uranium mines; mine processing sites; trans-uranic military radioactive waste transport routes, and a national geologic disposal site (WIPP); impaired rivers and streams, as well as groundwater; areas with high concentrations of air and ground pollution; methane hot spots; areas contaminated with radioactive fallout from the July 16, 1945 "Trinity" nuclear weapon test blast; downwind contamination from the Valentine's Day, 2014 WIPP leak; and radioactive fallout from massive wildfires at Los Alamos National (Nuclear) Lab. Given the large concentrations of Native American (Pueblo, Diné, Apache, etc.) communities, Hispanic communities, low income communities, etc., this amounts to a severe violation of environmental justice (EJ).)
WCS had sort of gone quiet for several long months. In mid-2017, a federal judge ruled in favor of the U.S. Department of Justice, which had argued that WCS's bailout merger with EnergySolutions of Utah (which operates a "low-level" radioactive waste dump near the Skull Valley Goshute Indian Reservation!), would have created an illegal monopoly in "low-level" radioactive waste disposal. WCS then went bankrupt. It requested NRC to suspend its CISF licensing proceeding.
But WCS has recently been "acquired" -- and the "pause button" on the suspended WCS CISF licensing proceeding could be lifted, and the "play button" pushed.
If this happens, both the Holtec/ELEA and the WCS CISF licensing proceedings could proceed simultaneously, further burdening the targeted communities, and their environmental justice and anti-nuclear allies in NM, TX, and nationwide. This is likely a conscious strategy by the radioactive waste dumping companies and their complicit collaborators at NRC, in an attempt to wear out our resistance. But we are a stubborn bunch, in our defense of Mother Earth, and environmental justice solidarity with low income/people of color communities!
A big part of the resistance must be waking up, educating, and activating countless communities, in most states, about the highly radioactive irradiated nuclear fuel train shipments that would pass through, bound for the TX/NM borderlands, if one or both of these dumps open.
See transport numbers and route maps for the proposed Yucca Mountain, Nevada permanent burial dump, to get an idea of how massive and long-term such shipping plans would be:
The Yucca plan is currently for 70,000 metric tons of irradiated nuclear fuel and high-level radioactive waste. By comparison, WCS has proposed to "temporarily" store 40,000 metric tons of irradiated nuclear fuel in TX, while Holtec/ELEA is scheming to "temporarily" park up to 120,000 metric tons of irradiated nuclear fuel in NM.
In addition to all that, Holtec/ELEA is scheming to REPROCESS the 120,000 metric tons of irradiated nuclear fuel -- very likely in order to provide a fuel supply for Holtec's touted, publicly funded Small Modular Reactors (SMRs). But reprocessing is a very bad idea: it would risk nuclear weapons proliferation; it would inevitably cause massive radioactive contamination of the environment (with large-scale discharges of hazardous radioactivity to both air and water); and it is astronomically expensive (and the public would be expected to pay for it all).
Just look at the harm reprocessing has caused in France.
All this nuclear madness, in the words of Beyond Nuclear's founding president, Dr. Helen Caldicott, just to enrich Holtec's executives and owners, as well as Eddy and Lea County elected officials and business "leaders," decision makers who are blinded by radioactive dollar signs.
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