MEMORANDUM OF LAW FOR THE STATES OF NEW YORK, CONNECTICUT, ILLINOIS, IOWA, MARYLAND, MICHIGAN, MINNESOTA, NEW JERSEY, NEW MEXICO, OREGON, PENNSYLVANIA, AND VERMONT AS AMICI CURIAE IN SUPPORT OF PETITIONER AND IN OPPOSITION TO THE MOTIONS TO DISMISS
re: COMMONWEALTH OF MASSACHUSETTS, Petitioner, v. U.S. NUCLEAR REGULATORY COMMISSION and UNITED STATES OF AMERICA, Respondents, HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, et al., Intervenors
before the UNITED STATES COURT OF APPEALS DISTRICT OF COLUMBIA CIRCUIT
See the 48 page Memorandum posted here.
Holtec International has also proposed a consolidated interim storage facility for irradiated nuclear fuel -- such as the highly radioactive wastes at Pilgrim nuclear power plant in MA -- targeted at southeastern New Mexico.