Don't Waste MI, et al., comments to NRC re: Holtec CISF DEIS

Don't Waste Michigan, et al., is a seven-group national grassroots environmental coalition, opposed to the Holtec Consolidated Interim Storage Facility for irradiated nuclear fuel targeted at New Mexico.

The seven groups include: Don't Waste MI; Citizens for Alternatives to Chemical Contamination (CACC, also based in MI); Public Citizen, Inc. (with a Texas Office and national offices in Washington, D.C.; San Luis Obispo Mothers for Peace (based in CA); Nuclear Energy Information Service (NEIS, based in Chicago, IL); Citizens' Environmental Coalition (CEC, based in Cuddebackville, NY); Nuclear Issues Study Group (NISG, based in Albuquerque, NM).

Don't Waste MI, et al., was an official legal intervenor in the U.S. Nuclear Regulatory Commission's (NRC) Atomic Safety and Licensing Board (ASLB) proceeding re: Holtec's application to construct and operate the CISF.

Don't Waste MI, et al.'s, legal counsel, Terry Lodge of Toledo, OH, filed public comments re: NRC's Holtec CISF DEIS, by the Sept. 22nd deadline. The comments include the following sections:

I. The Environmental Impact Statement Is Arbitrarily Limited To Analysis Of Holtec’s First 40 Years Of Existence

II. The First 40 Years Of Operations Comprise An Irretrievable Commitment Of Resources, Compelling NEPA Analysis Of Relicensings And De Facto Permanent Disposition At Holtec

III. The EIS Must Encompass and Address Environmental Impacts Associated With Relicensing And Decommissioning, Because Relicensing And Decommissioning Are Reasonably Foreseeable

IV. The Predominant Activity Of SNF Repackaging During Holtec Operations Goes Wholly Unmentioned In The DEIS

V. Holtec’s Controversial ‘Return To Sender’ Policy Is Marginalized And Unanalyzed In The DEIS

VI. The Omission Of Serious Transportation Analysis From The DEIS Comprises Segmentation And Fails To Fulfill NEPA Disclosure Obligations

VII. Failure to Consider Reasonable Alternatives Renders DEIS Inadequate And Incomplete

VIII. Incomplete Off-Normal Events Analysis Renders DEIS Inadequate

IX. The Staff Has Not Completed The FSER, So The DEIS Contains No Radiological Accident Analysis And Is Incomplete

X. The Continued Storage Rule Statement Is Inapplicable To Holtec’s First 120 Years

XI. The DEIS Misrepresents The Availability Of Federal Price-Anderson Insurance As Mitigation For Transportation Accidents

XII. The Low-Level Radioactive Waste Analysis Fails To Account For Canister Repackaging

XIII. Objection To Recent Alterations To NEPA Regulations And Interpretations