Holtec International's Answer Opposing Motions by Sierra Club, and Don't Waste Michigan et al., to adopt each other's contentions

Holtec International's Answer Opposing Motions by Sierra Club, and Don't Waste Michigan et al., to adopt each other's contentions.

Holtec's Motion for Extension of Time.

Sierra Club, as well Don't Waste MI et al., Jan. 17, 2019 filings opposed to Holtec/ELEA's CISF

SIERRA CLUB'S MOTION TO FILE A NEW LATE-FILED CONTENTION

SIERRA CLUB CONTENTION 26

SIERRA CLUB EXHIBIT 11

Don't Waste MI et al. Motion for Leave to File a New Contention

DWM et al.'s Contention 14

Update on February 19, 2019 by admin

Holtec Opposition to Late-Filed Sierra Club Contention 26 and Don’t Waste Michigan Contention 14, filed Feb. 19, 2019. It was filed in response, and opposition to, Sierra Club's, and Don't Waste MI et al.'s, Jan. 17, 2019 filings, above.

Press Advisory: Coalition Defends Interventions against Holtec/ELEA Forever Deadly High-Level Radioactive Waste Mega-Dump Targeted at Southeastern New Mexico

Press Advisory, For Immediate Release, January 16, 2019

Contact:

Legal counsel for Beyond Nuclear --

Mindy Goldstein; Turner Environmental Law Clinic, Emory University School of Law; 404-727-3432; mindy.goldstein@emory.edu

Diane Curran; Harmon, Curran, Spielberg + Eisenberg, LLP; 240-393-9285; dcurran@harmoncurran.com

Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear, (240) 462-3216, kevin@beyondnuclear.org

Legal counsel for Don't Waste Michigan, Nuclear Issues Study Group, et al. --

Terry Lodge, (419) 205-7084, tjlodge50@yahoo.com

Leona Morgan, Nuclear Issues Study Group, 505-879-8547, protectnewmexico@gmail.com

Michael Keegan, Don’t Waste Michigan, (734) 770-1441, mkeeganj@comcast.com

Coalition Defends Interventions against Holtec/ELEA

Forever Deadly High-Level Radioactive Waste Mega-Dump

Targeted at Southeastern New Mexico

Environmental Press Conference Jan. 22;

NRC Hearings on Trial Issues Begin Jan. 23 in Albuquerque

WHO: Environmental, and environmental justice (EJ), groups (and their legal counsel) opposing the Holtec/ELEA consolidated interim storage facility (CISF) in NM, as official parties in the U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board (ASLB) proceeding, include: Alliance for Environmental Strategies (Nancy Simmons, Albuquerque, NM), Beyond Nuclear (Diane Curran, Washington, D.C.; Mindy Goldstein, Turner Environmental Law Clinic, Emory University, Atlanta, GA); Sierra Club (Wally Taylor, Sierra Club Nuclear-Free Campaign, Cedar Rapids, IA); and a seven-group coalition including Don’t Waste Michigan, Citizens for Alternatives to Chemical Contamination (MI), Public Citizen (TX and DC), San Luis Obispo Mothers for Peace (CA), Nuclear Energy Information Service (IL), Citizens’ Environmental Coalition (NY), and Nuclear Issues Study Group (NM) (Terry Lodge, Toledo, OH).

WHAT: Environmental coalition press conference -- 3:30 MST, Tuesday, Jan. 22, at the State Bar of New Mexico ("Modrall Room”) , 5121 Masthead Street NE, Albuquerque, New Mexico – to address U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board (ASLB) oral argument pre-hearings, to be held in Albuquerque, re: the Holtec/ELEA license application to construct and operate a CISF for 173,600 metric tons of commercial irradiated nuclear fuel and other highly radioactive waste, targeted at southeastern New Mexico. (That quantity is 2.5 times the amount targeted at Yucca Mountain, Nevada for permanent burial.)

WHERE: The location of the environmental coalition press conference on Tues., Jan. 22 will be at the State Bar of New Mexico (“Modrall Room”), 5121 Masthead Street NE, Albuquerque, New Mexico.

Streaming address (URL) for press conference on Tuesday, January 22: https://www.youtube.com/channel/UCQ-WzQkZ589ZLkdc7SIT0EQ?view_as=subscriber

(The oral argument pre-hearings of the NRC ASLB will be at the same location, in the auditorium, on Wed., Jan. 23 and likely Thurs., Jan. 24. The NRC ASLB has made available listen-only, call-in phone lines, for taking in the proceedings: The telephone number is 1-888-790-1895 and the passcode is 5046496).

WHEN: The time of the environmental coalition press conference will be 3:30pm MST, Tuesday, Jan. 22, 2019. (The NRC ASLB hearings will begin Wed., Jan. 23, 2019, at 9:00 am MST, and will continue on Thursday, January 24, 2019, as needed.)

WHY: The environmental coalition first filed their petitions to intervene, and requests for hearing, in opposition to the Holtec/ELEA CISF proposal, on Sept. 14, 2018. 40 technical and legal contentions of opposition, many backed up by expert witness testimony, range from environmental justice violations, to lack of legal authorization for such a CISF, and a broad range of concerns regarding public health, safety, security, and the environment. (For the complete list of legal contentions, please see the OVERVIEW, below).

A comprehensive Summary of Holtec/ELEA CISF Licensing Application Proceeding is posted at the top of Beyond Nuclear’s CENTRALIZED STORAGE website section.

--End--

Overview of Environmental Coalition Contentions Opposing Holtec/ELEA’s CISF, and the NRC ASLB Licensing Proceeding:

As detailed in the environmental coalition filings, 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+):

(1) impacts on Native American and other historic and pre-historic properties on the site;

(2) insufficient assurances of financing for construction, operation, and decommissioning;

(3) underestimation of so-called “low-level” radioactive waste volumes that would be generated;

(4) improper reliance on NRC generic Environmental Impact Statement presumptions;

(5) natural gas fracking and potash mining beneath the site;

(6) cumulative risks of future reprocessing (plutonium extraction);

(7) 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;

(8) 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;

(9) inconsistent predicted lengths for “interim storage” period, from 40 to 100, 120, or even 300 years, timeframes that could dangerously exceed the design and surface life of the containers;

(10) unmet safety and security risk analyses for the scale of transport and storage proposed; (11) troubling geological formations and conditions beneath the site;

(12) no compelling purpose and need for the CISF;

(13) risk of the CISF becoming a de facto permanent surface storage “parking lot dump”;

(14) Holtec’s improper reliance on the Blue Ribbon Commission for America’s Nuclear Future’s 2012 Final Report;

(15) earthquake risks at the site;

(16) impacts on endangered and threatened species, such as the dunes sagebrush lizard; (17) 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;

(18) thermal concerns associated with corrosion of the containers;

(19) groundwater and brine concerns at the site, including threats of radioactive contamination reaching area drinking and irrigation water aquifers downstream;

(20) risks of high burnup irradiated nuclear fuel degradation and failure.

The NRC ASLB oral argument pre-hearings on January 23-24, 2019 in Albuquerque will address "standing and contention admissibility."

A comprehensive Summary of Holtec/ELEA CISF Licensing Application Proceeding is posted at the top of Beyond Nuclear’s CENTRALIZED STORAGE website section.

Licensing board announces listen-only phone lines for Holtec/ELEA CISF licesning hearing beginning 1/23 in ABQ, NM

Here is the relevant info. from the U.S. Nulcear Regulatory Commission Atomic Safety and Licensing Board:

"In connection with the oral argument scheduled to begin at 9:00 a.m. MST on January 23 and continue as necessary on January 24, 2019, the Board will make available listen-only telephone lines. This should allow interested members of the public—both in New Mexico and elsewhere—to hear the arguments in real time if it is not practicable to attend in person. The telephone number is 1-888-790-1895 and the passcode is 5046496."

Here is the link to the ASLB Order.

Please spread the word to your networks re: this opportunity to listen-in, to show solidarity with the opponents to the centralized interim storage facility (CISF) for 173,600 metric tons of highly radioactive irradiated nuclear fuel targeted at southeastern New Mexico!

Holtec International's Answer Opposing Don't Waste Michigan, et al., and Sierra Club's Joint Motion to Adopt Hearing Procedures

The U.S. Nuclear Regulatory Commission's legal pleading can be viewed at this link.