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« Mock nuke waste cask tour underway in NM, educating folks about the risks of highly radioactive waste shipments | Main | How to submit your public comments by the July 30th, 2018 deadline »
Tuesday
Apr102018

Additional sample comments you can use to write your own for submission to NRC in opposition to Holtec/ELEA CISF

SAMPLE COMMENTS (instructions for how to submit your comments are located below, towards the bottom of this web post -- or you can click here to see those instructions; NRC has extended the public comment deadline till July 30th)

(1.) On April 5th, Beyond Nuclear posted a first set of sample comments re: Mobile Chernobyl shipping risks.

Since, Beyond Nuclear has posted additional sets of sample comments, re: yet more high-risk aspects of the Holtec International/Eddy-Lea [Counties] Energy Alliance (ELEA) proposal to "temporarily store" (yeah, right!) 100,000+ metric tons of highly radioactive irradiated nuclear fuel, and other nuclear wastes, in s.e. NM, half-way between Hobbs and Carlsbad, NM.

Sample comments you can use to prepare you own, for submission to the U.S. Nuclear Regulatory Commission (NRC). See how to submit public comments, by the July 30th, 2018 environmental scoping period deadline, below.

We need to generate a large number of quality comments to NRC, just like we did over a year ago in opposition to a similar Centralized Interim Storage Facility (CISF, a.k.a. MRS, short for Monitored Retrievable Storage site) targeted at Andrews Co., w. TX, just 38 miles from the s.e. NM Holtec/ELEA site.

As mentioned above, the first set of Beyond Nuclear sample comments, are focused on Mobile Chernobyl shipping risks.

Here are direct links to that first set of Beyond Nuclear sample comments, in PDF format, and in Word (.docx) format.

Beyond Nuclear then posted additional sets of sample comments focused on other high-risk facets of the Holtec/ELEA scheme, including a set on the risk of so-called centralized "interim" storage facilities becoming de facto permanent surface storage “parking lot dumps.”

(2.) Here is that second set of sample comments, hot off the press, in PDF format, and in Word (.docx) format.

And here is another set of sample comments, focused on: Risks of Loss of Institutional Control if De Facto Permanent Surface Storage “Parking Lot Dumps” are Abandoned, Containers Fail, and Release Catastrophic Amounts of Hazardous Radioactivity into the Environment.

(3.) See this third set of sample comments, in PDF format, as well as Word (.docx) format.

And here is a fourth set of sample comments, focused on: Risks of “Routine” or “Incident-Free” Shipments Nonetheless Being Like “Mobile X-ray Machines That Can’t Be Turned Off,” and Risks of Externally Contaminated Shipments.

(4.) See this fourth set of sample comments, in PDF format, as well as Word (.docx) format.

Beyond Nuclear is now posting a fifth set of sample comments, this time focused on: Why Are All These High Risks Being Taken in the First Place?!

(5.) See this latest, fifth set of sample comments, in PDF format, as well as Word (.docx) format.

Beyond Nuclear also updated and adapted "We Do NOT Consent!" sample comments, from the U.S. Department of Energy's (DOE) "Consent-Based Siting" public comment proceeding, for use in this Holtec/ELEA CISF proceeding. 

(6.) See the 15-page version, in both PDF format, as well as Word (.docx) format.

See a boiled down 2-page summary version, in both PDF format, as well as Word (.docx) format.

Feel free to use Beyond Nuclear sample comments in any way that is helpful to you -- including copying them in their entirety. You can also use them to help shape your ideas to express in your own words.

(7.) See the public commments that Beyond Nuclear presented verbally at NRC's HQ meeting on Wed., April 25th in Rockville, MD. They are entitled "When It Comes to Highly Radioactive Waste Transportation Risks, We All Live in New Mexico!" They call for NRC public comment meetings to be held in dozens of states across the U.S. that will be significantly impacted by many thousands of "Mobile Chernobyl" train, truck, and/or barge shipments on rails, roads, and/or waterways, under this scheme. See the PDF format, as well as the Word (.docx) format.

(8.) See the public comments that Beyond Nuclear presented verbally at NRC's three environmental scoping meetings in southeast NM from April 30 to May 3, 2018: PDF format; Word (.docx) format.

(In future days and weeks, yet additional sample comments will be provided by Beyond Nuclear, covering a multiplicity of the multi-faceted high risks of the Holtec/ELEA CISF/MRS proposal. Watch for them, to help you submit your own version to NRC by the July 30th deadline!)

See also:

(9.) Nuclear Watch New Mexico has posted 2-page and 4-page long sample comments on its No High-Level Waste to New Mexico website section.

(10.) A coalition of New Mexico and Texas groups (including Sierra Club, Nuclear Issues Study Group, SEED Coalition, and others) handed out these 2-page talking points/sample comments entitled "100,000 Tons of High-Level Radioactive Waste -- We Don't Want It!" during their NM-wide mock nuke waste cask (inflatable parade float) educational tour.

(11.) No Nuclear Waste Aqui (aqui is the Spanish word for "here") has also posted sample comments at its website:

(12.) Nuclear Issues Study Group adapted Nuclear Watch New Mexico's sample comments, creating 2-pagers that folks can sign onto as is and submit, and also add your own additional comments. These come in both national, and local New Mexico, versions:

National version (PDF format, and Word (.docx) format);

Local NM version (PDF format, and Word (.docx) format).

(13.) Here is a link to the official transcript of NRC's Wed., April 25, 2018 agency HQ (Rockville, MD) public comment meeting. Most public participants took part by phone and/or webinar, although at least one (Diane D'Arrigo of NIRS) attended in person. You could study this 118-page transcript for additional ideas you can use to help you prepare your own public comments for submission to NRC by the July 30th deadline. 

(14.) And here, below, are links to the official transcripts of NRC's three public comment meetings in southeast NM, in Roswell, Hobbs, and Carlsbad, on April 30, May 1, and May 3:

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18130A901

Document Title: Holtec CISF Public Scoping Meeting April 30, 2018, Transcript.
Document Type: Meeting Transcript

Document Date: 04/30/2018

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18130A902

Document Title: Holtec CISF Public Scoping Meeting May 1, 2018, Transcript.
Document Type: Meeting Transcript

Document Date: 05/01/2018


https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18130A906

Document Title: Holtec CISF Public Scoping Meeting May 3, 2018, Transcript.
Document Type: Meeting Transcript

Document Date: 05/03/2018

 

(15.) A coalition of 52 environmental groups has urged NRC to grant another 18 public comment meetings nationwide: The coalition letter requested as many NRC public meetings as possible in the following locations --  Atlanta, GA; Boston, MA; Chicago, IL; Cleveland, OH; Dallas/Forth Worth and San Antonio, TX; Detroit, MI; Kansas City and St. Louis, MO; Los Angeles, CA; Miami and Tampa, FL; Minneapolis/Saint Paul, MN; Nashville, TN; New York City, NY; Newark, NJ; Omaha, NE; Philadelphia and Pittsburgh, PA; and Tampa, FL. These locations would all be hard hit by rail, road, and or waterway shipments, by train, truck, and/or barge, from atomic reactors, to Holtec/ELEA, NM. For this reason, they too deserve to have environmental scoping public comment meetings. Please urge NRC to hold additional meetings in such places, and/or in your own area, in your comments, as well.

HOW TO SUBMIT YOUR PUBLIC COMMENTS BY THE CURRENT JULY 30TH (EXTENDED FROM THE ORIGINAL MAY 29TH), 2018 DEADLINE:

Please include “Docket ID NRC–2018–0052” in your comment submission, such as in the subject line of your e-comments or snail-mailed hard copy comments.

An email option for submission of public comments was added on May 3rd. Thanks to Joni Arends of CCNS (Concerned Citizens for Nuclear Safety, Santa Fe, NM) requesting it (see note at bottom*) at the May 1st Hobbs, NM public comment mtg., NRC granted the request:

Here's the official NRC email address for folks to submit comments directly to NRC:

Holtec-CISFEIS Resource <Holtec-CISFEIS@nrc.gov>

You can also submit written comments electronically via the Federal Rulemaking website: Go to
http://www.regulations.gov and search for Docket ID NRC–2018–0052, then follow the instructions given there.
(**See note below.)

Submit written comments via snail mail, by sending them to: May Ma; Office of Administration; Mail Stop: TWFN-7-A60M; U.S. Nuclear Regulatory Commission; Washington, DC 20555-0001.

Notes:

[*The only reason NRC even has an email option for submitting public comments is because Joni Arends of CCNS -- Concerned Citizens for Nuclear Safety -- requested it, at the Hobbs, NM NRC public comment meeting on May 1st. Thank you Joni! And the reason Joni requested it, was because her friends and colleagues had encountered so much difficulty with the regulations.gov site, even at that point. In the year 2018, the public should not have to ask for an NRC email address to be provided, as one way for submission of public comments. And in the year 2018, NRC's regulations.gov site should not be out of order for two solid weeks, and counting! The question is, does NRC stand for Nobody Really Cares, or No Remaining Credibility -- or both at the same time?!] 

[**Update on June 14, 2018: Outrageously, NRC's regulations.gov site, re: this subject matter docket, had not worked, from May 18th to June 7th! It had been spotty even weeks before that, as indicated in the note* above. Beyond Nuclear, and other groups, called this to NRC's attention multiple times, beginning with Joni Arends of CCNS on May 1st as noted above, and again on May 22nd (Beyond Nuclear via emails, Nuclear Issues Study Group's Cody Slama via verbal testimony at the NRC public comment meeting in ABQ, NM), as well as again on May 31st (Beyond Nuclear emails to NRC staff). NRC's response was, for weeks on end, essentially, that's not our department, and there are other ways to submit your comments -- or even outright denial that there was even a problem. This was a real outrage. NRC cannot get away with being this irresponsible. NRC itself has held up regulations.gov as a gold standard way of submitting public comment. Only it was not working at all for a solid three weeks?! On June 7th, 2018, it was finally confirmed that the regulations dot gov site is working again, as it was supposed to be the whole time. If you do encounter any problems using the Regulations.gov site, please let Beyond Nuclear staffer Kevin Kamps know ASAP at kevin@beyondnuclear.org, or (240) 462-3216, so that Beyond Nuclear can continue to hold NRC's feet to the fire!

In an effort to get NRC to do its job, and grant the public unfettered rights and means to submit comments on the environmental scoping, a coalition of environmental groups (Beyond Nuclear, Don't Waste Michigan, Nuclear Information and Resource Service, and Nuclear Issues Study Group, represented by legal counsel) submitted a letter to NRC on June 12th, demanding NRC fix the Regulations.gov website once and for all, or else offer an alternative; and extend the current July 30th public comment deadline till October 30th. We'll keep you posted here as to how that develops! If NRC cannot even guarantee that its public comment webform works, how can we trust this agency to safeguard, secure, and contain forever deadly highly radioactive waste?!]

Submit verbal comments at NRC public meetings:

A national phone in/webinar for public comments was held on Wednesday, April 25, from 7-9pm Eastern Time at NRC HQ in Rockville, MD, located at 11555 Rockville Pike; once the transcript becomes available, Beyond Nuclear will post it here, so you can see comments by more than two-dozen opponents to the Holtec/ELEA CISF scheme; not one public commenter spoke in favor of the proposal!);

Those who live near enough to s.e. NM could provide verbal comments by attending in person (no phone-in or webinar being provided by NRC):

4-7pm Mountain Time, April 30, at Eastern New Mexico University, Roswell Campus, Union Building, Room 110, 48 University Blvd., Roswell, NM;

7-10pm Mountain Time, May 1, at the Lea County Event Center, 5101 N. Lovington Highway, Hobbs, NM;

7-10pm Mountain Time, May 3, at the Eddy County Fire Service, 1400 Commerce St., Carlsbad, NM.

On May 9, 2018, NRC announced the following:

NRC announced two more public comment meetings, apparently in direct response to a demand made by NM’s two Democratic U.S. Senators, Tom Udall and Martin Heinrich: Monday, May 21 from 6 to 9 pm Mountain Time, at Gallup Downtown Conference Center, 204 W. Coal Ave., Gallup, NM 87301; and Tuesday, May 22 from 6 to 9 pm MTN, at Crown Plaza, 1901 University Blvd., Albuquerque, NM 87102.

Also on May 9, a coalition of 52 environmental groups nationwide, including Beyond Nuclear, requested 18 additional public comment meetings, to be held in transport hubs that would be hard hit by NM-bound highly radioactive waste trains, trucks, and/or barges. The coalition also requested a 180-day extension to the May 29, 2018 deadline, in order to accommodate those additional meetings. NRC has not yet responded.

[Beyond Nuclear has joined with more than 50 other organizations demanding a significant number of additional NRC public comment meetings, to be held outside of NM, in transport corridor states impacted by road, rail, and/or barge shipments of highly radioactive irradiated nuclear fuel to Holtec/ELEA in s.e. NM.

Please join this call, by urging your U.S. Sens., as well as your U.S. Rep., to support requests by a coalition of 52 environmental groups, including Beyond Nuclear, by themselves contacting NRC and requesting public comment meetings in your state and congressional district. Thus far, not a single public in-person meeting has been held outside of NM, other than one at the NRC HQ in Rockville, MD (which the agency did very little to even notify the public about). This is unacceptable, in that most states would experience very large numbers of road and/or rail shipments of highly radioactive waste, by truck and/or train, if Holtec/ELEA's CISF opens; some states would even experience barge shipments on surface waterways. You can look up your two U.S. Sens.' contact info. here, and your U.S. Rep.'s contact info. here. Or you can phone your congress members' offices via the U.S. Capitol Switchboard at (202) 224-3121. Please spread the word to your networks re: the importance of submitting public comments to NRC opposing this environmental injustice (southeast NM has a large percentage of Hispanic residents; the area is already heavily polluted by fossil fuel and nuclear industries).]