Centralized Storage

With the scientifically unsound proposed Yucca Mountain radioactive waste dump now canceled, the danger of "interim" storage threatens. This means that radioactive waste could be "temporarily" parked in open air lots, vulnerable to accident and attack, while a new repository site is sought.



New Mexicans Speak Out About Radioactive Waste Risks


NRC Announces Hearing Opportunity on Holtec Application For Proposed New Mexico Spent Fuel Storage Facility

As published at NRC's website.

This NRC press release on July 18th came two days after the NRC's licensing proceeding legal intervention deadline date, posted in the Federal Register, on July 16th.

As Beyond Nuclear's Kevin Kamps stated at a July 16th reactor decommissioning and radioactive waste management congressional briefing, NRC's timing is tone deaf bordering on sociopathic or even ghoulish. July 16 is the annual commemoration of two radioactive disasters suffered by New Mexico -- the 1945 Trinity atomic bomb blast near Socorro, which created the world's first downwinders, such as the Tularosa Basin Downwinders Association; and the 1979 Church Rock uranium mill tailings spill, in Navajo Country near Gallup.

NRC chose this date, July 16th, to announce the beginning of the licensing proceeding for the Holtec/ELEA centralized interim storage facility for 173,600 metric tons of highly radioactive irradiated nuclear fuel, targeted at southeastern NM.

Beyond Nuclear, and its legal counsel (Diane Curran of Washington, D.C., and Mindy Goldstein of the Turner Environmental Law Clinic at Emory University in Atlanta, GA), fully intend to meet that deadline. So too do environmental, and environmental justice, allies, both in NM itself, as well as along transport routes that would be used to haul the highly radioactive wastes out there, by road, rail, and/or waterway, across the country.


Sample comments you can use to write your own for submission to NRC in opposition to Holtec's CISF in s.e. NM

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)

(Another convenient, efficient way to submit comments is via Public Citizen's webform, here.

(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:

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

Document Date: 04/30/2018

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

Document Date: 05/01/2018

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

Document Date: 05/03/2018

Document Title: Transcript of Public Scoping Meeting for the Environmental Impact Statement for Holtec International's Hi-store Consolidated Interim Storage Facility for Spent Nuclear Fuel Located in Lea County, New Mexico - 05/21/2018, Pages 1-115.

Document Type: Meeting Transcript

Document Date: 05/21/2018

Document Title: Transcript of Public Scoping Meeting, 05/22/2018, Pages 1-166.

Document Type: Meeting Transcript

Document Date: 05/22/2018


(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.


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 <>

You can also submit written comments electronically via the Federal Rulemaking website: Go to 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.


[*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 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 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 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 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 site, please let Beyond Nuclear staffer Kevin Kamps know ASAP at, 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 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).]


Request for redacted information re: "cultural properties" in Holtec/ELEA CISF Environmental Report

Toledo, OH attorney Terry Lodge, legal counsel for Don't Waste Michigan in the U.S. Nuclear Regulatory Commission's (NRC) Holtec/Eddy-Lea [Counties] Energy Alliance license application proceeding to construct and operate a centralized interim storage facility for irradiated nuclear fuel in southeastern New Mexico, has submitted a Freedom of Information Act (FOIA) request to the agency. It regards the redaction of a long section of the Holtec Environmental Report, on "Cultural Properties," for "security-related" reasons.

No explanation was given as to why or how "cultural properties" could have "security-related" issues that would justify such secrecy.

"Cultural properties" can refer to National Register of Historic Places under the National Historic Preservation Act. However, it can also refer to Native American archaeological sites, sacred sites, and even burial sites.

Such "cultural properties" could well be damaged or entirely destroyed (or in the case of Native American sacred or burial sites, desecrated) by the construction and operation of the Holtec/ELEA CISF.


NRC rejects 52-group environmental coalition's call for Holtec CISF comment deadline extension and more public meetings

By letter dated June 26, 2018, the U.S. Nuclear Regulatory Commission (NRC) staff rejected the call from an environmental coalition of 52 groups for 18 more environmental scoping public comment meetings, and an extension of the current July 30, 2018 deadline for public comment out to October 30, 2018, regarding the Holtec International/Eddy-Lea [Counties] Energy Alliance scheme to construct and operate a centralized interim storage facility for up to 173,600 metric tons of irradiated nuclear fuel in southeastern New Mexico.

The NRC apparently snail mailed the letter out to each of the 52 groups, as well as to Toledo, Ohio attorney Terry Lodge who serves as legal counsel for the coalition effort. The letter was not emailed. Thus, even though it was dated June 26, it took the coalition several days to even learn of the letter's existence.

And the deadline clock keeps ticking toward July 30th, NRC's deadline for public comments on environmental scoping for this most dangerous scheme.

This means we must redouble efforts to urge members of congress to demand additional public meetings, and an extension of the comment deadline. Such action by the two U.S. Senators from New Mexico (Tom Udall and Martin Heinrich, both Democrats) earlier this year successfully secured two additional meetings in northern New Mexico, which otherwise would not have happened.

As the coalition's request made clear more than two months ago now, given the transport risks alone of the proposed CISF, public meetings should be held nationwide. Thus far, meetings have only been held in New Mexico, and a single meeting at the NRC's HQ in Rockville, MD (the agency, per usual, barely circulated notice of the meeting in the local area, so a single member of the public was all that turned out in person; however, 70 concerned citizens and environmental group representatives from across the country turned out by phone, despite the short notice).

Here is a draft letter (in both PDF and .docx formats) that you could give to your own U.S. Representative, and to both of your own U.S. Senators, for their use in requesting a public meeting in your congressional district or state, and for requesting an extension to the current July 30, 2018 deadline. Please urge your members of congress to take action ASAP.

You can phone your members' of congress offices via the U.S. Capitol Switchboard at (202) 224-3121.

Or you can look up the specific contact info. for both your U.S. Senators here, and your U.S. Representative here.