ML20309B067

Comment (10324) E-mail Regarding ISP-CISF Draft EIS

ML20309B067
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	11/03/2020
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
85FR27447
Download: ML20309B067 (29)

Text

From:

Kevin Kamps <kevin@beyondnuclear.org>

Sent:

Tuesday, November 3, 2020 4:08 PM To:

WCS_CISFEIS Resource

Subject:

[External_Sender] Beyond Nuclear's 25th set of public comments, re:

Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Our objections to NRC's outrageous conduct of this ISP/WCS CISF public comment proceeding

Dear NRC Staff,

We submit these comments on behalf of our members and supporters, not only in New Mexico and Texas, near the targeted ISP/WCS CISF site, but across both of these states, and the rest of the country, along road, rail, and waterway routes that would be used for high risk, highly radioactive waste shipments to ISP/WCS's CISF, as well as to Yucca Mountain, Nevada, on Western Shoshone land -- wrongly and illegally assumed by ISP/WCS, as well as by NRC, to someday (or some decade, or some century) become a permanent disposal repository. This unnecessarily repeated, multiple legged, cross-continental transport of highly radioactive waste, is another significant aspect of the EJ (Environmental Justice) burden associated with this ISP/WCS CISF scheme.

The following subject matter has gotten little to no attention in NRC's ISP/WCS CISF DEIS, a far cry from NEPA's legally binding "hard look" requirement:

We object to NRC's outrageous conduct of this ISP/WCS CISF public comment proceeding.

On Wednesday, Oct. 26th, 2016, Beyond Nuclear and allies (Nuclear Information and Resource Service, Public Citizen, and SEED Coalition) sent a letter (linked here) to NRC, urging it stop reviewing a license application by Waste Control Specialists, LLC (WCS) to construct and operate a CISF, a de facto permanent parking lot dump for commercial irradiated nuclear fuel in Andrews County, west Texas. This was required, Beyond Nuclear et al.'s legal counsel argued, because the application, and its review, are illegal, in several regards. (WCS's CISF has since been renamed ISP, for Interim Storage Partners.)

On Thursday, Oct. 27th, 2016, the environmental coalition issued a press release (linked here).

Beyond Nuclear's Radioactive Waste Specialist, Kevin Kamps, was quoted:

By requiring a permanent deep geological repository to be operating before centralized interim storage could be opened, Congress wanted to prevent the very real danger of a de facto permanent parking lot dump - a nuclear waste storage site that would be designed for the short-term but be there forever," said Kevin Kamps, radioactive waste specialist, Beyond Nuclear. He added: WCS is a cynical shell game and taxpayers are sure to lose. Congress was right that liability for the costs of storing commercial irradiated nuclear fuel belongs with the generators and should not be shifted onto the backs of the American public.

On all of these high-level radioactive waste regulatory and legal matters, Beyond Nuclear is served by legal counsel Diane Curran of Harmon, Curran, Spielberg + Eisenberg, LLP of Washington, D.C., as well as Mindy Goldstein, as well as Geoff Toy, of Turner Environmental Law Clinic at Emory University in Atlanta, GA.

But NRC did not stop processing the Holtec/ELEA, nor the ISP/WCS, CISF license applications.

Beyond Nuclear et al. have continued to object, for the past 4+ years, at every twist and turn of both licensing proceedings, as well as during environmental scoping, and now the DEIS phase, in both CISF proceedings; we have continued to argue that NRC should cease and desist processing them, as they are illegal. Beyond Nuclear's, and others', appeals have now gone to the second highest court in the land, the U.S. Court of Appeals for the District of Columbia Circuit, vis-a-vis the Holtec CISF case. If and when the NRC Commissioners reject Beyond Nuclear's et al.'s appeals in the ISP/WCS CISF case, then those rulings will likewise be appealed to the second highest court in the land, as well, by CISF opponents.

NRC has continued to ram its ISP/WCS CISF DEIS public comment process through, despite the national pandemic emergency.

For example, making November 3rd -- Election Day -- the deadline for public comments is a form of voter suppression. It's also a thinly veiled attempt by NRC to suppress media coverage of the widespread public resistance to ISP/WCS, as shown by the large number of quality comments submitted in opposition to the CISF.

There has also been an inappropriate disparity between the two very closely related and even overlapping NRC NEPA proceedings, when comparing and contrasting the Holtec/ELEA proposal in NM, and the ISP/WCS proposal in TX, as well as comparing both CISF proceedings to the previous Yucca Mountain, NV proceedings conducted by DOE.

At the environmental scoping stages some years ago, NRC held only three in-person public comment meetings for ISP/WCS's CISF scheme. Only one of those, remarkably, was held in Texas, the state targeted for the CISF. All three were held on very short notice, making it very difficult for concerned members of the public to even show up. The very worst of these short notices was for the public comment in-person meeting held at NRC HQ in Rockville, MD. The meeting notice appeared on the NRC's website a mere two days before the meeting took place.

NRC supposedly strives to provide ten days' notice to the public regarding even minor meetings.

This was a major meeting, of great significance and public interest, even controversy, and NRC provided a mere two days' notice. That was outrageous and objectionable. Was NRC attempting to suppress public participation? It seems so.

By contrast, NRC held six in-person public comment meetings re: environmental scoping on Holtec/ELEA's CISF scheme. All were held in NM. A seventh public comment meeting was held at NRC HQ in Rockville, MD. Yet again, NRC provided so little and so ineffective public notice, that a single member of the public actually attended the meeting in person (Diane D'Arrigo of NIRS). However, scores of concerned citizens, environmental group representatives, etc. attended by phone, and provided public comment from afar.

Why the disparity? Why did Holtec get seven comment meetings, while ISP got only three?

(Please note that environmental coalitions requested not three meetings, nor seven, but rather dozens, and were denied by NRC. See below.)

But as documented in the following press release, below (which includes links to the letter to the NRC, as well as to news updates re: NRC's rejection of the requests), during the Yucca Mountain, Nevada environmental scoping stage, decades ago, the U.S. Department of Energy (DOE) held some two-dozen in-person public comment meetings, not only at several locations across Nevada (as well as a number nearby in California, including downstream of Yucca Mountain, but also on transport routes that would be impacted), but in a dozen states outside Nevada, on Mobile Chernobyl high-level radioactive waste and irradiated nuclear fuel road, rail, and waterway transport routes that would be impacted.

[Opponents Request Comment Period Extension re:

Holtec/ELEA Highly Radioactive Waste Centralized Interim Storage Site in New Mexico NEWS FROM BEYOND NUCLEAR For immediate release: May 9, 2018

Contact:

Terry Lodge, environmental coalition attorney, (419) 205-7084, tjlodge50@yahoo.com Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear, (240) 462-3216, kevin@beyondnuclear.org Opponents Request Comment Period Extension re: Holtec/ELEA Highly Radioactive Waste Centralized Interim Storage Site in New Mexico Environmental Coalition Cites Need for Additional Meetings in Cities Hard Hit by High-Risk Road, Rail, and/or Barge Shipments of Irradiated Nuclear Fuel WASHINGTON, D.C. -- A coalition of 52 environmental, social justice, and public interest organizations, has requested that the U.S. Nuclear Regulatory Commission (NRC) extend the public comment period on environmental scoping by 180 days, in the proceeding considering Holtec International/ELEAs (Eddy-Lea Counties Energy Alliance) application to construct and operate a centralized interim storage facility, for 100,000 to 173,600 metric tons of highly radioactive irradiated nuclear fuel, in southeast New Mexico. The coalitions petition to NRC

(posted online at this link) also requests 18 additional public comment meetings across the country, in cities that would serve as transport hubs for the 10,000 or more high-risk shipments of irradiated nuclear fuel, by road, rail, and/or waterway, over the course of decades, from commercial atomic reactors, to the site in southeast NM located halfway between Hobbs and Carlsbad.

Thus far, NRC has held only four meetings: one at its agency headquarters in Rockville, MD, which had the added opportunity to call-or webinar-in; and three in southeast NM (Roswell, Hobbs, and Carlsbad), relatively near the Holtec/ELEA targeted site. Just today, NRC announced two more public comment meetings, apparently in direct response to a demand made by NMs 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.

By comparison, a significantly smaller proposal - the Yucca Mountain, Nevada, permanent geological dump-site, limited to 70,000 metric tons, only 63,000 of which is reserved for commercial irradiated nuclear fuel - had two-dozen public comment meetings, convened by the U.S. Department of Energy, in many of the very same transport hub cities cited in the coalitions request letter to NRC.

While the two additional New Mexico meetings are welcome, this is still a woefully inadequate number of public meetings, as compared to what NRC should be holding for a proposal of such national significance, said Kevin Kamps of Beyond Nuclear. The high-risk shipments of highly radioactive waste would travel through most states in the Lower 48 en route to New Mexico, and so far NRC has held not a single public meeting in the scores of large cities that would be impacted by many thousands of shipments, over the course of several decades, Kamps added.

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.

One of countless concerns we have with the Holtec/ELEA proposal is that DOZENS of shipments from the Fermi nuclear power plant, bound for New Mexico, would have to pass, by rail, through the heart of metro Detroit, said Terry Lodge, environmental attorney based in Toledo, legal counsel for Dont Waste Michigan, which intends to legally intervene in opposition to the Holtec/ELEA application.

And that's only the half of it. There would also be 10,000 shipments nationwide of the highly radioactive waste, decades or a century later, supposedly moving the irradiated nuclear fuel on to an as yet unidentified, permanent repository, Lodge added. If, as the NRC holds, present on-site storage arrangements are satisfactory, why should we put Americans at such dangerous risk 20,000 times?" Lodge asked.

Even routine, incident-free shipments would be like mobile X-ray machines that cant be turned off, emitting hazardous gamma-and neutron-radiation at close range as they pass by, but there is also the potential for Mobile Chernobyls, catastrophic radioactivity releases, as due to container breaches during severe accidents or intentional attacks, Lodge added.

The road and rail route maps prepared by Dr. Fred Dilger on behalf of the State of Nevada Agency for Nuclear Projects, in the context of the Yucca Mountain permanent burial dump proposal, are instructive regarding the Holtec/ELEA, NM centralized interim storage facility (also known as a monitored retrievable storage site, or away from reactor so-called temporary storage facility). The further east, or west for that matter, from NM, the more similar, or identical, would be the routes, by rail or road, between the NV and NM schemes. The Dilger routing analyses show that 44 states, scores of major cities, and 330 of 435 U.S. congressional districts, would host road and/or rail routes for highly radioactive irradiated nuclear fuel truck and/or train transport to NV. Dr. Dilgers three reports, including route maps, shipment numbers, and congressional districts impacted, are posted online at the State of NV Agency for Nuclear Projects website, here.

In addition to the high risks of truck and train transports of irradiated nuclear fuel, there is the specter of potential barge shipments, Kamps of Beyond Nuclear said. As but one example, barges on Lake Michigan, from Michigan and Wisconsin atomic reactors into the ports of Muskegon and Milwaukee, could put at risk the drinking water supply for 40 million people in several U.S. states, two Canadian provinces, and a large number of Native American First Nations downstream, if one were to sink by accident, or be sunk by terrorist intent, Kamps added.

For this reason, two Canadian groups, drawing their drinking water from downstream of such high-risk shipments on the Great Lakes, added their names as signatories to the letter. They are Bruce Peninsula Environment Group in Ontario, and Canadian Coalition for Nuclear Responsibility in Quebec. (Examples of national and grassroots U.S. signatory groups are listed below.)

Reactors lacking direct rail access would either ship the 100+ ton Holtec shipping containers by barge (on multiple U.S. surface waterways, in many states), or heavy haul truck, to the nearest rail head, for transfer to train, for shipment to NM.

Despite this, no NRC public meeting has been scheduled anywhere in the Lake Michigan basin, such as Chicago, a city of many millions, the drinking water of which is drawn from Lake Michigan. In addition, the director of the State of Nevada Agency for Nuclear Projects, Robert Halstead, has stated that 40% of all shipments bound for Yucca Mountain would pass through the Chicagoland area. So too, then, would shipments bound for Holtec/ELEA, NM.

The coalition letter was signed by national, regional, and local grassroots groups representing 17 states. National groups include Beyond Nuclear, Food & Water Watch, Friends of the Earth (FOE), Nuclear Information and Resource Service (NIRS), Physicians for Social Responsibility (PSR), Public Citizen, and Sierra Club. Grassroots groups include several from New Mexico, the state targeted by Holtec/ELEA, including: Alliance for Environmental Strategies; Citizens for

Alternatives to Radioactive Dumping; Concerned Citizens for Nuclear Safety; Current-C Energy Systems, Inc., on behalf of Cooperative Catalyst; Los Alamos Study Group; Nuclear Watch New Mexico; and Sisters of Mercy. Significantly, many reactor community groups, fully aware of the risks of on-site storage with which they are burdened, also protested the environmental injustice of this centralized interim storage scheme, by signing on, including: Citizens Awareness Network of the Northeast, with members near the shutdown Connecticut Yankee, Vermont Yankee, and Yankee Rowe (Massachusetts) atomic reactor sites; San Clemente Green, near the San Onofre, CA shutdown nuclear power plant; Nuclear Energy Information Service of Illinois, the state with the most reactors (14) in the U.S., including Zion, the largest nuclear power plant decommissioning in American history, 30 miles north of Chicago; Citizens for Alternatives to Chemical Contamination (CACC) and For Love of Water (FLOW), with members living in the shadows of the Big Rock Point decommissioned atomic reactor in Michigan; and San Luis Obispo Mothers and Grandmothers for Peace, near the still operating Diablo Canyon reactors.

These reactor community groups, joined by hundreds more groups representing all 50 states, have long called for Hardened On-Site Storage, as close as is safely possible to the point of waste generation, as an interim alternative to such dangerous proposals as the Yucca burial dump, and the Holtec/ELEA de facto permanent, surface storage, parking lot dump.

--30 Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic. The Beyond Nuclear team works with diverse partners and allies to provide the public, government officials, and the media with the critical information necessary to move humanity toward a world beyond nuclear. Beyond Nuclear: 6930 Carroll Avenue, Suite 400, Takoma Park, MD 20912.

Info@beyondnuclear.org. www.beyondnuclear.org.

Update on July 5, 2018 by admin On July 5, 2018, the 52-group coalition learned that NRC had rejected their requests, in a letter dated June 26, 2018.]

On July 19, 2018, another coalition made a second request to NRC to extend the Holtec/ELEA environmental scoping deadline, as documented here:

[38 environmental groups call on NRC to extend comment period till Oct. 30, postpone license intervention deadline for proposed Holtec/ELEA CISF An environmental coalition of 38 organizations has written the five U.S. Nuclear Regulatory Commission commissioners, as well as the safety and environmental NRC staff leads on the Holtec International/Eddy-Lea Energy Alliance centralized interim storage facility (CISF) license application proceeding, urging a 90-day extension to the environmental scoping public

comment deadline. The current deadline is July 30; the coalition is requesting an extension till Oct. 30.

In addition, the coalition is requesting the legal intervention deadline in the licensing proceeding be postponed, and that proceeding suspended. Just this past Monday, July 16th, NRC published a Federal Register Notice, announcing September 14, 2018 as the deadline for requesting a hearing, and submitting legal contentions against the proposal. Legal intervenors must also establish legal standing in that short 60-day time frame.

The three main points in today's environmental coalition letter, justifying the requested 90-day extension for public environmental scoping comments, and suspension of the licensing proceeding, are:

1.) Redaction of 25% of the Holtec CISF Environmental Report Limits Public Commenting and Ongoing Preparations To Intervene In Licensing Proceeding; 2.) Serial Unavailability of Regulations.gov and ADAMS (the NRC's Agency-wide Document Access and Management System), making the preparation and submission of public comments unacceptably difficult; 3.) The NRC Is Legally Obligated to Restore Fairness To the Scoping Stage of This Licensing Proceeding.

Regarding the second point, the largely to entirely out-of-order status of Regulations.gov for most of the public comment period thus far, right up to the present: NRC in recent days has responded to a mid-June request, by Beyond Nuclear's legal counsel, Diane Curran of Washington, D.C., for an extension to the comment deadline, due to the dysfunction of the primary comment submission mechanism provided by NRC to the public.

NRC's response essentially blamed the victim, stating that the public should have worked with Regulations.gov itself to make sure the system worked properly. Concerned citizens, and environmental group representatives, have been notifying NRC since at least May 1st that its Regulations.gov site for public comment was not working properly, or at all. NRC's letter rejects the environmental coalition's mid-June request for an extension of the scoping deadline.

"The signers of today's letter suggest that there are 'extremely compelling circumsances' present here that obligate the NRC to extend the public comment scoping period, and further compel the delay of commencement of the intervention petition filing period until after interested parties have obtained relief under the Freedom of Information Act," said Terry Lodge, Toledo-based legal counsel for Don't Waste Michigan. "Fundamental concerns of fairness, coupled with the National Environmental Policy Act's expectation of maximal public participation, and the high significance of the Holtec/ELEA CISF itself, as a policy determination, all militate in favor of altering the present deadlines," Lodge added.

"Not only do we have to do NRC's job for it, in terms of protecting public safety, security, health, and the environment, but now we also have to do the agency's job for it by making sure its computer systems work," said Kevin Kamps, radioactive waste specialist at Beyond Nuclear.

"It makes me wonder why NRC needs to have thousands of employees, and a budget of many hundreds of millions of dollars per year, when the concerned public is constantly forced to do NRC's job for it, because the agency can't be bothered," Kamps said.

"The public demands NRC return the funds provided by ratepayers and taxpayers to the agency, due to its regulatory incompetence -- and worse, complicity and collusion with the hazardous industry it is supposed to regulate," Kamps added.

The Holtec/ELEA CISF is an environmentally unjust proposal, for up to 173,600 metric tons of highly radioactive irradiated nuclear fuel to be "temporarily stored" in southeastern New Mexico.

The Texas/New Mexico borderlands are home to large Hispanic populations; they are already badly polluted by intensive fossil fuel and nuclear industires. If opened, this de facto permanent, surface storage, "parking lot dump" would significantly worsen New Mexico's treatment as a "nuclear sacrifize zone," but would also launch unprecedented thousands of high-risk, highly radioactive waste shipments, by truck, train, and/or barge, on roads, rails, and/or waterways, through most states, many major cities, and the vast majority of U.S. congressional districts, over the course of a half-century. If the highly radioactive irradiated nuclear fuel ever did leave someday, after 40, 100, 120, or 300 years of "interim storage" (all figures Holtec/ELEA has cited at various times), then the departing shipments would double transport risks, sometimes in the very same communities through which they passed in order to reach New Mexico in the first place.]

NRC again rejected the request, as documented here:

[NRC officially rejects environmental coalition's call for extension of public comment period, postponement of legal intervention deadline, re: Holtec/ELEA CISF By a letter dated July 30th, the U.S. Nuclear Regulatory Commission (NRC) officially rejected a 38-group environmental coalition's call for an extension of the environmental scoping public comment deadline, as well as a postponement of the legal intervention deadline, re: Holtec International/Eddy-Lea [Counties] Energy Alliance's proposal to construct and operate a centralized interim storage facility for 173,600 metric tons of highly radioactive waste in southeastern New Mexico.

Thus, the July 30th deadline for environmental scoping public comment has now passed (but opponents to Holtec/ELEA's proposal nonetheless met that deadline in a big way, with over 25,000 public comments in opposition to the CISF!)

And groups planning to legally intervene in the NRC's Atomic Safety (sic) and Licensing Board (ASLB) proceeding on the application, face an arbitrarily and capriciously short 60-day deadline, that expires on Sept. 14, to establish legal standing, and to submit quality contentions that the

ASLB would allow for hearings on the merits. Beyond Nuclear, as well as a broad coalition of other environmental groups, plan to do just that! Beyond Nuclear's legal counsel are Diane Curran of Washington, D.C., and Mindy Goldstein of Emory University's Turner Environmental Law Clinic in Atlanta, GA.]

Why did DOE hold two-dozen in-person public comment meetings during the Yucca Mountain, Nevada permanent repository environmental scoping phase, while NRC held only a combined total of ten for the NM and TX CISF schemes, and only three for the ISP/WCS CISF scheme?

Why, when DOE held numerous environmental scoping in-person public comment meetings in NV and CA, did NRC hold a single, solitary in-person public comment meeting in TX, and even that one on unacceptably short, rushed notice?

This makes even less sense when you consider the quantities of irradiated nuclear fuel and high-level radioactive waste involved in the various proposals. Yucca Mountain, Nevada's proposed irradiated nuclear fuel and high-level radioactive waste dump -- cancelled by the Obama administration in 2010, and its licensing suspended for as long due to a lack of congressional appropriations -- would have been limited by law to a total of 70,000 metric tons uranium (MTU) or metric tons heavy metal (MTHM), at least until a second permanent repository was opened in this country, this time in the East. This was a regional equity provision in the Nuclear Waste Policy Act of 1982, as Amended, to make sure Nevada wasn't the only state in the union to be thus "screwed," to make sure "East exclusively dumps on West" was not the law of the land.

But the amount of irradiated nuclear fuel and high-level radioactive waste proposed to be "temporarily stored" at the CISFs is much greater than 70,000 MT. The ISP/WCS CISF scheme could store up to 40,000 MT. The Holtec/ELEA CISF scheme could store up to 173,600 MT.

The total for both CISFs -- separated by only 39 miles across the TX/NM border -- is 213,600 MT, or more than three times the amount targeted at Nevada for permanent disposal. So why did TX get only one in-person public comment meeting during environmental scoping?! Is it because NRC would like to keep Texans largely to entirely in the dark about this scheme? Most Texans along the transport routes that would be used to haul high-level radioactive waste to Andrews County had not even heard about this scheme, because NRC has helped keep it so quiet. Even those who knew about it then faced the daunting challenge of travelling for many hours, and many hundreds of miles, at their own expense in terms of time and money, to reach the single in-person meeting, held in Andrews.

But the DEIS stage has been even worse. After all, NRC has rammed the DEIS public comment periods for both CISFs through, despite the national pandemic emergency raging throughout our country since March 2020.

NRC did this despite the early April 2020 call, by 14 Democratic U.S. House of Representatives Committee Chairs, and 25 Democratic U.S. Senators (including several who had recently been campaigning for the Democratic presidential nomination, and one, Kamala Harris from CA, who today stands for election as the first Black, and the first South Asian, vice president in U.S.

history), addressed to the Trump administration Office of Management and Budget, to suspend all executive branch public participation processes until the end of the pandemic emergency.

This would have included these NRC CISF DEIS public comment proceedings. Both OMB and NRC rejected the requests, and rammed these CISF DEIS public comment periods through, regardless of the pandemic, and its consequent economic collapse. As most Americans strive daily to protect their own and their loved ones' health and safety, while also paying the bills despite loss of income for many millions, NRC has been ramming through this ISP/WCS CISF DEIS public comment period.

Individual members of congress have also written to NRC, demanding extensions of the comment period deadline, and/or in person public meetings in their U.S. House districts. This has included Jamie Raskin of Maryland, and Lloyd Doggett of Texas. Their requests fell on deaf ears at NRC, as well.

Adding to the burden is the environmental injustice. ISP/WCS's CISF targets a majority Latinx region of our country. The land has many connections to various Indigenous nations. A disproportionate impact on the BIPOC (Black, Indigenous, People of Color) communities in most states can be expected, as that is who lives along major transport corridors, such as railways, interstate highways that would be used for heavy haul truck transport, and waterway facilities such as ports. For NRC to ram such an environmental injustice through, during the racial reckoning protests following George Floyd's murder in late May, is also outrageous and objectionable.

In addition to scores of members of Congress, large national coalitions also requested suspensions of both CISF NRC DEIS public comment proceedings due to the national pandemic emergency, and also called for in-person public comment meetings, once the pandemic emergency was over, such as when a universally available, safe, effective vaccine exists.

Here is documentation of the coalition's request in the Holtec case:

[Press Release -- 50 Groups to NRC: Suspend Holtec High-Level Radioactive Waste CIS Proceeding, Till COVID-19 Emergency Ends; Coalition Calls for DEIS Public Comment Meetings Along Targeted Transport Routes Outside New Mexico NEWS FROM BEYOND NUCLEAR For immediate release: April 1, 2020

Contact:

Rose Gardner, Alliance for Environmental Strategies (AFES), NM, nmlady2000@icloud.com, (575) 390-9634

Leona Morgan, Nuclear Issues Study Group (NISG), NM, protectnewmexico@gmail.com, (505) 879-8547 Terry Lodge, legal counsel for Don't Waste Michigan, et al.,

tjlodge50@yahoo.com, (419) 205-7084 Molly Johnson, San Luis Obispo Mothers for Peace, CA, mollypj@yahoo.com, (805) 467-2431 Barbara Warren, Citizens Environmental Coalition, NY, (845) 754-7951, warrenba@msn.com Wally Taylor, legal counsel for Sierra Club Rio Grande Chapter, wtaylorlaw@aol.com, (319) 366-2428 Michael Keegan, Don't Waste MI & Coalition for a Nuclear-Free Great Lakes, mkeeganj@comcast.net, (734) 770-1441 Kevin Kamps, Beyond Nuclear, kevin@beyondnuclear.org, (240) 462-3216 50 Groups to NRC: Suspend Holtec High-Level Rad Coalition Calls for DEIS Public Comment Meetin EUNICE, NM/WASHINGTON, D.C. --

A coalition of 50 environmental and environmental justice groups has written the U.S. Nuclear Regulat Interim Storage Facility (CISF) for irradiated nuclear fuel targeting New Mexico. See the letter, here.

The coalition urges NRC to:

[I]ndefinitely extend, for the duration of the national COVID-19 pandemic emergency, the ongoing public comme New Mexico. At the formal termination of the national emergency as declared by the U.S. Centers for Disease C when in-person hearings again become possible that the NRC conduct plenary-style public hearings in 5 alread The 199-day public comment period (as opposed to NRC's current 60-day public comment period, set to end on public comment proceeding at the DEIS phase of the proposed Yucca Mountain, Nevada permanent repository Yucca scheme: 173,600 metric tons of irradiated nuclear fuel, versus 70,000.

The coalition letter came five days after the entire New Mexico U.S. congressional delegation wrote NRC, also u the public comment period be held open until after the in-person meetings are completed.

Of the 50 groups on the letter, seven are from NM: Alliance for Environmental Strategies (AFES); Citizen Action Environment (MASE); Nuclear Issues Study Group (NISG); and Sierra Club Rio Grande Chapter. Of these, AFE Board proceeding.

Terry Lodge, an attorney based in Toledo, Ohio, represents seven grassroots environmental groups nationwide Regarding the coalition letter to NRC, Lodge said: "The NRC's official position, that tens of thousands of extrem flag. There is zero justification to rush this ill-considered cash cow to licensing. The NRC must not be allowed to

Rose Gardner of Alliance for Environmental Strategies in Eunice, NM said: "NRC has set up some hea when the whole nation, including New Mexico, is under stress and even dangerous conditions which d these hearings, as well as extend the comment period. The most vulnerable In our communities would Gardner added: "I also admit that I am unable to concentrate on the dangers associated with the stora discuss as this could possibly impact the futures of all New Mexicans. NRC must take into account tha never thought we would have to deal with. Living in the oil patch is especially difficult now because job two weeks as far as 'shelter at home' has been ordered by the New Mexico governor In order to help m Coordinator of the NM-based organization Nuclear Issues Study Group, Leona Morgan, remarked: "These are u Mexico have been ordered to shelter in place by Gov. Michelle Lujan-Grisham. We at the Nuclear Issues Study and support our Congressional delegation's urge to the NRC for an extension of the public comment period. Fur again, 2) Expand the hearings to include major cities along the likely routes, and 3) Leave the public comment p participation by all impacted peoples. It would be unconscionable for the NRC to ramrod this process through du legitimacy and credibility."

Wally Taylor, an attorney based in Cedar Rapids, IA, represents the Sierra Club Rio Grande Chapter's intervent requires intense study, and probably expert review and opinions, that 60 days is clearly not enough time to subm process to prevent genuine public input. We will not allow that to happen."

Molly Johnson, a member of the board of San Luis Obispo Mothers for Peace (SLOMPF) in California, said: "Th storage solution is dangerous and irrational. San Luis Obispo Mothers for Peace advocates for storing waste at a decades-long watchdog on the Diablo Canyon nuclear power plant, is also an official intervenor against the C Barbara Warren, Executive Director of Citizens Environmental Coalition (CEC), said: Multiple New York activis of nuclear waste that will be hazardous for millions of years. NRC has not required controls adequate to handle NO evaluation of the entire hazardous journey high-level nuclear waste will require, the enormous costs to fix tra lines. In addition, barge transport poses unique hazards. Hearings are also needed in Albany, Syracuse and Bu In its letter, the locations along major transport routes where the coalition urges NRC to hold public comment m Kansas City, MO; Miami, FL; Minneapolis/St. Paul, MN; Nashville, TN; New York, NY/Newark, NJ; Omaha, NE; Beyond Nuclear is a 501(c)(3) nonprofit membership organization. Beyond Nuclear aims to educate and activate the public Nuclear advocates for an energy future that is sustainable, benign and democratic. The Beyond Nuclear team works with d humanity toward a world beyond nuclear. Beyond Nuclear: 7304 Carroll Avenue, #182, Takoma Park, MD 20912. Info@be And here is documentation of the coalition's similar request in the ISP/WCS CISF DEIS public comment proceeding:

[Letter from 60 Organizations in 22 states, re: Docket No. 72-105 Specialists, LLC Consolidated Interim Storage Facility Project (

convening of public meetings at multiple sites across Texas, as July 8, 2020 Kristine L. Svinicki, Chairman Jeff Baran, Commissioner Annie Caputo, Commissioner David A. Wright, Commissioner Christopher T. Hanson, Commissioner

U.S. Nuclear Regulatory Commission Mail Stop O-4F00 Washington, DC 20555-0001 Via email only to Chairman@nrc.gov, CMRBARAN@nrc.gov, CMRCaputo@nrc.gov NRC Staff Contacts:

James Park, Office of Nuclear Material Safety and Safeguards, Project Manager, James.Park@nrc.go Jennifer Borges, Jennifer.Borges@nrc.gov NRC Comments Address: WCS_CISF_EIS@nrc.gov Cinthya I. Roman-Cuevas, Chief, Environmental Review Materials Branch, Division o Safeguards, cinthya.roman@nrc.gov Annette Vietti-Cook, Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Via email to annette.vietti-cook@nrc.gov

SUBJECT:

Docket No. 72-1050 (NRC-2016-0231), Interim Storage Partners, LLC/W indefinitely prolonged DEIS public comment period and convening of public meetings

Dear NRC Commissioners:

The undersigned 60 organizations from 22 states hereby propose a significant restru Environmental Impact Statement (DEIS) of the Interim Storage Partners/Waste Cont (CISF) for spent nuclear fuel (SNF, also known as irradiated nuclear fuel, INF -- high organizations sought leave to intervene in the ISP/WCS CISF adjudicatory licensing status, as well as a hearing on the merits of admissible contentions, but has since be licensing proceeding, and the proceeding terminated by the ASLB. Beyond Nuclear a intervenor status, but were denied intervention because of a supposed lack of an adm Information Service, San Luis Obispo Mothers for Peace, Leona Morgan, Public Citiz standing entirely.

All of the undersigned organizations hereby request that the Commission indefinitely comment period for the Draft Environmental Impact Statement (DEIS) for the ISP/WC of the national emergency, as via a safe and effective vaccine available to all people extended for a period of 180 days, post-pandemic. We further request that when in-p

style, in-person public comment meetings in the following six Texas locations: San A person public comment meetings likewise be held, post-pandemic, in more than a do later in this letter.

The undersigned 60 groups seek these changes in the public participation arrangem American public is beset with concerns of maintaining individual and family health, fre economic reversals and dislocations associated with global recession or even econo cases, Texas, unfortunately, is currently an epicenter of an alarming resurgence of th processing of a license for the ISP/WCS CISF, and the implementation of procedures governments must address crisis-borne difficulties daily. As COVID-19 ravages majo citizens to perform needed research and analysis and consultation of experts in orde Our requests in this letter are echoed by large blocs of U.S. Congress members. We presidency up until recently), who wrote the White House Office of Management and comment periods, during this pandemic. In addition, 14 Democratic U.S. House of Re April 1, 2020.

1. The ISP/WCS CISF Project Is Unprecedented And Controversial ISP/WCS is presently seeking an NRC license for authorization to construct and ope ISP/WCS intends initially to store 500 canisters (containing 5,000 metric tons, or MT)

ISP/WCS plans eventually to store 40,000 MT of SNF at the facility. Even at 40,000 M ISP/WCS proposes to accept more than half the total volume of SNF planned for ent repository, targeting Western Shoshone land in Nevada: 40,000 MT of irradiated nuc ISP/WCS's transport volume, risks, and impacts will be more than half as intense as The largely-ignored or under-analyzed transportation effects of the ISP/WCS CISF w the sense that ISP/WCS plans to transport the INF, post-"interim storage" at the CIS Yucca's (40,000 MT of SNF, transported twice, versus 70,000 MT, transported once)

ISP/WCS plans long-term INF storage for up to 60 years, awaiting completion of a de services before a repository is built (2), which if approved by the Commission would c be opposed by intervening parties.

It further is very questionable whether the facility will operate for less than 60 years. H away from ISP/WCS's proposed CISF, has applied for up to a 120-year license for its 300 years. (4) And in 2019, then-Secretary of Energy Rick Perry - former Texas gov CISF might de facto become the final repository for SNF, if a geological repository be Simpson (R-ID) at a U.S. House appropriations subcommittee hearing on March 26,

CISF would be located, do not object to the ISP/WCS CISF becoming a de facto per the interim storage concept, alone, is reason enough to extend the public comment p would have to bear the burden of a different, forever mission.

2. The Present Public Comment Arrangements Are Grossly Inadequate The NRC has granted only 120 days for public comment on the ISP/WCS CISF DEIS DEIS public comment stage on the Yucca Mountain, Nevada INF geologic repository different public comment meetings in 2001 and 2002, scattered across the country. B the SNF volume of Yucca - the NRC has yet to schedule any public comment meetin comment meetings were held, one in Hobbs, New Mexico, and one in Andrews, Texa The DOE convened half a dozen Yucca DEIS public comment meetings in Nevada a through which the INF would be shipped. Although deliberately excluded from the IS Weight Truck (LWT), and rail, over literally millions of shipment miles, will expose mo for the Yucca Mountain repository in Nevada targeting Western Shoshone land. Besi Worth, Houston, El Paso, Midland, and Andrews), the undersigned organizations, on public comment meetings be held at each of these sites, all located along one or mo City; Miami; Minneapolis/Saint Paul; Nashville; New York/Newark; Omaha; Philadelp The possibility of a spent nuclear fuel leak, explosion, criticality or canister breach in radiation emissions during canister transport, surely warrants the scheduling of public process that is much more visible and accessible than at present.The NRCs concep environmental concerns raised by the proposal. There were more than 47,000 public opposed to the plan. That degree of public interest will be eclipsed by the sponsorsh Texas. The NRCs restrictive level of public engagement is grossly inadequate for so

3. NEPA Requires Maximum Public Participation at the DEIS Stage The NRCs NEPA regulations at 10 C.F.R. § 51.73 require that at least 45 days be a C.F.R. § 1501.8, however, impose nuanced considerations on the structuring of the c NEPA process, but expects agencies to set time limits that are appropriate to indivi considerations of national policy. Id. The regulation suggests consideration of the fo

---Potential for environmental harm.

---Size of the proposed action.

---State of the art of analytic techniques.

---Degree of public need for the proposed action, including the consequences of dela

---Number of persons and agencies affected.

---Degree to which relevant information is known and if not known the time required f

---Degree to which the action is controversial.

---Other time limits imposed on the agency by law, regulations, or executive order.

40 C.F.R. § 1501.8(b)(i-viii).

The magnitude of the ISP/WCS CISF project against these factors supports the prov potential in hauling SNF by the thousands of cargoes to Andrews County, Texas. On perfectly contained when received, handled, stored at the surface, monitored, retriev considerations in the DEIS is extensive and may require interested commenters to se public policy determination for which there are years available to make the best-infor from long-distance and transcontinental shipments of SNF, over 200,000,000 people federal and state agencies are affected and will have a role in regulation or implemen U.S. Department of Transportations Federal Highway Administration and its Federal Hundreds of state and local utility, transportation, environmental, and emergency pre decommissioning phases. Given the controversial nature of the project, the foregoing comment stage than the NRC has committed to do.

4. NRC Discretion to Limit Public Comments Is Constrained Congress intended that agency discretion, and not the courts, be used to determine F.2d545, 559 (10th Cir.1986) (emphasis omitted) (quoting Vermont Yankee Nuclear omitted). But a reviewing court can overturn an agency decision for failure to provide 435 U.S. at 543.

Such circumstances are present here, where the DEIS for an enormous undertaking Construction and operation of the ISP/WCS CISF demands flawless transportation fr duration SNF storage site where extraordinarily deadly substances will have to be co reactor sites, in hardened on-site or near-site storage, as an alternative to the ISP/W accident or act of sabotage, if accompanied by catastrophic releases of hazardous ra concentrated in west Texas.

Perhaps there can be no time when 100% of the interested public can participate at t ISP/WCS CISF, and participate, must be made as convenient and informed as possi calamity. We thus request that the DEIS public comment opportunity for the ISP/WCS COVID-19 pandemic crisis, as when a safe, effective vaccine is universally available and that the agency also convene more than a dozen, geographically widespread, in Texas plenaries. The undersigned organizations have previously participated in this we ask for an expedited decision from the Commission as to these requests, given th Thank you very much.

/s/ Terry J. Lodge Terry J. Lodge, Esq.

316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 205-7084 tjlodge50@yahoo.com Counsel for Dont Waste Michigan, Citizens Environmental Coalition, Citizens f Citizen, Inc., San Luis Obispo Mothers for Peace, Sustainable Energy and Econ

/s/ Wallace L. Taylor Wallace L. Taylor 4403 1st Ave. S.E., Suite 402 Cedar Rapids, Iowa 52402 wtaylor@aol.com Counsel for Sierra Club (Additional organizations in alphabetical order by group name)

Alliance for Environmental Strategies Rose Gardner, Founding Member Box 514 Eunice, NM 88231 Nmlady2000@icloud.com Beyond Nuclear Kevin Kamps, Radioactive Waste Specialist 7304 Carroll Avenue, #182 Takoma Park, MD 20912 kevin@beyondnuclear.org Cape Downwinders Diane Turco, Director P.O. Box 303 South Harwich, MA 02664 tturco@comcast.net Citizen Action New Mexico David B. McCoy, J.D., Executive Director

Albuquerque, NM 87110 dave@radfreenm.org Citizens for Alternatives to Radioactive Dumping (CARD)

Janet Greenwald, Coordinator 112 Highway 580, Box 485 Dixon, NM 87527 contactus@cardnm.org Citizens Awareness Network Deb Katz, Executive Director P.O. Box 83 Shelburne Falls, MA deb@nukebusters.org Citizens' Environmental Coalition Barbara Warren, RN, MS, Executive Director 422 Oakland Valley Road Cuddebackville, NY 12729 warrenba@msn.com Citizen Power, Inc.

David Hughes, President 4037 Ludwick Street Pittsburgh, PA 15217 hughes@citizenpower.com Citizens' Resistance at Fermi 2 (CRAFT)

Jessie Pauline Collins, Co-Chair 17397 Five Points Street Redford, MI 48240 shutdownfermi@gmail.com Concerned Citizens for Nuclear Safety Joni Arends, Co-Founder and Executive Director P.O. Box 31147 Santa Fe, NM 87594 jarends@nuclearactive.org

Don't Waste Arizona Scott Meyer, President 2934 West Northview Avenue Phoenix, AZ 85051 Samiam667@live.com Don't Waste Michigan Michael Keegan, Co-Chair 811 Harrison Street Monroe, MI 48161 mkeeganj@comcast.net Energía Mía Alice Canestaro-Garcia, Visual Artist/Pájara/Energía Mía Volunteer San Antonio, TX alice.canestraro@gmail.com Environmental Justice Task Force of the Western New York Peace Center Charley Bowman, Chair 1272 Delaware Avenue Buffalo, NY 14209 RenewableEnergy@wnypeace.org Freshwater Future Kristy Meyer, Associate Director 3890 Charlevoix Avenue, Suite 230 P.O. Box 2479 Petoskey, MI 49770 Kristy@freshwaterfuture.org Friends of Bruce Eugene Bourgeois, President 2 Alma Street Tiverton, Ontario, Canada N0G 2T0 eugene@bmts.com Georgia WAND (Women's Action for New Directions)

Cee'Cee' Anderson

250 Georgia Avenue Atlanta, GA 30312 ceceand2003@yahoo.com Great Lakes Environmental Alliance (GLEA)

Tanya Keefe, Chairperson 525 Court Street Port Huron, MI 48060 tkeefe@greatlakesenvironmentalalliance.org Greenaction for Health and Environmental Justice Bradley Angel, Executive Director 315 Sutter Street, 2nd Floor San Francisco, CA 94108 greenaction@greenaction.org Green State Solutions Mike Carberry, Director 2029 Friendship Street Iowa City, IA 52245 Mike@GreenStateSolutions.com Healthy Environmental Alliance of Utah (HEAL Utah)

Scott Williams, M.D., M.P.H., Executive Director 824 South 400 West, Suite B-111 Salt Lake City, UT 84101 scott@healutah.org Lone Tree Council Terry Miller, Chairman P.O. Box 1251 Bay City, MI 48706 terbar@charter.net Los Angeles Alliance for Survival Jerry Rubin, Director 2035 4th Street, #103C Santa Monica, CA 90405 jerrypeaceactivistrubin@earthlink.net

Multicultural Alliance for a Safe Environment Susan Gordon, Coordinator P.O. Box 4524 Albuquerque, NM 87196 sgordon@swuraniumimpacts.org Nevada Nuclear Waste Task Force Judy Treichel, Executive Director 4587 Ermine Court Las Vegas, NV 89147 judynwtf@aol.com North American Water Office George Crocker PO Box 174 Lake Elmo, MN 55042 gwill@nawo.org Northwatch Brennain Lloyd, Project Coordinator Box 282 North Bay, Ontario, Canada P1B 8H2 northwatch@northwatch.org Nuclear Age Peace Foundation Alice Slater, New York Director 1622 Anacapa Street Santa Barbara, CA 93101 alicejslater@gmail.com Nuclear Energy Information Service (NEIS)

David A. Kraft, Director 3411 W. Diversey #13 Chicago, IL 60647 neis@neis.org Nuclear Free World Committee of the Dallas Peace and Justice Center Mavis Belisle and Lon Burnham, Co-Chairs 2710 Woodmere

Dallas, Texas 75233 justpeace4@yahoo.com and lonburnam@gmail.com Nuclear Information and Resource Service Diane D'Arrigo, Radioactive Waste Project Director 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912 dianed@nirs.org Nuclear Watch New Mexico Scott Kovac, Research Director 903 W. Alameda #325 Santa Fe, NM 87501 scott@nukewatch.org Nuclear Watch South Glenn Carroll, Coordinator P.O. Box 8574 Atlanta, GA 31106 Atom.girl@nonukesyall.org Nukewatch John LaForge, Co-Director 740a Round Lake Road Luck, WI 54853 nukewatch1@lakeland.ws Oak Ridge Environmental Peace Alliance Ralph Hutchison, Coordinator P.O. Box 5743 Oak Ridge, TN 37831 orep@earthlink.net On Behalf of Planet Earth Sheila Parks, EdD, Founder 319 Arlington Street Watertown, MA 02472 sheilaruthparks@comcast.net

Our Developing World Barby Ulmer 13004 Paseo Presada Saratoga, CA 95070 odw@magiclink.net The Peace Farm Cletus Stein, Board Member 5113 SW 16th Amarillo, TX 79106 cletusjg3@suddenlink.net Physicians for Social Responsibility-Los Angeles Denise Duffield, Associate Director 617 S. Olive Street, Suite 1100 Los Angeles, CA 90014 dduffield@psr-la.org Physicians for Social Responsibility Nashville, TN Chapter Karen Cisler 442 Brooksboro Terrace Nashville, TN 37217 karencisler@bellsouth.net Physicians for Social Responsibility, San Francisco Bay Area Chapter Robert M. Gould, MD, President 548 Market Street #90725 San Francisco, CA 94104-5401 rmgould1@yahoo.com Physicians for Social Responsibility, Western North Carolina Chapter Terry Clark, MD, Chairman 10 Chestnut Creek Road Candler, NC 28715 terryclarkpsych@gmail.com Proposition One Campaign for a Nuclear-Free Future Ellen Thomas Washington, D.C. and Tryon, NC et@prop1.org

Public Citizen - Texas Adrian Shelley, State Director 309 East 11th Street, Suite 2 Austin, TX 78701 ashelley@citizen.org Safe Energy Rights Group (SEnRG)

Nancy Vann, President 201 Union Avenue Peekskill, NY 10566 nancy_vann@hotmail.com San Clemente Green Gary Headrick San Clemente, CA gary@sanclementegreen.org San Luis Obispo Mothers for Peace Molly Johnson, Board Member 6290 Hawk Ridge Place San Miguel, CA 93451 mollypj@yahoo.com Straits Area Concerned Citizens for Peace, Justice and the Environment (SACC David and Anabel Dwyer, Members 8100 Edgewater Beach Mackinaw City, MI 49701 dwyer@msu.edu Sustainable Energy and Economic Development (SEED) Coalition Karen Hadden, Executive Director 605 Carismatic Lane Austin, TX 78748 karendhadden@gmail.com Three Mile Island Alert, Inc.

Eric Epstein, Chairman 315 Peffer Street Harrisburg, PA 17102

epstein@efmr.org Toledo Coalition for Safe Energy T. Jonathon Lodge, Convenor 316 N. Michigan Street, Suite 520 Toledo, OH 43604 tjlodge50@yahoo.com Tri-Valley CAREs (Communities Against a Radioactive Environment)

Marylia Kelley, Executive Director 4049 First Street, Suite 243 Livermore, CA 94551 marylia@earthlink.net Uranium Watch Sarah Fields, Program Director 140 South Main Street, Suite 12 Monticello, UT 84535 sarah@uraniumwatch.org Vermont Yankee Decommissioning Alliance Deborah Stoleroff, Steering Committee Chairperson Montpelier, VT debrastoleroff@protonmail.com Women's International League for Peace and Freedom, Detroit Branch Laura Dewey, Coordinator 1891 Lancaster Grosse Pointe Woods, MI 48236 wilpfdetroit@att.net Women's International League for Peace and Freedom U.S.

Darien De Lu, President, U.S. Section Friends House P.O. Box 13075 Des Moines, IA 50310 President@WILPF.org

References:

(1) From Environmental Impact Statement for Interim Storage Partners LLC's Intern in Andrews County, Texas, Draft Report for Comment, NUREG-2239 (ISP/WCS DE (2) From the ISP/WCS CISF DEIS, Section 2.2.1, Proposed Action, p. 2-2: "By the en nuclear fuel] stored at the proposed facility would have been shipped to a permanent (3) From Environmental Impact Statement for the Holtec Internationals License Application for a Cons NUREG-2237 (Holtec DEIS), Docket ID NRC-2018-0052, p. 2-2.

(4) Letter, Joy Russell, Holtec Vice-President, to DOE, Response to RFI on Private 1/27/2017,https://www.energy.gov/sites/prod/files/2017/02/f34/Jan%2027%2C%2020

%20Response%20to%20the%20RFI%20on%20Private%20Initiatives.pdf (5) See Perry testimony from 23 minutes 30 seconds to 29 minutes 30 seconds at ht (6) Federal Register Notice for WCS' DEIS, FR Doc. 2020-09795, Filed: 5/7/2020 8:4 (7) Letter from U.S. Representative Lloyd Doggett (35th District, Texas) to NRC Cha Vietti-Cook, and Mr. James Park, Office of Nuclear Material Safety and Safeguards,

<http://static1.1.sqspcdn.com/static/f/356082/28319398/1593466400517/6+16+20+U Also notable, the environmental scoping comment period for ISP/WCS's CISF was lim Environmental Impact Statement for a Geologic Repository for the Disposal of Spent DOE/EIS-0250, Vol. 1, pp. 1-23-24.

(8) In the Final Environmental Impact Statement for a Geologic Repository for the D County, Nevada, Volume I (February 2002), the U.S. Department of Energy pronoun routes is 800 meters (0.5 mile) from the center line of the transportation rights-of-way influence was extended to 80 kilometers (50 miles) to address potential human healt bound for the ISP/WCS CISF is identical to the INF targeted for deep repository buria radius of 0.5 miles for incident-free transports, and 50 miles for accident scenarios, c headed to the ISP/WCS CISF in Texas. Additionally, every single one of the several to be shipped, yet again, to a geological repository for permanent disposal.]

Along the same lines, in late spring, a coalition of 80+ environmental groups, spearhe both CISF DEIS public comment periods, due to the national pandemic emergency.

NRC yet again rejected all such requests, and continued to ram through the public co corresponding national economic crisis, as well as the racial reckoning protests that f

Although NRC did allow for 180 days of public comment opportunity in both of the CI the pandemic emergency ended, we requested, would any such 180-day NRC deadl the pandemic emergency.

It has been objectionable and outrageous the way that NRC has rammed through thi emergency. NRC has denied our coalition requests for equivalent treatment by NRC stage. Yet again, DOE held around two-dozen in-person public comment meetings, n dozen states outside NV. In the case of NRC's DEIS public comment meetings, none meetings were held via call-in/webinars. The Holtec CISF call-ins were especially ba ISP proceeding -- only four.

Please address the subject matter above, re: our many objections to N proceeding.

And please acknowledge your receipt of these comments, and confirm Thank you.

Sincerely, Kay Drey, President, Board of Directors, Beyond Nuclear and Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear Kevin Kamps Radioactive Waste Specialist Beyond Nuclear 7304 Carroll Avenue, #182 Takoma Park, Maryland 20912 Cell: (240) 462-3216 kevin@beyondnuclear.org www.beyondnuclear.org

Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.

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[External_Sender] Beyond Nuclear's 25th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Our objections to NRC's outrageous conduct of this ISP/WCS CISF public comment proceeding Sent Date:

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